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0 PRO ~ l \ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 

## APR 2 6 2018 THEADMINISTRATOR The Honorable Linda Lingle Governor of Hawaii 

### State Capitol Honolulu, Hawaii 96813 Dear Governor Lingle: This is in response to your letter of November 25, 2009, urging the Environmental Protection Agency (EPA) to conduct quantitative air quality and economic analyses before including Hawaii in the NorthAmerican Emission Control Area (ECA) . I sincerely apologize for not responding directly to you before today, andwe are reviewing internal processes to ensure this will not happen again. Also, please be assured that your comments were received and given full consideration and have been included in the official administrative docket for our Category 3 Marine Diesel Engines Rule, signed in December 2009 . The Summary andAnalysis of Comments for that rule cites your letter and includes an Agency response to the primary issues you raised. At this time, I would like to offer you a more personal response. Large diesel engines on ships are significant contributors to air pollution. In presenting its proposal to the International Maritime Organization (IMO) in July 2009, the U .S. Government explained that a combination of methodologies was used to demonstrate the need for ECA controls. Because Hawaii is not included in the domain for the air quality models used for the continental U

.S., an alternative approach was used. This included detailed emission inventory modeling ofpollution fromships operating offthe coasts of Hawaii . We also assessed whether emissions from

ships would reach populated areas in Hawaii based on meteorological data. This analysis concluded that ships are contributing to ambient air concentrations ofozone and PM2 .5 in the southeastern Hawaiian Islands. At that meeting ofthe IMO, a technical committee reviewed the North American ECAproposal and found it to satisfy fully the criteria in MARPOL Annex VI . EPAstaffcoordinatedwith the Hawaii Department of Health (DOH) in developing the environmental case for inclusion of Hawaii . As you noted, early on the DOHstaffperceived a "lack ofsufficient data" to support the inclusion ofsoutheastern Hawaii in the ECA . The DOH was, however, supportive ofthe ultimate goal of including Hawaii and, upon further analysis, we became more confident of having a strong case for protection of human health and the environment of Hawaii . In developing the ECAproposal, EPAconsulted with stakeholders, including representatives fromthe shipping industry, ports, master mariners, environmental interests and

9 Recycled/Recyclable a % Internet Address (URL) http //wwwepa.gov Printed with Vegetable Oil Based Inks on 100 Postconsumer, Process Chlorine Free Recycled Paperrepresentatives from state and provincial governments. Through our coordinated strategy to address emissions fromocean-goingvessels, EPAis striving to minimize the impact on the shipping community, while achieving needed environmental protection. In your letter, you expressed special concern about the potential local economic impacts ofthe fuel standards. The fuel industry was involved at the IMOduring development of the international standards. Through ECAdesignation, EPAis providing industry with the certainty necessary to make business plans to have the required fuels available when and where they will be needed. The environmental case for this ECAwas approved bythe IMO's Marine Environment Protection Committee (MEPC) in July 2009 and the coordinates bounding its application were adopted on March 26, 2010. The NorthAmerican ECA, including the requirements for cleaner burning fuel, will enter into force in August 2012. EPAis committed to working with the Government of Hawaii and regional/local businesses to assist with implementation in anyway possible. Thank youfor your letter. Ifyou have further questions or concerns, please contact me or your staff may call Sarah Hospodor-Pallone, Deputy Associate Administrator for Intergovernmental Relations, at (202) 564-7178. 

### Sincerely,

c .-~.--- Lisa P . Jackson