ANN ARBOR, Mich. — The Environmental Protection Agency wants to impose regulations on marine manufacturers that would reduce evaporative
hydrocarbon emissions by 80 percent by 2008. Members of the National Marine
Manufacturers Association voiced their concerns at the EPA's hearing
on evaporative emissions on Monday, Oct. 7, 2002.

The manufacturers are opposing elements of this proposed rule due to boater
safety concerns and increased production costs, record keeping, and
liability. While the EPA is proposing the pressurization of fuel tanks as a
way of achieving the reduction, the U.S. Coast Guard and the American
Boating and Yacht Council both disapprove of pressurizing fuel systems
because of the danger it poses to boaters.

"Our members are working diligently with the EPA to find ways to reduce
emissions because our industry depends on a clean environment," said John
McKnight, NMMA's director of environmental and safety compliance. "However
our first priority is safety. NMMA's members will not compromise the safety
of our boaters."

The hearing was held by the EPA to gain technical knowledge from fuel hose,
fuel tank and boat manufacturers on the effects of the proposed evaporative
emissions standards for the various companies involved in the boat
manufacturing process. EPA is suggesting various tests and technologies to
achieve the reduction, but these are not simple or inexpensive changes, NMMA
members pointed out.

"Our challenge is to accomplish these goals without sacrificing our
customers' safety or creating compliance requirements that effectively put
my company and other small boat builders out of business," said Tom Trabue,
president of Ebbtide Corporation, a 150-employee boat manufacturer located
in White Bluff, Tenn.

In order to pressurize fuel tanks, as recommended by EPA, new tank molds
would need to be designed. The cost of redesigning fuel tank molds or
incorporating other technologies into the manufacturing process could quite
possibly close small businesses. The marine industry is made up of small
companies, many of which employ less than 100 employees. According to Tony
Riviezzo, technical director of Moeller Marine Products, a manufacturer of
cross-linked polyethylene fuel tanks, it would take $10 million and over 14
years to completely phase out the old molds and create the new ones.

NMMA members also noted that the marine industry is very different from the
automotive industry saying that EPA's proposal seems to follow the
regulations imposed on automotive vehicles.

"A boat is not a car," said Rolf Lichtner, director of regulatory affairs
and product safety for Mercury Marine, a company of the Brunswick
Corporation. "Our safety rules require [boat fuel] hoses to pass a burn
test, something that the automotive hoses will not pass as is."

NMMA recommends a 3-point framework for achieving emissions reductions. The
compromise with the EPA proposal suggests that EPA approve fuel tanks that
meet permeation standards, EPA and NMMA conduct a five-year study on tank
and fuel line durability, and lastly that EPA drop diurnal emissions
regulations because the industry already exceeds the proposed limits, as
demonstrated by recent tests.