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PVA Comments on EPA Marine Engines Emissions Rule

Responding to the agency’s Notice of Proposed Rule Making (NPRM) EPA-HQ-OAR-2003-0190, Control of Emissions of Air Pollution from Locomotive Engines and Marine Compression-Ignition Engines Less Than 30 Liters per Cylinder, PVA president, Jonathon Claughton, noted that the diversity of the U.S. passenger vessel industry makes it very different from the towboat and railroad industries. Describing that diversity, Mr. Claughton explained that many of the vessels in the 6,000-plus U. S. Coast Guard-inspected passenger fleet operate only in the hundreds of hours per year. For example, many vessels are used for seasonal excursions and thus have a minimal impact on the environment. “The operators of these vessels are small business owners who manage thin operating margins,” explained Mr. Claughton. “Saddling them with additional costs should only happen when a clear overall benefit to society is likely.”

In its comments, PVA called on EPA to reconsider the deadlines for compliance, especially for the still-to-be-developed, Tier 4 marine engines which will be based on land technologies that have not yet been shown to be adaptable to the marine environment. PVA also suggested that any possible requirement calling for existing marine engines to be altered for better emissions performance when they are “remanufactured” be the subject of a separate rulemaking to allow more time for coordination between government and industry. Further, PVA asked EPA to perform a cost/benefit analysis to ensure that reducing emissions of sulfur and nitrogen oxide from marine engines will not result in increased fuel consumption, carbon emissions, or have other unintended outcomes.

PVA stated that proposed Tier 4 Emission Technology presents problems for both existing and new high speed ferry and passenger vessels. For example, Mr. Claughton noted the challenge to vessels operating outside the U.S. where the ultra low sulfur fuel and urea required by the proposed technology may not be available. Likewise, the heavy on-board equipment called for by EPA would likely have a negative impact on existing and planned vessels tightly designed for speed and performance.

“Our business relies on a beautiful, healthy marine environment,” explained Mr. Claughton. “So we support decreases in diesel engine emissions unequivocally. However, this NPRM as currently written does not accomplish this important goal in a cost-effective manner.” Mr. Claughton encouraged EPA to visit vessel owners around the country to see first-hand the diversity of the fleet and the impact of proposed regulations.

• About the Passenger Vessel Association

The Passenger Vessel Association is the national association representing the interests of owners and operators of dinner cruise vessels, sightseeing and excursion vessels, car and passenger ferries, gaming vessels, private charter boats, whale watching and eco-tour vessels, day-sailers and windjammer sailing vessels, overnight cruise ships and amphibious DUKW. PVA members operate U.S. Coast Guard certificated, Canadian Coast Guard or state inspected vessels. The passenger vessel industry carries more than 200 million passengers each year. Visit PVA on the Internet at: http://www.passengervessel.com