November 3. 2010 

## 2?1JNOV 10 PM12= 35

The Honorable Lisa Jackson EPAAdministrator 

### United States Environmental ProtectionAgency Ariel Rios Building (Mail Code 1101) 1200 Pennsylvania Avenue NW Washington, DC 20460 Dear AdministratorJackson: Re: Petition for Reconsideration ofPortions 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 harmacross 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 SECOwe have seven (7) small diesel emergency generator sets, which serve a hospital, several schools (that are used as hurricane shelters), and SECOfacilities. These generators are also used for peak shaving to lower the cost ofelectricity 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 ATawc utotK Enet;v' Cwx4w,acne 1(.t-. PO Box iUl 50 Vv'rNr rtrdi,r r\~enuc 8510 \orth I-fow-e'v Road 610 US Hix~wati~ 41 Jourh 330 South L~ I :i,qhw-a", 301 LuS:i, FL 32-2i,-6=43 Growrland, FL 34736-223H Irecmrss

. FL 3-145p-603(i Sumtenille.Fl-33ig5-i13111 (35213_4;-%0i1 (3>?i-Z29-_195 (3521 -2(i-3944 ~35_; -<13-3801 -i8- =SW (>+)ch Avcaue l1Qil .i,Fl_-34V4- -1 !S (3i21 -3'-~l :p~Lisa Jackson, Administrator Page 2 November 3. 2010

by the co-op in peak-shaving programs. SECOis 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 esi - iid businesses in the SECOservice area. r 'dents 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 fromthese 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 fromhaving 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. Thankyou for your consideration of this very important matter. In this time ofeconomic strain on rural American, it is important that we reduce costs where we can without causing environmental harm . Sincerely, 

### I'. es P. Duncan &General ManagerO .J 4^ W V M pr; ~ d~ ~ a 

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