Julie
Becker
<
JBECKER@
autoalliance.
org>
02/
23/
2005
06:
32
PM
To:
Michael
Horowitz/
DC/
USEPA/
US@
EPA
cc
"
Mitch
Bernstein
(
Van
Ness
Feldman)"
<
mhb@
vnf.
com>
Subject
RE:
revisions
to
86.1834­
01
Thanks
for
this,
and
thanks
also
for
meeting
with
us
today.

­­­­­
Original
Message­­­­­
From:
horowitz.
michael@
epamail.
epa.
gov
[
mailto:
horowitz.
michael@
epamail.
epa.
gov]
Sent:
Wednesday,
February
23,
2005
5:
25
PM
To:
jbecker@
autoalliance.
org;
mhb@
vnf.
com
Subject:
revisions
to
86.1834­
01
Julie
and
Mitch,

I
hope
the
meeting
today
was
helpful.
Feel
free
to
follow
up
as
this
issue
develops.
As
promised,
here
are
the
revisions
we
will
be
making
to
86.1834­
01
to
fix
the
incorrect
cross­
references.
Any
questions
you
or
your
clients
have
on
these
revisions
would
be
welcome.

Section
86.1834­
01
is
amended
by
revising
paragraph
(
b)(
4)
introductory
text,
(
b)(
6)(
ii)
introductory
text,
and
(
b)(
6)(
ii)(
D)
to
read
as
follows;
§
86.1834­
01
Allowable
maintenance.
*
*
*
*
*
(
b)
*
*
*
(
4)
For
diesel­
cycle
light­
duty
vehicles
and
light­
duty
trucks,
emission­
related
maintenance
in
addition
to,
or
at
shorter
intervals
than
the
following
will
not
be
accepted
as
technologically
necessary,
except
as
provided
in
paragraph
(
b)(
7)
of
this
section:
*
*
*
*
*
(
6)
*
*
*
(
ii)
All
critical
emission­
related
scheduled
maintenance
must
have
a
reasonable
likelihood
of
being
performed
in
use.
The
manufacturer
shall
be
required
to
show
the
reasonable
likelihood
of
such
maintenance
being
performed
in
use,
and
such
showing
shall
be
made
prior
to
the
performance
of
the
maintenance
on
the
durability
data
vehicle.
Critical
emission­
related
scheduled
maintenance
items
which
satisfy
one
of
the
following
conditions
will
be
accepted
as
having
a
reasonable
likelihood
of
the
maintenance
item
being
performed
in
use:
*
*
*
(
D)
A
manufacturer
may
desire
to
demonstrate
through
a
survey
that
a
critical
maintenance
item
is
likely
to
be
performed
without
a
visible
signal
on
a
maintenance
item
for
which
there
is
no
prior
in­
use
experience
without
the
signal.
To
that
end,
the
manufacturer
may
in
a
given
model
year
market
up
to
200
randomly
selected
vehicles
per
critical
emission­
related
maintenance
item
without
such
visible
signals,
and
monitor
the
performance
of
the
critical
maintenance
item
by
the
owners
to
show
compliance
with
paragraph
(
b)(
6)(
ii)(
B)
of
this
section.
This
option
is
restricted
to
two
consecutive
model
years
and
may
not
be
repeated
until
any
previous
survey
has
been
completed.
If
the
critical
maintenance
involves
more
than
one
test
group,
the
sample
will
be
sales
weighted
to
ensure
that
it
is
representative
of
all
the
groups
in
question.
*
*
*
*
*
­
Michael
Mitch
Bernstein
<
MHB@
vnf.
com>
02/
23/
2005
08:
10
PM
To
Michael
Horowitz/
DC/
USEPA/
US@
EPA
cc
jbecker@
autoalliance.
org
Subject
Re:
revisions
to
86.1834­
01
Michael:

It
was
very
nice
to
make
your
acquaintance
this
afternoon.
The
meeting
was
very
helpful,
and
we
very
much
appreciate
you
and
John
making
the
time
for
it,
as
well
as
your
quick
follow­
up.

Thanks
again,
Mitch
>>>
<
horowitz.
michael@
epamail.
epa.
gov>
2/
23/
05
5:
24:
31
PM
>>>
Julie
and
Mitch,

I
hope
the
meeting
today
was
helpful.
Feel
free
to
follow
up
as
this
issue
develops.
As
promised,
here
are
the
revisions
we
will
be
making
to
86.1834­
01
to
fix
the
incorrect
cross­
references.
Any
questions
you
or
your
clients
have
on
these
revisions
would
be
welcome.

Section
86.1834­
01
is
amended
by
revising
paragraph
(
b)(
4)
introductory
text,
(
b)(
6)(
ii)
introductory
text,
and
(
b)(
6)(
ii)(
D)
to
read
as
follows;
§
86.1834­
01
Allowable
maintenance.
*
*
*
*
*
(
b)
*
*
*
(
4)
For
diesel­
cycle
light­
duty
vehicles
and
light­
duty
trucks,
emission­
related
maintenance
in
addition
to,
or
at
shorter
intervals
than
the
following
will
not
be
accepted
as
technologically
necessary,
except
as
provided
in
paragraph
(
b)(
7)
of
this
section:
*
*
*
*
*
(
6)
*
*
*
(
ii)
All
critical
emission­
related
scheduled
maintenance
must
have
a
reasonable
likelihood
of
being
performed
in
use.
The
manufacturer
shall
be
required
to
show
the
reasonable
likelihood
of
such
maintenance
being
performed
in
use,
and
such
showing
shall
be
made
prior
to
the
performance
of
the
maintenance
on
the
durability
data
vehicle.
Critical
emission­
related
scheduled
maintenance
items
which
satisfy
one
of
the
following
conditions
will
be
accepted
as
having
a
reasonable
likelihood
of
the
maintenance
item
being
performed
in
use:
*
*
*
(
D)
A
manufacturer
may
desire
to
demonstrate
through
a
survey
that
a
critical
maintenance
item
is
likely
to
be
performed
without
a
visible
signal
on
a
maintenance
item
for
which
there
is
no
prior
in­
use
experience
without
the
signal.
To
that
end,
the
manufacturer
may
in
a
given
model
year
market
up
to
200
randomly
selected
vehicles
per
critical
emission­
related
maintenance
item
without
such
visible
signals,
and
monitor
the
performance
of
the
critical
maintenance
item
by
the
owners
to
show
compliance
with
paragraph
(
b)(
6)(
ii)(
B)
of
this
section.
This
option
is
restricted
to
two
consecutive
model
years
and
may
not
be
repeated
until
any
previous
survey
has
been
completed.
If
the
critical
maintenance
involves
more
than
one
test
group,
the
sample
will
be
sales
weighted
to
ensure
that
it
is
representative
of
all
the
groups
in
question.
*
*
*
*
*

­
Michael
