Seasons at Rose Creek

1500 E Rose Creek Pkwy S Fargo, ND 58104 

## 2050NOV 1S PM4' 11

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### ;-;1.;;_ Ur I rt November 4, 2010 The Honorable Lisa Jackson Administrator United States Environmental Protection Agency Ariel Rios Building (Mail Code 1101) 1200Pennsylvania Ave., NW Washington, D

.C. 20460 5 ., .- ~,E ; 

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Re: Petition for Reconsideration of Portions of the Final Rule: National Emission Standards for HazardousAir Pollutants for Reciprocating Internal Combustion Engines Dear AdministratorJackson: I am writing in support ofthe National Rural Electric CooperativeAssociation's (NRECA) October 19, 2010, Petition for Reconsideration of portions ofthe Final National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines promulgated on August 20, 2010, (75 Fed . Reg . 51,570) . Seasons at Rose Creek is a member-owner ofCass 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 100hours. Inasmuch as the Environmental Protection Agency (EPA) rules allowan emergency use engine generator to operate up to 100 hours annually for non-emergency situations, why should it make anydifference how a business chooses to operate its generator within that 100hour limitation? In other words, why are there restrictions within those 100hours of non-emergency use for peak shaving? The option to use my generator as part of a peak shaving programon 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 rules more reasonable without sacrificing air quality. Seasons at Rose Creek supports NRECA's petition to remove the restrictions in useof emergencystationary engine generators as they pertain to use for peak shaving. Since the EPAhas determined that 100hours of non-emergency use ofa stationary engine generator poses little health risk or environmental harmabove that already contemplatedThe Honorable Lisa Jackson

November 4, 2010 Page 2 

### in the rule, I believe it should not make anydifference under what conditions the unit is operated within that the 100hours ofallowable non-emergency operation In conclusion, Seasons at Rose Creek 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 thefinal NESHAP rule consistent and uniform throughout all stationary engine generators powered by liquid fossil-fuels. Seasons at Rose Creek respectfully requests consideration ofits request and proposed changes, and thanks the EPAin advance for the same. Thank you for your prompt attention and I look forward to your response. 

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cc: Robert Wayland, EPA Melanie King, EPA Kevin Bromberg, SBA

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ass County C ._ Electric Cooperative

Your Touchstone Energy' Partner ---- URGENT November 3, 2010 Dear CCEC Member, We shared with you news in September of the EPA's recent ruling regarding new operating rules for diesel engine generators. While the comment period for those rules, specific to diesel engines, is closed and the rules are technically in effect, the EPAis continuing to rewrite the NESHAP (National Emissions Standards for Hazardous Air Pollutants) rules as they nowpertain to spark-ignition (SI) engines. The proposed rules `Or the SI group of engines is Glmost a direct mirror of the rules for diesel engines. The EPA recognized, however, they had some problems in their wording on the rules issued in May, and they are attempting to make some corrections in this go-round of rule-writing. That may provide us with a very small and short window of 

### opportunity to affect some positive change to these potentially damaging rules as they pertain to diesel engines. Our national organization, the National Rural Electric Cooperative Association, has filed a petition with the EPAfor reconsideration of their proposed rules a copy of this petition is available on our website at www .kwh.comunder the Conservation and Environment link. In this petition, the NRECA is pointing out to the EPAsome obvious issues and problems in their rule wording and seeking the EPAto reconsider its position with regard to SI engines. The logic being used is simple: if the EPAchanges its rules with regard to SI engines, they could then be prompted/urged to make the 

### rules uniformfor all combustion engines and revise the rules that are already in effect for diesel engines. Our window

of opportunity is very short, thus if you're interested in helping, please act quickly. The EPAcan be influenced to consider petitions such as NRECA has filed, and that's done by interest/persuasion by others. Thus, your letters could be influential in getting the EPA to accept NRECA's petition for reconsideration. Attached is a draft letter which you can use in sending your letter of support for the NRECA petition request. If you would like an electronic version of this letter mailed to you please e-mail any of the CCECpersonnel listed at the end ofthis letter. Feel free to use this letter as you see fit, or write your own letter. It is suggested that in addition to sending your letter to Administrator Jackson, you also email copies to Robert Wayland at EPA (wayland .robertj@epa .gov), Melanie King at EPA (king .melanie@epa .gov), and Kevin Bromberg at the Small Business Administration 

### (Kevin.bromberg@sba.gov) . If you have any questions, please don't hesitate to give me a call or send me an email at any time. Cass County Electric would be very appreciative of your interest to send a letter of supportfor this petition, and thanks you in advance for consideration of the same. Sincerely, Marshal Albright Vice President of Member &Energy Services (701) 356-4532 malbrightPkwh.com 

# ,Y'i If you have questions, you may also contact: Jodi Bullinger, (701) 356-4475, ibullinger@kwh.cUr7a Jeremy Mahowald, (701) 356-4514, imahowald6aJk.ti~ :~.,cQs~~

4100 32nd Ave SW

" Fargo, ND 58104 " 701/356-4400 or 1-800-248-3292 9 Fax: 701/356-4501 0 www .kwh.comO ` fp v, Z n O O

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