U.S. Environmental Protection Agency

Sterndrive and Inboard Marine

SI Engine Technologies and Costs

Preliminary Report

July 2006

021348

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U.S. Environmental Protection Agency

Sterndrive and Inboard Marine

SI Engine Technologies and Costs

Final Report

July 2006

Prepared for

U.S Environmental Protection Agency

Office of Transportation and Air Quality

2000 Traverwood Drive

Ann Arbor, Michigan 48105

Prepared by:

Louis Browning and Seth Hartley

ICF International

394 Pacific

San Francisco, CA 94111

(415) 677-7100

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Table of Contents

  TOC \o "1-2" \h \z \t "Heading 3,3"    HYPERLINK \l "_Toc139853049"
1.	Introduction	  PAGEREF _Toc139853049 \h  1-1

  HYPERLINK \l "_Toc139853050"  2.	Background	  PAGEREF _Toc139853050 \h
 2-1

  HYPERLINK \l "_Toc139853051"  3.	Technology Description	  PAGEREF
_Toc139853051 \h  3-1

  HYPERLINK \l "_Toc139853052"  3.1.	Baseline Technologies	  PAGEREF
_Toc139853052 \h  3-1

  HYPERLINK \l "_Toc139853053"  3.2.	Advanced Technologies	  PAGEREF
_Toc139853053 \h  3-1

  HYPERLINK \l "_Toc139853054"  3.2.1.	Fuel System Technologies
PAGEREF _Toc139853054 \h  3-1

  HYPERLINK \l "_Toc139853055"  3.2.2.	Exhaust Gas Recirculation
PAGEREF _Toc139853055 \h  3-2

  HYPERLINK \l "_Toc139853056"  3.2.3.	Oxygen Sensors	  PAGEREF
_Toc139853056 \h  3-2

  HYPERLINK \l "_Toc139853057"  3.2.4.	Electronic Control Modules
PAGEREF _Toc139853057 \h  3-3

  HYPERLINK \l "_Toc139853058"  3.2.5.	Catalysts	  PAGEREF _Toc139853058
\h  3-3

  HYPERLINK \l "_Toc139853059"  4.	Cost Methodology	  PAGEREF
_Toc139853059 \h  4-1

  HYPERLINK \l "_Toc139853060"  4.1.	Hardware Costs	  PAGEREF
_Toc139853060 \h  4-1

  HYPERLINK \l "_Toc139853061"  4.2.	Fixed Costs	  PAGEREF _Toc139853061
\h  4-2

  HYPERLINK \l "_Toc139853062"  4.3.	Operating Costs	  PAGEREF
_Toc139853062 \h  4-3

  HYPERLINK \l "_Toc139853063"  5.	Results	  PAGEREF _Toc139853063 \h
5-1

List of Figures

  TOC \h \z \c "Figure"    HYPERLINK \l "_Toc139853080"  Figure 2-1.
Volvo Sterndrive Gasoline Aquamatic Engine	  PAGEREF _Toc139853080 \h
2-1

List of Tables

  TOC \h \z \c "Table"    HYPERLINK \l "_Toc139853066"  Table 2-1.
Sterndrive and Inboard Boat Sale Estimates (2000-2004) (NMMA)	  PAGEREF
_Toc139853066 \h  2-2

  HYPERLINK \l "_Toc139853067"  Table 3-1. Three Way Catalyst
Characteristics	  PAGEREF _Toc139853067 \h  3-4

  HYPERLINK \l "_Toc139853068"  Table 4-1.  Production Levels (units per
year)	  PAGEREF _Toc139853068 \h  4-2

  HYPERLINK \l "_Toc139853069"  Table 5-1. Water Cooled Marine Gasoline
Engine 3.0 liters In-line	  PAGEREF _Toc139853069 \h  5-3

  HYPERLINK \l "_Toc139853070"  Table 5-2. Water Cooled Marine Gasoline
Engine 4.3 liters V-6	  PAGEREF _Toc139853070 \h  5-4

  HYPERLINK \l "_Toc139853071"  Table 5-3. Water Cooled Marine Gasoline
Engine 5.7 liters V-8	  PAGEREF _Toc139853071 \h  5-5

  HYPERLINK \l "_Toc139853072"  Table 5-4. Water Cooled Marine Gasoline
Engine 8.1 liters V-8	  PAGEREF _Toc139853072 \h  5-6

  HYPERLINK \l "_Toc139853073"  Table 5-5. Three-way Marine Catalysts
Cost Estimates	  PAGEREF _Toc139853073 \h  5-7

  HYPERLINK \l "_Toc139853074"  Table 5-6. Engine Manufacturer Research,
Development and Prototype Costs	  PAGEREF _Toc139853074 \h  5-8

  HYPERLINK \l "_Toc139853075"  Table 5-7. Engine Manufacturer Tooling
Costs	  PAGEREF _Toc139853075 \h  5-8

  HYPERLINK \l "_Toc139853076"  Table 5-8. Marinizer Research,
Development and Testing Costs	  PAGEREF _Toc139853076 \h  5-9

  HYPERLINK \l "_Toc139853077"  Table 5-9. Marinizer Tooling Costs
PAGEREF _Toc139853077 \h  5-9

  HYPERLINK \l "_Toc139853078"  Table 5-10. Summary of Incremental
Technology Costs	  PAGEREF _Toc139853078 \h  5-10

  HYPERLINK \l "_Toc139853079"  Table 5-11.  Operating Cost Savings
PAGEREF _Toc139853079 \h  5-10

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Introduction

	Adopted in 1996, the United States Environmental Protection Agency’s
(USEPA) final rule on spark-ignited (SI) marine engines did not contain
emission limits for sterndrive-inboard SI engines.  USEPA is considering
new emission standards for sterndrive and inboard marine SI propulsion
engines similar to those recently passed by the California Air Resources
Board.

	Updated technology will be required to reduce emissions from
uncontrolled sterndrive and inboard marine SI engines to a level that
will meet new standards.  The purpose of this report is to provide
details on incremental technology and estimated costs for sterndrive and
inboard marine SI engines that could meet reduced emission standards.
ICF International developed technology packages for sterndrive marine SI
engines, which include electronically controlled fuel injection systems,
three-way catalysts, and exhaust gas recirculation.  These technology
packages are representative of what might be used on inboard marine SI
engines.  The cost estimates include fixed and variable costs and rely
on information obtained from information gathered from engine and
equipment manufacturers and experience in costing other SI engine
technologies.  Representative engine models of different sizes are used
to develop incremental technologies. Particular attention is given to
catalyst sizes, given the limited space between the engine exhaust port
and the point at which the exhaust system is cooled with water.  Early
drafts of the technology package descriptions and cost estimates were
submitted for review to industry contacts that provided initial
information.  Their comments were incorporated in the results presented
in this report.

	The following sections will discuss background information on
sterndrive and inboard marine SI engines (Section 2), describe baseline
and advanced technologies (Section 3), and present the cost estimate
methodologies (Section 4) and the results obtained (Section 5).

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Background

	The marine engine manufacturing process consists in most cases of two
phases: the first phase is performed by the engine block manufacturer
and the second by the marinizer.  Unlike marine diesel engines, it is
rare for the engine block manufacturer to provide a completed engine.
Engine block manufacturers are responsible for assembling the block,
cylinder head, and occasionally the intake manifold. The block
manufacturers also install fuel systems on a few of the engine models
produced.  This trend is projected to increase in the future.  Block
manufacturers also provide separately several of the parts that
marinizers will later add to the engine.

	 Marinizers transform the engine blocks they receive from the
manufacturers and add the features that permit optimal performance as
marine engines.  This process includes waterproofing, adding a fuel
system, a sterndrive or an inboard gear package, a marine exhaust
system, and a marine cooling system.  Marinizers may also be water craft
manufacturers and in that capacity install their completed engines in
boats.

