Seasons at Rose Creek 

1500 E Rose Creek Pkwy S 

Fargo, ND 58104 

2050 NOV 1S PM 4' 11 

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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 

5 ., .- ~,E ; EXEOUTI~' c ~~., :.c_ 

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 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 for Reciprocating Internal 

Combustion Engines promulgated on August 20, 2010, (75 Fed. Reg. 51,5 70) . 

Seasons at Rose Creek 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 business chooses to operate its generator within that 

100 hour limitation? In other words, why are 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 rules more reasonable without sacrificing air quality. 

Seasons at Rose Creek 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 
The Honorable Lisa Jackson 

November 4, 2010 

Page 2 

in the rule, I 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, 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 the final NESHAP rule consistent and uniform 

throughout all stationary engine generators powered by liquid fossil-fuels . 

Seasons at Rose Creek 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. 

4 ~~" 

cc: Robert Wayland, EPA 

Melanie King, EPA 

Kevin Bromberg, SBA 
i,'^~,~ C 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 EPA is continuing to rewrite the NESHAP (National Emissions Standards for Hazardous Air Pollutants) rules as 

they now pertain 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 EPA for 

reconsideration of their proposed rules a copy of this petition is available on our website at www .kwh.com under the 

Conservation and Environment link . In this petition, the NRECA is pointing out to the EPA some obvious issues and 

problems in their rule wording and seeking the EPA to reconsider its position with regard to SI engines. The logic being 

used is simple: if the EPA changes its rules with regard to SI engines, they could then be prompted/urged to make the 

rules uniform for 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 EPA can 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 CCEC personnel listed at the end of this 

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 support for 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 .cUr7 a 

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.com 
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