# RP^ .rIdea One~ 

# 331242nd ielecom Fargo. ND 58104 U-r . 

# EXECUi ;~2,~~: t 2010 DEC 10 AM6~ 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 ofCass County Electric Cooperative Inc. (CCEC) and is currently participating in its electric load management programby using our stationary engine generator. The engine generator provides electric power to our facility during times ofpeak load conditions. In the past several years, the total hours ofoperation logged on the generator for this programhas not exceeded 100hours. Inasmuch as the Environmental Protection Agency (EPA) rules allowan emergency use engine generator to operate up to 100hours 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 ethere restrictions within those 100 hours of non-emergency use for peak shaving? The option to use my generator as part ofa peak shaving program

on a limited basis is important to me and helps my cooperative operate its distribution systemmost 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 100hours of non-emergency use ofa stationary engine generator poses little health risk or environmental harmabove that already contemplated in the rule, I



### 3312 42nd St. S. Suite 100 " Fargo, ND 58104 " 701-356-6000 " www .ideaone.comThe 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 100hours ofallowable non-emergency operation in conclusion, Idea one respectfully requests the EPAreconsiders its proposed rule for spark ignition (SI) engines. Assuming the agency recognizes the common-sense logic presented in this letterwith 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 uniformthroughout 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