	Sterndrive marine engines have unique cooling and exhaust systems as
shown in Figure 2-1. Inboard marine engines are similar to sterndrive
engines but have fewer design constraints.  The cost estimates for
sterndrive engines developed in this study can therefore be considered
worst-case scenarios for inboard marine engines.  Sterndrive marine SI
engines are essentially all gasoline powered.

Figure   STYLEREF 1 \s  2 -  SEQ Figure \* ARABIC \s 1  1 . Volvo
Sterndrive Gasoline Aquamatic Engine

Source: Volvo-Penta – Global at   HYPERLINK
"http://www.volvo.com/volvopenta/global/en-gb/marineengines/powerforleis
ureboats/gasoline_sterndrive/57sx/"
http://www.volvo.com/volvopenta/global/en-gb/marineengines/powerforleisu
reboats/gasoline_sterndrive/57sx/

	According to the National Marine Manufacturers Association’s (NMMA)
estimates, which can be found in Table 2-1, the sales of sterndrive and
inboard marine boats fluctuate slightly from year to year.  Sterndrive
and inboard boats account for about 18% and 5% respectively of the total
mechanically propelled recreational boat sales in the United States in
2004, and have shown a slight decreasing trend in market share over the
last several years.

Table   STYLEREF 1 \s  2 -  SEQ Table \* ARABIC \s 1  1 . Sterndrive and
Inboard Boat Sale Estimates (2000-2004) (NMMA)

Year	2000	2001	2002	2003	2004

Sterndrive Units Sold	78,400	72,000	69,300	69,200	71,100

Inboard Units Sold	23,900	21,900	22,300	19,200	20,200

	Current trends in the sterndrive and inboard marine industry include
the increased use of fuel injection over carburetion, especially among
larger engines (4.3 L and above). Engine production is estimated to be
mostly or completely fuel injected within the next five years.  In
addition, block manufacturers are starting to increase their production
of more complete engines, which would include intake manifold and fuel
system.  This change is motivated by the block manufacturers’ desire
to simplify the manufacturing process and by the potential financial
profit to be gained by selling to marinizers a more complete product at
a higher price.  This change shifts more of the emissions performance
responsibility on the engine manufactures where production volumes are
higher.

Technology Description

	The subsections to follow will describe baseline uncontrolled
sterndrive marine SI engines and the technologies likely to be
implemented to meet possible future emissions standards to meet reduced
HC+NOx and CO emissions.  This study focuses on four representative
sterndrive marine SI engines sizes: a 3.0 L in-line 4 cylinder engine, a
4.3 L V-6 engine, a 5.7 L V-8 engine, and an 8.1 L V-8 engine.  Other
engine models of similar sizes will have similar changes and costs.
Table 3-1 lists the advance advanced technology packages for all four
chosen engine sizes.

Baseline Technologies

	The baseline technologies on the four sterndrive marine SI engine
models consist of a mixture of carbureted and fuel injected systems that
are not calibrated for low emissions.  The smaller 4-cylinder engines’
production tend to have a higher percentage of carbureted models whereas
fuel injection is already becoming the most common fuel system for V-6
and V-8 engines.  V-6 engines and V-8 engines are typically port fuel
injected (PFI).  The industry has been moving towards incorporating more
fuel injected engines in their product lines, but still maintain their
carbureted models to provide a low-cost, entry-level marine engine for
their clients.

Advanced Technologies

	The advanced technology changes projected to comply with lower emission
standards consist of feedback-controlled fuel injection replacing all
the remaining carbureted and all the uncontrolled fuel-injected engines.
 It is envisioned that three-way catalysts will be added to most
engines; however, exhaust gas recirculation (EGR) might be used on some
engines to gain partial reductions in emissions.  The three-way
catalysts may be inserted into each exhaust manifold bank.  PFI provides
advantages in both controlling emissions and in performance because it
provides manufacturers with the ability to control the fuel-air ratio
for each individual cylinder.

	Technologies investigated in this report include fuel system
technologies, exhaust gas recirculation, oxygen sensors, electronic
control modules, and catalysts.

Fuel System Technologies

	A port fuel injection (PFI) system includes an injector per cylinder, a
fuel rail, a pressure regulator, an electronic control module (ECM),
manifold air pressure and temperature sensors, an oxygen sensor for each
exhaust bank, a high pressure fuel pump, a throttle assembly, a throttle
position sensor, and a magnetic crankshaft pickup for engine speed.  On
V-6 and V-8 engines, the fuel rails are connected into one assembly and
one pressure regulator is used.

	PFI systems also require a cool fuel system in order to prevent vapor
lock problems.  When a boat’s engine is turned off, its heat can turn
the fuel in the fuel line into vapor.  If an attempt is made to restart
the engine, no fuel is supplied to the engine as the fuel injector
cannot inject vapor and because of the positive vapor pressure in the
fuel line, the pump will not pump liquid fuel into the line.  Cooling
the fuel using a cool fuel system will keep it in liquid state and
eliminate the occurrence of vapor lock.

	In general, PFI systems provide better fuel distribution between
cylinders than carbureted fuel systems.  PFI allows for better fuel
control during transients than carbureted engines.  In addition,
feed-back controlled fuel injected systems can maintain stoichiometry
for better catalyst efficiency.

Exhaust Gas Recirculation

	The exhaust gas recirculation (EGR) valve permits a portion of the
exhaust gas to recirculate into the intake manifold.  This dilutes the
air/fuel mixture and lowers the combustion temperature, which in turn
reduces the formation of oxides of nitrogen (NOx).  EGR systems have
typically not been used in marine engines because they weren’t judged
necessary in the absence of emission standards.  Certain manufacturers
believed that EGR systems may cause higher exhaust temperatures,
although with a water cooled exhaust system this is unlikely to be a
safety problem.

	EGR systems are comprised of a short tube section between the intake
and exhaust manifold and a valve which is usually mounted on the intake
manifold.  Most EGR valves used today are electronically controlled for
more accurate control at all engine conditions.

Oxygen Sensors

	Oxygen sensors are added before the catalyst for closed-loop control
purposes. A sterndrive marine engine will require one sensor per exhaust
bank.  This practice will minimize the occurrence of maldistribution
between cylinders in V-6 and V-8 engines.  Oxygen sensors also help hold
the air/fuel mixture at stoichiometry for better combustion and catalyst
efficiency.

	Oxygen sensors are generally not used in uncontrolled systems.
Controlled systems will most probably use non-heated sensors, since
cold-starting emissions on these engines are not regulated.  While there
is some concern about oxygen sensor life in marine engines, placing the
oxygen sensor before the catalyst in the exhaust riser should prevent
water contact.  Initial durability tests at Southwest Research Institute
show reasonable oxygen sensor life using heated marine-grade oxygen
sensors.

Electronic Control Modules

	Electronic control modules (ECM) control fuel injection and ignition
timing in uncontrolled and controlled fuel injected systems.  Carbureted
systems may also use an ignition control module (ICM) which has limited
functions.

	Currently fuel injected systems’ ECMs are 32-bit systems.  Although
fuel injected systems’ ECMs will be required to perform more tasks to
meet emissions standards, the 32-bit processors are still adequate for
these additional requirements.  A large portion of ECM costs are related
to software development which is part of fixed costs.

Catalysts

	Three-way catalysts are an essential component of the emission
reduction systems of controlled engines.  The catalyst envisioned for
sterndrive marine engines will be a small “brick” (0.75 to 1.5 L)
which will be located inside the exhaust riser.   Southwest Research
Institute has tested both metal and ceramic catalysts in this position
in inboard engines and found that adequate emission reductions can be
realized with reasonable catalyst life.

	Table 3-2 summarizes the characteristics of three-way marine catalysts
costed in this analysis.  Platinum/Rhodium precious metal catalysts will
most likely be used.  Precious metal loading of around 1.0 grams per
liter of catalyst size is expected to be used.

