----- Forwarded by Melanie King/RTP/USEPA/US on 11/01/2010 04:14 PM

----- |------------> | From: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |"Ronald A Kunkel" <rkunkel@woodburyrec.com> |

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |------------> | To: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |<wayland.robert@epa.gov>, Melanie King/RTP/USEPA/US@EPA, <Kevin.bromberg@sba.gov>, <bill.wemhoff@nreca.coop> |

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |------------> | Cc: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |"'Ronald A Kunkel'" <rkunkel@woodburyrec.com>, "'Chuck Soderberg'" <csoderberg@nipco.coop>, "'Kent Pauling'" <kpauling@nipco.coop> |

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |------------> | Date: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |11/01/2010 04:08 PM |

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |------------> | Subject: | |------------>

>--------------------------------------------------------------------------- ---------------------------------------------------------------| |Support for NRECA's RICE Petition for Reconsideration |

>--------------------------------------------------------------------------- ---------------------------------------------------------------|Ladies/Gentlemen EPA/SBA:

We are sending email copies of Woodbury REC support for NRECA;s RICE Petition for Reconsideration to Robert Wayland at EPA ( wayland.robert@epa.gov ), Melanie King at EPA ( king.melanie@epa.gov ), and Kevin Bromberg at the Small Business Administration ( Kevin.bromberg@sba.gov ). Bill Wemhoff bill.wemhoff@nreca.coop is also receiving a copy.

NRECA’s Petition for Reconsideration was filed Wednesday October 20th and argues for rule revisions that would eliminate the peak shaving and demandreduction restrictions EPA has placed on the units in the 100 hours of nonemergency operation. It also argues for a petition provision whereby owners/operators with special circumstances requiring additional operating hours could petition the Agency for those additional hours without being required to add emission controls.

Woodbury REC supports this Petition for Reconsideration in the attachment “2010 Woodbury REC - - EPA RICE letter.docx”.

.

Sincerely,

Ronald A. Kunkel, CEcD, EDFP CEO & General Manager Woodbury County Rural Electric Association (Woodbury REC) PO Box 566 Moville,
Iowa 51039

Tele: 712-873-3125(See attached file: 2010 Woodbury REC - - EPA RICE letter.docx)November 1, 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

Re: Petition for Reconsideration of Portio ns of the Final Rule : National Emission
Standards for Hazardous Air Pollutants for Re ciprocating Internal Combustion Engines

Dear Administrator Jackson:

I am writing in support of the National Rural Electric Cooperative Association’s (NRECA) October 19, 2020, Petition for Reconsideration of portions of the Final National Emission
Standards for Hazardous Air Pollutants for R eciprocating Internal Combustion Engines promulgated on August 20, 2010, ( 75 Fed. Reg. 51,570 ).

Woodbury Rural Electric Cooperative Association (Woodbury REC) is headquartered in Moville, Iowa 51039. Woodbury REC is one of th e 7 Member Cooperatives of Northwest Iowa Power Cooperative (NIPCO). NIPCO is a Generation and Transmission Cooperative headquartered in Le Mars, Iowa. Woodbury REC provides power and various services to its 3,300 member/consumer/owners in western Iowa that covers 2,000 square miles. Woodbury REC with NIPCO have also had a very successful active load management system in place since 1983. Over 30% of the 3,300 consumer/member/ow ners participate in this demand-side
management program.

If left in place, the EPA National Emissi on Standards for Hazardous Air Pollutants for Reciprocating Internal Combusti on Engines (RICE NESHAP) rule wi ll severely restrict and limit our ability to maximize efficient operations of our electric systems. This ruling will also have negative power supply implications as we will be una ble to operate our syst em as efficiently as
we current do. This will increase our co sts and ultimately our rates to the consumer/member/owners. Along with other part s of our country, western Iowa struggles to meet the challenges of the downturn in the c ountry’s economy. Unemployment is high, people are struggling to make ends meet and businesses ar e fighting to stay open. This is certainly not the time to place additional burdens on them.

Woodbury REC, as a Distribution C ooperative, has no major electric generation facilities of our own, but we are concerned primarily with distribu ting electric power to our retail consumers. Woodbury REC simply does not have the resources or a practical reason to keep track of and review the many EPA rulemaking activities under the Clean Air Act to see if one of these rulemakings may have an impact on our operation of delivering electrical power. Without anoutreach from EPA, which was absent in thes e rulemakings, Woodbury REC could not anticipate that the proposed rule for emergency generators would undermine and dest roy our very practical and highly successful peak shaving programs.

The bulk of the small emergency generating units, the subject matter of th is petition, are owned by the rural consumer/member/owners of the el ectric cooperatives and not by Woodbury REC. These small emergency generating units are utili zed in an efficient and productive manner for the
benefit of our rural consumer/member/owners. It is hard to understand and explain that the efficiency benefits derived from the use of these resources would be wiped out by a Federal Government that professes goals of increased energy efficiency and resource conservation.

NRECA’s petition addresses restric tions contained in the final rule that prohibit the use of small emergency generating units for peak shaving programs and limits demand reduction service beginning in 2013 without the addition of expe nsive emission reduction technology on units larger than a specified size.

To help operate our electric sy stem more efficiently and maxi mize not only our power supply, but our distribution system, our load management system includes a peak shaving program that uses the engines you will be regulating an d restricting the use thereof. Without the use of these back-up generators, the cost of power will increase as ther e will be no other cost-effective option to reduce our demand during peak usage times. The added capital expenditures placed on our consumer/member/owners to make the required upgr ades under this regula tory mandate places a very significant financial burden on them. This may force us to cease future peak shaving demand side management program as they will no longer be cost effective for us or the consumer-owner to
consider.

We support the recommendation contained in NRECA’s petition regarding removal of the restrictions on the use of these engines for p eak shaving and demand reduction purposes in the 100 hours of non-emergency operations allowed in th e rule. The use of these engines up to 100 hours for non-emergency operation per year, as already allowed in th e final rule, would not cause any additional emissions and therefore, no additional health risk or environmental harm above that already contemplated in the rule.

In conclusion, Woodbury REC, its consumer/mem ber/owners support protecting public health and the environment. However, in this case th e restrictions are unnece ssary, too severe, will cause a significant detriment to our consumer/member/owners, and wi ll not result in any meaningful environmental benefit. We urge the agency to reconsider these restrictions on peak shaving and demand reduction contained in the fina l rules and amend the rules avoid diminishing the value of these programs and increase the co st of power to our consumer/member/owners.

If you have any questions or need additional information, please contact me at 712-873-3125. Thank you Administrator Jackson for your consider ation of our request. On behalf of our 3,300 consumer/owners/members, we express our desire you will respond favorably on this critically important issue.

Sincerely,

Ronald A. Kunkel CEO & General Managere-mail cc: Robert Wayland Melanie King Kevin Bromberg, SBA