Comment submitted by Jalyn Brock

I support the EPA's proposed conditional approval of SDCAPCD Rule 69.7 regulating NOX emissions from landfill gas flares. Establishing clear emissions limitations and monitoring requirements for these sources is an important step toward improving air quality in the San Diego region, which remains in serious nonattainment for ozone standards. However, I urge the EPA to ensure that the identified deficiency regarding unapproved alternative test methods is resolved promptly and completely. Allowing operators to use unreviewed versions of ASTM methods undermines the enforceability of the rule and could compromise accurate emissions monitoring. The one-year deadline for SDCAPCD and CARB to submit corrected rule language should be treated as a firm ceiling, not a target, and the EPA should be prepared to follow through with disapproval if the revision is not submitted on time. Enforceable monitoring standards are essential to ensuring this rule achieves its intended public health benefits. 67345