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

Page 1EPA-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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