RP^. rIdea One~ 

3312 42nd ielecom 

Fargo. ND 58104 

U-r . EXECUi;~2 ,~~: t 

2010 DEC 10 AM 6~ 03 

November 4,2010 

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 Portions of the Final Rule: National Emission 

Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion 

Engines 

Dear Administrator Jackson: 

I am writing m support of the National Rural Electric Cooperative Association's 

(NRECA) October 19, 2010, Petition for Reconsideration of portions of the Final 

National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal 

Combustion Engines promulgated on August 20, 2010, (75 Fed. Reg. 51,570) . 

Idea One is a member-owner of Cass County Electric Cooperative Inc. (CCEC) and is 

currently participating in its electric load management program by using our stationary 

engine generator . The engine generator provides electric power to our facility during 

times of peak load conditions . In the past several years, the total hours of operation 

logged on the generator for this program has not exceeded 100 hours. 

Inasmuch as the Environmental Protection Agency (EPA) rules allow an emergency use 

engine generator to operate up to 100 hours annually for non-emergency situations, why 

should it make any difference how a b iness chooses to operate its generator within that 

100 hour limitation? In other words, wh e there restrictions within those 100 hours of 

non-emergency use for peak shaving? The option to use my generator as part of a peak 

shaving program on a limited basis is important to me and helps my cooperative operate 

its distribution system most effectively . It seems to me that this small change to your 

rules would make the mles more reasonable without sacrificing air quality. 

Idea One supports NRECA's petition to remove the restrictions in use of emergency 

stationary engine generators as they pertain to use for peak shaving . Since the EPA has 

determined that 100 hours of non-emergency use of a stationary engine generator poses 

little health risk or environmental harm above that already contemplated in the rule, I 

3312 42nd St. S . Suite 100 " Fargo, ND 58104 " 701-356-6000 " www.ideaone .com 
The Honorable Lisa Jackson 

November 4, 2010 

Page 2 

believe it should not make any difference under what conditions the unit is operated 

within that the 100 hours of allowable non-emergency operation 

in conclusion, Idea one respectfully requests the EPA reconsiders its proposed rule for 

spark ignition (SI) engines. Assuming the agency recognizes the common-sense logic 

presented in this letter with regard to the proposed SI rules, and the proposed changes put 

forth by NRECA, we also urge the agency to apply that same logic to the current RICE 

rules so as to make the final NESHAP rule consistent and uniform throughout all 

stationary engine generators powered by liquid fossil-fuels . 

Idea One respectfully requests consideration of its request and proposed changes, and 

thanks the EPA in advance for the same. Thank you for your prompt attention and I look 

forward to your response. 

Sincerely, 

- 

cc: Robert Wayland, EPA 

Melanie King, EPA 

Kevin Bromberg, SBA