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 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, 2010, 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). 

Midwest Electric is a rural cooperative serving 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 backup generators in order to ensure the 

livelihood of their livestock and their business. 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 and the customer is switched to their backup 

generator. This annually saves our cooperative $400,000 in avoided demand charges, 

which represents about 3% of our annual power costs. The majority of our load control is 

through the generator program. Our generator load control 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 delay 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 understand the positive benefit – economically and 

environmentally – these load control programs have in America. 

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 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 engines for peak shaving and demand reduction 

purposes in the 100 hours of non-emergency operations allowed in the rule. Use of these 

engines up to 100 hours for non-emergency operation per year, as already 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 rule. Our load control 

program, based on historical data, operates less than 100 hours. 

In conclusion, we support protecting public health 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 meaningful 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