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I'm a 20 year employee for Cummins Sales and Service North America.
I have worked on several projects and prototype engine systems
designed to reduce emissions. Cummins emission reduction technology
has revolutionized the diesel engine industry. For a time the only
diesel engine approved for sale in the state of California was a
Cummins engine. Cummins has made a huge capital investment in clean
diesel technology and we continue to develop this technology today.
Cummins development of the high pressure common rail fuel system
revolutionized the diesel engine. Not only did it reduce emissions.
It increased fuel efficiency. This technology did not come without
a price. Hundreds of millions of dollars have be spent perfecting
this technology. This has not detoured Cummins from continued
development of ways to reduce emissions. 
  The point with all this Cummins has made a commitment to develop
not only on highway but marine propulsion systems that will benefit
our environment and enrich the lives of mankind. We have just begun
development on a hybrid marine propulsion system which will help
address CARB's concerns. Please withhold the application of the
proposed standards until the needed technology is perfected and
developed for the marine application. Unlike on highway a marine
vessels donot lend to themselves to easily adapt the current
technology. Dry stacks is the only way to apply a dpf and urea
injection exhaust systems. Wet exhaust will creat too much back
pressure for a dpf to be adapted to a wet stacked marine engine.
Unfortunately to adapt the current technology would require
extensive engineering and because of this it would not be
economically viable to adapt this technology to most vessels.  Here
at Cummins we again have made a huge capital investment to address
the needs of the marine industry with regards to reducing
emissions. We intend to be the first that has a viable marine
exhaust after treatment system that can be adapted to current
marine applications. Again I ask on behalf of all the principles
that will be affected to withhold the implementation of your
standards until current technology has been perfected for the
marine industry.