Alan
Stout
EPA­
OAR,
OTAQ,
ASD
Received
Date:
11/
30/
2004
05:
13:
17
PM
To:
Takami_
Yano@
ahm.
honda.
com
cc:
Darin_
Johnson@
ahm.
honda.
com,
Michael_
Tyrrell@
ahm.
honda.
com,
Yasuto_
Nakata@
ahm.
honda.
com,
Emily
Chen/
AA/
USEPA/
US@
EPA
Subject:
Re:
Our
telephone
conversation
­
Definition
change
in
the
technical
amendments
Takami,
In
talking
things
over
here,
we
feel
it
is
best
to
have
alternate
useful­
life
information
on
the
label,
even
if
the
odometer
and/
or
hour­
meter
is
not
present
on
the
vehicle.
In
part,
this
comes
from
the
concern
that
our
compliance
and
enforcement
staff
should
be
able
to
readily
recognize
that
a
product
has
a
longer
useful
life,
rather
than
keeping
track
of
this
information
from
the
various
cert
applications.
Since
families
with
an
alternate
useful
life
will
likely
be
a
relatively
rare
occurrence,
we
believe
the
label
would
be
an
appropriate
way
to
make
this
clear
to
anyone
who
would
need
to
know.
Also,
I
have
pointed
out
earlier
that
we
intend
to
adjust
the
useful­
life
definition
from
the
proposal
to
acknowledge
that
a
vehicle's
degree
of
service
accumulation
can
be
verified
separately
(
without
hour
meters
or
odometers)
to
establish
whether
in­
use
vehicles
are
within
their
useful
life
or
not.

The
proposed
labeling
instructions
allow
flexibility
in
wording,
which
may
help
you
avoid
adding
confusion
to
the
consumer.

I
hope
this
clarifies
our
thinking.
If
you
would
like
to
follow
up,
your
best
bet
is
to
contact
Emily
Chen
directly.

Alan
Takami_
Yano@
ahm.
honda.
c
om
Received
Date:
11/
29/
2004
05:
29:
54
PM
To:
Alan
Stout/
AA/
USEPA/
US@
EPA
cc:
Darin_
Johnson@
ahm.
honda.
com,
Michael_
Tyrrell@
ahm.
honda.
com,
Yasuto_
Nakata@
ahm.
honda.
com
Subject:
Re:
Our
telephone
conversation
­
Definition
change
in
the
technical
amendments
Alan,

Thank
you
for
your
response.

Regarding
item
#
3,
I
understand
our
description
was
not
exactly
what
you
and
Mike
had
a
conversation
but
would
like
to
clarify
the
criteria.
We
basically
have
no
motivation
to
apply
alternative
useful
life
except
the
case
we
harmonize
with
CA
model.
The
case
Mike
brought
was
small
off­
road
MC
or
ATV
which
EPA
has
different
miles
and
hours
conditions
(
5000
miles,
500
hours)
from
ARB's
(
10000
miles,
1000
hours)
but
year
condition
is
the
same
for
both
(
5
years).

We
would
plan
to
certify
with
same
useful
life
(
5
years,
10000
miles
or
1000
hours
which
ever
comes
first)
but
realized
EPA's
technical
amendment
now
would
limit
the
conditions
to
be
only
measurable
ones.
(
Disregard
non­
equipped
condition)
Although
this
language
needs
to
be
modified
somehow
to
link
with
durability
provision
as
like
durability
test
still
needs
to
follow
hour
or
mile
based
cycle,
we
also
understand
such
non­
equipped
useful
life
condition
has
no
real
meaning
in
the
field.
This
is
why
we
believe
"
10000
miles"
and
"
1000
hours"
should
not
be
necessary
on
label.
Thus,
in
other
words,
label
only
requires
an
alternative
useful
life
description
only
when
it
is
equipped
or
measurable.

I
think
it
depends
on
what
language
you
are
replacing
with.
We
guess
you
are
trying
to
keep
the
intention
of
technical
amendment
(
focus
on
real
measurable
condition)
but
allow
durability
cycle
to
be
miles
or
hour
based.
If
the
revised
language
will
be
the
same
manner
as
original
language
(
final
reg:
"
which
ever
comes
first"
regardless
of
whether
meter
is
equipped
or
not),
we
understand
it
literally
requires
mile
and
hour
conditions
on
label
but
we
still
wouldn't
like
to
be
required.

Bottom
line
is
that
we
need
hour
or
mile
based
durability
test
but
wouldn't
like
to
put
useful
life
on
label
which
could
mislead
customers.

I
hope
this
helps
you
to
understand
our
intention.
Please
let
us
know
if
EPA
allows
not
stating
non­
measurable
or
non­
eqiuipped
useful
life
condition
on
emission
label.
If
you
have
further
questions,
please
call
me,
Mike
or
Darin.
Thank
you.

Takami
Yano
/
American
Honda
/
310­
783­
3286
/
310­
408­
1909
From:
Stout.
Alan@
epamail.
epa.
gov
To:
Michael_
Tyrrell@
ahm.
honda.
com
cc:
Darin_
Johnson@
ahm.
honda.
com,
Takami_
Yano@
ahm.
honda.
com
11/
29/
2004
01:
29
Subject:
Re:
Our
telephone
conversation
­
Definition
change
in
the
technical
PM
amendments
Michael,
My
responses
are
inserted
below.
Let
me
know
if
you
have
follow­
up
questions.

Alan
From:
Michael_
Tyrrell@
ahm.
honda.
com
To:
Alan
Stout/
AA/
USEPA/
US@
EPA
cc:
Takami_
Yano@
ahm.
honda.
com,
Darin_
Johnson@
ahm.
honda.
com
Received
Date:
11/
23/
2004
Subject:
Our
telephone
conversation
­
Definition
change
in
07:
04:
07
PM
the
technical
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
