MEMORANDUM
Subject:
Conference
Call
with
Ingersoll
Rand
Attorneys,
March
19,
2004
From:
Steven
Silverman,
Attorney
Office
of
General
Council
To:
Environmental
Protection
Agency
(
EPA),
Air
Docket
A­
2001­
28;
E­
DOCKET
OAR­
2003­
0012
Date:
April
15,
2004
____________________________________________________________________________

On
March
19,
2004,
members
of
EPA
staff
(
including
Cleophas
Jackson,
Phil
Carlson,
and
myself)
further
discussed
equipment
flexibility
issues
with
counsel
for
Ingersoll
Rand
(
Alan
McConnell
and
Bill
Lane).
We
discussed
potential
details
of
a
technical
hardship
provision
and
potential
details
of
a
provision
whereby
equipment
manufacturers
could
earn
additional
flexibilities
for
using
Tier
4
engines
before
Tier
4
standards
take
effect.
We
also
agreed
to
share
draft
regulatory
language
with
them.
