NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD DRIVE

ANN ARBOR, MICHIGAN 48105

                                                                        
          	     

December 17, 2009

MEMORANDUM

Subject: 	Communications Related to the Proposed Emission Standards for
Category 3 Marine Engines and Vessels Prior to the Final Rule

From:		Byron Bunker, Assessment and Standards Division

To:		Docket EPA-HQ-OAR-2007-0121

	  SEQ CHAPTER \h \r 1 The following table documents several phone calls
and meetings with individuals outside of EPA after the NPRM and prior to
the final rule.  The NPRM was signed on June 26, 2009.

Date	Participants	Subject

7/2	Michael Crye, Cruise Line International Association	General
questions on proposed ECA, Applicability of SOx scrubbers and shore
power as equivalent technologies

7/29	Michael Crye, Cruise Line International Association	Applicability
of SOx scrubbers and shore power as equivalent technologies, fuel
switching, CO2 tradeoffs with NOx

8/27	Michael Crye, Cruise Line International Association	Applicability
of SOx scrubbers as equivalent technology

9/3	Peter Greenwald, South Coast Air Quality Management District	EPA
concept for a voluntary vessel verification program showing compliance
with Tier 2 & 3 NOx standards, SCAQMD’s concerns with in-use vessels

9/3	Coralie Cooper, NESCAUM	General questions re: proposal, lack of PM
standard, why does EPA expect PM reductions, expectations for ECA
adoption by IMO

9/10	Michael Crye, Cruise Line International Association	200nm ECA size,
average global sulfur for 2020, EPA cost estimates, potential for a
fleet average program, potential for biofuels

9/29	David Podrantz, Amanda Sunderland, Murphy Oil	Murphy’s comments
on the proposal, confirm that Murphy will be able to produce 1.0%
residual fuel at all viscosity grades, Murphy can supply almost any fuel
spec but has concerns about the appropriateness/cost effectiveness of
the standards

10/5	Noel Basset, American Steamship	American Steamships expectation
that they will repower their steamships because they are self unloaders
and therefore cost effective operators, diesel power is much more fuel
efficient that steam vessels, value of any ship is based on the demand
for its services

10/7	Jim Weakley, Mark Ruge, Lake Carriers Association	Concerns re:
steamship economics and potential to repower, need for additional time
for steamships to comply, difficulty in getting financing to repower a
steamship, concerns about mode shift to rail or truck, limited shipyard
availability for steamship repower

10/23	Michael Crye, Cruise Line International Association	Desire for
national wastewater discharge standard, concerns over inclusion of
Hawaii and Alaska in the ECA, ECA process at IMO

10/28	Michael Crye, Cruise Line International Association	Different
processes for the ECA at IMO and the internal waters under APPS,
potential for credit for shore power, solar, gas turbines, sulfur
trading

11/2	Sue Maurmann, Director Environmental Programs Port of Tacoma
Concerns about the impact of the ECA on Jones Act shippers operating
between Tacoma and Alaska, RO-RO and Container traffic, mode shift to
AlCan highway

11/2	Jim Weakley, Lake Carriers Association	Approaches to address fuel
availability, economic hardship, ability for shippers to recover capital
investments

11/2	Mark Barker, Interlake Steamship	Recognizing significant capital
investments to repower steamships, recognizing benefit of early Tier 2
compliance for C3 engines

11/2	Rich Berkowitz, Transportation Institute	Concerns about the impact
of the ECA on Jones Act vessels, primarily those from Washington State
to Alaska but also Hawaii, concerns about mode shift, interest in
promoting marine highways

11/4	Jim Weakley, Lake Carriers Association	Addressing mode shift
concerns for C3 diesel vessels on Great Lakes, potential for incentives
to encourage repower of steamships

11/10	Paul Billings, American Lung Association	Is EPA aware of any
studies that look at direct exposure of marine crews on OGVs or
passengers on cruise ships?

11/10	Michael Crye, Cruise Line International Association	General
concerns re: equivalencies under MARPOL Annex VI

11/12	Jim Weakley, Lake Carriers Association	Discussed how lake carriers
bunker fuel and the viability of a reporting requirement when shippers
availed themselves of a potential fuel availability provision.  Believed
quarterly reporting would be reasonable.  Discussed potential hardship
provision for 2015 0.1% fuel standard and need for hardship applications
to come well before the standard date.

11/12	Mark Barker, Interlake Steamship	Recommended that any hardship
provision reflect both operating and capital costs for vessels

11/12	Dennis McLerran, Puget Sound Clean Air Agency	Ensure that EPA was
aware of the progress that Krystallon and Wartsila are making in SOx
scrubbing technology, encourage EPA to work with marine community on
wide range of technologies to meet environmental goals

11/13	Jim Weakley, Lake Carriers Association	Encouraged EPA to look at
potential for mode shift from DTE Monroe, MI powerplant (ship to rail),
recommend that in evaluating fuel availability EPA consider economics
(i.e., trucking fuel from Gulf Coast would not be considered available
in Jim’s opinion), recommend economic hardship reflect all cost for
shippers, expressed LCA’s commitment to work with EPA on the 6 month
study described in the Conference Report language

11/13	Valerie Devlin, Transport Canada	General questions on EPA’s
responsibilities coming from the appropriations bill and the associated
report language

11/16	Mark Barker, Interlake Steamship	Encouraged EPA to look at capital
recovery plans in considering economic hardship waiver provisions

11/17	Bruce Buie, Canadian Shipowners Association	General questions on
EPA’s responsibilities coming from the appropriations bill and the
associated report language.  How will EPA/Coast Guard work with
Environment Canada/Transport Canada as Transport Canada moves forward to
regulate the Canadian side of the Great Lakes

11/17	Tim Smith, Warner Petroleum	General discussion of how fuel is
bunkered on the Great Lakes.  Fuel in Chicago is supplied by truck from
Detroit.  Current price difference between Chicago and Detroit is about
15 cents based primarily on trucking costs.  Fuel tankers don’t cross
lake Superior due to OPA spill regulations.

11/19	Dennis McLerran, Puget Sound Clean Air Agency	General discussion
of IMO equivalency provisions and merits of SOx scrubber technologies,
capital constraints on shippers

11/20	Kathy Metcalfe, Chamber of Shipping of America	Raised concerns re:
coastal steamvessels and the need to address technical issues on those
vessels

11/20	Sue Mauermann, Port of Tacoma, Margo Oge, OTAQ, Dennis McLerran,
Puget Sound Clean Air Agency	Discussion of the technical challenges
facing steamships under the ECA program, ability of SOx scrubber
technology to lower compliance costs, opportunity for shorepower to
lower emissions, concerns of Jones Act Vessels shipping between
Washington State and Alaska, primary issue is compliance with fuel
program in 2015

11/23	Jacques Bellavance 

Manager - Industry and Government Affairs, Shell Canada Products
Bunkering characteristics on the Great Lakes

11/24	Jim Weakley, Lake Carriers Association and Jim Priem, Interlake
Steamships	Discussed Bunkering practices in ports, discussed method to
define a port area, recommendation to use US Army Corp of Engineers
descriptions



OFFICE OF

AIR AND RADIATION

