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 . 20406

Dear Administrator Jackson:

I am writing in regards to National Rural Electric Cooperative Association’s (NRECA) 

October 19, 2010, Petition for Reconsideration of portions of the EPA rules that set 

National Emission Standards for Hazardous Air Pollutants (“NESHAP”) for 

Compression Ignition and Spark Ignition Stationary Reciprocating Internal Combustion 

Engines (“RICE”) (75 Fed. Reg. 51,570)). While Withlacoochee River Electric 

Cooperative understands and appreciates the EPA’s efforts to continue to improve air 

quality across the country, we are deeply concerned about the impact this will have on 

members and our state. 

WREC is a not-for-profit electric cooperative that owns 32 small diesel emergency

generator sets that total about 50 MW. These units are located throughout our hurricane 

prone service area in west central Florida. Among the engines covered by these rules are 

small diesel engines used in emergency generator sets. In Florida, many of these small 

units are located at residential, commercial, and institutional facilities. For example: 

WREC has units located at two regional well fields that supply fresh drinking water for the 

entire Tampa Bay Region. We also have emergency generators located at hospitals that 

provide full backup power to run the entire facility. Without these units, these hospitals 

would be forced to buy their own emergency units at a cost of millions of dollars. In 2004 

when our service territory was hit by two separate hurricanes back to back these units 

helped keep critical infrastructure up and running when the entire electric grid experienced 

significant damage. 

WREC and the State of Florida also rely on these generators to help prevent grid failure 

and blackouts when the state experiences critical generation shortages. For example 

Florida experience 15 days of record cold weather January of this year. These units were 

critical to help meet the states energy needs and prevent rolling blackouts. 

Withlacoochee serves some of the most economically depressed areas in the country and 

the cost of power has to be held in check. One of the few benefits to the Cooperative is the 

ability to use these generators for peak shaving purposes. WREC’S generators are used 

100 hours or less per year. This in conjunction with our aggressive energy conservation 

program reduces the need to build central station power. 
The EPA NESHAP rules, however, will prohibit the use of these small emergency units for 

peak-shaving programs beginning May 2013 without the addition of expensive emissions 

reduction technology on units 300 horse power or larger. Withlacoochee estimates that it 

will cost about $100,000 per unit to add this technology not counting the on-going 

maintence cost associated with the new equipment. The additional cost will likely make it 

economically prohibitive for the continued use of these units for peak-shaving. Without 

the economic benefit WREC will likely have to discontinue the program. 

In light of the minimal environmental effects and significant public benefits from having 

these units available, WREC requests that you consider the National Rural Electric 

Cooperative Association’s “Petition for Reconsideration of Portions of the Final Rule: 

National Emissions Standards for Hazardous Air Pollutants for Reciprocating 

Internal Combustion Engines” delivered to your office on October 19, 2010. 

Thank you for your consideration of this very important matter. If I can be of assistance 

in this matter please let me know. 

Sincerely,

Billy E. Brown, 

Executive Vice President and

General Manager

Withlacoochee River Electric Cooperative, Inc.

P.O. Box 278

Dade City FL, 33526-0278

352-567-5133 Ext. 6100