November 3, 2010

The Honorable L isa 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 Fina l 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 fo r 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 an y of the generating
units affected b y the EPA ruling. Our membe rs; 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 adversel y affect our peak shaving programs. NRECA’s p etition addresses r estrictions 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 large r than a specified size

. We wo rk w ith 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 b y gasoline and diesel engines, to provide electricit y 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 notallowed for these ty pes of engines, we will n ot be able to reduce demand during peak periods and our members will pay higher costs for their electricit y. Specificall y, Dunn Energy Cooperative supports the recommendation contained in NRECA’s petition to remov e the restrictions on the use of these e ngines for peak shaving and demand reduction purposes in the 100 hours of non

- emergency operations allowed in the rule . The request b y NRECA doesn't ask for more hours of operation, just including peak shaving use within the 100 hour limit. This would no t cause an y additional emissions

– and therefore, no additional health risk or environmental harm above that alread y contemplated in the rule. Dunn Energy

Cooperative and our power supplier, the Dairyland Power Cooperative, are strong environmental supp orters. Dunn Energy works closel y 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 p rograms 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 th ese programs to our members. Thank y ou for y our consideration of m y request Administrator Jackson. Ihope that y ou will respond favorably . If y ou have an y questions or require additional inf ormation y ou can reach me at: Dunn Energy

Cooperative Attn: James R. Hathaway PO Box 220 Menomonie WI54751 jhath@dunnenergy .com
Regards,

James R. Hathaway General Manager/CEO

cc: Robert Wayland Melanie King Kevin Bromberg, SBA