	V-6 and V-8 engines will require two bricks, one in each exhaust bank.
According to catalyst manufacturers, a ceramic substrate will be
sufficiently strong to withstand the vibration and temperature
variations marine systems are subjected to. Advances over the past few
decades in the matting used to package the catalysts have led to very
durable ceramic catalysts.  To avoid underestimating costs, we
calculated costs for the ceramic substrate mounted in the exhaust riser
with a steel shell. In practice, the substrate can be mounted with or
without a shell.

Table   STYLEREF 1 \s  3 -  SEQ Table \* ARABIC \s 1  1 . Three Way
Catalyst Characteristics

Engine Size	3.0 L I-4	4.3 L V-6	5.7 L V-8	8.1 L V-8

Number of Catalysts	1	2	2	2

Catalyst Size	1.00 L	0.75 L	1.00 L	1.40 L

Total Volume	1.00 L	1.50 L	2.00 L	2.80 L

Substrate	Ceramic

400 cells per inch	Ceramic

400 cells per inch	Ceramic

400 cells per inch	Ceramic

400 cells per inch

Washcoat	75% cerium

25% alumina oxide	75% cerium

25% alumina oxide	75% cerium

25% alumina oxide	75% cerium

25% alumina oxide

Precious Metals	Pt/Rh   4/1

Loading 1.0 g/liter	Pt/Rh   4/1

Loading 1.0 g/liter	Pt/Rh   4/1

Loading 1.0 g/liter	Pt/Rh   4/1

Loading 1.0 g/liter

Cost Methodology

	In order to determine costs for technologies that manufacturers are
likely to employ to comply with potential future emission regulations,
representative models of the four engine sizes described earlier were
chosen among several manufacturers’ engine lines and cost information
was collected for each.  No single model’s costs were used to develop
the estimates presented in this report, but rather representative
averages of all costs collected were used for each technology.

	The technologies described in Section 3 have benefits that go beyond
emission control.  Assigning the full incremental cost of these
technologies as an impact of emissions standards may therefore
overestimate the true cost of emission control.  The costing described
herein only focuses on emissions-related improvements and not
performance-related ones. All costs are reported in 2005 dollars and
represent the incremental costs for engines to meet the proposed
emission standards.

Hardware Costs

	The main components of the hardware cost to the manufacturers are the
fuel system and the catalyst or exhaust gas recirculation.  Manufacturer
prices of components were estimated from various sources including
confidential information from engine manufacturers, marinizers, and
previous work performed by ICF International on spark-ignited engine
technology.  Discounted dealer and parts supplier prices were used to
verify the range of component prices, as were prices obtained directly
from marinizers.

	Catalyst component information was obtained directly from catalyst
manufacturers.  Although there are presently no three-way catalysts for
marine SI engines available on the market, a recent program at Southwest
Research Institute tested catalysts on inboard marine engines which
provided size and catalyst formulations used for this analysis.
Catalyst manufacturers verified our estimates on precious metal and
washcoat loadings as well as catalyst volumes and overall prices for the
units.   The prices of precious metal per troy oz. represent average
prices over the last three years. Washcoat and steel prices represent
current estimates. The labor cost is based upon a small scale production
of catalysts of a similar size of 15,000 units per year and an average
labor time of three quarters of an hour per unit, which includes the
time necessary to install the catalyst in the exhaust manifold.  To
minimize costs, marinizers with similar-sized engines will most likely
use a similar catalyst.  Labor rates used are estimated $17.50 per hour
plus a 60% fringe rate for a total labor cost of $28 per hour.

	All hardware costs to the engine manufacturer are subject to a 29%
mark-up which represents a typical mark-up of technologies on new engine
sales. This mark-up includes manufacturer overhead, manufacturer profit,
dealer overhead and dealer profit.  A separate supplier mark-up of 29%
is also applied to the catalyst. The 5% warranty markup is added to the
hardware cost to represent an overhead charge covering warranty claims
associated with new parts. This is a lower rate than what would be
typically used because of the long history of electronic fuel injection
systems in other applications.

Fixed Costs

	The fixed costs to the manufacturer include the cost of researching,
developing and testing a new technology.  It also includes the cost of
retooling the assembly line for the production of new parts.  Reflecting
the two stages in manufacturing a marine SI engine, the fixed costs are
listed separately for the engine block manufacturer and the marinizer.
Because advanced fuel system technology needed to reduce emissions is
already in part present in a considerable share of many current product
lines, research and development for this technology is not considered in
the fixed costs. Most of the fixed cost represents the research and
development needed to develop and test controlled engines with EGR,
oxygen sensors, and three-way catalysts.  Much of this development work
will be done by marinizers.

	The number of units per year and the number of years to recover are
used to determine the fixed cost per unit in 2005 dollars. Sales
production in units per year for the four engine sizes are shown in
Table 4-1. These numbers are estimates derived from confidential
information received from the certification database.  The numbers
reflect the variation in average production between large and small
businesses that share the market.

 Table   STYLEREF 1 \s  4 -  SEQ Table \* ARABIC \s 1  1 .  Production
Levels (units per year)

Engine Size	3.0 L I-4	4.3 L V-6	5.7 L V-8	8.1 L V-8

Manufacturer	15,000	15,000	15,000	15,000

Marinizer	2,000	2,000	2,000	1,000

	Fixed costs include research and development engineers, technicians,
mechanics and drivers with a 45% fringe and 40% overhead mark-up.  The
dynamometer test cost of $200 per hour includes the amortized capital
costs for the test cells over a 10 year period and allocated costs for
calibration gases and maintenance on the equipment.

	Five years represents a typical length of time used in the industry to
recover an investment in new technology.

Operating Costs

	Fuel injection systems typically reduce fuel consumption by about 10%
over carbureted versions due to better cylinder to cylinder fuel
distribution, better air/fuel mixing, and better control of transients.
Fuel cost savings for use of fuel injection over carburetion have been
analyzed using an average gasoline price of $1.92 per gallon.  A load
factor of 0.21 has been used along with an activity of 47.6 hours per
year and an average life of 19.7 years to calculate total fuel savings.
A discount rate of 3% per annum over the life of the engine was used to
calculate present values.

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Results

	Preliminary cost estimates for engines and catalysts were submitted for
review to the industry contacts that provided the initial cost
information.  Their comments were incorporated in the final version of
the cost estimates which are presented in the tables at the end of this
document.

	Tables 5-1 to 5-4 show a detailed development of cost estimates for
each of the technology packages for each engine.

	Electronic control unit costs include hardware and software costs.  The
hardware costs are shown under the hardware costs to the manufacturer in
Tables 5-1 through 5-4.  Software costs are included in the fixed costs
to the manufacturer and marinizer as the software is developed during
the design and development process and refined during the prototype
testing process.

	The catalysts prices presented in Table 5-5 are the prices per unit.
The total catalyst price depends on the number of units used for each
engine.  Prices per units vary between $89 and $127 and total prices
between $103 and $254.

	Tables 5-6 to 5-9 describe in detail the composition of the research
and development costs and the tooling costs for both engine
manufacturers (Table 5-6 and 5-7) and marinizers (Table 5-8 and 5-9).
The research and development costs for engine manufacturers (Table 5-6)
and marinizers (Table 5-8) consist of the engineering design costs, the
product development costs, and the prototype testing costs.  The design
and development costs are essentially engineer and technician hours.
The bulk of these hours are incurred by the engine manufacturer. This
may increase in the future as a result of new emission standards.
Prototype testing costs consist of performing stationary tests as well
as tests in water.

	The tooling costs for engine manufacturers are summarized in Table 5-7.
  Marinizers’ only tooling costs (Table 5-9) will consist of the costs
of updating their assembly line with new tools.

