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 PUBLIC HEARING FOR PROPOSED EMERGENCY VEHICLE 

 and SCR MAINTENANCE RULE

 Ann Arbor, Michigan 

 June 27, 2012

 10:00 a.m.

 

 Presider: Matthew Spears

 

 Panel Members

 Michael Horowitz

 Lauren Steele

 

 

 Reported by:

 Amy Shankleton-Novess (CER 0838)

 

 Prepared by:

 

 Ann Arbor Reporting Service, Inc.

 106 North Fourth Avenue

 Ann Arbor, Michigan 48104
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 LIST OF ATTENDEES:

PRESENT: 

Keith Brown

Giedrius Ambrozaitis 

Joseph Kubsh

Frank Seymour

Brian Chaput

Chris Riley

Dave Drehobl

Kipp Bottorff

Roger Lackore

Mark Clothier

Nakia Simon

Steve Spata

Wes Chestnut

APPEARING VIA TELECONFERENCE:

Josee Lavergne

Bridget Rezier

Michael Spiess

Kimberly Pryor

Michael Tham Babak-Pazokifard

Paul Abnani

Zach Evans
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(1) Ann Arbor, Michigan 

(2) 10:07 a.m.

(3) * * *

(4) MR. SPEARS: Good morning. Welcome to all of

(5) you with us here in Ann Arbor as well as those listening

(6) by phone, and thanks to each of you for taking the time to

(7) participate today.

(8) My name is Matt Spears, and I am the Director

(9) of the Heavy-Duty Onroad and Nonroad Center here at EPA's

(10) Office of Transportation and Air Quality. I will be

(11) serving as the Presiding Officer for today's hearing, and

(12) this hearing is on the proposed Emergency Vehicle and SCR

(13) Maintenance Rule.

(14) Representing EPA with me is Michael Horowitz

(15) from our Office of General Counsel, along with Lauren

(16) Steele of our Assessment and Standards Division. 

(17) Today we will hear testimony on the Emergency

(18) Vehicle and SCR Maintenance Rule, which was published in

(19) the Federal Register on June 8th. There are three

(20) components of our proposed action: first, SCR maintenance

(21) provisions; second, regulatory flexibility for nonroad

(22) equipment used during emergency responses; and third,

(23) regulatory flexibility for dedicated emergency vehicles.

(24) For the first component, EPA is proposing to

(25) add fluid replenishment to the list of scheduled emission
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(1) related maintenance in connection with the use of

(2) selective catalytic production technologies that use a

(3) consumable chemical reductant. We are also proposing

(4) minimum fluid refill intervals for diesel engines and

(5) vehicles that use SCR.

(6) For the second component, EPA is proposing to

(7) allow short-term relief from emissions standards for

(8) general purpose nonroad equipment, only when such

(9) equipment is needed to respond to an emergency, such as a

(10) flood or a hurricane.

(11) For the third component, EPA is offering

(12) engine and vehicle manufacturers the flexibility to ensure

(13) that there will not be emission-related power loss on

(14) emergency vehicles. I want to highlight that that the

(15) advanced emission control technology would remain on the

(16) vehicles. The revisions would allow manufacturers to

(17) request and EPA to approve modifications to emission

(18) control systems on new and in-use emergency vehicles so

(19) they can be operated as intended, without reduced

(20) performance during emergency situations.

(21) While EPA is accepting comments on all parts

(22) of the proposed rule, EPA also published the provisions

(23) offering flexibility for dedicated emergency vehicles in a

(24) parallel Direct Final Rule. The provisions in the Direct

(25) Final Rule will take effect August 7th unless we receive
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(1) adverse comments.

(2) We look forward to hearing your testimony

(3) today. There is also opportunity for anyone to send us

(4) written comments for 30 days, until July 27th. 

(5) Instructions for submitting written comments are provided

(6) in the Notice of Proposed Rulemaking, and copies of those

(7) instructions are available at the reception table.

(8) Before getting started with today's testimony,

(9) I would like to take a few minutes to read a prepared

(10) statement to outline how we will hold this hearing:

(11) "We are conducting this hearing in accordance

(12) with Section 307(d)(5) of the Amended Clean Air Act,

(13) which requires EPA to provide interested persons

(14) with an opportunity for oral presentation of data,

(15) views, or arguments, in addition to an opportunity

(16) to make written submissions. This hearing provides

(17) the opportunity for such oral presentations.

(18) The official record of this hearing will be

(19) kept open until July 27th, 2012, for the submission

(20) of rebuttal and supplemental testimony. The hearing

(21) will be conducted informally, and formal rules of

(22) evidence will not apply. The Presiding Officer,

(23) however, is authorized to strike statements from the

(24) record which are deemed irrelevant or needlessly

(25) repetitious, and to enforce reasonable limits on the
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(1) duration of the statements of any witness.

(2) Witnesses must state their name and

(3) affiliation prior to making their statement. When a

(4) witness has finished his or her presentation,

(5) members of the panel will have an opportunity to ask

(6) questions related to the testimony. Witnesses are

(7) reminded that any false statements or false

(8) responses to questions may be a violation of law. 

