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August 30, 2004

Environmental Protection Agency

Air Docket

Mailcode 6102T

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Re.: Docket Number OAR-2003-0190: Control of Emissions of Air Pollution
from New Locomotive Engines and New Marine Compression-Ignition Engines
Less than 30 Liters per Cylinder

Dear Sir or Madam:

Thank you for opening this ANPRM for comment with sufficient lead-time
for affected industries to work with the EPA in developing applicable
standards and compliance timetables. The Offshore Marine Service
Association (OMSA) is the national trade association representing more
than 250 companies that operate vessels, or provide equipment, services
and supplies, in support of offshore oil and gas exploration and
production operations worldwide. Our association members operate over
1200 vessels engaged in domestic Outer Continental Shelf (OCS) support
activities with hundreds more supporting oil and gas operations in
international service.

While reiterating our appreciation that you have opened these rules for
discussion and consultation well in advance of any proposed compliance
dates, we would like to emphasize, and cannot understate the importance
of, government/industry cooperation in addressing a rulemaking of this
scope. It is vitally important that the EPA fully understand that the
various components of the U.S. maritime fleet (inland, coastwise,
offshore oil support, deep-sea) have very significant differences in
operations.

The offshore support vessel fleet is comprised primarily of Anchor
Handling Tug Supply Vessels (AHTS), Offshore Supply Vessels (OSV),
Liftboats, Small Passenger Vessels (Crewboats) and Utility Vessels. In
addition, the fleet has lesser numbers of offshore towing vessels,
seismic and geophysical vessels, well stimulation and diving support
vessels. About two-thirds of the fleet is over 20 years-old and
one-third under 10 years-old. Except for offshore towing vessels, most
vessels in the offshore oil and gas support vessel fleet have the same
general profile (or look) with a forward deck-house and flat open deck
aft. The function of the vessels drives their differences in size
(length, breadth), the horsepower of engines (2000-30,000 hp), and
installation of support equipment such as winches, cranes and passenger
compartments. A typical vessel in the fleet would have two to four
propulsion engines and two to four electrical generators. Many new
generation vessels are being designed as diesel-electric. Most auxiliary
equipment such as winches and cranes are either electric or hydraulic.
The offshore towing vessels are similar in design to ocean-going towing
vessels, with the differences reflecting their use primarily in an
offshore oil and gas production towing support role.

For a pictorial reference and list of machinery specifications found on
offshore support vessels you may wish to visit the websites of some of
our member companies. Several examples would be
[www.botruc.com](http://www.botruc.com/),
[www.seacorsmit.com/profile/fleet.html](http://www.seacorsmit.com/profile/fleet.html),
[www.hornbeckoffshore.com](http://www.hornbeckoffshore.com/),
[www.tdw.com](http://www.tdw.com/) or
[www.chouest.com](http://www.chouest.com/).

With regard to the ANPRM we would like to make the following points:

1.  Any new engine requirements should only apply to newly constructed
    vessels.

    a.  An offshore support vessel is a complex system whereby each
        individual component must be designed into the system. The
        engine systems on our vessels are integral to the construction
        design of the vessel.

    b.  The domestic and international regulatory scheme for vessels is
        based upon a measure of the cubic volume of a vessel. Vessel
        designers strive to minimize the physical space utilized for
        vessel systems where each component of the engine system is
        optimally placed to allow for maximum performance in the minimum
        of physical space. This leaves no room for the addition of new
        equipment (after treatment systems). This measurement by tonnage
        has no correlation to the weight of a vessel. Vessels are
        typically designed so that their regulatory measurement
        (tonnage) falls just below a regulatory threshold, i.e., because
        the lower threshold is 100 regulatory tons, vessels in this
        category are typically designed to 99 regulatory tons. The
        addition of any cubic volume (such as that for after-treatment
        systems) would cause a vessel to cross a regulatory threshold
        and subject the vessel to substantial additional equipment and
        personnel costs. In some cases, the differences in regulatory
        tonnage application, when combined with current Coast Guard
        policy interpretations, may be so great as to be economically
        impractical to comply with.

    c.  These systems (propulsion engines and generators) are literally
        built into the vessels. Removal of an engine for replacement or
        rebuild is extremely difficult (costly).

    d.  As the construction and equipment of U.S. vessels are tightly
        regulated by the U.S. Coast Guard we would suggest that the EPA
        work closely with the Coast Guard in the development of these
        rules to prevent any conflict with Coast Guard vessel design
        and/or safety standards. Vessel regulators such as the Coast
        Guard have typically applied new standards to vessels according
        to build date. New vessel equipment standards are usually
        announced well in advance, to apply to vessels whose build date
        is after the assigned implementation date of the new standard.
        This process has served government and industry well as it
        allows for new standards to be incorporated into the design and
        construction of vessels, and new equipment to go through the
        approval process well in advance.

2.  The offshore support vessel industry is unique in that the vessels
    carry fuel for offshore facilities in the same tanks that provide
    fuel for vessel operations. Unlike tankships or tankbarges, offshore
    support vessels are designed with large integral fuel tanks.
    Offshore support vessels support offshore drilling and production by
    transferring fuel from the vessel's integral fuel tanks to the
    drilling units or platforms for use by the offshore facilities to
    fuel their diesel engines. With over 1,200 vessels supporting over
    4,000 fixed offshore facilities and over 150 mobile offshore
    drilling units in the Gulf of Mexico alone (not counting California
    and Alaska) great care must be exercised in developing the domestic
    implementation timeline for new rules. If great diligence is not
    exercised in developing the implementation timetables, the situation
    may arise in which vessels and the facilities they support are using
    different blends of fuels. A number of different mixtures could be
    in use in the offshore environment, creating a logistical nightmare.

3.  The offshore support vessel segment of the United States' is
    successfully competing, head-to-head, in international markets.
    Vessels operating in domestic service may move on short notice to an
    international support location and/or return from an international
    location to domestic operations. Vessels operating in domestic
    service may be called upon to support a foreign-flag mobile drilling
    unit on the U.S. Outer Continental Shelf, with the potential of
    differing fuel composition. Sufficient forethought needs to be put
    into the implementation of these new rules and consideration needs
    to be made as to the negative technical and engineering implications
    of domestic requirements on vessels working in foreign locations or
    supporting foreign drilling units where the very fuel called for
    (ultra low sulphur diesel) is not compatible.

While OMSA represents the largest companies in our industry (some with
over 100 U.S. flag vessels), approximately 75% of our members are
family-owned businesses (small-entities). Of these family-owned
businesses, most operate five or fewer vessels. These small entities
could face severe economic hardship if forced to replace or extensively
modify existing engines before the useful economic life of those engines
has elapsed.

It is critical that the EPA work with, and consider as a separate
element, the offshore support segment affected by these proposed rules.
We suggest that an overall group made up of the Offshore Marine Service
Association, International Association of Drilling Contractors (offshore
drilling) and Offshore Operators Committee (oil and gas producers) be
allowed to work with you in development of the rules as they apply to
the drilling, production and support of our strategically important
offshore oil and gas resources.

If you have any questions please feel free to contact us at (504)
734-7622 or email ken@offshoremarine.org.

Sincerely,

Offshore Marine Service Association

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height="0.5645833333333333in"}

K. B. Parris

Vice President