On October 11, 2006 AGA submitted comments on EPA Proposed Rule on Standards of Performance for Stationary Spark Ignition Internal Combustion Engines and National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines, 71 Fed. Reg. 33804. These comments note AGA supports the detailed technical comments that the Interstate Natural Gas Association of America (INGAA) has filed in this docket regarding the IC Engine Proposed Rules. AGA appreciates EPA’s intention to develop a proposal that could offer some flexibility and streamlining. However, AGA agrees with INGAA that there are several problems with the way that the proposal is structured. The proposed engine certification provisions raise some serious concerns, in large part because EPA has modeled this stationary engine rule on the standards and concepts that EPA uses for mobile and non-road engines. As a result, the IC Engine Proposed Rules have imported mobile source concepts that are confusing and are not based on the operational realities of natural gas-fired stationary engines.
These comments are posted under Environmental Comments and can be accessed by clicking here.