July 2, 2007 Air Docket Environmental Protection Agency Mailcode: 6102T 1200 Pennsylvania Avenue, NW Washington, DC 20460 Re: EPA-HQ-OAR-2003-0190 Dear Sir/Madam: The Passenger Vessel Association (PVA) is pleased to comment on the Environmental Protection Agency?s (EPA) Notice of Proposed Rulemaking (NPRM) EPA-HQ-OAR-2003-0190, Control of Emissions of Air Pollution from Locomotive Engines and Marine Compression-Ignition Engines Less Than 30 Liters per Cylinder. PVA is the national trade association for U.S. flag, U.S. Coast Guard (USCG) inspected passenger vessels. The Association consists of approximately 400 vessel operating members and approximately 200 associate members who design, build, repair, outfit, supply and otherwise support the passenger vessel industry. We estimate that our members operate more than 2,000 of the some 6,500 USCG inspected vessels in the domestic passenger vessel fleet. PVA members operate ferry, dinner, excursion, sightseeing, eco-tourism, overnight, gaming, windjammer, amphibious vehicle, and thrill) vessels. Our members operate in 42 states, the District of Colombia, Puerto Rico, and the Virgin Islands. Except for the larger government related ferry systems they are almost exclusively small businesses. Passenger vessels operate in the major harbors, river systems, tributaries, headwaters, and lakes of the nation?s waterways. In the major harbors they serve the transportation and entertainment needs of the urban setting. In many small cities they form the heart of waterfront development. In more remote areas they serve the needs of island access, vacation destinations, and National Parks. The message is that we are critical infrastructure, an economic engine, a unique recreational or dining experience, an employer of thousands, and a widespread public resource. The passenger vessel impact on the air quality in their areas is related to their operating/duty schedule. Ferries in metropolitan areas generally run 24 hours; 365 days a year. These operations intensify and slacken in direct relation to the commuting patterns of the area and to a lesser extent seasonality. Other passenger vessels, such as dining, sightseeing, or experience may be seasonal, unscheduled, and of minimal impact on urban air quality. Their light duty cycle minimizes their impact even without upgraded engine emission control Tier classification. A passenger vessel operation in much of the country that is dependent on weather, recreation, vacation periods, and discretionary spending is typically seasonal, often unscheduled, on demand service and of relatively small contribution to the impact on area air quality. Many of these vessels only have utilizations in the 100s of hours per year. Coastal overnight cruising vessels relocate depending on the season. They operate up and down the coasts of the 49 continental states often calling at smaller, underserved ports during temperate weather. Many relocate to Mexico, Central America, and the Caribbean during the winter and, as a result, are in direct competition with foreign vessels in the North American cruise trade. Overnight cruise vessels also operate on the nation?s major river systems and tend to be seasonal; often scheduling lay up or maintenance periods during the winter months. Other than ferries serving islands without roadway connection to the mainland, all passenger vessel service is, to an extent, in direct competition with landside endeavors. Restaurants, amusement parks, aquariums, sightseeing tours, parks, casinos, and even commuter transportation, and even activities provide an alternative outlet for discretionary spending and can be viewed as significant competition for the passenger vessel industry. Attached are the results of a survey of PVA members that was conducted by the PVA Regulatory Committee to define the demographics of our industry as relates to engine installation and operation. We learned that…
EPARulemakingEPA-HQ-OAR-2003-0190
Control of Emissions from New Locomotive Engines and New Marine Compression-ignition Engines less than 30-liters per Cylinder
RIN
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Last modified
Apr 16, 2024
Comment window
closed 6966d ago
Passenger Vessel Association filings
2
Activity
Passenger Vessel Association filed 2 comments on this docket between Aug 30, 2004 and Jul 5, 2007. 41 other organizations filed here. The comment window closed 6966d ago.
What Passenger Vessel Association filed (2)
Jul 5, 2007· Comment submitted by Jonathan Claughton, President, The Passenger Vessel Association (PVA)· EPA-HQ-OAR-2003-0190-0576
Aug 30, 2004· Comment referring to "We would be happy to familiarize policy makers and persons involved in this rulemaking with the breadth and the variety of passenger vessels potentially covered by the forthcoming rules," submitted by Peter Lauridsen, Regulatory Consultant, Passenger Vessel Association· EPA-HQ-OAR-2003-0190-0029
Filed on regulations.gov — full text not in the inline record.
Abstract
Contact: Alan Stout, USEPA,OTAQ, 2000 Traverwood Drive Ann Arbor, MI 48105 Telephone Number: (734) 214-4805. Fax Number (734) 214-4816 Email Address: stout.alan@epa.gov
View on regulations.gov →Co-filers (41)
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