On February 19, 2003 AGA submitted comments to EPA on National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines ("Proposed IC Engine MACT Rule”). These comments note that AGA supports the detailed technical comments dated February 19, 2003 that INGAA filed in this docket on EPA’s Proposed Engine MACT Rule. We agree, for example, that EPA should not adopt any of the proposals that INGAA has shown are not supported by evidence in the rulemaking record, such as the proposal to require carbon monoxide (CO) continuous emissions monitoring (CEMS) rather than allow parameter monitoring for lean burn engines greater than 5,000 horsepower. We also agree that EPA should not stifle innovation by mandating particular control technologies. Instead, EPA should set emission standards and then allow operators to use their creative ingenuity and any technology that can achieve the goal. We also agree that EPA should establish applicability criteria that focus MACT regulation on larger, higher-emitting units and relieve smaller and lower emitting engines from the burden of MACT regulation. This change in applicability criteria could help limit burdens on smaller and more efficient engines used in distributed energy as well as natural gas utility and pipeline operations.