Comment Log Display

93118.5.e.6.C.3.b. (Method C3) Mentions that DECS can be
implemented for meeting tier 3 standards but appears to not
mention that simply meeting tier 2 might be appropriate for some
engines prior to EPA tier 3 being available.  

Additionally, DECS diesel emission control strategies are not
proven technologies for the marine market as demonstrated thru the
state funded ferry system vessels employing these technologies in
which they have been very difficult and costly to maintain.  It
seems inappropriate to push this unproven solution on some
applications were repower is too costly but the deadline requires
updating.

The low hours designation for marine vessels is too low given the
nature of some classic and specialty cruise vessels and the
installation cost of repowering them.  A higher hour limit or an
additional duty cycle calculation should be reevaluated.