(9) Witnesses will have a chance later in the hearing to

(10) provide rebuttal and supplemental testimony. In

(11) addition, witnesses can submit rebuttal and

(12) supplemental testimony until July 27, 2012. 

(13) If any members of the audience that wish to

(14) testify has not already signed up, please submit

(15) your name at the reception table. We should be able

(16) to accommodate everyone who wants to testify. 

(17) Everyone attending should also sign the register at

(18) the reception table whether or not you testify.

(19) Finally, if you would like a transcript of the

(20) proceedings, you should make arrangements directly

(21) with the court recorder."

(22) Before we bring up the first speaker, I want to

(23) ask if there are any clarifying questions? Okay.

(24) Before we get started, I would like to take a

(25) roll call and brief introduction for those here in Ann
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(1) Arbor, and then second of those listening in by phone. So

(2) if we could just start from the front of the room, just so

(3) we know who is attending.

(4) MR. BROWN: Sure. Keith Brown from the

(5) Southeastern Association of Fire Chiefs.

(6) MR. SPEARS: Thank you.

(7) MR. AMBROZAITIS: Giedrius Ambrozaitis with

(8) the Alliance of Automobile Manufacturers.

(9) MR. KUBSH: Joe Kubsh for the Manufacturers of

(10) Emission Controls Association.

(11) MR. SEYMOUR: Frank Seymour, Detroit Diesel,

(12) Compliance and Regulatory Affairs.

(13) MR. CHAPUT: Brian Chaput, Detroit Diesel,

(14) application engineering.

(15) MR. RILEY: Chris Riley, Cummins,

(16) Incorporated, regulatory affairs.

(17) MR. DREHOBL: Dave Drehobl from Cummins,

(18) Incorporated.

(19) MR. BOTTORFF: Kipp Bottorff, Cummins,

(20) Incorporated.

(21) MR. LACKORE: Roger Lackore with Oshkosh

(22) Corporation.

(23) MR. CLOTHIER: Mark Clothier with Bloomberg

(24) News.

(25) MS. SIMON: Nakia Simon, Chrysler Regulatory
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(1) Affairs.

(2) MR. SPATA: Steve Spata, National Truck

(3) Equipment Association.

(4) MR. CHESTNUT: Wes Chestnut with Spartan

(5) Motors.

(6) MR. SPEARS: Okay. Thank you very much.

(7) And for those on the phone, if you wouldn't

(8) mind just stating your name and affiliation, please?

(9) MS. LAVERGNE: Josee Lavergne with Environment

(10) Canada.

(11) MR. SPEARS: Thank you.

(12) MS. REZIER: Bridget Rezier, Cummins.

(13) MR. SPEARS: I'm sorry. We could not hear

(14) that.

(15) MS. REZIER: Bridget Rezier, Cummins.

(16) MR. SPEARS: Hi, Bridget. Okay.

(17) UNIDENTIFIED: The Air Resources Board.

(18) MR. SPEARS: And who is it?

(19) MR. SPIESS: Michael with Environment Canada.

(20) MR. SPEARS: I'm sorry, I missed the name for

(21) those that were from the Air Resources Board.

(22) MS. PRYOR: Kimberly Pryor.

(23) MR. THAM BABAK-PAZOKIFARD: Michael Tham Babak-

(24) Pazokifard.

(25) MR. ABNANI: Paul Abnani.
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(1) MR. SPEARS: Okay, perhaps once we finish

(2) testimony, if those on the phone could stay on the line to

(3) make sure that we have a record of those that are on the

(4) line. I know that I do have all of the affiliations, but

(5) I'm not sure if I got all of the names. Okay, we didn't. 

(6) Okay, so just if you could please stay on the line

(7) afterward we can make sure that we can get those names.

(8) Is there anyone else on the phone? 

(9) Okay. Thank you very much.

(10) With that I believe we can begin with the

(11) first speaker. Okay, let's see, our first witness on our

(12) schedule today, I understand it's both, okay, from the

(13) Fire Apparatus and Manufacturers Association, Wesley

(14) Chestnut and Roger Lackore.

(15) MR. LACKORE: My name is Roger Lackore, and

(16) I'm the Director of Product Safety and Compliance with

(17) Oshkosh Corporation.

(18) MR. CHESTNUT: I'm Wes Chestnut. I manage

(19) Compliance and Regulatory Affairs at Spartan Motors, Inc.

(20) MR. LACKORE: And both of us are here

(21) representing the Fire Apparatus Manufacturers Association

(22) and coauthored what you're going to -- our speech.

(23) The Fire Apparatus Manufacturers Association,

(24) or FAMA, is a group of manufacturers that serve the

(25) emergency vehicle community, and our membership includes
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(1) both vehicle and engine manufacturers. We care about our

(2) customers and look forward to working in conjunction with

(3) the EPA in the implementation of the proposed rule.

