November 3 . 2010 

2? 1J NOV 10 PM 12= 35 

The Honorable Lisa Jackson 

EPA Administrator 

United States Environmental Protection Agency 

Ariel Rios Building (Mail Code 1101) 

1200 Pennsylvania Avenue NW 

Washington, DC 20460 

Dear Administrator Jackson: 

Re : Petition for Reconsideration of Portions of the Final Rule : National Emission 

Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion 

Engines 

I am writing in regard to recent EPA rules that set National Emission Standards for 

Hazardous Air Pollutants (NESHAP) for compression ignition and spark ignition 

stationary Reciprocating Internal Combustion Engines (RICE). While I understand and 

appreciate the EPA's efforts to continue to improve air quality across the country, I am 

deeply concerned that the agency has gone too far with these regulations . The 

unnecessary- restrictions in these rules will cause economic harm across rural America 

without providing any meaningful environmental benefit . 

Sumter Electric Cooperative, Inc. ( :SECO) and its 172,000 member-owners support the 

NRECA petition for reconsideration . Among the engines covered by- these rules are 

small diesel engines used in emergency generator sets . At SECO we have seven (7) small 

diesel emergency generator sets, which serve a hospital, several schools (that are used as 

hurricane shelters), and SECO facilities. These generators are also used for peak shaving 

to lower the cost of electricity for our members and shave 7.2 MIA' off our peak demand. 

These units are located throughout our service area in central Florida, which has been hit 

with high unemployment. 

The EPA NESHAP rules, however, will prohibit the use of these small emergency units 

for peak-shaving programs beginning May 2013 without the addition of expensive 

emission reduction technology on units that are 300 horsepower and larger. SECO 

estimates that it vvill cost about $100,000 per unit to add this technology . The additional 

cost uill likely make it economically prohibitive for the continued use of these engines 

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Lisa Jackson, Administrator Page 2 November 3 . 2010 

by the co-op in peak-shaving programs. SECO is a not-for-profit electric utility, whose 

purpose is to provide affordable, reliable electric service to its members . %Vithout the 

economic benefit of these programs. SECO's costs will increase and it will be forced to 

pass these costs along to its consumer-owners . Or it may be forced to discontinue this 

service for hospitals and shelters . In which case, these facilities will be forced to 

purchase their own units. Either way, the higher costs will be passed along to the 

r esi 'dents - iid businesses in the SECO service area . 

Peak-shaving programs require that these engines run less than 100 hours per year. 

Removal of the prohibition on these engines for peak-shaving and demand reduction 

purposes. therefore, will not cause any measureable public health risk or environmental 

harm. but will provide the much needed cost reduction. 

The EPA rule provisions also limit the use of these generators to 15 hours per year when 

required to help prevent system-wide electric failures, including grid blackouts. Collapse 

of the grid potentially could cause significant environmental impacts, well in excess of 

the effects of emissions from these small units if used for more than the restrictive 15 

hours per year to prevent such disasters. 

In light of the minimal environmental effects but significant benefits from having these 

units available. I request that you reconsider the provisions in the final RICE NIESHAP 

rules that restrict the operation of these emergency units for peak-shaving and demand 

reduction programs. This could be done by revising section 63 .6640 to include 

unrestricted peak-shaving and demand reduction operation within the 100 hours per year 

provided in the rule for maintenance and readiness testing . 

Thank you for your consideration of this very important matter. In this time of economic 

strain on rural American, it is important that we reduce costs where we can without 

causing environmental harm. 

Sincerely, 

I' . 

es P . Duncan 

& General Manager 
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