	The costs presented in Table 5-10 are the incremental cost of all the
possible combinations of baseline and controlled technology scenarios.
The results show that the most costly technology change is the upgrade
from a baseline of uncontrolled carbureted engines to controlled
fuel-injected systems with catalysts.  The cost for these changes range
between $925 and $1,366 per engine. Upgrading from a baseline of
uncontrolled to controlled fuel injected systems with catalysts costs
about $291 to $647.

	Operating cost savings for conversion from carburetor to fuel injection
are shown in Table 5-11.  Fuel consumption differences for using EGR or
three-way catalysts are negligible.

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  1 . Water Cooled
Marine Gasoline Engine 3.0 liters In-line

 	Uncontrolled Carburetor	Uncontrolled PFI	Controlled PFI w EGR
Controlled PFI w Catalyst

Hardware Cost to Manufacturer

     Carburetor	$140 	N/A	N/A	N/A

     Injectors (each) 	 	$17 	$17 	$17

          Number 	 	4	4	4

    Pressure Regulator	 	$15 	$15 	$15

    Fuel filter	$3 	$4 	$4 	$4

    Intake Manifold	$101 	$115 	$120 	$115

    Fuel Rail	 	$80 	$80 	$80

    Throttle Assembly (incl. position sensor)	 	$150 	$150 	$150

    Cool Fuel System	 	$120 	$120 	$120

     Fuel Pump	$21 	Included in Cool Fuel System

     Fuel Line	 	$16 	$16 	$16

    Oxygen Sensor (each)	 	 	$17 	$17

          Number 	 	 	1	1

    ECM	$30 	$100 	$100 	$100

    Air Intake Temperature Sensor	 	$5 	$5 	$5

    Manifold Air Pressure Sensor	 	$14 	$14 	$14

    Crank Position Sensor	 	$16 	$16 	$16

    Wiring/ Related Hardware	 	$80 	$80 	$80

Exhaust Gas Recirculation	 	 	$25

	Fuel System with EGR cost (if applicable)	$295 	$783 	$830 	$800

Catalyst	 	 	 	$74

Incremental exhaust manifold cost	 	 	$2 	$10

Total Hardware Cost	$295 	$783 	$832 	$884

Labor @ $28/hr	$1	$4	$5	$6

Labor Overhead @ 40%	$1	$2	$2	$2

Markup @ 29%	$86 	$229 	$243 	$259

Warranty Markup at 5%	 	 	$27	$29

Total  Component Cost	$383 	$1,018 	$1,109	$1,180

Fixed Cost to Engine Manufacturer

R&D Costs	          -   	           -   	$137,673 	$137,673

Tooling Costs	          -   	           -   	$30,000 	$30,000

Units/yr.	15,000	15,000	15,000	15,000

Years to recover	5	5 	5 	5

Fixed cost/unit	-   	-   	$5 	$3

Total Cost from Engine Manufacturer	$383 	$1,018 	$1,112 	$1,183

Fixed Cost to Marinizer

R&D Costs	-   	-   	$238,773	$238,773

Tooling Costs	-   	-   	$35,000 	$35,000

Units/yr.	2,000	2,000	2,000	2,000

Years to recover	5	5 	5 	5

Fixed cost/unit	-   	-   	$38 	$38

Total Cost from Marinizer	$383 	$1,018 	$1,150 	$1,221

Incremental Cost from Uncontrolled Carburetor	$635	$767	$838

Incremental Cost from Uncontrolled PFI

$132	$203

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  2 . Water Cooled
Marine Gasoline Engine 4.3 liters V-6

	Uncontrolled Carburetor	Uncontrolled PFI	Controlled PFI w EGR
Controlled PFI w Catalyst

Hardware Cost to Manufacturer

     Carburetor	$145 	N/A	N/A	N/A

     Injectors (each) 	 	$17	$17 	$17

          Number 	 	6	6	6

    Pressure Regulator	 	$15	$15 	$15

    Fuel filter	$3 	$4	$4 	$4

    Intake Manifold	$90 	$115	$120 	$115

    Fuel Rail Assembly	 	$110	$110 	$110

    Throttle Assembly (incl. position sensor)	 	$150	$150 	$150

    Cool Fuel System	 	$120	$120 	$120

     Fuel Pump	$35 	Included in  cool fuel system

     Fuel Lines	 	$35	$35 	$35

    Oxygen Sensor (each)	 	 	$17 	$17

          Number 	 	 	2	2

    ECM	$35 	$100	$100 	$100

    Air Intake Temperature Sensor	 	$5	$5 	$5

    Manifold Air Pressure Sensor	 	$14	$14 	$14

    Crank Position Sensor	 	$16	$16 	$16

    Wiring/ Related Hardware	 	$80	$80 	$80

Exhaust Gas Recirculation	 	 	$25

	Fuel System with EGR cost	$308 	$866	$930	$900

Catalyst ( 2 units)	 	 	 	$119

Incremental exhaust manifold cost	 	 	$5 	$20

Total Hardware Cost	$308 	$866	$935 	$1,039

Labor @ $28/hr	 $1	 $5	 $6	 $6

Labor Overhead @ 40%	 $1	 $2	 $2	 $3

Markup @ 29%	$90 	$253 	$273 	$304

Warranty Markup at 5%	 	 	$3 	$9

Total  Component Cost	$400 	$1,126 	$1,220 	$1,360

Fixed Cost to Engine Manufacturer

R&D Costs	-   	-   	$140,348 	$140,348

Tooling Costs	-   	-   	$35,000 	$35,000

Units/yr.	15,000	15,000	15,000	15,000

Years to recover	5	5 	5 	5

Fixed cost/unit	-   	-   	$3 	$3

Total Cost from Engine Manufacturer	$400 	$1,126 	$1,223 	$1,363

Fixed Cost to Marinizer

R&D Costs	-   	-   	$245,773 	$245,773

Tooling Costs	-   	-   	$45,000 	$45,000

Units/yr.	2,000	2,000	2,000	2,000

Years to recover	5	5 	5 	5

Fixed cost/unit	-   	-   	$40 	$40

Total Cost from Marinizer	$400 	$1,126 	$1,263 	$1,403

Incremental Cost from Uncontrolled Carburetor	$726	$863	$1,003

Incremental Cost from Uncontrolled PFI

$137	$277

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  3 . Water Cooled
Marine Gasoline Engine 5.7 liters V-8

	Uncontrolled Carburetor	Uncontrolled PFI	Controlled PFI w EGR
Controlled PFI w Catalyst

