107 Selden Street, Berlin, CT 06037 

Northeast Utilities Service Company 

P.O. Box 270 

Hartford, CT 06141-0270 

(860) 665-5000 

June 30, 2004 

D21131 

Mr. Robert Donaldson 

Bureau of Waste Prevention 

Department of Environmental Protection 

One Winter Street, 8th Floor 

Boston, MA 02108 

Dear Mr. Donaldson: 

Northeast Utilities System 

Comments on Proposed Engines and Combustion Turbines Rule 

Northeast Utilities Service Company (NUSCo), on behalf of Western Massachusetts Electric 

Company, Holyoke Water Power Company, Northeast Generation Services Company, and Select 

Energy, hereby submits comments on the proposed Engines and Combustion Turbines Rule 

(310 CMR 7.00). 

NUSCo supports the efforts of the Department of Environmental Protection (DEP) to develop 

regulations that will enhance air quality, and that are consistent with the regulations in other 

jurisdictions. In particular, we believe that permitting the use of existing fuel stocks after the 

effective date of the rule is a logical approach. Similar regulations are presently under 

consideration by the Connecticut DEP. 

NUSCo offers specific three comments on the proposed rule, as outlined below. 

1. Coordination of Carbon Dioxide Controls with Climate Change Strategy 

NUSCo has supported climate change actions in the past, which have all been subject to a larger, 

overall plan. With the recent Climate Action Plan approved by Governor Romney, NUSCo 

would like to know how this proposed rule figures into the overall strategy of the State's Climate 

Change plans. We are concerned that significant changes adopted in piece meal fashion could 

significantly disrupt the reliability of the transmission and distribution system. We would 

appreciate it if DEP would articulate its larger plan. 

2. Records Location 

Numerous places in the regulations, including 310 CMR 7.42(f) (2) requires that all records be 

kept on-site at the facility where the engine or combustion turbine is located. Many facilities 

where such equipment is located are un-staffed and do not have structures where records can 

Northeast 

Utilities System 

OS3422 REV. 8-9S 
Mr. Robert Donaldson 

D21131/Page2 

June 30, 2004 

be stored. In order to simplify the process for both the regulated community and DEP, NUSCo 

suggests that DEP modify the language to enable records to be stored at the closest facility that 

can accommodate the recordkeeping requirements, that is owned by the owner or operator of the 

engine or turbine. 

For inspections at un-staffed facilities, DEP will need to contact the owner or operator of the 

engine or turbine prior to the inspection, and records can be made available at the inspection. In 

addition, DEP can request records at any time regardless of where the records are stored. 

3. Engine Certification 

We believe that DEP has unnecessarily confused the issue of the engine certification 

requirements detailed in 310 CMR 7.42 (e) (1). DEP in 310 CMR 7.42 (b) (1) states that engines 

greater than 37 kW meeting the requirements in 40CFR 89.105 are automatically certified under 

this section. DEP is requiring a letter of compliance from the supplier. However, NUSCo 

believes that it is unlawful to sell such engines that do not meet the emissions limitations in 

Massachusetts after the applicable date. Therefore, certifying that one has purchased a 

complying unit is unnecessary. Verification of the engine's manufacture date should suffice. 

We further believe that it would be more efficient and to the point to require engine 

manufacturers to certify that their products meet the applicable requirements rather than stack 

testing engines that will have limited operating hours. Requiring a manufacturer's certification 

will likely result in far less effort on both the DEP and the regulated community. 

NUSCo appreciates the opportunity to offer comments on this proposal. If you have any 

questions, please contact Mr. H. L. (Ledge) Chamberlain, Environmental Management 

Department, at (860) 665-3183. 

Very truly yours, 

NORTHEAST UTILITIES SERVICE COMPANY, as Agent for 

WESTERN MASSACHUSETTS ELECTRIC COMPANY, 

HOLYOKE WATER POWER COMPANY, 

NORTHEAST GENERATION SERVICES COMPANY, and 

SELECT ENERGY 

itricia McCullough 

Director - Environmental Management 

i