(4) FAMA supports the actions of the EPA to

(5) provide flexibility with regard to the emissions

(6) certification of compression-ignition engines in emergency

(7) vehicles. Our support extends to all aspects of the

(8) Direct Final Rule, and the Notice of Proposed Rulemaking

(9) affecting diesel particulate filter operation, including:

(10) the intent to allow DPF regeneration to occur more

(11) frequently; allowing engine calibrations that produce less

(12) soot; and other methods that may become clear as the

(13) engine manufacturers pursue solutions to compliance from

(14) the emergency vehicle user community.

(15) FAMA also supports the intent to relax the

(16) inducement strategies related to the diesel exhaust fluid,

(17) or DEF tank. We believe that a light and buzzer strategy

(18) is much more appropriate to emergency vehicles than a

(19) strategy that limits the speed of the vehicle, or in other

(20) ways hampers its ability to perform life-saving tasks.

(21) We also support the NPRM move to increase the

(22) minimum DEF tank size for emergency vehicles as long as

(23) the effective date of the change provides at least 18

(24) months for manufacturers to retool.

(25) The only aspect of the Direct Final Rule where
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(1) we have recommendations to make concerns the Agency's

(2) definition of ambulance and fire truck. We feel that

(3) these definitions may preclude other specialty emergency

(4) vehicles with similar duty cycles, such as rescue trucks,

(5) command and communication apparatus, SWAT vehicles, or

(6) other vocational vehicles used for emergency response, but

(7) that are not directly associated with either fire

(8) suppression or patient transport. Therefore, FAMA

(9) proposes to replace the definitions of the fire truck and

(10) ambulance with a general definition of emergency vehicle

(11) as follows: "Emergency vehicle: a vocational vehicle or

(12) other mobile equipment designed to be used under emergency

(13) conditions such as fire suppression, patient transport,

(14) police activity, or homeland security operations."

(15) We believe this broader definition will

(16) encompass the range of vehicles susceptible to the problem

(17) this rulemaking is intended to address.

(18) While this concludes our comments on the Final

(19) Direct Rule and the NPRM in question, FAMA would also like

(20) to take this opportunity to address the treatment of

(21) emergency vehicles in the recent Greenhouse Gas and Fuel

(22) Economy Rulemaking.

(23) Without taking anything away from our sincere

(24) support for the current EPA actions related to the Heavy

(25) Duty Highway Program, Revisions for Emergency vehicles, we
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(1) feel compelled to point out that none of the issues being

(2) addressed by this rulemaking were unanticipated. FAMA

(3) representatives expressed serious concerns in discussions

(4) with the EPA prior to implementation of both the 2007 and

(5) the 2010 emissions regulations. Both the effect of unique

(6) emergency vehicle duty cycles on DPF regeneration, and the

(7) SCR driver inducement topics were covered. We believe

(8) that had these concerns been heeded at that time, a

(9) considerable amount of frustration, risk, and the EPA's

(10) need to react "after the fact" could have been avoided. 

(11) It would also have avoided what we anticipate to be

(12) considerable work and expense once this direct final rule

(13) takes effect.

(14) While that is water over the dam, we would

(15) like to remind the EPA that several FAMA member companies

(16) expressed concerns regarding the impact of the Greenhouse

(17) Gas and Fuel Economy rulemaking on emergency vehicle

(18) performance. We pointed out the potential impact of

(19) restricting the use of aggressive tire treads by mandating

(20) the use of low rolling resistance tires. Like the DPF and

(21) SCR issue, it is unlikely that the impact of this tire

(22) tread restriction will be apparent until lower rolling

(23) resistance tires have been implemented and emergency

(24) vehicle users begin to experience reduced off-road

(25) traction and reduced high-speed cornering and
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(1) maneuverability. As with recent events and complaints

(2) that arose from the Southeast Association of Fire Chiefs,

(3) there may be a significant lag before the true impacts of

(4) the Greenhouse Gas and Fuel Efficiency Rules are realized.

(5) FAMA therefore urges the EPA to revisit our

(6) previous comments and data on this issue and reconsider

(7) authorizing an emergency vehicle exemption to the rolling

(8) resistance requirements now, so that we can avoid the

(9) potential for another hearing like this in the future. 

(10) The very minimal impact this action would have on over-all

(11) vehicle emissions seems like a small price to pay to avoid

(12) another industry-upsetting event.

(13) That being said, we at FAMA would like to

(14) express our appreciation to Lauren Steele, Matt Spears,

(15) and others at the EPA who have worked very hard to

(16) understand the needs of the emergency vehicle community. 

(17) Your enthusiasm and dedication has been apparent

(18) throughout the process. We are confident that the

(19) nation's first responders will benefit from the Agency's

(20) greater level of engagement both now and in the years to

(21) come. Thank you.

(22) MR. CHESTNUT: The one thing that I would like

(23) to add to the proposed definition for emergency vehicle in

(24) the Proposed Rulemaking and in the Final Rule, an

(25) emergency situation can be defined as a number of things. 
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(1) I think by, if you take a look at our proposed definition

(2) it gives some examples of what an emergency -- could

(3) constitute an emergency condition which would further

(4) clarify what an emergency situation is, and at this point

(5) we believe that's a concern with other manufacturers as

(6) well as engine manufacturers, so.

