Michael Samulski/AA/USEPA/US 

12/06/2007 11:04 AM	

To

rap@vnf.com

cc

Glenn Passavant/AA/USEPA/US@EPA, Alan Stout/AA/USEPA/US@EPA

Subject

Fw: Diurnal phase In for Installed Tanks on OB and SD/I Vessels

	

	

Dick,

Over the past week or so, we have been engaged with Jim Hardin on the
issue of phase-in flexibility for diurnal standards applying to boats
with installed fuel tanks.  He provided us information on his product
range which was useful for these discussions.  With this information in
mind, we have revised our thinking slightly on an appropriate approach.

Our initial suggestion (see email below) was for allowances of 500/300
in 2011/2012.  Our new concept would be for a total of 1,200 allowances
that could be used, at the manufacturers discretion, over the 2011 and
2012 model years.  For instance, a boat builder could use 800 allowances
in the first year and 400 in the second year.

Under this approach, no boat builder certification would be required. 
Boat builders would simply add a statement to their label acknowledging
when an allowance was used.  Also, the boat builder would maintain
records of allowances used.

I spoke with Jim Hardin about this concept.  He still prefers the
percentage based approach, but initially thought that this may work for
Grady-White Boats.  He told me that he wanted to think about it further
and would get back with me.

At this point, we believe that this flexibility should address the small
business issues, especially given that we have already agreed to delay
the proposed date by one year.  We prefer an allowance approach to a
phase-in approach because using a phase-in approach would involve a much
more complicated compliance effort and increased paperwork burden, for
both EPA and manufacturers.  We think the allowance approach achieves
our mutual objective without introducing a program modeled after the
much more complicated Transition Program for Equipment Manufacturers
with nonroad diesel engines.

Please let me know if you have any questions or comments.

Michael Samulski

U.S. Environmental Protection Agency

National Vehicle and Fuel Emissions Laboratory

2000 Traverwood Drive

Ann Arbor, MI  48105

(734) 214-4532

----- Forwarded by Michael Samulski/AA/USEPA/US on 12/06/2007 10:41 AM
-----

Glenn Passavant/AA/USEPA/US 

11/26/2007 10:28 AM	

To

rap@vnf.com

cc

Alan Stout/AA/USEPA/US@EPA

Subject

Diurnal phase In for Installed Tanks on OB and SD/I Vessels

	

	

Hi Dick:

After some intenal discussion we wanted to provide NMMA some input on
the structure of the potential diurnal phase-in scheme.

We'd suggest an allowance based approach as opposed to percentages of
sales. 

We've already given industry the 2010 model year for installed tanks, so
we'd suggest a 500 vessel allowance for 2011 and a 300 vessel allowance
for 2012, independent of mfr size. No allowances for 2013 and later.  

There would be manufacturer record keeping and vessels using allowances
would have to be so labeled.

GLENN W. PASSAVANT

ASSESSMENT & STANDARDS DIVISION

OFFICE OF TRANSPORTATION AND AIR QUALITY

US EPA

734-214-4408

