P.O. Box 10 St. Marys, OH 45885

Phone- 419-394-4110 1-800-962-3830

Fax- 419-394-8333

www.midwestrec.com

November 8, 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 fo r Reciprocating Internal Combustion Engines

Dear Administrator Jackson:

I am writing in support of the National Rural Electric Cooperative Association’s (NRECA) October 19, 2010, Petition for Rec onsideration of portions of the Final

National Emission Standards for Hazardous Ai r Pollutants for Reci procating Internal Combustion Engines promulgated on August 20, 2010, ( 75 Fed. Reg. 51,570 ).

Midwest Electric is a rural cooperative servi ng west central Ohio, including the largest agricultural income producing area of the state. Much of this is livestock such as poultry, dairy and swine – operations that rely on b ackup generators in order to ensure the

livelihood of their livestock and their busin ess. When the power goes out, livestock animals die, especially in warmer months when cooling fans are needed. And for economic and environmental reasons, we have a load management program where we shut off utility power during peak periods a nd the customer is switched to their backup generator. This annually saves our coope rative $400,000 in avoided demand charges, which represents about 3% of our annual power costs. The majo rity of our load control is through the generator program. Ou r generator load c ontrol is able to shave about 15% off our peak megawatt demand. Therefore, without this program we would see immediate

electric cost increases for our members. In this economy, such an increase would be

noticeable and difficult.

Environmentally, our generator load control program helps de lay or avoid the need to build expensive new coal or natural gas power plants.Further, we were not aware of the RICE NESHAP rules until recently. And we believe that with more dialogue, EPA would understa nd the positive benef it – economically and environmentally – these load cont rol programs have in America.

NRECA’s petition addresses restri ctions contained in the fina l rule that prohibit the use of small emergency generating units for peak shaving programs and limits demand reduction service beginning in 2013 without th e addition of expensive emission reduction technology on units larger than a specified size.

We also believe it would be cost-prohibitive for local farmers to add expensive emissionreducing technology to their generators.

We support the recommendation contained in NRECA’s petition regarding removal of the restrictions on the use of these engi nes for peak shaving and demand reduction purposes in the 100 hours of non-emergency opera tions allowed in the rule. Use of these engines up to 100 hours for non-emergency operati on per year, as alre ady allowed in the final rule, would not cause any additional emissions – and therefore, no additional health risk or environmental harm above that already contemplated in the ru le. Our load control program, based on historical data , operates less than 100 hours.

In conclusion, we support protecting public heal th and the environment but in this case the restrictions are unnecessary, too severe , will cause significant detriment to our consumer-owners, and will not result in any me aningful environmental benefit. We urge you to reconsider these restrictions on peak shaving and demand reduction contained in

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

our consumer-owners.

Please contact me if you have questions or need additional information. Thank you for considering our request.

Regards,

Rick D. Gerdeman Manager/CEO

rgerdeman@midwestrec.com

cc: Robert Wayland Melanie King Kevin Bromberg, SBA