November 8, 2010

The Honorable Lisa Jackson

Administrator

United States Environmental Protection Agency

Ariel Rios Building (Mail Code 1101)

1200 Pennsylvania Ave., NW

Washington, D.C.  20460

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

Dear Administrator Jackson:

I am writing in support of the National Rural Electric Cooperative
Association’s (NRECA) October 19, 2020, Petition for Reconsideration
of portions of the Final National Emission Standards for Hazardous Air
Pollutants for Reciprocating Internal Combustion Engines promulgated on
August 20, 2010, (75 Fed. Reg. 51,570).  

Allamakee-Clayton Electric Cooperative (ACEC) is a member-owned electric
distribution cooperative located in northeast Iowa.  We serve
approximately 9748 member-consumers and are about 95% rural residential
or agricultural farm operations in consumer makeup.  Farms are typically
grain and/or livestock based operations, including a significant dairy
and swine industry which is very dependent on affordable and reliable
electric service.

We have only recently become aware of the proposed RICE NESHAP rules and
the potential impact of these rules on our cooperative member-consumers.
 As a distribution cooperative without our own generation facilities, we
have had no practical reason to track and review the many and varied
rulemaking activities under the Clean Air Act.  Lacking any outreach
from the EPA, we have been taken off-guard by the proposed rules and the
potential adverse impact that such changes would have on what has been
heretofore, a very successful and practical peak shaving program.

NRECA’s petition addresses restrictions contained in the final rule
that prohibit the use of small emergency generating units for peak
shaving programs. ACEC has offered a variety of load management programs
for many years, including a Peak Alert Program which allows
member-consumers to utilize their emergency generators for peak shaving
purposes.  Currently we have 20 such accounts which help the cooperative
to realize approximate 1655 kW in demand reduction during times of
system peak demand.  While the resultant savings are beneficial to the
cooperative membership as a whole, the real measure of success is with
the member-owners of the generating units.  These units have largely
been installed as emergency backup generators for livestock operations. 
Without these critical units, the livestock producers could suffer large
financial loss due to livestock mortality during power outages.  By
including these generating units in our Peak Alert Program, the owners
have realized additional financial benefits from the generating units
and are better able to justify the costs of what is in reality, a
necessity for the financial safeguarding of their farm operations.

ACEC’s peak shaving programs typically involve minimal hours of
operation, and would not generally add to the 100 annual hours of
operation allowed under the rules.  Continuing to allow use of
member-owned generators for peak shaving programs would not, therefore,
cause any significant additional public health risks or environmental
harm.  Elimination of this program would, however, require procurement
of additional central station generation capacity as well as possible
additional transmission and distribution line capacity in order to serve
the increased demand.

In light of the minimal adverse environmental effects and the offsetting
benefits of continuing to allow use of small emergency generating units
for peak shaving programs, ACEC is requesting that the EPA reconsider
the provisions of the final RICE NESHAP rules that would otherwise
restrict the operation of these units for peak shaving and demand
reduction programs.

Please contact me if you have any questions or need additional
information.  Thank you for your careful consideration of this matter.

Sincerely,

Paul D Foxwell

Executive Vice President/General Manager

cc: 	Robert Wayland

	Melanie King

	Kevin Bromberg, SBA

