In Parts 1 and 2 of this report, we documented how 2007 and 2010-compliant engines work and some of the problems fire departments have had in integrating them into their fleets. With even more EPA regulations due in 2013, it’s important to look at the long-range implications of cleaner emissions in the fire service.
As the diesel particulate filter (DPF) issue heats up, one suggested approach has been for the fire service to lobby the EPA for an exemption to the emissions rules, similar to the exemption given to the military.
In fact, this is nothing new. “FAMA [the Fire Apparatus Manufacturers’ Association] has been working to get the fire service vocation exempted ever since the diesel emissions appeared in 2003,” says Tim Johnson, Southern Regional Sales Manager for Rosenbauer and vice chair of the chassis committee for the FAMA. “
The FAMA Technical Committee, in comments prepared for this article, expanded on its involvement with the EPA (emphasis added): “In 2006, FAMA again approached the EPA with concerns regarding the proposed 2007 emission regulation changes. Several requests were presented to the EPA, including the idea of requesting a complete exemption from the new regulations. Two factors made exemption a non-starter. First, the EPA had made it clear that they did not have authority to exempt any vehicle from the regulations. Their mandate came from Congress, and only an act of Congress could change this. Secondly, the engine manufacturers pointed out that given the low volume of fire apparatus, they would not be able to justify continuing to manufacture old model engines in the unique configuration required by fire apparatus. In the end, the EPA consented to continue to allow the EGR [exhaust gas recirculation] relief that they agreed to in 2004, but a complete exemption was both unavailable and impractical.”
This process has led Johnson to conclude: “The EPA has shown no interest in granting an exemption at this time. The fire service will need to work through their congressional representatives to champion the exemption within our government.”
In San Diego, city council representatives are doing just that. While visiting local fire stations, San Diego City Council member Marti Emerald, who chairs San Diego’s Public Safety and Neighborhood Services Committee, heard from firefighters about San Diego’s apparatus going out of service due to regen issues. Emerald held a fact-finding meeting to get information on how the systems are affecting the safety of San Diego residents. She also began efforts to exempt fire apparatus from the emission requirements, enlisting the help of Congressman Bob Filner in filing a petition with the EPA for exemption.
“While I am fully supportive of the EPA’s goal of reducing the level of air pollution, these regeneration systems are most effective on trucks driven long distances at highway speeds,” Filner says. “This is not the case with firefighting vehicles; emergency crews drive short trips in which the carbon deposits do not burn off, and as a result the fire equipment often has to be taken off-line, at times putting lives and property in danger. While we must be responsible stewards of the environment, we have a duty to protect public safety.”
The Southeastern Association of Fire Chiefs, the largest division of the IAFC, also recently petitioned the EPA. In an Oct. 14 letter to EPA Administrator Lisa Jackson (available on the group’s website, the association noted, “Fire trucks across the country are breaking down at record rates because of this filter system that EPA forces them to use. Fire apparatus are going into ‘Regeneration’ at the scene of fires to begin the burn off process causing units to shut down, thus leaving firefighters with no water to fight a fire until replacement units can arrive. The impact of these break downs are extremely costly and are rendering primary emergency response units out of service until they can be reprogrammed and returned to service.”
Capt. Homer Robertson, who manages the Fort Worth Fire Department’s apparatus fleet and is a FireRescue/FirefighterNation.com editorial board member, believes the fire service should be exempt. But he also notes that the FWFD has not had any instances of apparatus not operating properly at the fire scene.
While an EPA exemption might be tempting, it will not be a cure-all. First, many 2007 and 2010 engines have already been delivered. Most departments won’t be able to afford replacing those engines any time soon. And the solution is not as simple as just removing the DPF filter. With engines and computer systems built to provide optimum performance with the emission systems in place, extensive and expensive retrofitting would need to take place.
“The exemption from future requirement is one issue, but the removal of systems from the current fleet would require involvement of the engine and apparatus manufacturers,” says Battalion Chief Kevin Ester, SDFRD’s Fleet Liaison Officer. “This isn’t just putting in a different muffler or turning off a switch. Electronics play such a significant part of all apparatus systems, and emissions are no exception. There will be very real costs associated with this change over.”