(7) MR. SPEARS: Okay. Thank you very much.

(8) MR. HOROWITZ: Oh, wait, wait.

(9) MR. SPEARS: Oh. We have an opportunity here

(10) for questions for clarification. 

(11) MR. HOROWITZ: Yeah. First, just a

(12) clarification on the comment with regard to the

(13) definition, your comment is directed towards the Notice of

(14) Proposed Rulemaking. You're not suggesting that we

(15) withhold the Direct Final Rule based on that comment,

(16) right? It's not an adverse comment on the Direct Final

(17) Rule?

(18) MR. LACKORE: It's -- no. It's not an adverse

(19) comment. Nothing in our testimony today should be

(20) construed as something that would slow up the

(21) implementation of the Direct Final Rule.

(22) MR. HOROWITZ: Just wanted to clarify.

(23) MR. SPEARS: Questions? 

(24) MR. LACKORE: Thank you very much.

(25) MR. SPEARS: Okay, thank you very much.
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(1) Next on my list here is Keith Brown with

(2) Southeastern Association of Fire Chiefs.

(3) MR. BROWN: Thank you, Matt.

(4) Again my name is Keith Brown. I represent the

(5) Southeastern Association of Fire Chiefs. I'm actually a

(6) fire chief from south Mississippi. I've been in the

(7) business for quite a while, and I apologize for not having

(8) a prepared statement, but I found out about ten minutes

(9) before the meeting I was supposed to speak, and Dan sends

(10) his regards. He was supposed to attend but had to back

(11) out for personal reasons; something came up at the last

(12) minute. But anyway, to echo what Roger and Wes said, we

(13) would like to commend the EPA and thank you for having

(14) your willingness to listen to us and hear our concerns and

(15) never had any ill-effect to what we were saying to you, so

(16) thank you for your willingness to listen and work with us.

(17) Across the United States ever since we opened

(18) this up we've got flooded by emails and different letters

(19) and phone calls of people that were having issues with

(20) these regeneration issues, so that's kind of what got us

(21) to try to get some amended rulemakings to the process to

(22) where we could actually do our business and not have to

(23) worry about someone getting hurt or killed in the process,

(24) so again, thank you for what you do and thank you for

(25) listening to us. 
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(1) With that being said, I think it's pretty

(2) obvious why we're here, and I'm not going to get into it

(3) any further, but thank you again for what you do, and our

(4) phones or emails are always open, and do you have any

(5) questions for me?

(6) MR. SPEARS: Thank you very much. 

(7) Are there any other questions of this witness?

(8) MS. STEELE: I have one.

(9) MR. SPEARS: Okay. 

(10) MR. BROWN: Okay.

(11) MS. STEELE: Keith, do you have a sense from

(12) your emails, how many of the emails are folks that are

(13) saying, "We don't have any problems with our trucks,"

(14) because how many people are saying that they need help?

(15) MR. BROWN: I'm sorry, Lauren, and I told you

(16) I was going to expand. I actually have two trucks within

(17) my department that have Cummins engines in them and

(18) haven't had an issue. So personally I have not had an

(19) issue. I think in the state of Mississippi, at current

(20) count I was telling Roger a while ago, I think there's

(21) currently five, and I can't give you specifics on those

(22) five, but that's as of Friday because Dan just sent out

(23) the paperwork to try to get some numbers back within the

(24) last two weeks, and as of Friday we had five surveys

(25) filled out of issues with trucks. So I can follow-up
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(1) after I get back. Dan was not able to send me that

(2) information yet, but I can speak for my department; we've

(3) had good results, so.

(4) MS. STEELE: Thank you.

(5) MR. BROWN: Thank you.

(6) MR. SPEARS: Thank you very much.

(7) MR. BROWN: Thank you. 

(8) MR. SPEARS: Any other questions?

(9) Okay, thanks. Thank you very much, Keith.

(10) Actually, that is the entire list of folks

(11) that have signed up to testify today. First I would like

(12) to ask if there are any other supplemental comments or

(13) comments for rebuttal at this point?

(14) Okay. 

(15) And finally, are there any other people here

(16) today in Ann Arbor that would like to make a statement at

(17) this hearing? 

(18) Okay. Any other questions?

(19) Conclude?

(20) MR. HOROWITZ: Yeah, sure.

(21) MR. SPEARS: I can't think of anything.

(22) MR. HOROWITZ: Yeah.

(23) MR. SPEARS: Okay. Well --

(24) MS. STEELE: If there are people who wish to

(25) remain and have a dialogue after the adjournment of this
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(1) hearing, I understand that we have the room reserved all

(2) day, but if EPA is in the room we must document it and

(3) docket the occurrence of that meeting and the nature of

(4) the discussion.

(5) MR. SPEARS: Okay. Good point. Thank you.

(6) At this point if there are no other people

(7) here at the hearing today that would like to make a

(8) statement or ask questions for clarification, I will be

(9) adjourning this hearing.

(10) (At 10:27 a.m., hearing concluded.)

