Date: November 19, 1999
To: Art Fraas, Office of Information and Regulatory Affairs, Office of Management and Budget (OMB)
From: Jere Glover, Chief Counsel, Office of Adocacy, Small Business Administration
Subject: Draft Final Commercial Marine Diesel Rule – Relaxed Standards for Small Volume – Small Diesel Marinizers
EPA’s draft preamble concedes the significant economic problems faced by small marinizers of Category 1 engines (the smallest), which we estimate at about one dozen (EPA has identified two). EPA’s one-year extension for small marinizers, and its pending suggestion of potentially waiving the relatively small production line testing (not now in the rule) are not adequate. These would provide little if any regulatory relief or flexibility.
We suggest the addition of a permanent relaxed 100 Category I vessels per year per firm standard for the several marinizers who cannot afford the very large R&D and certification costs. Unlike the measures suggested, this has the virtue of eliminating the largest costs on the small businesses. The firms would still need to certify engines at a lower standard, which should save significant R&D dollars. Also, our approach would be consistent with other flexibilities already supported by EPA in other rulemakings. Panel members in the recreational marine panel unanimously supported a 10-year exemption of 50 diesel engines per year per firm. Also, EPA recently provided several years of relief to small outboard manufacturers for hundreds of engines/year.
Further, this measure would amount to only a very small emissions loss over a small number of marinizers making the smallest engines, and will have no significant environmental effect. The relaxed standard could be the Maripol standard of 9.8 gm/kw-hr., or the recreational vessel standard, yet to be designated.