Comment submitted by Tony Eng, Ecospec USA, Inc.

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.