(11)

(12)

(13)

(14)

(15)

(16)

(17)

(18)

(19)

(20)

(21)

(22)

(23)

(24)

(25)
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STATE OF MICHIGAN )

COUNTY OF WASHTENAW )ss.

 I certify that this transcript is a complete, true, and

correct transcript to the best of my ability of the PUBLIC

HEARING FOR PROPOSED EMERGENCY VEHICLE and SCR MAINTENANCE RULE,

held in Ann Arbor, Michigan on June 27, 2012 10:07 a.m.

 I also certify that I am not a relative or employee of a

party, or a relative or employee of an attorney for a party, nor

have a contract with a party, nor am I financially interested in

the aforementioned action.

DATED: July 2, 2012

 

 _______________________________________

 Amy Shankleton-Novess (CER0838)

 

 

Monday, July 02, 2012

Notary Public, Washtenaw County, Michigan

Acting in Washtenaw County

My Commission Expires: 10/23/18
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accepting 4:21

accommodate 6:16

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action 3:20 13:10 19:12

actions 10:4 11:24

activity 11:14

add 3:25 13:23

addition 5:15 6:11

address 11:17,20

addressed 12:2

adjourning 18:9

adjournment 17:25

advanced 4:15

adverse 5:1 14:16,18

affairs 7:12,16 8:1 9:19

affiliation 6:3 8:8

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aforementioned 19:12

afterward 9:7

Agency's 11:1 13:19

aggressive 12:19

ago 16:20

Air 3:10 5:12 8:17,21

Alliance 7:8

allow 4:7,16 10:10

allowing 10:11

Ambrozaitis 2:4 7:7,7

ambulance 11:2,10

amended 5:12 15:21

amount 12:9

Amy 1:19 19:18

Ann 1:4,23,25 3:1,5 6:25 17:16

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anticipate 12:11

anyway 15:12

apologize 15:7

apparatus 9:13,21,23 11:5

apparent 12:22 13:17

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application 7:14

apply 5:22

appreciation 13:14

appropriate 10:18

approve 4:17

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arose 13:2

arrangements 6:20

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attorney 19:10

audience 6:13

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Automobile 7:8

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a.m 1:6 3:2 18:10 19:7

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Bloomberg 7:23

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Brian 2:7 7:13

Bridget 2:19 8:12,15,16

brief 6:25

bring 6:22

broader 11:15

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catalytic 4:2

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Chaput 2:7 7:13,13

chemical 4:3

Chestnut 2:15 8:4,4 9:14,18,18

13:22

chief 15:6

Chiefs 7:5 13:2 15:2,5

Chris 2:8 7:15

Chrysler 7:25

clarification 14:10,12 18:8

clarify 14:4,22

clarifying 6:23

Clean 5:12

clear 10:12

Clothier 2:12 7:23,23

coauthored 9:22

come 13:21

command 11:5

commend 15:13

comment 14:12,13,15,16,19

comments 4:21 5:1,4,5 11:18

13:6 17:12,13

Commission 19:24

communication 11:5

community 9:25 10:14 13:16

companies 12:15

compelled 12:1

complaints 13:1

complete 19:4

compliance 7:12 9:16,19 10:13

component 3:24 4:6,11

components 3:20

compression-ignition 10:6

concern 14:5

concerns 11:1 12:3,8,16 15:14

Conclude 17:19

concluded 18:10

concludes 11:18

condition 14:3

conditions 11:13

conducted 5:21

conducting 5:11

confident 13:18

conjunction 10:2

connection 4:1

considerable 12:9,12

constitute 14:3

construed 14:20

consumable 4:3

contract 19:11

control 4:15,18

Controls 7:10

copies 5:6

cornering 12:25

Corporation 7:22 9:17

correct 19:5

Counsel 3:15

count 16:20

County 19:2,22,23

court 6:21

covered 12:7

Cummins 7:15,17,19 8:12,15

16:17

current 11:24 16:19

currently 16:21

customers 10:2

cycles 11:4 12:6

D

dam 12:14

Dan 15:9 16:22 17:1

data 5:14 13:6

date 10:23

DATED 19:14

Dave 2:9 7:17

day 18:2

days 5:4

dedicated 3:23 4:23

dedication 13:17

deemed 5:24

DEF 10:17,22

defined 13:25

definition 11:2,10,15 13:23 14:1

14:13

definitions 11:3,9

department 16:17 17:2

designed 11:12

Detroit 7:11,13

dialogue 17:25

diesel 4:4 7:11,13 10:9,16

different 15:18

direct 4:24,24 10:8,25 11:19

12:12 14:15,16,21

directed 14:13

directly 6:20 11:7

Director 3:8 9:16

discussion 18:4

discussions 12:3

Division 3:16

docket 18:3

document 18:2

DPF 10:10 12:6,20

Drehobl 2:9 7:17,17

driver 12:7

duration 6:1

duty 11:4,25 12:6

E

echo 15:12

Economy 11:22 12:17

effect 4:25 12:5,13

effective 10:23

Efficiency 13:4

either 11:7

emails 15:18 16:4,12,12

emergency 1:1 3:12,17,22,23 4:9

4:14,18,20,23 9:25 10:6,14,18

10:22 11:3,6,10,11,12,21,25

12:6,17,23 13:7,16,23,25 14:2

14:3,4 19:6

emission 3:25 4:15,17 7:10

emissions 4:7 10:5 12:5 13:11

emission-related 4:13

employee 19:9,10

encompass 11:16
ENVIRONMENTAL PROTECTION AGENCY HEARING - JUNE 27, 2012

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Ann Arbor Reporting Service, Inc.

