November 3, 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).  

EPA’s rulemaking process resulted in confusion for us at the Dunn
Energy Cooperative as well as the owners and operators of small
emergency generating units participating in our peak shaving programs. 
Dunn Energy Cooperative does not own any of the generating units
affected by the EPA ruling.  Our members; farmers and small business
owners do.  Without an outreach from EPA, which was absent in these
rulemakings, we had no idea that the proposed rule for emergency
generators would adversely affect our peak shaving programs.  

NRECA’s petition addresses restrictions contained in the final rule
that prohibit the use of small emergency generating units for peak
shaving programs and limits demand reduction service beginning in 2013
without the addition of expensive emission reduction technology on units
larger than a specified size.

We work with our members to offer them reduced electric rates in
exchange for reducing their electric demand during times of peak
electric demand.  Some of our farms and small businesses use backup
generators, powered by gasoline and diesel engines, to provide
electricity during these peak shaving times.  There may also be times
that they can use the equipment to provide electricity to their farms
and businesses.  If peak shaving is not allowed for these types of
engines, we will not be able to reduce demand during peak periods and
our members will pay higher costs for their electricity.  

Specifically, Dunn Energy Cooperative supports the recommendation
contained in NRECA’s petition to remove the restrictions on the use of
these engines for peak shaving and demand reduction purposes in the 100
hours of non-emergency operations allowed in the rule.  The request by
NRECA doesn't ask for more hours of operation, just including peak
shaving use within the 100 hour limit.  This would not cause any
additional emissions – and therefore, no additional health risk or
environmental harm above that already contemplated in the rule.  

Dunn Energy Cooperative and our power supplier, the Dairyland Power
Cooperative, are strong environmental supporters.  Dunn Energy works
closely with our members who are interested in developing renewable
energy sources.  We have also taken steps to reduce energy consumption
at our headquarters building.  Dairyland Power has already met the State
of Wisconsin goal, not required until 2015, of generating 10% of their
power from renewable sources.  But we like to keep the cost of the
electricity as low as possible for our members too.  That means offering
peak shaving and demand response programs for a number of our members. 
These programs won't be possible if peak shaving is not allowed in the
100 hours for reciprocating internal combustion engines.  I urge you and
the EPA to reconsider these restrictions on peak shaving and demand
reductions contained in the final rules and amend the rules so as to not
diminish the value of these programs to our members.

Thank you for your consideration of my request Administrator Jackson.  I
hope that you will respond favorably.  If you have any questions or
require additional information you can reach me at:

Dunn Energy Cooperative

Attn:  James R. Hathaway

PO Box 220

Menomonie WI 54751

jhath@dunnenergy.com

Regards,

James R. Hathaway

General Manager/CEO

cc: 	Robert Wayland

	Melanie King

	Kevin Bromberg, SBA

