# @} JouruDeene

July 

### 14,2011

Mr. Brian Shrager Energy Strategies Group Sector Policies and Programs Division (D243-01) Office ofAir Quality Planning and Standards U.S. Environmental Protection Agency Research Triangle Park, 

### NC 27711 

## SUBJECT: Comments 

### on "National Emission Standards 

### for Hazardous 

### Air pollutants for 

### Major 

## Sources: lndustrial, Commercial, 

### and lnstitutional Boilers 

### and process Heaters,' ("lndustrial Boiler MACT')

Dear Mr. Shrager:
On behalf of Deere 

### & Company ("Deere" or "John Deere"), Iam pleased to submitthe following 

### comments 

### on

### the United States Environmental Protection 

### Agency's 

### (EPA) lndustrial Boile-r MACT standard referenced 

### above. These comments 

### are submitteð puisuant 

### totheAgency's 

### !9tj9e to

### delaythe effective date of

### the standard published in

### the Federal Register 

### ontúay 

### íg, 

### 2ol1 (p.28663), and stated intention to reconsider certain aspects ofthe

### rule. ln regards tótné 

### lndustrial Boiler MACT, 

### we acknowledge 

### the technical comments 

### that have beeñ submitted 

### previously 

### by

## others. However, 

### our comments 

### today 

### focus 

### onthe business aspects of implementing this regulation and provide an alternative compliance timing 

### proposalfor industrial coal-fired units.
Deere 

### is 

### aworld leader in 

### providing advanced products 

### and services 

### for agriculture, forestry, 

### construction, 

### lawn and 

### turf care, landscaping

### and irrigation. Deere 

### also manufactures and markets off-highway diesel engines, and provides fínancial services

### worldwide. As 

### a 1z4-year

### old company

### with nearly 60,000 global employees,

### we are proud 

### of our strong histoiy of environmental compliance and sustainability efforts worldwide. 

### Scope 

### of Boiler MACT 

### and 

### its affect 

### on Deere 

### & Company Although

### the EPA estimatesl 

### thatthere

### are more

### than 13,600 boilers

### and process heaters located

### at major hazardous 

### air pollutants 

### (HAP) sources 

### that

### will be subject 

### to

### the lndustrial 

### Boiler MACT, 

### the rule is expected 

### to have 

### the most significant impact 

### onfacilities 

### that utilize 

### coal- 

## or biomass-burning 

### boilers (solid-fuel-fired 

### boilers).

### The EPA estimates 

### there are approximately 

### 580 coal-fired boilers (4o/o

### ofthe anticipated regulated population)

# - of which Deere ownssix coal-fired boilers attwo different

### facilities. The EPA estimates tnai 

### the average 

### 1 Environmentat Protection Agency (EPA) proposed rule, "National Emission Sfandards 

### for Hazardous Air Pollutants for Major Sources: lndustrial, Commerciat, and lnstitutionat Boiters and process Heaters," Federal Register 

### / Vol. 75, No. 107/ Friday,June 4, 2010/ pg. S2OS| Deere & Company One John Deere Place Moline, lL 61265 USA Phone: (309) 765-5151 zelniolauriel@ohndeere.com
Laurie L.Zelnio Director, Environment

# 'G,Jonru Deene

capital cost of retrofitting an industrial coal-fired boiler

### with pollution-control equipmentthat will 

### meet emissions limits 

### will be nearly 

### $8 

### million. Deere 

### is 

### a singularly careful steward 

### of the environment 

### (since 1972

### we have, 

### for example, 

### reduced our greenhouse 

### gas emissions by 670/o) and

### we make 

### our business decisions 

### in light 

### of our environmental 

### responsibilities. Our 

### efficient 

### and economical operation 

### of these boilers requires careful lifecycle analysis and planning.


### Differences Between Utility and 

### lndustrial Sources lndicate Need 

### for Different 

### Application of MAGT 

### Standard Compliance Timing
The Utility MACT

### will encompass coal-fired generation within 

### the electric utility 

### industry. The economic and regulatory model

### for regulated utilities allows them 

### to recover compliance costs through ratemaking 

### cases. Utilities 

### that operate in 

### a rate-regulated environment may apply to utility commissions

### to recover 

### the costs of "prudent 

### investments." Pollution controls necessary 

### for compliance aretypically deemed 

### a prudent investment and this allows costs

### to be allocated 

### to many customers and recovered relatively quickly

### with limited 

### risk. The direct applicability to electric utilities and common features of compliance requirements across utilities will likely raise competitive prices, allowing

