"Jim Hardin" <Jhardin@gradywhite.com> 

12/21/2007 08:53 AM	

To

Glenn Passavant/AA/USEPA/US@EPA

cc

Michael Samulski/AA/USEPA/US@EPA

Subject

RE: Diurnal Implementation Proposal for marine fuel systems

	

	

Glenn and Mike,

From our perspective any type of allowance system creates one basic

problem that exists regardless of the allowance numbers.  It creates a

disadvantage to any builder who manufacturers a higher volume of boats.

As a small business, we would have to install diurnal controls on over

50% of our units while most of our direct competitors will have to

install no controls until the last year of the allowance system.  This

scheme allows our competitors who construct less than 400 boats to delay

any and all price increases associated with these controls until the

last year of the phase-in.  This, in-effect, means the USEPA is exerting

unjust regulations that show favoritism towards any builder who happens

to have a low unit production.  This is creating a competitive advantage

for one small business over another should be avoided.  A percentage

phase-in approach treats all small businesses the same.

One other advantage that a 30/60/100 phase-in offers an decrease in the

probability of safety related issues.  High volume boat builders will

have to implement these changes on a majority of their units in the

first year.  Demands for engineering and training resources will be high

and the likelihood of problems will increase as the volume of changes

increases.  The additional time a percentage phase-in offers also allows

each manufacturer to increase the internal corporate knowledge regarding

the system.  

The percentage phase-in will limit exposure from potential problems in

the first year.  It could be catastrophic for a higher volume producer

to have to recall more than 50% of their annual production if some

component fails or there is some unforeseen problem.  An approach that

phases-in on a more even basis allows experience to be gained and

adjustments can be made based upon lessons learned and experience in the

field.  There is no testing that is as demanding as placing the new

system in the field and into the customer's hands.  

When it comes to the safety aspect, I believe a prudent even phase-in

offers time to all boat builders to learn and adjust as we institute

these requirements.  The allowance proposal will not offer the learning

curve that a 30/60/100 percentage phase-in will allow.

Sincerely,

Jim Hardin

Compliance Manager

Grady-White Boats, Inc.

PO Box 1527

Greenville NC  27835-1527

Phone- 252-752-2111 ext. 270

Fax- 252-752-4217

Cell- 252-864-3020

Email- jhardin@gradywhite.com

   

-----Original Message-----

From: Passavant.Glenn@epamail.epa.gov

[mailto:Passavant.Glenn@epamail.epa.gov] 

Sent: Thursday, December 20, 2007 1:40 PM

To: Jim Hardin

Cc: Samulski.Michael@epamail.epa.gov

Subject: Re: Diurnal Implementation Proposal for marine fuel systems

Hi Jim:

Thanks for your reply.  we look forward to more information on how our

allowance concept of 1200 units total over two years would work for

Grady White and other small manufacturers.

GLENN W. PASSAVANT

ASSESSMENT & STANDARDS DIVISION

OFFICE OF TRANSPORTATION AND AIR QUALITY US EPA

734-214-4408

