                                                                  June 17, 2011
                                       
                                       
                          Engine Certification Issues
                                       
                             With the GHG/FE Rule
                                       
                                       
                                       
Parent and Child Ratings

	The Agencies should require that all engines in a family deploy equivalent GHG control technologies.  Those equivalent hardware and software technologies may vary consistent with engine power, but must not involve removing critical parent rating technology from child engine ratings in a manner that would unnaturally increase GHG emissions.

Engine Families

	The Agencies should eliminate the proposed requirement that manufacturers use the same engine families for GHG and criteria pollutants.  Manufacturers should be able to establish GHG engine families that are not linked to criteria pollutant families.

Early Credits

	The Agencies should provide an alternative to the proposed requirement that a manufacturer must certify its entire U.S.-directed production volume within an averaging set to generate early (MY13) credits.  Manufacturers should be able to certify individual families without the 1.5x early credit multiplier.




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