Hardware Cost to Manufacturer

     Carburetor	$145 	N/A	N/A	N/A

     Injectors (each)	 	$17 	$17 	$17

          Number 	 	8	8	8

    Pressure Regulator	 	$15 	$15 	$15

    Fuel filter	$3 	$4 	$4 	$4

    Intake Manifold	$95 	$125 	$135 	$125

    Fuel Rail Assembly	 	$115 	$115 	$115

    Throttle Assembly (incl. position sensor)	 	$150 	$150 	$150

    Cool Fuel System	 	$120 	$120 	$120

     Fuel Pump	$35 	Included in  cool fuel system

     Fuel Line	 	$35 	$35 	$35

    Oxygen Sensor (each)	 	 	$17 	$17

          Number 	 	 	2	2

    ECM	$35 	$100 	$100 	$100

    Air Intake Temperature Sensor	 	$5 	$5 	$5

    Manifold Air Pressure Sensor	 	$14 	$14 	$14

    Crank Position Sensor	 	$16 	$16 	$16

    Wiring/ Related Hardware	 	$80 	$80 	$80

Exhaust Gas Recirculation	 	 	$25

Fuel System with EGR cost	$313 	$915 	$984 	$949

Catalyst (2 units)	 	 	 	$148

Incremental exhaust manifold cost	 	 	$5 	$25

Total Hardware Cost	$313 	$915 	$989 	$1,122

Labor @ $28/hr	 $1	 $6	$6 	 $7

Labor Overhead @ 40%	 $1	 $2	 $3	 $3

Markup @ 29%	$91 	$268 	$289 	$328

Warranty Markup at 5%	 	 	$4 	$10

Total  Component Cost	$406 	$1,190	$1,291 	$1,470

Fixed Cost to Engine Manufacturer

R&D Costs	-   	-   	$142,798 	$142,798

Tooling Costs	-   	-   	$40,000 	$40,000

Units/yr.	15,000	15,000	15,000	15,000

Years to recover	5	5 	5 	5

Fixed cost/unit	-   	-   	$3 	$3

Total Cost from Engine Manufacturer	$406 	$1,190 	$1,294 	$1,474

Fixed Cost to Marinizer

R&D Costs	-   	-   	$254,273 	$254,273

Tooling Costs	-   	-   	$55,000 	$55,000

Units/yr.	2,000	2,000	2,000	2,000

Years to recover	5	5 	5 	5

Fixed cost/unit	-   	-   	$43 	$43

Total Cost from Marinizer	$406 	$1,190 	$1,337 	$1,516

Incremental Cost from Uncontrolled Carburetor	$784	$931	$1,110

Incremental Cost from Uncontrolled PFI

$147	$326

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  4 . Water Cooled
Marine Gasoline Engine 8.1 liters V-8

	Uncontrolled Carburetor	Uncontrolled PFI	Controlled PFI w EGR
Controlled PFI w Catalyst

Hardware Cost to Manufacturer

     Carburetor	$145 	N/A	N/A	N/A

     Injectors (each)	 	$20 	$20 	$20

          Number 	 	8	8	8

    Pressure Regulator	 	$15 	$15 	$15

    Fuel filter	$3 	$4 	$4 	$4

    Intake Manifold	$100 	$140 	$150 	$140

    Fuel Rail Assembly	 	$125 	$125 	$125

    Throttle Assembly (incl. position sensor)	 	$60 	$60 	$60

    Cool Fuel System	 	$120 	$120 	$120

     Fuel Pump	$35 	Included in  cool fuel system

     Fuel Line	 	$35 	$35 	$35

    Oxygen Sensor (each)	 	 	$17 	$17

          Number 	 	 	2	2

    ECM	$40 	$100 	$100 	$100

    Air Intake Temperature Sensor	 	$5 	$5 	$5

    Manifold Air Pressure Sensor	 	$14 	$14 	$14

    Crank Position Sensor	 	$16 	$16 	$16

    Wiring/ Related Hardware	 	$80 	$80 	$80

Exhaust Gas Recirculation	 	 	$25

	Fuel System with EGR cost	$323 	$874 	$943 	$908

Catalyst (2 units)	 	 	 	$195

Incremental exhaust manifold cost	 	 	$5 	$30

Total Hardware Cost	$323 	$829 	$948 	$1,133

Labor @ $28/hr	 $1	$6	 $6	$7

Labor Overhead @ 40%	 $1	$2	 $3	$3

Markup @ 29%	$94 	$256 	$277 	$331

Warranty Markup at 5%	 	 	$4	$13

Total  Component Cost	$419 	$1,138 	$1,238 	$1,487

Fixed Cost to Engine Manufacturer

R&D Costs	-   	-   	$147,848 	$147,848

Tooling Costs	-   	-   	$45,000 	$45,000

Units/yr.	15,000	15,000	15,000	15,000

Years to recover	5	5 	5 	5

Fixed cost/unit	-   	-   	$4 	$4

Total Cost from Engine Manufacturer	$419 	$1,138 	$1,242 	$1,491

Fixed Cost to Marinizer

R&D Costs	-   	-   	$262,773 	$262,773

Tooling Costs	-   	-   	$55,000 	$55,000

Units/yr.	1,000	1,000	1,000	1,000

Years to recover	5	5 	5 	5

Fixed cost/unit	-   	-   	$88 	$88

Total Cost from Marinizer	$419 	$1,138 	$1,329 	$1,579

Incremental Cost from Uncontrolled Carburetor	$718	$910	$1,159

Incremental Cost from Uncontrolled PFI

$192	$441

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  5 . Three-way
Marine Catalysts Cost Estimates

Table 5-5a.  Catalyst Parameters

Washcoat Loading	g/L	160

% ceria	by wt.	75

% alumina	by wt.	25

Precious Metal Loading	g/L	1.0

% Platinum	by wt.	80.0

% Palladium	by wt.	0.0

% Rhodium	by wt.	20.0

Labor Cost 	$/hr	$28.00

Table 5-5b.  Material Costs

Material	$/troy oz	$/lb	$/g	Density (g/cc)

Alumina	 	$64.00 	$0.141 	3.9

Ceria	 	$22.00 	$0.049 	7.132

Platinum	$811 	 	$26.08

Palladium	$210 	 	$6.76

Rhodium	$1,121 	 	$36.04

Stainless Steel	 	$0.85 	$0.003 	7.817

Table 5-5c.  Catalyst Unit Price

Engine Size (L)	3.0	4.3	5.7	8.1

Catalyst Volume (L) (each)	1.00	0.75	1.00	1.40

Number of Catalysts	1	2	2	2

Substrate Diameter (cm)	9.5	8.3	9.5	11.0

Substrate	$7.67	$6.50	$7.67	$9.53

Ceria/Alumina	$11.47	$8.60	$11.47	$16.06

Pt/Pd/Rd	$28.07	$21.06	$28.07	$39.30

Can (18 gauge 409 SS)	$3.49	$3.15	$3.49	$4.06

     Substrate Diameter (cm)	9.5	8.3	9.5	11.0

     Substrate Length (cm)	14.1	13.9	14.1	14.7

     Working Length (cm)	16.9	16.7	16.9	17.5

     Thick. Of Steel (cm)	0.121	0.121	0.121	0.121

     Shell Volume (cm3)	126	116	126	144

     Steel End Cap Volume (cm3)	19	15	19	25

     Vol. Of Steel (cm3)w/20% scrap	174	157	174	203

     Wt. Of Steel (g)	1361	1228	1361	1584

TOTAL MAT. COST	$50.70	$39.30	$50.70	$68.95

LABOR	$4.76 	$4.76 	$4.76 	$4.76

Labor Overhead @ 40%	$1.90 	$1.90 	$1.90 	$1.90

Supplier Markup @ 29%	$16.63 	$13.33 	$16.63 	$21.93

Manufacturer Price per unit	$73.99 	$59.30 	$73.99 	$97.54

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  6 . Engine
Manufacturer Research, Development and Prototype Costs

3.0 L In-Line 4 135 hp	4.3 L V-6 205 hp	5.7 L V-8 285 hp	8.1 L V-8 400
hp

Hours	Rates	Cost	Hours	Rates	Cost	Hours	Rates	Cost	Hours	Rates	Cost

Design	Engineer	600	$64.41 	$38,648	600	$64.41 	$38,648	600	$64.41
$38,648	600	$64.41 	$38,648

Development	Engineer	800	$64.41 	$51,531	800	$64.41 	$51,531	800	$64.41
$51,531	800	$64.41 	$51,531

	Technician	1000	$41.87 	$41,869	1000	$41.87 	$41,869	1000	$41.87
$41,869	1000	$41.87 	$41,869

Prototype 	Engine	 	 	$3,625	 	 	$5,800	 	 	$7,750	 	 	$12,300

	Shipping	 	 	$2,000	 	 	$2,500	 	 	$3,000	 	 	$3,500

Total Cost	$137,673	Total Cost	$140,348	Total Cost	$142,798	Total Cost
$147,848

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  7 . Engine
Manufacturer Tooling Costs

Engine Size	3.0 L	4.3 L	5.7 L	8.1 L

Fixture/Tools	$30,000	$35,000	$40,000	$45,000

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  8 . Marinizer
Research, Development and Testing Costs