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engagement 13:20

engine 4:12 10:1,11,13 14:6

engineering 7:14

engines 4:4 10:6 16:17

ensure 4:12

enthusiasm 13:17

entire 17:10

Environment 8:9,19

EPA 3:14,24 4:6,11,17,21,22

5:13 10:3,4 11:24 12:4,15 13:5

13:15 15:13 18:2

EPA's 3:9 12:9

equipment 3:22 4:8,9 8:3 11:12

Evans 2:24

event 13:12

events 13:1

evidence 5:22

examples 14:2

exemption 13:7

exhaust 10:16

expand 16:16

expense 12:12

experience 12:24

Expires 19:24

express 13:14

expressed 12:3,16

extends 10:7

F

fact 12:10

false 6:7,7

FAMA 9:24 10:4,15 11:8,19 12:2

12:15 13:5,13

Federal 3:19

feel 11:2 12:1

filled 16:25

filter 10:9

final 4:24,25 10:8,25 11:18 12:12

13:24 14:15,16,21

finally 6:19 17:15

financially 19:11

finish 9:1

finished 6:4

fire 7:5 9:13,21,23 11:2,7,9,13

13:2 15:2,5,6

first 3:20,24 6:22 9:11,11 13:19

14:11 17:11

five 16:21,22,24

flexibility 3:21,23 4:12,23 10:5

flood 4:10

flooded 15:18

fluid 3:25 4:4 10:16

folks 16:12 17:10

follows 11:11

follow-up 16:25

formal 5:21

forward 5:2 10:2

found 15:8

Fourth 1:24

Frank 2:6 7:11

frequently 10:11

Friday 16:22,24

front 7:2

frustration 12:9

Fuel 11:21 12:17 13:4

further 14:3 16:3

future 13:9

G

Gas 11:21 12:17 13:4

general 3:15 4:8 11:10

getting 5:8 15:23

Giedrius 2:4 7:7

give 16:21

gives 14:2

going 9:22 16:2,16

good 3:4 17:3 18:5

greater 13:20

Greenhouse 11:21 12:16 13:4

group 9:24

H

hampers 10:20

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hearing 1:1 3:11,12 5:2,10,11,16

