
November 15, 2011


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).  

Price Electric Cooperative serves 9000 members in parts of nine counties in Northern Wisconsin including Price, Iron, Vilas, Ashland, Oneida, Lincoln, Taylor, Rusk, and Sawyer.  Our membership is mostly rural residential and seasonal cabins.  We have one of the lowest member densities with less than 5 members per mile of distribution line.  Also the monthly kWh average per meter is one of the lowest among cooperatives in the state.  Price Electric Cooperative has a staff of 24 full time employees.

It is very difficult for a cooperative the size of Price Electric Cooperative to have the staff on hand to review all of the EPA's rulemaking process, particularly in regard to owners and operators of small emergency generating units participating in peak shaving programs.  There seems to be inconsistencies in the rules regarding how certain RICE are to be regulated.

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.

The main reason this is a problem for Price Electric Cooperative and the members, who take part in this program is that it will have an impact on our ability to help keep cost down to our members while maintaining reliability.  These members have invested in systems to enhance their reliability in many cases to provide service to their customers and are willing to help Price Electric Cooperative manage the electric distribution load.   These engines run during a peak usage situation to help the rest of the members maintain level service and to reduce the overall cost to the cooperative.  In turn the member receives a reduced rate for the overall kWh used.  When the system is operated for peak shaving the member is paid a rate of $.50 per kWh that is offset by the generator.  Both of these programs benefit the entire membership of the cooperative and without the program there will surely be a rate increase.  This will also impact the chance of additional generator sets being added to the program due to the cost increase of the equipment.  Since these generators are owned by the members we have no control over their ability to cover the capital cost for the controls needed to continue the program.

Price Electric Cooperative recommends that the restrictions on the use of small stationary compression ignition and spark ignition RICE emergency generating units for peak shaving and demand reduction purposes should be eliminated entirely.  An alternate solution would be to minimize the restrictions so that the value of our programs would remain. 
EPA'S RICE NESHAP rules allow emergency units to operate up to 100 hours-per-year or more for testing, maintenance, etc., including 50 hours-per-year for non emergency situations -- but specifically not for peak-shaving purposes.  Peak shaving programs involve minimal hours of operation, thereby potentially not adding to the allowed 100 annual hours of operation contained in the rules. Continuing the use of peak shaving programs, therefore, would not cause additional public health risks or environmental harm beyond those already contemplated in the final rule.  Elimination of peak-shaving programs, however, would require the procurement of additional central station capacity and potentially the addition of transmission and distribution line capacity to service the demand increase. 

Price Electric Cooperative supports the EPA'S efforts to protect public health and the environment from harm caused by the presence of toxic air pollutants.  Price Electric Cooperative is very concerned, however, that the Agency has included unnecessary restrictions in this rule that will cause economic harm to our members without providing any meaningful environmental benefit.

Please contact me if you have any questions or require additional information.  I can be reached at 1-715-339-2155 or twerner@price-electric.com.

Sincerely, 


Timothy L. Werner,
Vice President of Member Service
Price Electric Cooperative
P.O. Box 110
Phillips, WI  54555


cc: 	Robert Wayland
	Melanie King
	Kevin Bromberg, SBA