3.0 L In-Line 4 135 hp	4.3 L V-6 205 hp	5.7 L V-8 285 hp	8.1 L V-8 400
hp

Hours	Rates	Cost	Hours	Rates	Cost	Hours	Rates	Cost	Hours	Rates	Cost

Design	Engineer	600	$64.41 	$38,648	600	$64.41 	$38,648	600	$64.41
$38,648	600	$64.41 	$38,648

Development 	Engineer	800	$64.41 	$51,531	800	$64.41 	$51,531	800
$64.41 	$51,531	800	$64.41 	$51,531

	Technician	800	$41.87 	$33,495	800	$41.87 	$33,495	800	$41.87 	$33,495
800	$41.87 	$33,495

Prototype Test	Boat	 	 	$10,000	 	 	$15,000	 	 	$20,000
$25,000

	Dyno	300	$250	$75,000	300	$250	$75,000	300	$250	$75,000	300	$250
$75,000

	Boat Testing Tech	200	$41.87 	$8,374	200	$41.87 	$8,374	200	$41.87
$8,374	200	$41.87 	$8,374

	Boat Testing Mech	200	$41.87 	$8,374	200	$41.87 	$8,374	200	$41.87
$8,374	200	$41.87 	$8,374

	Test Fuel ($5/gal)	300	3 gal/hr	$4,500	300	4 gal/hr	$6,000	300	6 gal/hr
$9,000	300	8 gal/hr	$12,000

	Shipping	 	 	$2,000	 	 	$2,500	 	 	$3,000	 	 	$3,500

	Driver	300	$22.84 	$6,851	300	$22.84 	$6,851	300	$22.84 	$6,851	300
$22.84 	$6,851

Total Cost	238,773	Total Cost	$245,773	Total Cost	$254,273	Total Cost
$262,773

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  9 . Marinizer
Tooling Costs

Engine Size	3.0 L	4.3 L	5.7 L	8.1 L

Pattern Work	$20,000	$25,000	$30,000	$30,000

Fixture/Tools	$15,000	$20,000	$25,000	$25,000

Total Cost	$220,000	$265,000	$310,000	$355,000

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  10 . Summary of
Incremental Technology Costs

Engine Size	Technologies	Controlled PFI with EGR	Controlled PFI with TWC

3.0 liter I- 4	Uncontrolled Carburetor	$767	$838

	Uncontrolled PFI	$132	$203

4.3 liter V-6	Uncontrolled Carburetor	$863	$1,003

	Uncontrolled PFI	$137	$277

5.7 liter V-8	Uncontrolled Carburetor	$931	$1,110

	Uncontrolled PFI	$147	$326

8.1 liter V-8	Uncontrolled Carburetor	$910	$1,159

	Uncontrolled PFI	$192	$441

Table   STYLEREF 1 \s  5 -  SEQ Table \* ARABIC \s 1  11 .  Operating
Cost Savings

Engine Size	3.0 L I-4	4.3 L V-6	5.7 L V-8	8.1 L V-8

Fuel System	Carb	FI	Carb	FI	Carb	FI	Carb	FI

Horsepower	135	135	205	205	285	285	400	400

BSFC (lbs/hp-hr)	0.658	0.567	0.658	0.567	0.658	0.567	0.658	0.567

Load Factor	0.21	0.21	0.21	0.21	0.21	0.21	0.21	0.21

Hours/year	47.6	47.6	47.6	47.6	47.6	47.6	47.6	47.6

Gallons per year	143.2	123.4	217.5	187.4	302.3	260.5	424.3	365.7

Cost per year	$275 	$237 	$418 	$360 	$581 	$500 	$815 	$702

Life, yrs	19.7	19.7	19.7	19.7	19.7	19.7	19.7	19.7

Total Cost	$4,046 	$3,486 	$6,144 	$5,294 	$8,541 	$7,360 	$11,987
$10,330

Cost Savings	 	$560 	 	$850 	 	$1,181 	 	$1,658

  Update of EPA’s Motor Vehicle Emission Control Equipment Retail
Price Equivalent (RPE) Calculation Formula,” Jack Faucett Associates,
Report No. JACKFAU-85-322-3, September 1985.

 National average retail gasoline prices for 2005 without taxes from the
Energy Information Administration.

 Load factor, activity and lifetime values are consistent with values
used in EPA’s NONROAD model.

Table of Contents

ICF International	  PAGE  ii 	EPA Contract No.  68-C-01-164/WA 4-7

021348		 July 2006

ICF International	  PAGE  i 	EPA Contract No.  68-C-01-164/WA 4-7

021348		July 2006

Introduction

ICF International	  PAGE  1-2 	EPA Contract No.  68-C-01-164/WA 4-7

021348		July 2006

ICF International	  PAGE  1-1 	EPA Contract No.  68-C-01-164/WA 4-7

021348		July 2006

Background

ICF International	  PAGE  2-2 	EPA Contract No.  68-C-01-164 / WA 4-7

021348		July 2006

ICF International	  PAGE  2-1 	EPA Contract No.  68-C-01-164 / WA 4-7

021348		 July 2006

Technology Description

Cost Methodology

Results

ICF International	  PAGE  5-9 	EPA Contract No.  68-C-01-164 / WA 4-7

021348		July 2006

Results

ICF International	  PAGE  5-8 	EPA Contract No.  68-C-01-164 / WA 4-7

021348		 July 2006

ICF International	  PAGE  5-11 	EPA Contract No.  68-C-01-164 / WA 4-7

021348		July 2006

ICF International	  PAGE  5-10 	EPA Contract No.  68-C-01-164 / WA 4-7

021348		 July 2006.


[Federal Register Volume 80, Number 108 (Friday, June 5, 2015)]
[Proposed Rules]
[Pages 32078-32081]
[FR Doc No: 2015-13804]

-----------------------------------------------------------------------

ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 52

[EPA-R03-OAR-2015-0274; FRL-9928-77-Region 3]

Approval and Promulgation of Air Quality Implementation Plans;
Virginia; Prevention of Significant Deterioration; Plantwide
Applicability Limits for Greenhouse Gases

AGENCY: Environmental Protection Agency.

ACTION: Proposed rule.

-----------------------------------------------------------------------

SUMMARY: The Environmental Protection Agency (EPA) is proposing to
approve aMay 12, 2014 State Implementation Plan (SIP) revision
submitted for the Commonwealth of Virginia by the Virginia Department
of Environmental Quality (VADEQ). This revision will add Plantwide
Applicability Limit (PAL) provisions for Greenhouse Gases (GHGs) to
Virginia's Prevention of Significant Deterioration (PSD) program. This
action is being taken under the Clean Air Act (CAA).

DATES: Written comments must be received on or before July 6, 2015.

