Headquarters Branch Offices



# ~ Riverland - P .O . Bo. 276 h.O.Box248 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 

# CC 0( Fax : (608) 323-3014 Fax : (608) 783-7-204 Fax: (608) 685-4450 

# ooperative Servilig Bqffi Your Touchstone Energy oope

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November 5, 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 , m Y I-f~

~. J U F (,.j'1 ! t ;CCD 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 ofthe 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) . 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 ofthese small stationary S1 and CI engines are not owned by our cooperative, but rather by the members ofour 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 ofand reviewthe many EPA rulemaking activities under the Clean Air Act to see if one ofthese rulemakings may have an impact on our operation ofdelivering electrical power or our members operation. Without an outreach fromEPA, whichwas 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. ` .{~

In addition, because the bulk of the small emergency generating units, which are the subject matter ofthis 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 ofour rural members would be wiped out by a FederalGovernment that professes goals of increased energy efficiency and resource

conservation. NRECA's petition addresses restrictions contained inthe 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 ofexpensive 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 ofthese engines for peak shaving and demand reduction purposes in the 100 hours of non-emergency operations allowed in the rule. The use ofthese engines up to 100 hours fornon-emergency operation per year, as already allowed inthe final rule, would not cause any additional emissions - and therefore, no additional health risk or environmental harmabove 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, andwill 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 ofthese programs to our members. Feel free to contact me at 608-323-3381 at any time ifyou 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 ofour members. Cooperatively yours 

# )v~/C/' ~~x' David R . Oelkers General Manager^1 r n

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