5:18,20 6:9 13:9 17:17 18:1,7,9

18:10 19:6

Heavy 11:24

Heavy-Duty 3:9

heeded 12:8

held 19:7

help 16:14

Hi 8:16

highlight 4:14

Highway 11:25

high-speed 12:25

hold 5:10

homeland 11:14

Horowitz 1:12 3:14 14:8,11,22

17:20,22

hurricane 4:10

hurt 15:23

I

ill-effect 15:15

impact 12:16,18,21 13:10

impacts 13:3

implementation 10:3 12:4 14:21

implemented 12:23

includes 9:25

including 10:9

Incorporated 7:16,18,20

increase 10:21

inducement 10:16 12:7

industry-upsetting 13:12

informally 5:21

information 17:2

instructions 5:5,7

intended 4:19 11:17

intent 10:10,15

interested 5:13 19:11

intervals 4:4

introduction 6:25

in-use 4:18

irrelevant 5:24

issue 12:21 13:6 16:18,19

issues 12:1 15:19,20 16:25

J

Joe 7:9

Josee 2:18 8:9

Joseph 2:5

July 5:4,19 6:12 19:14,21

June 1:5 3:19 19:7

K

Keith 2:3 7:4 15:1,4 16:11 17:9

kept 5:19

killed 15:23

Kimberly 2:21 8:22

kind 15:20

Kipp 2:10 7:19

know 7:3 9:4

Kubsh 2:5 7:9,9

L

Lackore 2:11 7:21,21 9:14,15,15

9:20 14:18,24

lag 13:3

Lauren 1:12 3:15 13:14 16:15

Lavergne 2:18 8:9,9

law 6:8

letters 15:18

let's 9:11

level 13:20

life-saving 10:20

light 10:17

limits 5:25 10:19

line 9:2,4,6

list 2:1 3:25 15:1 17:10

listen 15:14,16

listening 3:5 7:1 15:25

long 10:22

look 5:2 10:2 14:1

loss 4:13

low 12:20

lower 12:22

M

maintenance 1:2 3:13,18,20 4:1

19:6

making 6:3

manage 9:18

mandating 12:19

maneuverability 13:1

manufacturers 4:12,16 7:8,9

9:13,21,23,24 10:1,13,24 14:5

14:6

Mark 2:12 7:23

Matt 3:8 13:14 15:3

Matthew 1:8

meeting 15:9 18:3

member 12:15

members 1:11 6:5,13

membership 9:25

methods 10:12

Michael 1:12 2:20,22 3:14 8:19

8:23

Michigan 1:4,25 3:1 19:1,7,22

mind 8:8

minimal 13:10

minimum 4:4 10:22

minute 15:12

minutes 5:9 15:8

missed 8:20

Mississippi 15:6 16:19

mobile 11:12

modifications 4:17

Monday 19:21

months 10:24

morning 3:4

Motors 8:5 9:19

move 10:21

N

Nakia 2:13 7:25

name 3:8 6:2,15 8:8,20 9:15 15:4

names 9:5,7

National 8:2

nation's 13:19

nature 18:3

need 12:10 16:14

needed 4:9

needlessly 5:24

needs 13:16

never 15:15

new 4:18

News 7:24

nonroad 3:9,21 4:8

North 1:24

Notary 19:22

Notice 5:6 10:8 14:13

NPRM 10:21 11:19

number 13:25

numbers 16:23

O

obvious 16:2

occur 10:10

occurrence 18:3

offering 4:11,23

Office 3:10,15

Officer 3:11 5:22

official 5:18
ENVIRONMENTAL PROTECTION AGENCY HEARING - JUNE 27, 2012

(734) 330-5472

Ann Arbor Reporting Service, Inc.