ADDRESSES: Submit your comments, identified by Docket ID Number EPA-
R03-OAR-2015-0274 by one of the following methods:
    A. www.regulations.gov. Follow the on-line instructions for
submitting comments.
    B. Email<EMAIL_ADDRESS>    C. Mail: EPA-R03-OAR-2015-0274, David Campbell, Associate Director,
Office of Permits and Air Toxics, Mailcode 3AP10, U.S. Environmental
Protection Agency, Region III, 1650 Arch Street, Philadelphia,
Pennsylvania 19103.
    D. Hand Delivery: At the previously-listed EPA Region III address.
Such deliveries are only accepted during the Docket's normal hours of
operation, and special arrangements should be made for deliveries of
boxed information.
    Instructions: Direct your comments to Docket ID No. EPA-R03-OAR-
2015-0274. EPA's policy is that all comments received will be included
in the public docket without change, and may be made available online
at www.regulations.gov, including any personal information provided,
unless the comment includes information claimed to be Confidential
Business Information (CBI) or other information whose disclosure is
restricted by statute. Do not submit information that you consider to
be CBI, or otherwise protected, through www.regulations.gov or email.
The www.regulations.gov Web

site is an ``anonymous access'' system, which means EPA will not know
your identity or contact information unless you provide it in the body
of your comment. If you send an email comment directly to EPA without
going through www.regulations.gov, your email address will be
automatically captured and included as part of the comment that is
placed in the public docket and made available on the Internet. If you
submit an electronic comment, EPA recommends that you include your name
and other contact information in the body of your comment and with any
disk or CD-ROM you submit. If EPA cannot read your comment due to
technical difficulties and cannot contact you for clarification, EPA
may not be able to consider your comment. Electronic files should avoid
the use of special characters, any form of encryption, and be free of
any defects or viruses.
    Docket: All documents in the electronic docket are listed in the
www.regulations.gov index. Although listed in the index, some
information is not publicly available, i.e., CBI or other information
whose disclosure is restricted by statute. Certain other material, such
as copyrighted material, is not placed on the Internet and will be
publicly available only in hard copy form. Publicly available docket
materials are available either electronically in www.regulations.gov or
in hard copy during normal business hours at the Air Protection
Division, U.S. Environmental Protection Agency, Region III, 1650 Arch
Street, Philadelphia, Pennsylvania 19103. Copies of the Commonwealth's
submittal are available at the Virginia Department of Environmental
Quality, 629 E. Main Street, Richmond, Virginia, 23219.

FOR FURTHER INFORMATION CONTACT: David Talley,<PHONE_NUMBER>, or by
email at<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION: On May 12, 2014, VADEQ submitted a proposed
revision to the Virginia SIP.

I. Background

    The proposed SIP revision incorporates amendments to Chapter 85
under Article 9 of the Virginia Administrative Code (9VAC5). In a June
3, 2010 final rulemaking action, EPA promulgated regulations known as
``the Tailoring Rule,'' which phased in permitting requirements for GHG
emissions from stationary sources under the CAA PSD and title V
permitting programs. See 75 FR 31514. For Step 1 of the Tailoring Rule,
which began on January 2, 2011, PSD or title V requirements applied to
sources of GHG emissions only if the sources were subject to PSD or
title V ``anyway'' due to their emissions of non-GHG pollutants. These
sources are referred to as ``anyway sources.'' Step 2 of the Tailoring
Rule, which began on July 1, 2011, applied the PSD and title V
permitting requirements under the CAA to sources that were classified
as major, and, thus, required to obtain a permit, based solely on their
potential GHG emissions and to modifications of otherwise major sources
that required a PSD permit because they increased only GHGs above
applicable levels in the EPA regulations. Subsequently, on May 13,
2011, EPA took final action to approve a revision to Virginia's PSD
SIP, incorporating preconstruction permitting requirements for major
stationary sources and major modifications of GHGs, consistent with the
Federal PSD requirements at the time. See 76 FR 27898.
    In a June 12, 2012 final rulemaking action entitled ``Prevention of
Significant Deterioration and Title V Greenhouse Gas Tailoring Rule
Step 3 and GHG Plantwide Applicability Limits,'' \1\ (hereafter,
Tailoring Rule Step 3), EPA promulgated a number of streamlining
measures intended to improve the administration of GHG PSD permitting
programs. Included in that rulemaking were provisions to allow sources
to obtain GHG PALs on a carbon dioxide equivalent (CO2e) \2\
basis, rather than strictly on a mass basis. A PAL is an emissions
limitation for a single pollutant expressed in tons per year (tpy) that
is enforceable as a practical matter and is established source-wide in
accordance with specific criteria. See 40 CFR 52.21(aa)(2)(v). PALs
offer an alternative method for determining major New Source Review
(NSR) applicability: If a source can maintain its overall emissions of
the PAL pollutant below the PAL level, the source can make a change
without triggering PSD review. Virginia's May 12, 2014 submittal
incorporates PAL provisions into Virginia's PSD program, consistent
with EPA's Tailoring Rule Step 3.
---------------------------------------------------------------------------

    \1\ See 77 FR 41051.
    \2\ CO2e is defined as the mass of the specific GHG
(in tons), multiplied by its Global Warming Potential, as codified
in 40 CFR part 98.
---------------------------------------------------------------------------

    On June 23, 2014, the United States Supreme Court, in Utility Air
Regulatory Group v. Environmental Protection Agency,\3\ issued a
decision addressing the Tailoring Rule and the application of PSD
permitting requirements to GHG emissions. The Supreme Court said that
the EPA may not treat GHGs as an air pollutant for purposes of
determining whether a source is a major source required to obtain a PSD
permit. The Court also said that the EPA could continue to require that
PSD permits, otherwise required based on emissions of pollutants other
than GHGs, contain limitations on GHG emissions based on the
application of Best Available Control Technology (BACT). The Supreme
Court decision effectively upheld PSD permitting requirements for GHG
emissions under Step 1 of the Tailoring Rule for ``anyway sources'' and
invalidated PSD permitting requirements for Step 2 sources.
---------------------------------------------------------------------------

    \3\ See 134 S.Ct. 2427.
---------------------------------------------------------------------------

    In accordance with the Supreme Court decision, on April 10, 2015,
the U.S. Court of Appeals for the District of Columbia Circuit (D.C.
Circuit) issued an amended judgment vacating the regulations that
implemented Step 2 of the Tailoring Rule, but not the regulations that
implement Step 1 of the Tailoring Rule.\4\ The amended judgment
preserves, without the need for additional rulemaking by the EPA, the
application of the BACT requirement to GHG emissions from sources that
are required to obtain a PSD permit based on emissions of pollutants
other than GHGs (i.e., the ``anyway'' sources). The D.C. Circuit's
judgment vacated the regulations at issue in the litigation, including
40 CFR 51.166(b)(48)(v), ``to the extent they require a stationary
source to obtain a PSD permit if greenhouse gases are the only
pollutant (i) that the source emits or has the potential to emit above
the applicable major source thresholds, or (ii) for which there is a
significant emissions increase from a modification.'' \5\
---------------------------------------------------------------------------

    \4\ Coalition for Responsible Regulation v. EPA, D.C. Cir., No.
09-1322, 06/26/20, judgment entered for No. 09-1322 on 04/10/2015.
    \5\ Id.
---------------------------------------------------------------------------

    EPA may need to take additional steps to revise federal PSD rules
in light of the Supreme Court decision and recent D.C. Circuit
judgment. In addition, EPA anticipates that many states will revise
their existing SIP-approved PSD programs. EPA is not expecting states
to have revised their existing PSD program regulations at this
juncture. However, EPA is evaluating PSD program submissions to assure
that the state's program correctly addresses GHGs consistent with both
decisions.
    Virginia's currently approved PSD SIP continues to require that PSD
permits (otherwise required based on emissions of pollutants other than
GHGs) contain limitations on GHG emissions based on the application of
BACT when sources emit or increase GHGs in the amount of

75,000 tpy, measured as CO2e. Although Virginia's SIP may
also currently contain provisions that are no longer necessary in light
of the D.C. Circuit's judgment or the Supreme Court decision, this does
not prevent the EPA from approving the submission addressed in this
rule. Virginia's May 12, 2014 SIP submission does not add any GHG
permitting requirements that are inconsistent with either decision.
    Likewise, the GHG PAL provisions included in Virginia's May 12,
2014 submittal include some provisions that may no longer be
appropriate in light of both the D.C. Circuit judgment and the Supreme
Court decision. Since the Supreme Court has determined that sources and
modifications may not be defined as ``major'' solely on the basis of
the level of GHGs emitted or increased, PALs for GHGs may no longer
have value in some situations where a source might have triggered PSD
based on GHG emissions alone. However, PALs for GHGs may still have a
role to play in determining whether a modification that triggers PSD
for a pollutant other than GHGs should also be subject to BACT for
GHGs. These provisions, like the other GHG provisions discussed
previously, may be revised at some future time. However, these
provisions do not add new requirements for sources or modifications
that only emit or increase GHGs above the major source threshold or the
75,000 tpy GHG level in Sec.  52.21(b)(49)(iv). Rather, the PAL
provisions provide increased flexibility to sources that wish to
address their GHG emissions in a PAL. Since this flexibility may still
be valuable to sources in at least one context described above, EPA
believes that it is appropriate to approve these provisions into the
Virginia SIP at this juncture.

