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 DELIVERY WEDNESDAY, 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: 

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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 Hazardous Air 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 of the least populated areas in 

the United States, with most of them serving 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, one of our small member cooperatives 

(about 5,000 members) in North Dakota experienced two major winter ice storms resulting in 

$35 million in damages and causing power outages that lasted up to four weeks. 

Basin Electric is a member of NRECA and we work together on many legislative and regulatory 

issues that affect electric generation and transmission cooperatives . The NESHAP for 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 NRECA to 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 these generators available to shave peaks or support the electric 

Equal 

Employment 

Opportunity 

A Touchstone Energy' Cooperative ~,~~i Employer 
Lisa Jackson, EPA Administrator 

November 2, 2010 

Page 2 

system during times of extreme temperatures . These efforts, which have helped maintain the 

integrity of our electric system while saving consumers dollars, are now being threatened by the 

NESHAP for RICE rules. 

While the NRECA petition 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 problem created 

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. 

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BASIN ELECTRIC POWER COOPERATIVE 

INTERSTATE AVENUE 'S~ IJ I la BISMARCK ND 50503056 

THE HONORABLE LISA JACKSON 

ADMINISTRATOR 

U S ENVIRONMENTAL PROTECTION AGNCY 

ARIEL RIOS BUILDING (MAIL CODE 1101) 

1200 PENNSYLVANIA AVE NW 

WASHINGTON DC 20460 

TO REUSE: Cover or mark through any previous shipping information . 

ORIGIN ID : OXCA (701) 557-5482 Actual 

Date 

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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 FedEx 

ARIEL RIOS BUILDING MAIL CODE 1101 

1200 PENNSYLVANIA AVENUE NW Express 

WASHINGTON, DC 20460 (us) 

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Delivo Address 

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20460 -DC-US 

B_ ASIN ELECTRIC POWER COOPERATIVE 

1717 EAST INTERSTATE AVENUE