B.
Issues to be Aware Of
The EPA regulations leave several key terms and concepts undefined. EPA has provided
verbal guidance on their recommended interpretations for several terms discussed below.
Issues of concern may include definitions for the following terms or phrases:
Federal Installation - EPA interprets this term to refer to government - owned facilities only.
The Coast Guard supports this interpretation. Several states have indicated that they may also
consider including leased spaces.
Operating on a Federal Installation - Questions have arisen as to whether or not parking on
the installation is included in the term "operating". Vehicles which are driven onto Coast
Guard- owned land more than 60 days per year (including to parking lots) shall be considered
as operating on that unit.
Enclosure (3) to COMDTINST 4454.1
Employee - I/M requirements apply to employees operating vehicles on Coast Guard
property. This includes vehicles operated by military, civilians, vendors and contractors. All
must be in compliance with I/M requirements if they operate vehicles on base 60 or more
calendar days per year.
C.
Alternative Fuel Vehicles
Most of the Coast Guard's vehicle fleet is leased from GSA. Steps toward compliance will be
taken by updating government fleets with alternative fuels such as methanol 85, compressed
natural gas, or electricity which generally emit lower levels (if any) of ozone and carbon
monoxide. The CAA along with the Energy Policy Act and Executive Order 12844 have
specific requirements for fleet purchases of alternative fuel vehicles. Retrofitting current gas-
powered vehicles to accommodate alternative fuels is also being considered. States may
choose to exempt alternatively fueled vehicles from I/M testing.
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