CARISCH, INC.

681 E LAKE ST.   #262

WAYZATA, MN  55391

TEL: 952-476-7280

FAX: 952-697-1912

CELL: 612-812-5275

e-mail:   HYPERLINK "mailto:george@carischinc.com" 
george@carischinc.com 

  DATE \@ "MMMM d, yyyy"  November 23, 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).

Arby's 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.

The Honorable Lisa Jackson

November 23, 2010

Page 2

Arby's 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, Arby's 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.

Arby's 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 1 look forward to your response.

Sincerely,

George Carisch

Carisch, Inc. DBA Arby’s

cc: 	Robert Wayland, EPA

Melanie King, EPA

Kevin Bromberg, SBA

