What the EPA’s Recent Emissions “Relief” Means for the Fire Service

A review of the recent regulatory statement and next steps for apparatus manufacturers and fire department customers

By Bob Graham
Published Wednesday, July 18, 2012

By now, departments taking delivery on new apparatus are used to their choice of engine being limited to those that meet strict emissions requirements from the Environmental Protection Agency (EPA). Such regulations began in 2007 and were refined in 2010.

In 2011, when 2007-compliant engines had been in service for a while and 2010-compliant engines began to be delivered to fire departments, the emissions issue heated up. Many departments reported having problems with the diesel particulate filters (DPF) that were installed on these apparatus to limit emissions, as well as the process by which such filters were cleaned (known as regen).

Now, it seems the uproar may have had some effect. In May, the EPA took the unusual step of issuing relief for fire apparatus and ambulances in regards to the emission issue. Granting relief does not mean exemption, but it did establish a time period to allow manufacturers to submit plans to amend the operational parameters of emergency vehicle emission systems.  

Building Steam
The EPA requires fire apparatus to use the same emission systems as over-the-road heavy trucks. But because fire apparatus aren’t used in the same way as their heavy-hauling counterparts, the emissions systems often don’t function as expected. As a result, departments across the country taking delivery on 2007- and 2010-compliant apparatus experienced issues related to the regeneration process—everything from vehicles refusing to go into regen to incomplete regen processes only detectable on a computer.

Read FireRescue/FirefighterNation’s exclusive report on regen issues in the fire service.

To add to the confusion, not all apparatus are affected the same. Some are simply taken out of service for short time for issues relating the emissions systems, while others spend far more time on the shop floor than the apparatus floor. Variables such as number of runs in a day, the duration of those runs and concerns about warranty issues all affect the mission-readiness of the apparatus in question when the regen system flashes its warning lights and demands attention.

When reports of out-of-service apparatus began hitting the public in 2010 and 2011, the issue of emissions control on fire and emergency apparatus became more urgent. The San Diego city council and Congressman Bob Filner got involved, petitioning the EPA for an exemption from the emissions standards for fire apparatus. The Southeastern Chapter of the IAFC also petitioned EPA with a particularly strong letter that stated that “Fire trucks across the country are breaking down at record rates because of this filter system that EPA forces them to use … going into ‘Regeneration’ at the scene of fires … thus leaving firefighters with no water to fight a fire until replacement units can arrive.”

The new ruling by the EPA is an indication that these efforts have had an effect, but the future of fire apparatus emissions is still unclear. I spoke with Cathy Milbourn, senior press officer for the EPA, to clarify some of the questions surrounding fire apparatus emissions systems and what will be happening when the EPA’s proposal comment period ends on July 27.

Not an Exemption
Milbourn explained that first and foremost, emergency vehicles and equipment are not being exempted from the EPA’s standards. That being said, the agency also believes it’s appropriate to ensure that fire apparatus can perform their life-saving missions without the risk of having their engines impaired when responding to an emergency. Milbourn added that the applicable standards for on-highway and non-road engines remain in place, and that the advanced emission control technology will remain on all vehicles.  

As far as emissions levels go, emergency vehicles contribute less than 1% of the annual air emissions from the heavy-duty diesel truck fleet, according to EPA statistics. Any change in that level due to this revised rule is expected to be small.

Although apparatus engines will still be produced in compliance with applicable standards, when an approved emergency vehicle auxiliary emission control device (AECD) or field modification is engaged during operation, emissions may temporarily increase. The new emission flexibilities are available only for manufacturers of engines for emergency vehicles and emergency equipment which, as defined, includes fire apparatus and ambulances.

No One Solution
In the EPA’s ruling, three types of systems were described as being solutions that were believed to be capable of solving a lot of problems with DPFs on apparatus:

  1. liberalized regeneration requests
  2. engine recalibration
  3. backpressure relief

In effect, these devices will allow fire apparatus to function as designed during emergency operation, eliminating the chance that emissions control could interfere with operation of the vehicle on emergency incident scenes. With those suggestions, the agency also hopes that the manufacturers will provide cost-effective solutions for their engines. The EPA’s examples were chosen not to restrict manufacturers to those types of solutions, but to ensure all issues related to the systems were addressed. Manufacturers were also able to submit applications for modifications to their engines and emissions systems based on their own research and design.  

