Darren.Milsom@brunswickboatgroup.com

Sent by: Darren.Milsom@brunswickboatgroup.com

Received Date:

04/22/2008 08:23 AM

Transmission Date:

04/22/2008 08:23:59 AM	

To

<Glenn.Passavant@selfridge.af.mil>

cc

Glenn Passavant/AA/USEPA/US@EPA, RAP@vnf.com, jeff.melby@genmar.com,
CScholte@fourwinns.com, dave.marlow@brunswickboatgroup.com,
jmcknight@nmma.org

Subject

RE: Diurnal Emissions Option

	

	

Glenn 

As far as I am aware, Brunswick has always asked for a 3 year phase in,
originally being the 30-60-100 approach and it was not until recently
that this was removed as an option. 

I apologize if my previous e-mail was misleading as Brunswick, Genmar
and the NMMA do not want to remove from the table the option of a
40-80-100 phase in, however after a more detailed review Brunswick,
Genmar and the NMMA do not feel the 1200 boat allowance is a viable
solution. 

Brunswick, Genmar and the NMMA got together last week and discussed the
options of a 40/80/100 and the 1200 allowance and during this review we
also threw in the third possible option, which is what we sent you. At
this time we also discussed the implementation time and not just the
date. 

The unanimous conclusion to this was that we do not want to make any
significant changes to any vessel under 26’ unless at model year due
to the following: 

1) Pricing for vessels is set at model year and the inclusion of diurnal
emission controls would add a significant percentage price increase
during a model year. 

2) Vessels under 20’ have flotation requirements and the inclusion of
diurnal emission controls could have significant effects on the
flotation and therefore require re-validation. 

3) The inclusion of diurnal emission controls could have a significant
effect on the aesthetics of the vessel. 

4) The inclusion of diurnal emission controls could have a significant
effect on the specifications of the vessel e.g. fuel tank size,
compartment space etc. 

We therefore reviewed the 3 options. 

Option 1 

>26’ – 100% compliance starting MY2012 

<26’ – 60% of US product would comply in MY2013 

<26’ – 100% of US product would comply in MY2014 

This was the favored option by both Brunswick and Genmar for the
following reasons. 

        1) For both Brunswick and Genmar, vessels 26' and greater would
cover an estimated 30% of the emissions savings. 

        2) Vessels over 20' do not require level flotation. 

        3) In general vessels over 26’ will be easier to implement,
allowing more time to plan for the smaller vessels. 

        4) Vessels over 26' will be able to absorb the cost impact
easier than less than 26'. 

        5) The additional time for less than 26' would provide
allowances for the carbon canister to be designed into the vessel in
advance. 

        6) Permeation requirements for fuel tanks are scheduled to be
introduced for MY2013. Vessels less than 26’ have a high likelihood of
requiring changes for both tank permeation and                 diurnal  
      emission controls. 

        7) Vessels 26’ and greater will allow for a streamlined
enforcement process. All an inspector would have to do is identify the
size and the model year to know if the vessel required                  
      compliance. 

Option 2 

40% of US product would comply in MY2012 

80% of US product would comply in MY2013 

100% of US product would comply in MY2014 

As previously stated, this option has not been ruled out by Brunswick,
Genmar and the NMMA, however option 1 achieves the industry’s need for
more time, whilst also obtaining a considerable emissions reduction and
streamlining the EPA enforcement program. 

Option 3 

1200 non-compliant boat allowance spread over 2 Years by brand. 

After a more detailed review of the numbers, both Brunswick and Genmar
cannot support this option due to economical and technical feasibility
issues. 

Thanks 

Darren Milsom 

Strategic Material Standards Engineer 

Brunswick Boat Group - Technology & Process Development. 

800 South Gay Street 

Knoxville, TN, 37929 

865-582-2264 

<Glenn.Passavant@selfridge.af.mil> 

04/19/2008 10:49 AM 	

	

To

<Darren.Milsom@brunswickboatgroup.com> 

cc

<passavant.glenn@epa.gov>, <RAP@vnf.com> 

Subject

RE: Diurnal Emissions Option

	

	

	

Gentlemen 

  

Will consider, but I’m pessimistic. This is very far from where we
started when you asked for one more year in your written comments and
even very far from the 40/80/100 you all said would work at our meeting
on April 4 and also far from the 1200 allowances per brand we talked
about on Thursday.  I thought we were looking for a mutually acceptable
outcome, but this proposal is not anything like that as it seems to have
even more delay. 

  

Glenn   

  

From: Darren.Milsom@brunswickboatgroup.com
[mailto:Darren.Milsom@brunswickboatgroup.com] 

Sent: Friday, April 18, 2008 4:14 PM

To: Passavant Glenn W Col 927 AMDF/CC; passavant.glenn@epa.gov

Cc: jeff.melby@genmar.com; CScholte@fourwinns.com;
dave.marlow@brunswickboatgroup.com; jmcknight@nmma.org

Subject: Diurnal Emissions Option 

  

Glenn. 

After further review, Brunswick Boat Group, Genmar Holdings Inc and the
National Marine Manufacturers Association would like to put the
following option forward for your consideration on the implementation of
diurnal emission controls. 

        For vessels 26' and greater: 

100% compliance starting MY2012 

        For Vessels less than 26': 

60% of US product would comply at MY2013. 

                100% of US product would comply at MY2014. 

(Note: Per 33CFR181.3(F) the model year production starts August 1st of
the previous year e.g. 2012 Model year production starts August 1st
2011) 

This in our opinion would be the best option due to: 

1) For both Brunswick and Genmar, vessels 26' and greater would cover an
estimated 30% of the emissions savings. 

        2) Vessels over 26' do not require level flotation. 

3) In general vessels over 26’ will be easier to implement, allowing
more time to plan for the smaller vessels. 

        4) Vessels over 26' will be able to absorb the cost impact
easier than less than 26'. 

5) The additional time for less than 26' would provide allowances for
the carbon canister to be designed into the vessel in advance. 

6) Permeation requirements for fuel tanks are scheduled to be introduced
for MY2013. Vessels less than 26’ have a high likelihood of requiring
changes for both tank permeation and diurnal emission controls. 

7) Vessels 26’ and greater will allow for a streamlined enforcement
process. All an inspector would have to do is identify the size and the
model year to know if the vessel required compliance. 

Thank you 

Darren Milsom 

Strategic Material Standards Engineer 

Brunswick Boat Group - Technology & Process Development. 

800 South Gay Street 

Knoxville, TN, 37929 

865-582-2264

