John Quinn	100 Constellation Way

Director – Environmental Affairs		Suite 1000C

			Baltimore, Maryland  21202				410-470-1751

			443-213-3204  Fax

3 September, 2010 								Via email and post

Robert Wayland, Group Leader

Energy Strategies Group

US EPA

Research Triangle Park, North Carolina  27711

Mail Drop D243-01

Cc: Melanie King

Re: Petition for Reconsideration of National Emission Standards for
Hazardous Air Pollutants for Reciprocating Internal Combustion Engines,
Final Rule

RIN 2060-AP36

EPA Docket No. OAR-2008-0708

Dear Ms. Jackson:

Constellation Energy appreciates the opportunity to express support for
EnerNOC’s Petition for Reconsideration of National Emission Standards
for Hazardous Air Pollutants for Reciprocating Internal Combustion
Engines, Final Rule, submitted by Beveridge & Diamond, PC, May 27, 2010.
 We understand EPA has granted the petition for reconsideration.

Constellation Energy

Constellation Energy ( HYPERLINK
"http://cts.businesswire.com/ct/CT?id=smartlink&url=http%3A%2F%2Fwww.con
stellation.com&esheet=6382682&lan=en-US&anchor=www.constellation.com&ind
ex=1&md5=c807813eb61d0e3ab248d95fb58ad5b2" www.constellation.com ) is a
leading supplier of energy products and services to wholesale and retail
electric and natural gas customers. It owns a diversified fleet of
generating units located in the United States and Canada, totaling
approximately 9,000 megawatts of generating capacity, and is among the
leaders pursuing the development of new nuclear plants in the United
States. The company delivers electricity and natural gas through the
Baltimore Gas and Electric Company (BGE), its regulated utility in
Central Maryland. A FORTUNE 500 company headquartered in Baltimore,
Constellation Energy had revenues of $15.6 billion in 2009.  

Petition for Reconsideration – Change 15-hour limit on emergency
engines to 60 hours or the minimum hours required by the ISO, whichever
is less

Constellation Energy supports EnerNOC’s petition for reconsideration
of the rule, specifically with respect to the 15-hour operating limit on
emergency DR.  The 15 hour limit for emergency engine operation in the
regulation currently says,  “The 50 hours per year for non-emergency
situations cannot be used for peak shaving or to generate income for a
facility to supply power to an electric grid or otherwise supply power
as part of a financial arrangement with another entity; except that
owners and operators may operate the emergency engine for a maximum of
15 hours per year as part of a DR program if the regional transmission
organization or equivalent balancing authority and transmission operator
has determined there are emergency conditions that could lead to a
potential electrical blackout, such as unusually low frequency,
equipment overload, capacity or energy deficiency, or unacceptable
voltage level.”  

Constellation Energy favors EnerNOC’s request that the italicized
language above be revised to read, "…may operate the emergency engine
for a maximum of 60 hours per year or the minimum hours required by
Independent System Operator tariff, whichever is less..."   

The Rationale behind the request for 60 hours is:

ISOs do not have the discretion to dispatch DR resources to take
advantage of the greater hours.  The emergency DR programs are only
called under very specific, planned, and controlled circumstances.  The
system operator must report operation in any emergency state to NERC. 
NERC requires development of formal plans for Capacity and Energy
Emergencies, and precise implementation when calling emergency DR
events.

The 15 hour limit may prevent emergency engines from participating in
emergency DR programs. The PJM FERC Tariff for the Emergency Load
Response program requires a minimum availability of 60 hours. PJM’s
Reliability Assurance Agreement states that a party must agree to
reserve for interruption …at least 10 interruptions per planning
period.  In addition, a party must agree to reserve interruptions of at
least 6-hour duration.  Hence the 60 hours: 10 interruptions at 6 hours
duration per year.

In summary, Constellation Energy feels a 60-hour or ISO limit is more
rational; based on the existing ISO system reliability requirements for
this equipment.

Respectfully,

John Quinn

Director, Environmental Affairs 

Constellation Energy

Cc: Melanie King    HYPERLINK "mailto:King.Melanie@epamail.epa.gov" 
King.Melanie@epamail.epa.gov 