Brian Chaput, senior application engineer for Detroit Diesel Corporation, agrees. “To institute an exemption at this stage would require development of new fuel maps and add the cost of reprogramming to apparatus already in the field,” he says. “In addition, the existing after-treatment devices would need to be replaced by a muffler and new piping. The approach of enacting an industry exemption now may seem like a simple solution, but the details are much more complicated and will incur considerable expense to implement.”
In addition, there remains the fact that as important as these issues are to the fire service, engines manufactured for fire apparatus are a very small part of the overall heavy-truck engines manufactured. What incentive do manufacturers have to continue building a specialized engine just for the fire service? “A custom fire apparatus manufacturer may see value in a financial involvement, but a commercial chassis manufacturer may not for such a small market segment,” Ester says.
Local government regulations on emissions would also play a factor. “It was believed that there would be customers or municipalities that would require full EPA 2010 compliance regardless of an exemption,” Chaput says.
And not all city councils will be as supportive as San Diego’s. Bill Foster, vice president and co-founder of Spartan Motors, says he believed the fire service would need an exemption until he talked the issue over with a city council member. The gist of the conversation: The council would be unlikely to support something that could be seen by the public as taking a step backward in reducing emissions.
Turning to the Manufacturers
Regardless of how the EPA responds to the fire service requests, departments must deal with the problems they’re facing now. Many departments are depending on the apparatus and engine manufacturers for information and training.
“While I suspect many chiefs were aware that new emission control requirements were being added to diesel engines in 2007, I doubt many anticipated the emergency response reliability impacts this equipment would have on our fleets,” says SDFRD Chief Javier Mainar. “I think it was reasonable for us to have expected that the manufacturers had considered the various operating parameters of their customers and designed their equipment to operate efficiently in any market segment they served. Unfortunately, our experience has been that these systems do not operate efficiently enough in a fire service application. Consequently, fire apparatus have to be removed from service simply to perform a routine regen cycle. This loss of response capability is unacceptable and must be addressed by the manufacturers.”
And manufacturers are working hard to do just that. Bill Foster, vice president of Spartan, says the company provides training across the country. He outlines several things that can help decrease the problems associated with the new engines:
- Use an ultra-low-sulfur fuel (15 ppm). Low-sulfur fuel will plug up the DPF.
- Use low-ash engine oils (CJ-4).
- Avoid extended idling. If you’re at a call and you’re not going to run the pump, put the engine on high idle whenever the parking brake is on. That will eliminate a lot of the soot buildup.
- Ensure the apparatus gets regular, proper maintenance and inspection.
- Make sure the insulation on the exhaust pipe is maintained. “If the insulation comes off on the exhaust pipe, you’ll have an issue because the high temperature coming from the turbo to the DPF is going to drop way down before it gets there,” Foster says. “Fire departments didn’t used to have to deal with this, and people don’t understand the need to maintain temperature with the DPF.”
- Maintain coalescing crankcase filtration–another feature of the systems that prevents engine crankcase blowby from going into the atmosphere. Foster recommends that the filter be inspected once a year at a minimum.
- Ask questions. Become involved. Understand what the lights are telling you so you’re reacting quickly to the need for regeneration.
Johnson of Rosenbauer notes that many departments have adapted a program to manually regenerate the system on a fixed schedule, regardless of whether the truck needs it. “The most common is weekly,” he says. “If the process is running, and a call is received, the driver can interrupt the process to respond. The process is then restarted after the run to complete. The success is in the fact that it removes the chance of an issue pertaining to the DPF. However, the fuel consumption used to regenerate, whether needed or not, becomes another expense to be noted. It does work to eliminate most DPF issues.”
Understand the Triggers
One issue that seems challenging yet hopeful is building a better understanding of what affects the regen process. “The manufacturer told us that if regen is interrupted, that can affect things,” says Robertson. “For example, you start the regen process and a fire call comes in, so you interrupt it. You’re supposed to wait so long before trying the regen again.” Robertson has asked CAT to provide a list of parameters that affect regen. Knowing those exact parameters could help resolve the issue.