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Oh 14:8,9

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once 9:1 12:12

Onroad 3:9

open 5:19 16:4

opened 15:17

operated 4:19

operation 10:9

operations 11:14

opportunity 5:3,14,15,17 6:5

11:20 14:9

oral 5:14,17

Oshkosh 7:21 9:17

outline 5:10

over-all 13:10

P

panel 1:11 6:5

paperwork 16:23

parallel 4:24

participate 3:7

particulate 10:9

parts 4:21

party 19:10,10,11

patient 11:8,13

Paul 2:23 8:25

pay 13:11

Pazokifard 8:24

people 15:19 16:14 17:15,24

18:6

perform 10:20

performance 4:20 12:18

personal 15:11

personally 16:18

persons 5:13

phone 3:6 7:1 8:7 9:2,8 15:19

phones 16:4

please 6:14 8:8 9:6

point 12:1 14:4 17:13 18:5,6

pointed 12:18

police 11:14

potential 12:18 13:9

power 4:13

preclude 11:3

prepared 1:21 5:9 15:8

PRESENT 2:2

presentation 5:14 6:4

presentations 5:17

Presider 1:8

Presiding 3:11 5:22

pretty 16:1

previous 13:6

price 13:11

prior 6:3 12:4

problem 11:16

problems 16:13

proceedings 6:20

process 13:18 15:21,23

produce 10:11

Product 9:16

production 4:2

Program 11:25

proposed 1:1 3:12,20 4:22 5:6

10:3,8 13:23,24 14:1,14 19:6

proposes 11:9

proposing 3:24 4:3,6

provide 5:13 6:10 10:5

provided 5:5

provides 5:16 10:23

provisions 3:21 4:22,24

Pryor 2:21 8:22,22

Public 1:1 19:5,22

published 3:18 4:22

purpose 4:8

pursue 10:13

Q

Quality 3:10

question 11:19

questions 6:6,8,23 14:10,23 16:5

16:7 17:8,18 18:8

quite 15:7

R

range 11:16

react 12:10

read 5:9

realized 13:4

reasonable 5:25

reasons 15:11

rebuttal 5:20 6:10,11 17:13

receive 4:25

reception 5:7 6:15,18

recommendations 11:1

reconsider 13:6

record 5:18,24 9:3

recorder 6:21

reduced 4:19 12:24,25

reductant 4:3

refill 4:4

regard 10:5 14:12

regarding 12:16

regards 15:10

regeneration 10:10 12:6 15:20

register 3:19 6:17

regulations 12:5

regulatory 3:21,23 7:12,16,25

9:19

related 4:1 6:6 10:16 11:24

relative 19:9,10

relax 10:15

relief 4:7

remain 4:15 17:25

remind 12:15

reminded 6:7

repetitious 5:25

replace 11:9

replenishment 3:25

Reported 1:18

Reporting 1:23

represent 15:4

representatives 12:3

representing 3:14 9:21

request 4:17

requirements 13:8

requires 5:13

rescue 11:4

reserved 18:1

resistance 12:20,23 13:8

Resources 8:17,21

respond 4:9

responders 13:19

response 11:6

responses 3:22 6:8

restricting 12:19

restriction 12:22

results 17:3

retool 10:24

revisions 4:16 11:25

revisit 13:5

Rezier 2:19 8:12,12,15,15

right 14:16

Riley 2:8 7:15,15

risk 12:9

Roger 2:11 7:21 9:14,15 15:12

16:20

roll 6:25

rolling 12:20,22 13:7

room 7:2 18:1,2

rule 1:2 3:13,18 4:22,24,25 10:3

10:8,25 11:19 12:12 13:24

14:15,17,21 19:6

rulemaking 5:6 10:8 11:17,22

12:2,17 13:24 14:14

rulemakings 15:21

rules 5:21 13:4

S

Safety 9:16

saying 15:15 16:13,14

schedule 9:12

scheduled 3:25

SCR 1:2 3:12,18,20 4:5 12:7,21

19:6

second 3:21 4:6 7:1

Section 5:12

security 11:14

see 9:11

selective 4:2

send 5:3 17:1

sends 15:9

sense 16:11

sent 16:22

serious 12:3

serve 9:24

Service 1:23

serving 3:11

Seymour 2:6 7:11,11

Shankleton-Novess 1:19 19:18

short-term 4:7

sign 6:17

signed 6:14 17:11

significant 13:3

similar 11:4

Simon 2:13 7:25,25

sincere 11:23

situation 13:25 14:4

situations 4:20

size 10:22

slow 14:20

small 13:11

solutions 10:13

soot 10:12

sorry 8:13,20 16:15

south 15:6

Southeast 13:2

Southeastern 7:5 15:2,5

Spartan 8:4 9:19

Spata 2:14 8:2,2

speak 15:9 17:2

speaker 6:22 9:11

Spears 1:8 3:4,8 7:6 8:6,11,13,16

8:18,20 9:1 13:14 14:7,9,23,25

16:6,9 17:6,8,21,23 18:5

specialty 11:3

specifics 16:21

speech 9:22

speed 10:19

Spiess 2:20 8:19

ss 19:2

standards 3:16 4:7

start 7:2

started 5:8 6:24

state 6:2 16:19 19:1

statement 5:10 6:3 15:8 17:16

18:8

statements 5:23 6:1,7

States 15:17

stating 8:8

stay 9:2,6

Steele 1:12 3:16 13:14 16:8,11

17:4,24

Steve 2:14 8:2

strategies 10:16

strategy 10:17,19

strike 5:23

submission 5:19

submissions 5:16

submit 6:11,14

submitting 5:5

suggesting 14:14

supplemental 5:20 6:10,12

17:12
ENVIRONMENTAL PROTECTION AGENCY HEARING - JUNE 27, 2012

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Ann Arbor Reporting Service, Inc.

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supports 10:4,15

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suppression 11:8,13

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surveys 16:24

susceptible 11:16

SWAT 11:5

systems 4:18

T

table 5:7 6:15,18

take 4:25 5:9 6:24 11:20 14:1

takes 12:13

tank 10:17,22

tasks 10:20

technologies 4:2

technology 4:15

TELECONFERENCE 2:17

telling 16:20

ten 15:8

testify 6:14,16,18 17:11

testimony 3:17 5:2,8,20 6:6,10

6:12 9:2 14:19

Tham 2:22 8:23,23

thank 7:6 8:6,11 9:9 13:21 14:7

14:24,25 15:3,13,16,24,24 16:3

16:6 17:4,5,6,7,9 18:5

thanks 3:6 17:9

thing 13:22

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think 14:1 16:1,19,20 17:21

third 3:22 4:11

three 3:19

time 3:6 12:8

tire 12:19,21

tires 12:20,23

today 3:7,17 5:3 9:12 14:19

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today's 3:11 5:8

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traction 12:25

transcript 6:19 19:4,5

transport 11:8,13

Transportation 3:10

tread 12:22

treads 12:19

treatment 11:20

truck 8:2 11:2,9

trucks 11:4 16:13,16,25

true 13:3 19:4

try 15:21 16:23

two 16:16,24

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unanticipated 12:2

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unique 12:5

United 15:17

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use 4:1,2,5 12:19,20

user 10:14

users 12:24

V

vehicle 1:1 3:12,18 4:12 9:25

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12:24 13:7,11,16,23 19:6

vehicles 3:23 4:5,14,16,18,23

10:7,18,22 11:4,5,6,16,21,25

views 5:15

violation 6:8

vocational 11:6,11

W

wait 14:8,8

want 4:14 6:22

wanted 14:22

wants 6:16

Washtenaw 19:2,22,23

water 12:14

ways 10:20

weeks 16:24

Welcome 3:4

Wes 2:15 8:4 9:18 15:12

Wesley 9:13

we're 16:2

we've 15:18 17:2

willingness 15:14,16

wish 6:13 17:24

withhold 14:15

witness 6:1,4 9:11 16:7

witnesses 6:2,6,9,11

work 12:12 15:16

worked 13:15

working 10:2

worry 15:23

wouldn't 8:7

written 5:4,5,16

Y

Yeah 14:11 17:20,22

years 13:20

Z

Zach 2:24

0

02 19:21

0838 1:19

1

10/23/18 19:24

10:00 1:6

10:07 3:2 19:7

10:27 18:10

106 1:24

18 10:23

2

2 19:14

2007 12:4

2010 12:5

2012 1:5 5:19 6:12 19:7,14,21

27 1:5 6:12 19:7

27th 5:4,19

3

30 5:4

307(d)(5) 5:12

4

48104 1:25

7

7th 4:25

8

8th 3:19