Q64. Should pilot gas be included in greenhouse gas calculations?
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No. Section 98.30(a) defines a stationary fuel combustion source as a device that combusts “....solid, liquid, or gaseous fuel, generally for the purposes of producing electricity, generating steam, or providing useful heat or energy for industrial, commercial, or institutional use, or reducing the volume of waste by removing combustible matter.....”. A pilot simply initiates the combustion process in a boiler, turbine, or other fuel combustion device, and is not used to produce electricity or steam, or to provide useful energy to an industrial process, or to reduce waste by removing combustible matter. Therefore, for the purposes of Part 98, a pilot is not considered to be a stationary fuel combustion source and pilot gas consumption is not required to be included in the GHG emissions calculations.

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