May 11, 2007

Mr. Robert Doyle, Attorney-Advisor

Certification and Compliance Division

U.S. Environmental Protection Agency

1200 Pennsylvania Ave. NW 6403J

Washington DC 20460

Dear Bob:

Recently, the California Air Resources Board has agreed to provide
relief to the stern drive and inboard (SD/I) marine engine manufacturers
on catalyst requirements for 2008-2009 4.3 liter or 8.1 liter engines.
The National Marine Manufacturers Association (NMMA) has discussed this
need for the same relief with both Glenn Passavant and Michael Samulski
of the EPA regarding rulemaking titled "Proposed Emission Standards for
New Non road Spark-Ignition Engines, Equipment and Vessels." April 2007.
 This relief is critical due to General Motors, the manufacturer of the
base engines, intent to halt production of these engines for the marine
market in 2009.

With this relief, the SD/I engine manufacturers are moving forward with
the development plans for achieving a 5 g/kW-hr fleet average for
California for either the 8.1 liter or the 4.3 liter and a 5 g/kW-hr cap
on all other SD/I engines.

Two outstanding issues still remain for the SD/I manufacturing industry
-- the Southwest Research Institute (SwRI) Saltwater Test Program and
the EPA Waiver. Even though the SwRI tests never proved catalyst
feasibility in salt water, our members believe that, at this stage of
catalyst development, there is little or no additional data to be
obtained by completing the tests.  The designs being tested at SwRI are
not designs that any of the engine companies are considering pursuing. 
Whether or not they could survive 480 hours is of no value. Our members
have their own compliance plans that include designs that appear to
withstand saltwater operation, although they will not know for sure
until it gets into the hands of customers.  Therefore, NMMA agrees that
EPA and CARB can cancel the SwRI saltwater test program.

The second issue is that of the EPA waiver.  Since one SD/I manufacturer
is already in production with catalysts, and the others will be ready to
meet the CARB standard in 2008, NMMA is dropping the objection to the
waiver.

In the context of EPA’s recently proposed rules for exhaust controls
for marine engines, there is a continuing concern regarding catalyst and
sensor durability, especially in salt water, and in engine technologies
not included in the SwRI test programs, for example, personal watercraft
engines installed in jetboats. The manufacturers of those items also
have been unable to provide any help to the engine manufacturers in this
regard as they have no experience in the salt water environment. It is
critical to both the marine industry and the hundreds of thousands of
American jobs that are created by this industry, that EPA delay
implementation of any nationwide catalyst-based rule until the
manufacturers have studied the effect of the catalyst through a complete
warranty cycle (three years) and the manufacturers gain the necessary
field experience in California.  In any waiver decision regarding
catalysts for SD/I, EPA must make clear that it is not predetermining
the outcome of the ongoing rulemaking, and that if durability problems
should arise in actual use in California, that EPA will work with CARB
and engine manufacturers to adjust any rules applicable to these
engines.

Thank you for your consideration of this matter.

Sincerely,

John McKnight, Director

Environmental & Safety Compliance

Cc:		Karl Simon, EPA

Bob Cross, CARB

Michael Carter, CARB  

Scott Rowland, CARB