The San Diego Fire-Rescue Department (SDFRD) has taken this a step further, seeking to build its own database of all events that trigger the need for regen procedures. It is now implementing a new regen procedure that can take place in the field, avoiding the need to bring the rig into the shop.
The challenge: training all its operators. “We have created two PowerPoint training sessions that will be rolled out via our online training program,” Ester says. “All personnel will be required to view the first presentation that explains what regen is, how it works, what the different levels of regen are, and what the appropriate action is. The second presentation is for all holders of a Class A or B license (we only use commercial licensing standards, not firefighter-restricted) and covers the actual procedure. Because we have several different makes of regen-equipped vehicles, we came up with a standard procedure that will work on all of them so the troops only need to remember one process. A double-sided, laminated regen procedure card will be in the engineer’s manual of all affected apparatus to aid operators if needed.”
Continued data entry is an essential part of this process. “[Operators] will also be required to complete a tracking entry on a Regeneration Record that is later submitted to Fleet Services so they can track trends in regen frequency and regen inhibits,” Ester says. He also advocates that apparatus undergo the regen procedure with a computer every 90 days and prior to leaving the shop after any repairs.
Looking Forward, But Dealing with Now
What does the future hold for fire apparatus? Engines and after-treatment devices were modified for the 2010 emissions changes, and with three years of experience under their belts, manufacturers of 2010-compliant apparatus may produce a better track record. Selective catalyst reduction (SCR), introduced on the 2010 engines, allows the engine to produce much less soot, so DPF soot accumulation should be improving on newer apparatus.
“The most important aspect of the EPA 2010 engines versus EPA 2007 engines is the addition of the SCR system and the need to keep the DEF fluid level maintained,” Detroit Diesel’s Chaput says. “We have tried to make this additional responsibility as simple as possible. The cost of DEF is comparable to the cost of diesel fuel and is used at a much lower rate. A typical fire apparatus has a fuel tank of 50—75 gallons. An operator would be required to top-off or fill a 4—5 gallon DEF tank at every other fuel fill-up. That is the only new requirement from an operator’s perspective when compared to an EPA 2007-powered fire apparatus. In addition, the regeneration interval for EPA 2010 engines has been greatly increased over the EPA 2007 interval, so the need for parked regeneration has been reduced considerably.”
Perhaps diesel will give way to a new fuel source. HME Ahrens-Fox is promoting a lighter weight, aluminum-bodied apparatus that uses compressed natural gas (CNG) for fuel. It’s a fuel source that has powered backyard mechanics vehicles since the 1950s, and is well known for keeping internal engine components looking new after accumulating tens of thousands of miles in travel. Oil change intervals are extended drastically, and there are no emissions issues from the tailpipe of a CNG-fueled vehicle. Although CNG vehicles aren’t suited for a long, mutual-aid-type of run to a rural area, more and more citywide transit systems and refuse operations rely on the fuel. In fact, there are over-the road tractors now using CNG instead of traditional diesel fuel.
Regardless of these promising developments, the DPF issue isn’t going away anytime soon. To address it effectively, departments must work with engine manufacturers, apparatus manufactures and, most importantly, one another to share strategies, collect data and use the collective intelligence of the fire service to address this problem.
FAMA certainly plays a role in that process. “To assist both our members and the industry as a whole, FAMA has several papers published on our website and located in the resource library,” the Technical Committee notes. “The papers include information on engine changes, operations (regeneration), and vehicle impact. The FAMA Technical Committee continues to monitor all of the concerns of OEMs and end users as well as current and upcoming EPA regulations. As more information and facts become available regarding the particulate filter issues, FAMA will continue to support its members and the fire industry while working jointly with government regulations and NFPA requirements to resolve any issues.”
Fire departments can take an active role in sharing information too. Since the implementation of a regen program and relevant record-keeping, the SDFRD has accumulated considerable emissions data. That information could be a real asset to departments dealing with 2007- or 2010-compliant systems.
“We are happy to continue sharing with other agencies any information we have gleaned from our experiences,” Ester says. “I believe the best thing we can do for the fire service is to be open and honest about our experiences, and have been grateful for those that have done the same for us.”