This comment letter response contains two parts:

(1) The original submittal from the commenter.

(2) A data base printout of EPA’s response to each point raised by the commenter.

Notes about the response letters:

• The response letters were generated by a data base used to track the content of all public

comment submittals and ensure that the Agency responds to each. Each comment letter

was assigned a Letter ID that corresponds to the last four digits of the docket number of the

original comment (as posted on www.regulations.gov).

• Each response letter includes: comment text; an EPA

‐ assigned comment code; and an

individual response. These are described and explained below.

• The data base contains Comment text from the letters submitted by commenters.

Many hard copy letters were scanned into electronic format for inclusion in the data

base. As a result, there may be some typographical errors attributable to optical

character recognition issues. However, all original submittals were reviewed in the

process of drafting responses to ensure that the comment content was understood and

appropriately addressed.

• The content of each comment letter was divided into topic areas and assigned a unique

Comment ID. Additionally, one or more Comment Codes (i.e., unique topic area ID) was

assigned to each discrete point raised by a commenter. This information was added to

the data base. To inform final rulemaking decisions, all comments and information

received on a given topic were reviewed by technical experts in each rule area (e.g., on

construction requirements).

• Following decisions on the final rule requirements, Individual responses were drafted

by topic area to ensure completeness and consistency of the responses with the final

rule and other responses to similar comments. Each discrete point made by a

commenter was given a unique response.

• Upon completion of comment responses, all information was entered into the data base.

Each letter response is a compilation of each comment and its individual response,

compiled in the order of the original comment letter. As a result of this process, there is

repetition in the response text. The Agency believes this approach ensures completeness

and attention to each comment letter that was submitted.

• All comments in a topic area were reviewed, evaluated, and responded to concurrently.

Responses on each topic area are compiled and are also available in the rulemaking docket.CO2 geologic sequestration is still not th e best solution as end results need

time to verify. There are few other ava ilable technologies within and outside

US. Of which, Ecospec CSNOx methodology (www.ecospec.com) by treating the CO2

emission using activated water is more feasible. Cost of CO2 low-energy

breakdown is also very attractive as comp ared with CO2 GS method. With estimated

costing over US$150 per ton of CO2, it ma y generate more carbon footprint while

during sequestration and transportation. CSNOx is one of few new methods

developed by R&D outfits that deserve more support and attention; whcih is

happening in Europe and Asia. The co mpany welcome participation from

gonvernmental and private insitutions for implementation. Currently working with

various installation in Europe and Aisa , this technology and few other similar

post combustion CO2 emission reduction t echnologies position itself as better

alternative against heavy scaled CO2 GS methodology. There should be a clear

advantage by simply breaking down the tough CO2 with very low energy source

instead of commencing heavy CO2 GS process. CSNOx technology manage to remove

every 100 kg of CO2 using merely 3 kW hr of energy, excluding water plumbing

power. Already with firm schedule of in stalling CSNOx system onboard of Aframax

class marine oil tanker after impressi ve onshore and onboard testings. One of

Asia power plant is also schedule to implement before end of 2009. EPA should

strongly consider this altern ative before pursuing CO2 GS.Letter ID: 0324

Commenter: Tony Eng

Organization: Ecospec USA, Inc.

Letter ID: 0324 Comment ID: 27858 Letter Lines: 16 to 35

Comment Code: 6000 6. Other Comments that are Out of Scope for the NODA

Comment: CO2 geologic sequestration is still not the best solution as end results need

time to verify. There are few other available technologies within and outside

US. Of which, Ecospec CSNOx methodology (www.ecospec.com) by treating the CO2

emission using activated water is more feasible. Cost of CO2 low

‐ energy

breakdown is also very attractive as compared with CO2 GS method. With estimated

costing over US$150 per ton of CO2, it may generate more carbon footprint while

during sequestration and transportation. CSNOx is one of few new methods

developed by R&D outfits that deserve more support and attention; whcih is

happening in Europe and Asia. The company welcome participation from

gonvernmental and private insitutions for implementation. Currently working with

various installation in Europe and Aisa, this technology and few other similar

post combustion CO2 emission reduction technologies position itself as better

alternative against heavy scaled CO2 GS methodology. There should be a clear

advantage by simply breaking down the tough CO2 with very low energy source

instead of commencing heavy CO2 GS process. CSNOx technology manage to remove

every 100 kg of CO2 using merely 3 kWhr of energy, excluding water plumbing

power. Already with firm schedule of installing CSNOx system onboard of Aframax

class marine oil tanker after impressive onshore and onboard testings. One of

Asia power plant is also schedule to implement before end of 2009. EPA should

strongly consider this alternative before pursuing CO2 GS.

Individual Response: This comment is outside the scope of the Notice of Data Availability and the UIC

Program’s authority under the GS rulemaking.