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Agency Documents , Alerts, Comments
AGA/EPA Boiler MACT Letters re Sierra Club Petition for Reconsideration-July 2011
AGA-APGA Comments on EPA Proposed Rule: Boilers and Process Heaters (August 23, 2010)
AGA Alert - EPA Proposed Boiler MACT Rule (June 29, 2010)
AGA Alert - EPA Publishes Diesel Engine MACT Final Rule (Feb. 8, 2010)
Engine Air Toxics (RICE MACT) Final Rule Postponed (Nov. 9, 2009)
AGA Comments on EPA Proposed Hazardous Air Pollutant Standards for RICE Engines (June 4, 2009)
AGA Comments on EPA Proposed Hazardous Air Pollutant Standards for RICE Engines (June 3, 2009)
AGA Comments on EPA's Proposal to Drop the "Once-In-Always-In" MACT Policy (May 4, 2007)
AGA Comments on EPA Engine NSPS & NESHAP Proposed Rule (Oct. 11, 2006)
AGA Comments on Boiler MACT (March 14, 2003)
INGAA Detailed Comments on EPA's Hazardous Air Pollutant MACT Proposed Rule for Combustion Turbines (February 28, 2003)
AGA Comment Letter Supporting INGAA Turbine MACT Comments (February 28, 2003)
AGA Comments Supporting INGAA Comments on EPA's IC Engine MACT Proposed Rule (February 20, 2003)
INGAA Comments on EPA's IC Engine MACT Proposed Rule (February 19, 2003)
INGAA Cover Letter for Comments on EPA's IC Engine MACT Proposed Rule (February 19, 2003)
AGA Alert - MACT Hammer for Case-by-Case Hazardous Air Pollutant Permits Deadline Extended (March 12, 2002)
Final Technical Amendments Published: MACT for Oil & Gas Production and Natural Gas Transmission & Storage (June 29, 2001)
Transmission and Storage MACT (Part 63, Subpart HHH) Final Rule : Gas Utilities Are Exempt (June 17, 1999)
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 AGA Comments Supporting INGAA Comments on EPA's IC Engine MACT Proposed Rule (February 20, 2003) 

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.

 

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