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US Engine Manufacturers Assoc Submission

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US Engine Manufacturers Assoc Submission

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									                                    Two North LaSalle Street
                                    Suite 2200
                                    Chicago, Illinois 60602
                                    Tel: 312/827-8700
www.enginemanufacturers.org         Fax: 312/827-8737


                                                          July 11, 2003



       Ms. Kate Ringvall                         Via Email (mvecdiscussionpaper@dotars.gov.au)
       Policy Group
       Economic Research & Portfolio Policy
       Department of Transport and Regional Services
       GPO Box 594
       CANBERRA ACT 2601

       Re:    MVEC Vehicle Emission & Fuel Standards Review Discussion Paper

       Dear Ms. Ringvall:

               The Engine Manufacturers Association is a national trade association of worldwide
       manufacturers of engines. Among EMA’s members are the major manufacturers of heavy-duty
       diesel, Otto-cycle (gasoline), and alternative- fuel engines and vehicles. EMA is responding to
       the Motor Vehicle Environment Committee Standards Review Discussion Paper (“Discussion
       Paper”) issued May 16, 2003, assessing future vehicle emissions and fuel standards in Australia.
       In particular, we are focussing on the merits of adopting Euro 5 standards for heavy-duty
       vehicles and whether US standards should be maintained as alternative standards.

              As described in Section 4.1 of the Discussion Paper, Australian vehicle emissions
       standards have always been based on overseas standards. Although the current heavy vehicle
       standards in Australia rely principally on the UN ECE standards, alternative compliance with US
       EPA standards is allowed. This allowance is provided in recognition of the stringency of the US
       standards which provide at least comparable emissions performance and the adverse financial
       and emissions impacts that would arise from forcing US engines to comply with the ECE
       standards.

       Question Box 2, Question #4 and #5

              If Australia finds that further action is required with respect to heavy-duty standards,
       EMA supports the adoption of US standards functionally equivalent to Euro 5 standards (US
       EPA 2007 standards), as an alternative to Euro 5 for heavy-duty vehicles. The US standards are
       extremely stringent and will provide equivalent emissions performance and benefits while
       reducing compliance costs. The US standards have been recognized in the past and the rationale
       for continuing to offer the US standards as alternative standards continues to exist. Moreover,
       the benefits of offering the US 2007 standards as an alternative have not diminished.

              As described in Section 6.2.1 of the Discussion Paper, the US sourced heavy-duty
       engines supplied to the Australian market tend to not be supplied to European markets.
       Moreover, small numbers of many different engine models are supplied to the Australian market.


                                  EMA European Office, C.P. 65, CH -1231 Conches, Switzerland
                                          Telephone and Facsimile: +41 22 784 3349
Failure to allow US standards as an alternative to Euro 5 would result in significant additional
testing burden to demonstrate compliance with ECE requirements, creating higher compliance
and product costs and potential product supply disruptions to the Australian market.

        It is worth noting that recently Canada finalized emission standards which reference and
align with US EPA 2004 and 2007 standards, recognizing the inherent value in gaining the
benefits of the significant stringency of the standards without imposing additional compliance
costs on engine manufacturers. We understand that Australia has made the decision to align with
UN ECE standards. However, we urge Australia to continue their recognition of US EPA
standards as an acceptable alternative. With respect to the timing of the standards under
consideration, alternative standards of comparable stringency (US EPA 2007) should be
applicable at the same time as the primary standards under consideration (Euro 5), but not earlier
than 2007.

Question Box 3, Question 6

        EMA is a strong proponent of the desulphurization of all fuels in order to improve engine
emission control. Reductions in diesel fuel sulfur not only will enable the use of technology
necessary to reduce emissions from new engines, but they also will provide emission reduction
benefits to the existing engine fleet, an important benefit that improves overall air quality.

        The Euro 5 and US EPA 2007 standards for heavy-duty diesel vehicles are extremely
stringent and will require the use of advanced aftertreatment technologies. Ultra low sulfur
diesel fuel is a technical requirement for use of those aftertreatment systems. In fact, EPA has
adopted rules requiring the sulfur level of commercial diesel fuel in the United States to be
reduced to a maximum level of 15 ppm beginning in mid-2006. Moreover, Canada has finalized
15 ppm sulfur die sel fuel requirements, that align with the US standards.

        Fuel requirements were finalized by the United States and Canada in conjunction with the
stringent 2007 emission standards in recognition of the critical role of fuel sulfur in controlling
emissions, and in allowing the use of advanced aftertreatment technology. Compliance with the
Euro 5 and US EPA 2007 standards is dependant on a systems approach - advanced engine
design, advanced exhaust control technologies, and improved diesel fuel standards all are
needed.

       Euro 5 standards (and US EPA 2007 alternative standards) should be adopted only in
conjunction with a diesel fuel sulfur limit of 10 ppm (or no greater than 15 ppm).

Conclusions

        In summary, EMA encourages the continued recognition of US EPA standards as
alternative standards. Specifically, US EPA 2007 heavy-duty standards should be allowed as
alternative standards to the Euro 5 standards. However, it is vital that ultra-low sulfur fuel
standards are adopted in conjunction with the emission standards in order to enable compliance
with the standards. We appreciate the opportunity to comment and we look forward to
continuing our participation in this process. Please include EMA in future correspondence



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related to this issue. If you ha ve any questions about EMA’s comments, please do not hesitate to
contact me.

                                            Very truly yours


                                            Dawn E. Friest


EMADOCS:2100:4303.2




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