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 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. 


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.