MEMORANDUM
Subject:
Meeting
with
Ingersoll
Rand
Representatives,
March
30,
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
30,
2004,
representatives
of
Ingersoll
Rand
(
counsel
Alan
McConnell
and
Bill
Lane,
and
Stephen
Neva
of
the
company)
met
with
EPA
representatives
(
Margo
Oge,
Chet
France,
Cleophas
Jackson,
Don
Kopinski,
and
myself)
to
discuss
remaining
issues
relating
to
the
nonroad
diesel
engine
rule.
The
IR
representatives
indicated
that
they
believed
the
technical
hardship
equipment
manufacturer
flexibility
provided
a
reasonable
mechanism
for
obtaining
sufficient
lead
time
in
the
event
the
company's
concerns
regarding
Tier
4
lead
time
adequacy
prove
correct.
They
also
indicated
general
support
for
the
equipment
manufacturer
early
engine
incentive
program,
certain
technical
changes
in
the
(
optional)
TRU
duty
cycle,
and
having
a
two­
way
technical
review
in
2007.

The
remainder
of
the
meeting
involved
further
discussion
of
issues
pertaining
to
the
early
engine
incentive
program,
specifically,
whether
a
rule
should
include
engine
manufacturer
production
dates
as
well
as
equipment
manufacturer
installation
dates.
Although
the
company
is
wary
because
it
cannot
control
an
engine
manufacturer
production
date,
EPA
representatives
noted
that
some
such
date
is
needed
both
to
assure
that
windfall
ABT
credits
are
not
generated
by
engine
manufacturers,
and
that
the
incentive
engines
are
indeed
`
early'.
However,
EPA
staff
agreed
to
consider
if
a
somewhat
later
engine
production
date
might
be
appropriate.
