Comment from City of Dodge City, Kansas

Summary: The City of Dodge City, Kansas, opposes the proposed rule because it forces the use of "background data" from the 45ZCF-GREET model that is tailored for wastewater sludge rather than the high-strength wastewater the City uses. They argue this results in an overstated emissions value and propose a modification to allow applicants to submit third-party verified energy usage data for fuels not currently in the model.