### From: Don DiCristofaro <DDiCristofaro@enernoc.com>

To: Melanie King/RTP/USEPA/US@EPA

Cc: Rick Counihan <RCounihan@enernoc.com>

Date: 12/03/2012 02:42 PM

Subject: RE: Testing Language in NESHAP r.e. DR Audits

Melanie,

Regarding the testing language in the NESHAP and NSPS, I recommend that

63.6640(f)(2)(i) (and the appropriate sections of 40 CFR 60 Subparts IIII and JJJJ) be

changed as per the attached. We added the following from the emergency DR trigger

language we sent to you last week:

or by the entity with jurisdiction over the relevant demand response program

to account for those ISOs that have CSPs (e.g., demand response providers) decide

when the audit should occur (e.g., PJM) rather than calling the audit directly (e.g., ISO

New England). Also, since there is not a separate testing clause for engines

participating in non-emergency demand response, I believe 63.6640(f)(2)(i) covers

audits for non-emergency DR programs also so long as the non-emergency DR use is

less than 50 hours (through April 16, 2017) and the total non-emergency use is 100

hours or less.

Let me know if you have any questions or require additional information.

Don

From: Don DiCristofaro

Sent: Sunday, December 02, 2012 7:28 PM

To: 'king.melanie@epa.gov'

Cc: Rick Counihan

Subject: Testing Language in NESHAP r.e. DR Audits

Melanie,

I am still working on a recommendation regarding how the language in the testing portion of the NESHAP and NSPS

should be modified to account for DR audits. It is not as easy as I thought to describe. Some ISOs (such as ISO NE)

call

their own audits (they like the surprise factor); whereas, other ISOs (such as PJM) have the DR provider call their

own audits. It is the latter method that I am trying to get a description of in terms of how to describe who calls it.

I will work to get you a response as soon as possible.

Don

Don DiCristofaro, CCM – Air Quality Meteorologist Consultant

EnerNOC, Inc. | 101 Federal Street, Suite 1100 | Boston, MA 02110

m: 617.834.8408 | f: 857.221.9464

DDiCristofaro@EnerNOC.com| www.EnerNOC.com

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EnerNOC, Inc. and is intended only for the person or entity to which it is addressed. This email may contain

information that is privileged, confidential or otherwise protected from disclosure. Distributing or copying any

information contained in this email to anyone other than the intended recipient is strictly prohibited. (See

attached file: NESHAP 40 CFR 63 - Testing Language with suggested change 120312.docx)NESHAP 63.6640(f)(2) and 40 CFR 60 Subparts IIII and JJJJ:

(i) Emergency stationary RICE may be operated for maintenance checks

and readiness testing, provided that the tests are recommended by

federal, state or local government, the manufacturer, the vendor,

Reliability Coordinator or other authorized entity as determined by the

Reliability Coordinator or by the entity with jurisdiction over the

relevant demand response program or the insurance company

associated with the engine. Deleted: the regional transmission authority

or equivalent balance authority and

transmission operator,

Deleted: