November 3, 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 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, 2020, 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. 51,570). 

EPA’s rulemaking process resulted in confusion for us at the Dunn Energy Cooperative as 

well as the owners and operators of small emergency generating units participating in our 

peak shaving programs. Dunn Energy Cooperative does not own any of the generating 

units affected by the EPA ruling. Our members; farmers and small business owners do. 

Without an outreach from EPA, which was absent in these rulemakings, we had no idea 

that the proposed rule for emergency generators would adversely affect our peak shaving 

programs. 

NRECA’s petition addresses restrictions 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 expensive emission reduction 

technology on units larger than a specified size.

We work with our members to offer them reduced electric rates in exchange for reducing 

their electric demand during times of peak electric demand. Some of our farms and small 

businesses use backup generators, powered by gasoline and diesel engines, to provide 

electricity during these peak shaving times. There may also be times that they can use the 

equipment to provide electricity to their farms and businesses. If peak shaving is not 
allowed for these types of engines, we will not be able to reduce demand during peak 

periods and our members will pay higher costs for their electricity. 

Specifically, Dunn Energy Cooperative supports the recommendation contained in 

NRECA’s petition to remove the restrictions on the use of these engines for peak shaving 

and demand reduction purposes in the 100 hours of non-emergency operations allowed in 

the rule. The request by NRECA doesn't ask for more hours of operation, just including 

peak shaving use within the 100 hour limit. This would not cause any additional 

emissions – and therefore, no additional health risk or environmental harm above that 

already contemplated in the rule. 

Dunn Energy Cooperative and our power supplier, the Dairyland Power Cooperative, are 

strong environmental supporters. Dunn Energy works closely with our members who are 

interested in developing renewable energy sources. We have also taken steps to reduce 

energy consumption at our headquarters building. Dairyland Power has already met the 

State of Wisconsin goal, not required until 2015, of generating 10% of their power from 

renewable sources. But we like to keep the cost of the electricity as low as possible for 

our members too. That means offering peak shaving and demand response programs for 

a number of our members. These programs won't be possible if peak shaving is not 

allowed in the 100 hours for reciprocating internal combustion engines. I urge you and 

the EPA to reconsider these restrictions on peak shaving and demand reductions 

contained in the final rules and amend the rules so as to not diminish the value of these 

programs to our members.

Thank you for your consideration of my request Administrator Jackson. I hope that you 

will respond favorably. If you have any questions or require additional information you 

can reach me at:

Dunn Energy Cooperative

Attn: James R. Hathaway

PO Box 220

Menomonie WI 54751

jhath@dunnenergy.com

Regards,

James R. Hathaway

General Manager/CEO

cc: Robert Wayland

Melanie King

Kevin Bromberg, SBA