Comment submitted by Dan Chisholm, Sr., MGI Systems, Inc.

Document ID: EPA-HQ-OAR-2010-0295-0021
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: June 24 2010, at 12:00 AM Eastern Daylight Time
Date Posted: June 28 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: June 8 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: September 8 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b09e15
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Healthcare facilities have been severely affected by the restrictions placed on them by the provisions of the original ruling enacted June, 2006. To exacerbate the problem there has been an increase in power interruptions in several areas of the country resulting from utilities not having the infrastructure to handle increased loads in times of inclement weather and power anomalies. To mitigate the inherent dangers of these issues healthcare facilities have sought to enter into Demand Response agreements with their electric utilities in order to be pro-active when power unreliability can be reasonable predicted. Unfortunately, power problems are going to increase, and will probably total in excess of 15 hours during any given year in certain areas. Therefore we are respectfully requesting that the proposed provisions of §60.4211(f)(4) be changed to read as per the attached recommendation.

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Comment attachment submitted by Dan Chisholm, Sr., MGI Systems, Inc.

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Comment attachment submitted by Dan Chisholm, Sr., MGI Systems, Inc.

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