EPA
Phase
3
Exhaust
Standards
for
Small
Non­
Road
Engines
Todd
Gerhardt
Director
of
Engineering
Kohler
Company
10/
3/
05
Kohler
Co.
Position
HC+
NOx
Standard
°
Harmonization
with
California
HC+
NOx
standard
is
in
best
interest
of
Industry
 
Reasonably
balances
benefits
to
the
environment
with
additional
product
cost
 
Reduces
the
number
of
SKUs
for
engine
manufacturers
and
OEMs
Kohler
Co.
Position
HC+
NOx
Standard
°
Based
on
testing
to
date:

 
8.0
g/
kW­
hr
for
Class
II
is
achievable
 
We
are
confident
that
compliant
product
will
perform
satisfactory
in
every
way,
including
safety
 
Will
be
some
increase
in
cost
 
Increase
in
exhaust
temperatures
are
manageable
°
Kohler
committed
to
working
with
Industry,
Fire
Marshals
and
EPA
to
work
through
details
 
Need
adequate
lead­
time
to
implement
in
50
states
 
ABT
program
needs
to
be
worked
out
 
No
in­
use
program