II. Summary of SIP Revision

    The proposed revision includes amendments to 9VAC5-85: ``Permits
for Stationary Sources of Pollutants Subject to Regulation.''
Specifically, 9VAC5-85-40: ``Prevention of Significant Deterioration
Area Permit Actions,'' and 9VAC5-85-50: ``Definitions'' are being
amended. Additionally, 9VAC5-85-55: ``Actual plantwide applicability
limits,'' is being added to the SIP. The proposed amendments are
consistent with the GHG PAL provisions of 40 CFR 52.21 as promulgated
by EPA on July 12, 2012. See 77 FR 41072-41075.

III. Proposed Action

    EPA's review of this material indicates the proposed SIP revision
is consistent with the CAA and the Federal PSD regulations at 40 CFR
52.21. EPA is proposing to approve Virginia's May 12, 2014 submittal as
a revision to the Virginia SIP, in accordance with CAA section 110. EPA
is soliciting public comments on the issues discussed in this document.
These comments will be considered before taking final action.

IV. Incorporation by Reference

    In this proposed rulemaking action, EPA is proposing to include in
a final EPA rule, regulatory text that includes incorporation by
reference. In accordance with requirements of 1 CFR 51.5, the EPA is
proposing to incorporate by reference Virginia's GHG PAL regulations,
as discussed in section II of this preamble. The EPA has made, and will
continue to make, these documents generally available electronically
through www.regulations.gov and/or in hard copy at the appropriate EPA
office (see the ADDRESSES section of this preamble for more
information).

V. General Information Pertaining to SIP Submittals From the
Commonwealth of Virginia

    In 1995, Virginia adopted legislation that provides, subject to
certain conditions, for an environmental assessment (audit)
``privilege'' for voluntary compliance evaluations performed by a
regulated entity. The legislation further addresses the relative burden
of proof for parties either asserting the privilege or seeking
disclosure of documents for which the privilege is claimed. Virginia's
legislation also provides, subject to certain conditions, for a penalty
waiver for violations of environmental laws when a regulated entity
discovers such violations pursuant to a voluntary compliance evaluation
and voluntarily discloses such violations to the Commonwealth and takes
prompt and appropriate measures to remedy the violations. Virginia's
Voluntary Environmental Assessment Privilege Law, Va. Code Sec. 10.1
1198, provides a privilege that protects from disclosure documents and
information about the content of those documents that are the product
of a voluntary environmental assessment. The Privilege Law does not
extend to documents or information that: (1) Are generated or developed
before the commencement of a voluntary environmental assessment; (2)
are prepared independently of the assessment process; (3) demonstrate a
clear, imminent and substantial danger to the public health or
environment; or (4) are required by law.
    On January 12, 1998, the Commonwealth of Virginia Office of the
Attorney General provided a legal opinion that states that the
Privilege law, Va. Code Sec. 10.1 1198, precludes granting a privilege
to documents and information ``required by law,'' including documents
and information ``required by Federal law to maintain program
delegation, authorization or approval,'' since Virginia must ``enforce
Federally authorized environmental programs in a manner that is no less
stringent than their Federal counterparts. . . .'' The opinion
concludes that ``[r]egarding Sec.  10.1-1198, therefore, documents or
other information needed for civil or criminal enforcement under one of
these programs could not be privileged because such documents and
information are essential to pursuing enforcement in a manner required
by Federal law to maintain program delegation, authorization or
approval.''
    Virginia's Immunity law, Va. Code Sec. 10.1 1199, provides that
``[t]o the extent consistent with requirements imposed by Federal
law,'' any person making a voluntary disclosure of information to a
state agency regarding a violation of an environmental statute,
regulation, permit, or administrative order is granted immunity from
administrative or civil penalty. The Attorney General's January 12,
1998 opinion states that the quoted language renders this statute
inapplicable to enforcement of any Federally authorized programs, since
``no immunity could be afforded from administrative, civil, or criminal
penalties because granting such immunity would not be consistent with
Federal law, which is one of the criteria for immunity.''
    Therefore, EPA has determined that Virginia's Privilege and
Immunity statutes will not preclude the Commonwealth from enforcing its
PSD program consistent with the Federal requirements. In any event,
because EPA has also determined that a state audit privilege and
immunity law can affect only state enforcement and cannot have any
impact on Federal enforcement authorities, EPA may at any time invoke
its authority under the CAA, including, for example, sections 113, 167,
205, 211 or 213, to enforce the requirements or prohibitions of the
state plan, independently of any state enforcement effort. In addition,
citizen enforcement under section 304 of the CAA is likewise unaffected
by this, or any, state audit privilege or immunity law.

VI. Statutory and Executive Order Reviews

    Under the CAA, the Administrator is required to approve a SIP
submission

that complies with the provisions of the CAA and applicable Federal
regulations. 42 U.S.C. 7410(k); 40 CFR 52.02(a). Thus, in reviewing SIP
submissions, EPA's role is to approve state choices, provided that they
meet the criteria of the CAA. Accordingly, this action merely approves
state law as meeting Federal requirements and does not impose
additional requirements beyond those imposed by state law. For that
reason, this proposed action:
     Is not a ``significant regulatory action'' subject to
review by the Office of Management and Budget under Executive Order
12866 (58 FR 51735, October 4, 1993);
     Does not impose an information collection burden under the
provisions of the Paperwork Reduction Act (44 U.S.C. 3501 et seq.);
     Is certified as not having a significant economic impact
on a substantial number of small entities under the Regulatory
Flexibility Act (5 U.S.C. 601 et seq.);
     Does not contain any unfunded mandate or significantly or
uniquely affect small governments, as described in the Unfunded
Mandates Reform Act of 1995 (Pub. L. 104-4);
     Does not have Federalism implications as specified in
Executive Order 13132 (64 FR 43255, August 10, 1999);
     Is not an economically significant regulatory action based
on health or safety risks subject to Executive Order 13045 (62 FR
19885, April 23, 1997);
     Is not a significant regulatory action subject to
Executive Order 13211 (66 FR 28355, May 22, 2001);
     Is not subject to requirements of Section 12(d) of the
National Technology Transfer and Advancement Act of 1995 (15 U.S.C. 272
note) because application of those requirements would be inconsistent
with the CAA; and
     Does not provide EPA with the discretionary authority to
address, as appropriate, disproportionate human health or environmental
effects, using practicable and legally permissible methods, under
Executive Order 12898 (59 FR 7629, February 16, 1994).
    In addition, this proposed rule, relating to Virginia's PSD
program, does not have tribal implications as specified by Executive
Order 13175 (65 FR 67249, November 9, 2000), because the SIP is not
approved to apply in Indian country located in the state, and EPA notes
that it will not impose substantial direct costs on tribal governments
or preempt tribal law.

List of Subjects in 40 CFR Part 52

    Environmental protection, Air pollution control, Carbon monoxide,
Incorporation by reference, Intergovernmental relations, Lead, Nitrogen
dioxide, Ozone, Particulate matter, Reporting and recordkeeping
requirements, Sulfur oxides, Volatile organic compounds.

    Authority: 42 U.S.C. 7401 et seq.

    Dated: May 26, 2015.
William C. Early,
Acting Regional Administrator, Region III.
[FR Doc. 2015-13804 Filed 6-4-15; 8:45 am]
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