






November 4, 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, 2010, 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).  

Lemke Farm is a member-owner of Cass County Electric Cooperative Inc. (CCEC) and is currently participating in its electric load management program by using our stationary engine generator. The engine generator provides electric power to our facility during times of peak load conditions. In the past several years, the total hours of operation logged on the generator for this program has not exceeded 100 hours.

Inasmuch as the Environmental Protection Agency (EPA) rules allow an emergency use engine generator to operate up to 100 hours annually for non-emergency situations, why should it make any difference how a business chooses to operate its generator within that 100 hour limitation? In other words, why are there restrictions within those 100 hours of non-emergency use for peak shaving? The option to use my generator as part of a peak shaving program on a limited basis is important to me and helps my cooperative operate its distribution system most effectively. It seems to me that this small change to your rules would make the rules more reasonable without sacrificing air quality.

Lemke Farm supports NRECA's petition to remove the restrictions in use of emergency stationary engine generators as they pertain to use for peak shaving. Since the EPA has determined that 100 hours of non-emergency use of a stationary engine generator poses little health risk or environmental harm above that already contemplated in the rule, I believe it should not make any difference under what conditions the unit is operated within that the 100 hours of allowable non-emergency operation 

In conclusion, Lemke Farm respectfully requests the EPA reconsiders its proposed rule for spark ignition (SI) engines.  Assuming the agency recognizes the common-sense logic presented in this letter with regard to the proposed SI rules, and the proposed changes put forth by NRECA, we also urge the agency to apply that same logic to the current RICE rules so as to make the final NESHAP rule consistent and uniform throughout all stationary engine generators powered by liquid fossil-fuels.

Lemke Farm respectfully requests consideration of its request and proposed changes, and thanks the EPA in advance for the same. Thank you for your prompt attention and I look forward to your response.

Sincerely,




cc: 	Robert Wayland, EPA
	Melanie King, EPA
	Kevin Bromberg, SBA
