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 . 20406

Dear Administrator Jackson:

I am writing in regards to National Rural Electric Cooperative Association's (NRECA) October 19, 2010, Petition for Reconsideration of portions of the EPA rules that set National Emission Standards for Hazardous Air Pollutants ("NESHAP") for Compression Ignition and Spark Ignition Stationary Reciprocating Internal Combustion Engines ("RICE") (75 Fed. Reg. 51,570)).  While Withlacoochee River Electric Cooperative understands and appreciates the EPA's efforts to continue to improve air quality across the country, we are deeply concerned about the impact this will have on members and our state.  

WREC is a not-for-profit electric cooperative that owns 32 small diesel emergency generator sets that total about 50 MW.  These units are located throughout our hurricane prone service area in west central Florida.  Among the engines covered by these rules are small diesel engines used in emergency generator sets. In Florida, many of these small units are located at residential, commercial, and institutional facilities.  For example: WREC has units located at two regional well fields that supply fresh drinking water for the entire Tampa Bay Region.  We also have emergency generators located at hospitals that provide full backup power to run the entire facility.  Without these units, these hospitals would be forced to buy their own emergency units at a cost of millions of dollars.  In 2004 when our service territory was hit by two separate hurricanes back to back these units helped keep critical infrastructure up and running when the entire electric grid experienced significant damage.  

WREC and the State of Florida also rely on these generators to help prevent grid failure and blackouts when the state experiences critical generation shortages.  For example Florida experience 15 days of record cold weather January of this year.  These units were critical to help meet the states energy needs and prevent rolling blackouts.  

Withlacoochee serves some of the most economically depressed areas in the country and the cost of power has to be held in check.  One of the few benefits to the Cooperative is the ability to use these generators for peak shaving purposes.  WREC'S generators are used 100 hours or less per year.  This in conjunction with our aggressive energy conservation program reduces the need to build central station power.  

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 emissions reduction technology on units 300 horse power or larger.  Withlacoochee estimates that it will cost about $100,000 per unit to add this technology not counting the on-going maintence cost associated with the new equipment.  The additional cost will likely make it economically prohibitive for the continued use of these units for peak-shaving.  Without the economic benefit WREC will likely have to discontinue the program.  

In light of the minimal environmental effects and significant public benefits from having these units available, WREC requests that you consider the National Rural Electric Cooperative Association's "Petition for Reconsideration of Portions of the Final Rule: National Emissions Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines" delivered to your office on October 19, 2010.   

Thank you for your consideration of this very important matter.  If I can be of assistance in this matter please let me know.  


Sincerely,


Billy E. Brown, 
Executive Vice President and
General Manager
Withlacoochee River Electric Cooperative, Inc.
P.O. Box 278
Dade City FL, 33526-0278
352-567-5133 Ext. 6100

 




