MEMORANDUM
Subject:
March
29,
2004
Telephone
Call
with
Ingersoll
Rand
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
29,
2004,
EPA
representatives
(
Chet
France,
Cleophas
Jackson,
and
myself,
among
others)
spoke
with
Ingersoll
Rand
counsel
and
Steve
Neva
of
the
company.
The
call
continued
discussions
from
the
previous
week
relating
to
details
of
the
equipment
maker
incentive
provision
for
early
introduction
of
Tier
4
engines.
Details
discussed
dealt
mostly
with
the
relationship
of
this
provision
to
the
proposed
engine
maker
clean
engine
introduction
provision.

One
remaining
issue
for
discussion
concerned
dates
for
producing
and
installing
these
clean
engines.
The
company's
position
is
that
an
engine
production
date
requirement
is
out
of
the
control
of
equipment
manufacturers
(
at
least
those
that
are
not
vertically
integrated)
and
therefore
that
equipment
manufacturers
planning
to
use
early
clean
engines
could
be
disadvantaged
if
their
suppliers
fail
to
complete
production
by
the
requisite
date.
