Alan
Stout
EPA­
OAR,
OTAQ,
ASD
Received
Date:
11/
29/
2004
04:
29:
42
PM
To:
Michael_
Tyrrell@
ahm.
honda.
com
cc:
Darin_
Johnson@
ahm.
honda.
com,
Takami_
Yano@
ahm.
honda.
com,
Subject:
Re:
Our
telephone
conversation
­
Definition
change
in
the
technical
amendments
Michael,
My
responses
are
inserted
below.
Let
me
know
if
you
have
follow­
up
questions.

Alan
Michael_
Tyrrell@
ahm.
honda.
com
Received
Date:
11/
23/
2004
07:
04:
07
PM
To:
Alan
Stout/
AA/
USEPA/
US@
EPA
cc:
Takami_
Yano@
ahm.
honda.
com,
Darin_
Johnson@
ahm.
honda.
com
Subject:
Our
telephone
conversation
­
Definition
change
in
the
technical
amendme
As
a
follow­
up
to
our
phone
conversation
Honda,
understands
EPA's
intention
and
clarification
as
follows.

1)
EPA
will
revise
1051.801
in
Technical
Amendment
to
address
a
mismatch
with
durability
requirement.
­­
Correct.
Final
language
is
still
under
development.

2)
EPA
allows
manufacturers
to
perform
durability
testing
based
on
defined
miles
or
hours
even
for
vehicles
not
equipped
with
either
an
odometer
or
an
hour
meter.
­­
Durability
testing
for
certification
testing
is
always
based
on
accelerated
service
accumulation,
so
this
makes
sense
only
in
terms
of
miles
or
hours
of
operation.

3)
Although
the
regulation
requires
alternative
useful
life
description
on
emission
label,
EPA
does
not
require
manufacturers
to
put
alternative
useful
life
on
emission
label
if
the
vehicle
is
not
equipped
with
a
device
to
measure
the
duration
(
miles
or
hours).
­­
That
is
a
new
twist
on
the
question
we
discussed
earlier.
From
what
you
had
described,
I
would
expect
that
you
don't
have
families
that
need
an
alternative
useful
life.
For
all
the
engines
that
go
with
the
default
useful
life
from
the
regulations,
we
have
proposed
(
and
intend
to
finalize)
the
provision
allowing
you
to
omit
the
useful
life
information
from
the
label.
There
has
been
no
discussion
of
omitting
the
alternative
useful­
life
values
from
emission
labels
if
the
corresponding
meter
is
not
installed.
We
can
consider
that,
but
it
doesn't
strike
me
as
an
automatic
or
self­
evident
conclusion.
Let
me
know
if
you
would
like
us
to
pursue
this
new
angle.

We
would
like
to
receive
your
confirmation
that
my
understanding
of
your
responses
during
this
telephone
conversation
is
correct.
And
would
ask
that
you
also
provide
us
with
a
written
response
to
our
question
about
how
EPA
plans
to
finalize
the
NER
equations
in
light
of
the
MIC's
comments
to
the
technical
amendments.
For
expediency
sake,
I
request
that
provide
your
response
by
E­
mail
and
that
you
also
copy
Darin
Johnson
and
Takami
Yano
when
you
respond.

­­
I
consider
MIC's
recommended
NER
changes
to
be
straightforward
and
intend
to
process
those
directly.

Darin
and
I
will
be
out
of
the
office
until
next
Tuesday
you
can
call
Mr.
Yano
[(
310)
783­
3286]
if
you
need
to
discuss
these
issues
further.

Thank
you
for
your
help
and,
Best
Regards.

American
Honda
Motor
Co.
Michael
Tyrrell
Administrator­
Certification
Michael_
Tyrrell@
ahm.
honda.
com
