November 10, 2010

The Honorable Lisa Jackson

Administrator United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) 1200 Pennsylvania Ave., NW Washington, D.C. 20460

Re: Petition for Reconsideration of Portio ns of the Final Rule: National Emission

Standards for Hazardous Ai r Pollutants for Reciprocating Internal Combustion Engines

Dear Administrator Jackson:

I am writing in support of the National Rural Electric Cooperative Association’s (NRECA) October 19, 2010, Petition for Rec onsideration to portions of the Final National Emission

Standards for Hazardous Air Pollutants for R eciprocating Internal Combustion Engines promulgated on August 20, 2010, ( 75 Fed. Reg. 51,570 ).

Pierce Pepin Cooperative Services (PPCS), headquart ered in Ellsworth, Wisconsin, is one of the 25 member cooperatives of Dairyl and Power Cooperative (DPC). Dairyland Power Cooperative, headquartered in La Crosse, Wisconsin, is a ge neration and transmission cooperative. PPCS is an electric cooperative serv ing over 6,500 electric members th roughout most of Pierce County and portions of Pepin, St. Croix and Buff alo counties in west central Wisconsin.

PPCS, in conjunction with DPC, has had a very successful active load management system in place for nearly 30 years. Over 60 percent of PPCS members participate in this demand-side

management program.

Specifically, I am very concerned about the impa ct to our rural members who own and operate their own generators. These members are small business owners and dairy farmers. The EPA

National Emission Standards for Hazardous Ai r Pollutants for Reci procating Internal Combustion Engines (NESHAP RICE) rule will seve rely limit our ability to maximize efficient operations of our electric system and negatively imp act our power supply. This will increase our costs and, ultimately, raise rates to our members.

PPCS has no major electric generation facilitie s of our own. Our prim ary concern is with distributing electric power to our retail consumers/member-owners. PPCS does not have the resources to keep track of and review the ma ny EPA rulemaking activitie s under the Clean AirThe Honorable Lisa Jackson Page 2 November 10, 2010

Act to verify if any of these regulations may im pact our business of delivering electrical power. Without an outreach from EPA, which was ab sent in these rulemakings, PPCS could not anticipate that the proposed ru le for emergency generators would undermine and destroy our very practical and highly succe ssful peak-shaving programs.

We currently have dairy farmers evaluating em ergency generators for business continuity reasons and for peak shaving to help lower their operating costs. We have informed these dairy producers of the EPA’s plans and the current 2013 deadline. These producers are appalled that the dairy farmer and agriculture, both great stewar ds of the environment who offer huge potential for supporting renewable energy resources, are the very ones to be hurt the most from this rulemaking.

The majority of small emergency generating units, the subject matter of th is petition, are owned by rural members of the electric cooperatives. These units are utilized in an efficient and productive manner for the benefit of our rural member s. It is hard to understand and explain why the efficiency benefits derived from the use of these resources would be wiped out by a federal government that professes goals of increased energy efficiency and resource conservation.

NRECA’s petition addresses restric tions contained in the final rule that prohibit the use of small emergency generating units for peak-shaving pr ograms, and limits demand reduction service beginning in 2013 without the addition of expe nsive emission reduction technology on units larger than a specified size.

To help operate our electric di stribution system more efficien tly and maximize our power supply, our load management system includes a peak-shaving program that uses the engines you will be regulating and restrictin g the use of. Without the use of these backup generators, power costs will increase with no other cost-effective option to reduce our demand during peak usage times. The added capital expenditures required by our members to make the necessary upgrades under this regulatory mandate place a very significant fi nancial burden on them. This may force us to cease future peak-shaving demand-side manage ment programs that will no longer be cost

effective for us or the member to consider.

We support NRECA’s petition to remove restrictions on the us e of these engines for peak shaving and demand reduction purposes in the 10 0 hours of nonemergency operations allowed in the rule. The use of these engines for nonemergency operation up to 100 hours per year, as already allowed in the final ru le, would not cause any additional emissions and, therefore, no

additional health risk or envir onmental harm above what is alr eady contemplated in the rule.

PPCS supports protecting public h ealth and the environment. However, in this case, the restrictions are unnecessary, too severe, will cause a significant detriment to our consumers/member-owners, and will not result in any meaningful environmental benefit. We urge the agency to reconsider these restricti ons on peak shaving and demand reduction asThe Honorable Lisa Jackson Page 3 November 10, 2010

contained in the final rules, and to amend the rules to avoid diminishing the value of these programs that would increase the cost of power to our consumers/member-owners.

Thank you, Administrator Jackson, for your consid eration of our request. On behalf of our consumers/member-owners, we urge you to respond favorably on this critical issue. PPCS also believes it is necessary and urges EPA to ame nd the March 2010 CI NESHAP RICE final rule and the July 2006 NSPS rule with conforming changes so all a pplicable rules are clear and

consistent.

If you have any questions or need additional information, please contact me at 715-273-4355.

Sincerely,

PIERCE PEPIN COOPERATIVE SERVICES

Larry J Dokkestul

President & CEO

LJD:lal

cc: Robert Wayland Melanie King Kevin Bromberg, SBA