### for some recovery by independent power producers in competitive electricity market areas, as

### well. That is not true

### for Deere and other industrial firms operatinq coal-fired boilers.
The 2015 Deadline 

### is lmpractical 

# 1. Competition between regulated sources will increase project cost
The utility industry has alreadyvoiced concerns about their ability 

### to retrofit existing boilers 

### with environmental 

### controls

## or build replacement 

### capacity

### by

## 2015. They cite the complicated logistics 

### of simultaneous installations, industry-wide competition

### for materials 

### and craft labor, 

### and increased permitting requirements 

### that threaten

### to require multiple simultaneous 

### changes. lndustrial sources faced with 

### the same retrofit requirement 

### will be 

### forced

## to compete

### with utilities

## for engineering 

### services, contractors, laborers, and materials over 

### this same 

### time 

### period. We believe 

### it is likely

### this competition 

### will escalate project costs. 

## 2. An accelerated compliance schedule disregards lifecycle cosfs of existing infrastructure and creates inefficiencies ofexpenditures


### A forced compliance 

### timeline may lead 

### to stranded investment 

### for Deere 

### where

### we still 

### have appreciable 

### bookvalue 

### in coal ancillary 

### assets. Businesses 

### need certainty for financial planning and 

### the ability 

### to manage their limited financial resources wisely with an eye to lifecycle efficiencies and return on investment.


### Alternative Proposal
Affected industrial coal-fired 

### boilers represent only 4o/o 

### of the anticipated regulated lndustrial Boiler MACT population andface 

### the highest cost-estimates 

### for pollution control 

### upgrades. ln Deere & Company One John Deere Place Moline, lL 61265 USA Phone: (309) 765-5151 zelniolauriel@oh ndeere.com
Laurie L.Zelnio Director, Env¡ronment

# @ JonruDeene

addition, they 

### will be competing against

### the electric utility industry under

### the same timeline for pollution control equipment and craft labor.
lnstead 

### of one compliance date 

### forthe estimated 13,600 affected boilers and process heaters under

### the lndustrial Boiler MACT,

### we propose

### the EPA consider 

### a stased implementation plan for 

### the affected industrial coal-fired boilers (4o/oof

### the regulated 

### population¡. WnereinStfecteO industrial coal-fired boilers submit 

### a transition plan 

### to be in compliance 

### by2018which would have to be approved by the appropriate agencies.
We believe staged implementation thattakes into account the types of sources and the source's abilityto spread out and recover costs in afiscally responsible manner will provide industry the 

### flexibility needed

## to incorporate 

### the lifecycle 

### of their assets, provide certainty 

### in business investment planning, 

### foster moretime 

### for innovation, 

### and encourage compliance technology transfer between the utility and índustrial sectors. 

### Closing

The Executive Order issued by President Obama last January laid out 

### a new review process 

### for regulations, stating 

### that an agency should "tailor 

### its regulations

### to impose

### the least burden on society, consistent with obtaining regulatory objectives,taking into account, among other things, and tothe extent practicable, the costs of cumulative regulations." 

### ln particular, the Order asfèO 

### Agencies

### to "consider 

### costs 

### and how best

### to reduce burdens 

### for American businesses and consumers." 

### We applaud 

### the Agency's 

### efforts

## to balance regulatory reform 

### with

### the need

## to support 

### American businesses 

### in

### this challenging 

### economy. We appreciate 

### your consideration 

### of our 

### proposalfor atime-limited transition planfor affected industrial coal-fired boilers.

Laurie L. Deere & Director

## - Environment & Energy, Standards & Product Safety Deere & Company One John Deere Place Moline, lL 61265 USA Phone: (309) 765-5151 zelniolauriel@ohndeere.com

Laurie L.Zelnio Director, Environment