Many departments have already implemented innovative methods for ensuring regen systems are not an issue during an emergency. Performing field regen procedures before the need arises is but one example, and it has cut out-of-service time drastically for the San Diego Fire-Rescue Department. Some manufacturers and dealers have been successful in addressing DPF problems on an individual basis prior to this rule change. Milbourn acknowledges that the need for solutions vary greatly by duty cycle, service area, engine or vehicle make and other factors.

What’s Next?
The EPA ruling is currently in a public comment period that ends July 27; if no adverse comments are received, the effective date of the direct final rule will be Aug. 7. After the ruling becomes final, manufacturers will be able to submit applications for modifications to their engines and emission control systems.

Although the gears can turn slowly when it comes to some government rule changes, Milbourn points out that a waiting period for testing and approval will not be required, and the EPA plans on conducting reviews and approvals expeditiously. She adds that the applications from manufacturers must contain sufficient information on which to base an approval. That information would generally include a detailed description of each device to be installed in or on any vehicle (or engine) covered by the application, as well as a detailed justification of each device that results in a reduction in effectiveness of the emission control system.

Milbourn added that manufacturers are free to submit requests to EPA with their solutions at any time. With the public comment period quickly coming to an end, what each manufacturer suggests and implements will soon be known. What is not known yet is the extent of the modifications, which could range from simple computer reprogramming to replacement of major assemblies and components, or the costs involved to carry out those modifications. It should be added that even if a modification is approved and available, the modification is voluntary for both the manufacturer and for the vehicle owner. If a manufacturer develops a modification, the owner is under no obligation to purchase it.

More to Come
Although the EPA’s action to grant the fire service some relief from the strict emissions requirements holds promise, there are clearly a lot of questions that remain to be answered. Will engine manufacturers invest in developing the devices needed to bypass the emissions control during emergency operations—and if so, how soon will such devices become available? Will those changes be a simple software program change, a redesign of operator controls, involve extensive mechanical modifications or be a combination of several changes? How will such devices affect the cost of fire apparatus engines, and if the design changes are extensive, will they involve frame or body modifications? Will most departments choose to continue operating existing apparatus with current emissions systems, outfit existing apparatus with the modifications as they become available or limit the purchase of engines with the newest emissions systems to newly delivered apparatus?

FireRescue/FirefighterNation will continue to monitor this developing situation and bring you the information you need to know as an operator and purchaser of emergency vehicles.

Comment Now: Post Your Thoughts & Comments on This Story

The Fort Worth Fire Department has experienced many issues with regen. Engine 2, pictured here, has been one of the most problematic recent deliveries. Photo Glen Ellman
On this 2010-compliant cab and chassis truck, the diesel particulate filter (DPF) sits inboard of the selective catalyst reduction (SCR) system. Note the high number of electronic sensors on both units. Photo Bob Graham
The 2007 and 2010 EPA-compliant engines require ultra-low-sulfur fuel. Use the wrong fuel and engine damage could be the end result. Photo Bob Graham


What the EPA’s Recent Emissions “Relief” Means for the Fire Service

A review of the recent regulatory statement and next steps for apparatus manufacturers and fire department customers Fort Worth Fire Department Engine 2
The Fort Worth Fire Department has experienced many issues with regen. Engine 2, pictured here, has been one of the most problematic recent deliveries. Photo Glen Ellman

2010 EPA-compliant engine
On this 2010-compliant cab and chassis truck, the diesel particulate filter (DPF) sits inboard of the selective catalyst reduction (SCR) system. Note the high number of electronic sensors on both units. Photo Bob Graham

Warning label on engine
The 2007 and 2010 EPA-compliant engines require ultra-low-sulfur fuel. Use the wrong fuel and engine damage could be the end result. Photo Bob Graham

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