BASIN ELECTRIC

POWER COOPERATIVE 1717 EAST INTERSTATE AVENUE BISMARCK, NORTH DAKOTA 58503-0564 PHONE: 701-223-0441 FAX: 701-557-5336 November 2, 2010 VIA EMAIL &FOR DELIVERYWEDNESDAY, NOVEMBER 3, 2010 The Honorable Lisa Jackson (Jackson. lisa@epa .gov) 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: ,-T -ti C , si ~ ~~-- , 0

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Basin Electric Power Cooperative is writing in 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 HazardousAir Pollutants (NESHAPS) for Reciprocating Internal Combustion Engines (RICE), August 20, 2010, (75 Fed . Reg. 51,570) . Basin Electric Power Cooperative (Basin Electric) is a consumer-owned, regional rural electric cooperative headquartered in Bismarck, N.D. Basin Electric generates and transmits electricity to 135 member rural electric systems in nine states: Colorado, Iowa, Minnesota, Montana, Nebraska, New

Mexico, North Dakota, South Dakota, and Wyoming. These member systems distribute electricity to about 2.8 million consumers. Basin Electric's member distribution cooperatives serve some ofthe least populated areas in the United States, with most of themserving less than one customer per mile of line. Our service territory is historically subject to severe weather-related disasters, including blizzards, ice storms, tornadoes, and floods. Earlier this year, oneofour small member cooperatives (about 5,000 members) in North Dakota experienced two majorwinter ice storms resulting in $35 million in damages and causing power outages that lasted up to four weeks. Basin Electric is a member of NRECAand we work together on many legislative and regulatory issues that affect electric generation and transmission cooperatives. The NESHAPfor RICE rules, however, directly affect many distribution rural electric cooperatives. Unfortunately, this fact was not fully recognized until the end stages of EPA's rule adoption process. As soon as Basin Electric became aware of the significance of the RICE rules to our member distribution cooperatives we worked with NRECAto determine how to constructively engage in providing EPA information on the effect of this rule on our distribution members. With our region's extreme weather conditions, stationary emergency standby generators are used to power many facilities, such as hospitals, schools, and hotels when central station power is interrupted or during times of high demand. For many years, some cooperatives have worked with their customers to make thesegenerators available to shave peaks or support the electric

Equal Employment Opportunity ATouchstone Energy' Cooperative ~,~~i EmployerLisa Jackson, EPAAdministrator

November 2, 2010 Page 2 systemduring times of extreme temperatures. These efforts, which have helped maintain the integrity of our electric systemwhile saving consumers dollars, are now being threatened by the NESHAP for RICE rules. While the NRECApetition relates to the spark ignition rule, and our cooperatives utilize compression ignition diesel engines for peak shaving programs, we believe that the limitation on use of emergency engines for peak shaving should be removed for all engines within the 100 hours allowed for testing, maintenance and non-emergency uses. Peak shaving often occurs specifically in response to emergency situations when distribution systems are stressed due to power outages or high demand. Removing the peak shaving restriction within the overall 100 hour limitation does not expand the time emergency generators can be used without installation of costly emission reduction technology. It does, however, help mitigate a huge problemcreated by the rules for many small electric cooperatives and their customers. We respect the important role of the Environmental Protection Agency in protecting and improving our environment, but in this case the restrictions are too severe and will cause significant detriment to our consumer-owners without any meaningful environmental benefit. ,V,1~e ,~~rgP th~

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THE HONORABLE LISAJACKSON ADMINISTRATOR U S ENVIRONMENTAL PROTECTION AGNCY ARIEL RIOS BUILDING (MAIL CODE 1101) 1200 PENNSYLVANIA AVE NW WASHINGTON DC 20460 

### TOREUSE: Cover or markthrough any previous shipping information. ORIGIN ID: OXCA (701) 557-5482 Actual Date Wgt~~ LB V10 JESSE ' BASIN ELECTRIC POWER System#: 607266 1717 E INTERSTATE AVE Account: S 1328-5818-7 BISMARCK ND 58503 UNITED STATES TO : ATTN LISA JACKSON US ENVIRONMENTAL PROTECTION AGENCY 

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