My comment refers to the…

My comment refers to the exemption of units co-generating electricity where the thermal output of the combustor is 50 kW or less.

Because technologies in the fields of steam, thermoelectric and thermoacoustic generators are advancing rapidly, I propose that there be no limit placed on the kW rating of the electrical power produced. The more efficient, the more desirable. There is no practical purpose for limiting the amount of electricity generated given that the maximum input power is stipulated. There is no reason to limit the electrical output to that produced by any current technology

I agree with the <50 kW exemption from EIA requirements provided the exemption applies to devices with a combustor operating at atmospheric air pressure (external combustion). The exemption should not apply to devices such as internal combustion engines and turbines with compressors including any device that compresses the fuel or creates pressure in an enclosed space as part of the combustion process.

An example of a device that should not be exempt is an internal combustion engine operating on gasified wood or charcoal.

The reason for not exempting such devices is that major and trace gas emissions from devices which operate above atmospheric pressure may include components that are already regulated, or will be in the foreseeable future. Such combustion products are not created by external combustion devices, e.g. heating stoves, low pressure boilers (hydronic heaters) and hot air furnaces.

Thank you