Headqua r ters 

Branch Offices 

~ Riverland - P.O . Bo . 276 h.O . Box 248 

P0. Box 277 

:~rcadia . N'1 3~612 Onalaska, «'I 5~1(~50 Alma, wl 54bli} 

Energy Phone: (608) 323-3381 Phone: (bll8) 7R3-2238 Phone: (608) 685-4440 

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Fax: (608) 323-3014 Fax: (608) 783-7-204 Fax: (608) 685-4450 

ooperative 

Servilig Bqffi 

Your Touchstone Energy oope do, Li Crosse, evid Trempetileem C01,11tieS 

November 5, 2010 

The Honorable Lisa Jackson 

Administrator 

United States Environmental Protection Agency 

Ariel Rios Building (Mail Code 1101) 

1200 Pennsylvania Ave., N W 

Washington, D.C . 20460 

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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. 51,5 70). 

Riverland Energy Cooperative serves 14,500 members in west central Wisconsin. This 

regulation will even further cripple the economy in our area, which has already been 

significantly impacted by the recent economic challenges . 

The majority of these small stationary S1 and CI engines are not owned by our 

cooperative, but rather by the members of our cooperative. We have no major electric 

generation facilities of our own. Our cooperative has only 43 employees and we simply 

do not have the resources or a practical reason to keep track of and review the many EPA 

rulemaking activities under the Clean Air Act to see if one of these rulemakings may 

have an impact on our operation of delivering electrical power or our members operation. 

Without an outreach from EPA, which was absent in these rulemakings, we could not 

anticipate that the proposed rule for emergency generators would undermine and destroy 

our very practical and highly successful peak shaving programs. 

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In addition, because the bulk of the small emergency generating units, which are the 

subject matter of this petition, are not owned by our cooperative, it was impractical for us 

to contemplate that the continued use of these resources in an efficient and productive 

manner for the benefit of our rural members would be wiped out by a Federal 
Government that professes goals of increased energy efficiency and resource 

conservation . 

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. 

Our cooperative has a peak shaving program that allows our members and our cooperative 

to reduce costs, saving our cooperative money and our member. 

We particularly support 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 . The 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 . 

Finally, we support the concept of protecting public health and the environment but in 

this case the restrictions are unnecessary, too severe, will cause a significant detriment to 

our members, and will not result in any meaningful environmental benefit. 

We urge the agency 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 members. 

Feel free to contact me at 608-323-3381 at any time if you should have questions. Thank 

you for considering my request and I hope that you can see the importance of 

reconsidering this regulation for the sake of our members. 

Cooperatively yours 

)v ~/C/' ~~x' 

David R. Oelkers 

General Manager 
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