
November 9, 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).  

Glades Electric Cooperative serves portions of four counties in Florida; Highlands, Okeechobee, Glades, and Hendry.  Our service territory is predominantly rural and heavily reliant on agriculture.  The recession has been extremely tough on our consumers and our counties have the highest unemployment figures in the state.  In fact, our service territory has been designated as a Rural Area of Critical Economic Concern (RACEC).  Additionally, the impending sale of U.S. Sugar Corporation to the State for Everglades' restoration has the potential to further devastate our area's economy.  The EPA does not need to be adding to the electricity bills of our members!

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. Glades Electric supports NRECA's recommendation of the removal of the restrictions on the use of these engines for peak shaving and demand reduction purposes within the 100 hours of non-emergency operations already allowed under EPA rule.  

We feel that, by not asking for additional hours beyond the 100 already provided within the rule, there would be no additional emissions and, therefore, no additional risk to health or environment, and would preserve a means of keeping energy affordable in rural areas.

Please do not hesitate to contact me should you have any questions or require additional information.  

Thank you for your consideration.

Paul McGehee
Business Development Manager

cc: 	Robert Wayland
	Melanie King
	Kevin Bromberg, SBA
