EMA PROPOSAL FOR MARINE USEFUL LIFE (UL)

June 25, 2004

# [CURRENT MARINE UL REGULATIONS (40CFR 94.9)]{.underline}

-   Regulations define UL to be 1000 hrs/10 yrs for recreational, 10,000
    hrs/10 yrs for Category 1 commercial and 20,000 hrs/10 yrs for
    Category 2

-   Longer UL is to be specified if engine is designed to remain in
    service longer

-   Manufacturer may request a shorter UL if the manufacturer has
    documentation from in-use engines showing that the engines will
    rarely operate longer than the alternate useful life.

[ISSUE]{.underline}

-   The default ULs given in the regulations are not appropriate for
    certain marine engines -- especially high power density commercial
    engines.

-   Manufacturers generally do not have (and can not have) the
    documentation from in-use engines that is needed to justify an
    alternate UL prior to obtaining certification and putting engines
    into service.

[EMA PROPOSAL:]{.underline}

EMA proposes that the regulatory UL be modified as shown in the
following table. This more closely reflects the design lives of current
marine engines and recognizes that the design life inherently varies
with engine cylinder size and power density. It also recognizes that
commercial and recreational engines of the same cylinder size and power
density tend to have similar design life and that, for the most part,
commercial and recreational engines can be assigned the same UL.

PROPOSED USEFUL LIFE MATRIX FOR COMMERCIAL AND RECREATIONAL MARINE
ENGINES

Hours/Years

+-------------+-------------+-------------+-------------+-------------+
| Disp / Cyl  | Power per   |             |             |             |
|             | D           |             |             |             |
| Liters      | isplacement |             |             |             |
|             |             |             |             |             |
|             | KW/Liter    |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
|             |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
|             | KW/liter    | 26\<k       | 37\<k       | K           |
|             | \<26        | W/liter\<37 | W/liter\<43 | W/liter\>43 |
+-------------+-------------+-------------+-------------+-------------+
| Category 1  |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| disp\< 0.9  | 4000/4      | 3000/3      | 2000/2      | 1000/2      |
+-------------+-------------+-------------+-------------+-------------+
| 0.9         | 6000/6      | 4000/4      | 3000/3      | 1500/2      |
| \<disp\<1.2 |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| 1.2         | 8000/8      | 6000/6      | 4000/4      | 2000/2      |
| \<disp\<2.5 |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| 2.5         | 10,000/10   | 8000/8      | 5000/5      | 2500/3      |
| \<disp\<4.0 |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| 4.0         | 12,000/10   | 9000/9      | 6000/6      | 4000/4      |
| \<disp\<5.0 |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| Category 2  |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| 5.0\        | 14,000/10   | 12,000/10   | 10,000/10   | 8000/10     |
| <disp\<15.0 |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| 15.0\       | 16,000/10   | 14,000/10   | 12,000/10   | 10,000/10   |
| <disp\<20.0 |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| 20.0\       | 20,000/10   | 18,000/10   | 16,000/10   | 14,000/10   |
| <disp\<25.0 |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| 25.0\       | 22,000/10   | 20,000/10   | 18,000/10   | 16,000/10   |
| <disp\<30.0 |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
|             |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+

This matrix selects the UL based on readily available and objective
design criterion. No additional information or subjective evaluation is
needed to determine the UL. This matrix will select the appropriate UL
for most engines. Use of this matrix will drastically reduce or perhaps
even eliminate the need for manufacturers to request and justify
alternate ULs.

One concern with use of this matrix is that many engine families as
currently defined will have engine ratings that will span two or more
kW/Liter categories and thus would fall into two or more useful life
categories. This could lead to a proliferation of engine families. To
address this concern, EMA proposes that manufacturers be allowed the
option of either allowing ratings with different useful lives to be
included in the same family or of separating the ratings into different
families by useful life categories. If the single family is retained,
the manufacturer would provide an emission label for each engine that
would appropriately identify its UL. The UL used to define the emission
deterioration factors used for the family would be based on the longest
UL category in the family.

    Importance: High

    -----Original Message-----

    From: French, Timothy 

    Sent: Monday, June 28, 2004 11:47 AM

    To: 'Passavant.Glenn@epa.gov'

    Subject: EMA Proposal for Marine Useful Life.

    Importance: High

    Dear Glenn: As a follow-up to our conference call last month, attached please find EMA's proposal (including a detailed matrix) for revised useful life standards for commercial and recreational marine engines. We recognize that it may be necessary to amend the underlying regulations to implement fully EMA's proposal. Nevertheless, the greater certainty and other benefits represented by EMA's proposal could be implemented on an interim basis in the near-term through an appropriate EMA guidance document indicating that useful lives selected and designated in accordance with the attached matrix would be accepted by the Agency as being in compliance with the useful life provisions set forth at 40 CFR section 94.9. We would like to convene a conference call or meeting with you and your colleagues as soon as practicable to discuss EMA's proposal in greater detail. To that end, please let me know the dates that you would be available for such a teleconference/meeting, and I will proceed to confirm the logistics. Thank you very much for your assistance on this matter. Tim French.