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Comment 2548 for Proposed Amendments to Commercial Harbor Craft Regulation (chc2021) - 45 Day.

First Namemike
Last Namedoherty
Email Addressmesmd91@gmail.com
Affiliationmarine engine service inc
Subjecttier 4 engines in fishing vessels
Comment
Hello I want to make some points about tier 4 engines in fishing
vessels 
tier 4 engines produce excessive amounts of heat and can not be in
confined spaces there is the likelihood of a fire at sea this
happens to trucks quite often 

tier 4 engines are meant to run at high load factors to make the
emissions and aftertreatment equipment work properly fishing
vessels run at low speed and load factors when fishing or trolling
this will lead to 2 things fire at sea or engines going into a limp
mode when the emission control equipment malfunctions lets think
about this if bad weather comes up and you're coming home and the
engines go to limp mode then you have a boat load of people in
danger 
bottom line I have been in the engine business for 30 years these
engine are nothing but trouble in the on road equipment they will
be even more problematic in the marine industry these facts above
are based on industry experience I have attended some of these
online meetings I was curious if any of the carb staff has any
diesel engine background I have not seen any practical application
reviews of these engines in this type of vessel 
thank you for your time in considering my comments 
Mike Doherty Marine Engine Service Inc.             

Attachment
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Date and Time Comment Was Submitted 2021-11-09 15:43:40

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