Emergency Vehicles and the EPA

By Wesley D. Chestnut
Lead, Compliance
Spartan Motors, Inc.

On June 8, 2012, the United States Environmental Protection Agency (EPA) announced the granting of relief for fire trucks and ambulances. This relief came through two methods of rule making: a direct final rule (DFR) and a notice of proposed rulemaking (NPRM). The announcement of this relief has generated misconceptions and questions for many individuals involved in the emergency vehicle community.

As of August 27, 2012, the DFR is final and is in effect as it was originally written. Meanwhile, the Chassis Technical Committee of the Fire Apparatus Manufacturers’ Association (FAMA) is working to gather information to aid emergency vehicle owners and operators to understand if certain vehicles will qualify for the relief.

Emissions Control Changes

The biggest misconception with both the DFR and NPRM is that emergency vehicles will now be exempt from having to meet current emissions standards. This may be a result of a regulatory announcement that carried a misleading title. Contrary to the general perception, 2007 and 2010 emissions components such as diesel particulate filters (DPFs) and selective catalytic reduction (SCR) components cannot be removed. Although the EPA is committed to allowing engine manufacturers some flexibility, emergency vehicles are still required to meet the emissions standards in place at the time the engine was produced.

What the new rules do allow for is for engine manufacturers to apply for the use of auxiliary emissions control devices (AECDs) that could be applied to an engine in an emergency vehicle. In most cases, and AECD is a modification to the engine control computer program that may allow the engine to operate outside the normal emission limits under very specific circumstances. The caveat is that the AECDs will only be allowed when the vehicle is responding to an emergency situation. The EPA wants to minimize any situations where the emissions control system on an emergency vehicle would adversely affect the performance of its mission.

Examples of engine control modifications that the EPA may approve include allowing manual regenerations more often, allowing the engine to produce more NOx but less soot during idling, bypassing emissions devices that are clogged, and eliminating driver inducements that would limit vehicle speed or engine torque. Any engine equipped with these or other AECDs must be labeled as being approved for emergency vehicle use only.

Diesel Exhaust Fluid Tank

From an emissions-related maintenance perspective, the NPRM will change the regulations to require that the diesel exhaust fluid tank contain enough solution to last for two fills of the diesel tank. This change will be phased in to allow manufacturers time to retool.

Nonroad Machine Flexibility

The NPRM also includes short-term relief for general-purpose nonroad vehicles while operating in temporary emergency service (e.g., a generator providing power to a medical facility or bulldozer repairing a levee). To date, the EPA has not responded to comments that were submitted during the NPRM period. On behalf of FAMA, both Roger Lackore and I commented on the proposed definition for emergency vehicles. In a recent conversation with the EPA, it indicated it is still reviewing comments; timing for response had not yet been determined.

To obtain factual information, FAMA’s Chassis Technical Committee has developed a document that can be used to gather information useful for determining if an application for an AECD is warranted. Certain information has been gathered thus far and is currently being analyzed. When a user of an emergency vehicle experiences an abnormal condition related to emission controls when responding to an emergency situation, departments are strongly encouraged to contact their dealer, selling agent, or a Chassis Technical Committee member.

As rules involving emergency vehicles continue to unfold, I will remain involved and provide updates as they become available. All of you should be reminded there is a process for rule makings that occur at a federal level which allows for public comment. I strongly encourage you to submit comments when rules involving emergency vehicles are proposed. If there are questions or concerns that anyone may have, please work through FAMA to have your concerns addressed.

Lastly, I feel it’s important to reiterate emergency vehicles are not exempt from meeting emissions standards set forth by the EPA. DPFs and SCR appear to be here to stay. However, the EPA is taking notice of the various duty cycles of emergency vehicles and is working to offer some level of relief to mitigate issues that may be attributed to abnormal conditions associated with an emissions control system. As future rules evolve, it is very important to engage the EPA in the rule-making process.

WESLEY D. CHESTNUT has been involved with the fire service since 1991. He has served as an assistant chief in a rural North Carolina fire department and joined Spartan Motors, Inc. in 1999. He was quality engineer for the Emergency Rescue Chassis Division for two years. He has been the compliance lead at Spartan for five years. As compliance lead, he interacts with federal agencies such as the National Highway Traffic Safety Administration (NHTSA) and the Environmental Protection Agency (EPA). He is also a member of the Technical Committee for National Fire Protection (NFPA) 1917, Standard for Automotive Ambulances.

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