EPA-HQ-OAR-2008-0708-DRAFT-1558.txt

From: "Cronmiller, Rae E." <rae.cronmiller@nreca.coop> 

To: Melanie King/RTP/USEPA/US@EPA, RobertJ Wayland/RTP/USEPA/US@EPA, Joseph 

Goffman/DC/USEPA/US@EPA, Peter 

Tsirigotis/RTP/USEPA/US@EPA 

Cc: "Cromwell, Ted T." <ted.cromwell@nreca.coop> 

Date: 10/31/2012 03:44 PM 

Subject: FW:

 

Greetings. NRECA has conferred with our membership regarding the issues raised in 

connection with the RICE June 

7, 2012 proposal. This e-mail and attachment represents our summary recommendations 

and answers to several 

questions posed by EPA over the several months. 

Regarding the following questions. Would your members be willing to file 

electronically with EPA on annual basis, 

hours and time durations of RICE dispatch for emergency demand response to begin in 

several years? Yes. We have 

to note that the utility knows when and why their dispatch of emergency RICE was 

ordered. However the utility has 

no way of knowing if the owner ran the unit for more or less than the time 

requested, although the total annual 

operated hours of each RICE would be recorded at the RICE site by a non resettable 

hours meter as required by the 

existing regulations. We also note that if the owner “takes the unit offline” 

without being dispatched by the utility, 

we would not know those hours of operation, but again, they would be recorded by the

no resettable hours meter. 

Would you members be willing to use ultra low sulfur diesel fuel for RICE dispatched

for emergency purposes? Yes, 

for emergency dispatch to maintain reliability at the sub-bulk power (non RTO/ ISO) 

level. We assume your question 

was directed at our efforts to broaden RICE emergency use at the local level to 

maintain local reliability. We have no 

position on whether those RICE responding to EE2 regional power alerts (capacity 

markets) for example would 

agree to an ultra low sulfur fuel mandate. 

The attachment provides text recommendations addressing the following areas: 1. 

Suggested Language in red 

identifying entity responsibility for ordering RICE dispatch following protocols 

necessary for maintaining local 

reliability as a follow up to Melanie’s question late last week. This language is an

amendment to what was submitted 

earlier as 63.6640(f)(ii)(b) in effort to further define appropriate RICE emergency 

dispatch at the local level. We 

have included the background materials submitted earlier as well. 

2. For economic demand response beyond the 2017 sunset, we suggested in an earlier 

meeting with EPA to allow 

RICE operation beyond the sunset if the RICE was equipped with crankcase ventilation

(CCV) and utilized ultra low 

sulfur diesel fuel along with the requirements included in Table 2d for emergency 

RICE (this could be defined as 

GACT). We have attached language pursuant to this earlier suggestion. 

3. For annual hours of operation, as we noted in our earlier written comments, the 

penalties for exceeding the 

annual cap are severe and not justified for accidental noncompliance. We believe 

defining compliance on a three 

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EPA-HQ-OAR-2008-0708-DRAFT-1558.txt

your annual rolling average is equitably justified here. We have included language 

to allow compliance with both 

the 100 hour cap and the 50 hour economic demand response cap based on the three 

year rolling average 

concept. After all whether emergency or economic demand response, all RICE use here 

is unplanned and cannot be 

predicted months or even days ahead of time. 

Lastly we do appreciate all your efforts to understand our concerns that reliable 

and affordable and electric power 

be maintained throughout rural America. The last few days here in Washington D.C. 

area and the northeast corridor 

are vivid reminders of how important RICE generation can be in times of distress. 

Our members pride themselves in 

providing excellent power quality and reliability even in rural and remote areas. We

endeavor to assist them in this 

RICE effort. 

Please feel free to contact us should you have any questions. 

Confidentiality Notice: This e-mail message, including any attachments, is for the 

sole use of the 

intended recipient(s) and may contain confidential and privileged information. Any 

unauthorized 

review, copy, use, disclosure, or distribution is prohibited. If you are not the 

intended recipient, 

please contact the sender by reply e-mail and destroy all copies of the original 

message. (See 

attached file: NRECA RICE recommendations.docx)

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