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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

APR 2 6 2018 

THE ADMINISTRATOR 

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 North American Emission Control Area (ECA). I sincerely apologize 

for not responding directly to you before today, and we 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 and Analysis 

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 of pollution from ships operating off the 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 of ozone and PM2.5 

in the southeastern Hawaiian Islands. At that meeting of the IMO, a technical committee 

reviewed the North American ECA proposal and found it to satisfy fully the criteria in MARPOL 

Annex VI. 

EPA staff coordinated with the Hawaii Department of Health (DOH) in developing the 

environmental case for inclusion of Hawaii. As you noted, early on the DOH staff perceived a 

"lack of sufficient data" to support the inclusion of southeastern Hawaii in the ECA. The DOH 

was, however, supportive of the 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 ECA proposal, EPA consulted with stakeholders, including 

representatives from the shipping industry, ports, master mariners, environmental interests and 

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representatives from state and provincial governments. Through our coordinated strategy to 

address emissions from ocean-going vessels, EPA is 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 

of the fuel standards. The fuel industry was involved at the IMO during development of the 

international standards . Through ECA designation, EPA is 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 ECA was approved by the IMO's Marine Environment 

Protection Committee (MEPC) in July 2009 and the coordinates bounding its application were 

adopted on March 26, 2010 . The North American ECA, including the requirements for cleaner 

burning fuel, will enter into force in August 2012. EPA is committed to working with the 

Government of Hawaii and regional/local businesses to assist with implementation in any way 

possible . 

Thank you for your letter . If you 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