To: Steele, Lauren[steele.lauren@epa.gov] From: Fleming, Joseph D -FS Sent: Wed 9/18/2013 2:19:42 PM Importance: Normal Sensitivity: None Subject: RE: Heavy emergency equipment and regulations Categories: EZ Record - Shared

Thank you for your prompt response, Lauren. It is my understanding that at least one manufacturer of wildfire suppression dozers already has a manual override for the

“ limp ” mode that is initiated when the machine gets too hot or tries to go into a regeneration cycle while still actively building fire line. Running at higher temperatures reduces the emissions from the machine but that can put it on the edge of failure when operating on a fire line and the machine will de-rate which puts the operator at risk. Sometimes they have to run the heater just to keep the machine running and that means they have to leave the doors open, which makes it impossible to hear their radio, and that’ s another safety issue.

So let me ask this; if a machine is certified for T2 or T3 emissions standards, isn ’ t it certified for the entire operating temperature range, or at least the “ normal ”range? If we can improve on the dozer’ s ability to reject heat above the normal range, while keeping the engine in the normal operating range, we wouldn ’ t be voiding the emissions certification would we?

Right now our agency has approximately 80-100 machines that are prone to overheating under extreme conditions and we still need to use them for another 7-10 years. The southern states are having the same issues and they have many more machines; hundreds I ’ d say. We think we have a remedy for the overheating issue and it does not involve modifying any of the emissions devices. We certainly have contacted the manufacturer regarding this but they have yet to provide an effective solution. That is probably more due to cost than technical feasibility.

Thanks again for your time,

Joe Fleming Mechanical Engineering Technician US Forest Service San Dimas, CA

From: Steele, Lauren [ mailto:steele.lauren@epa.gov] Sent: Wednesday, September 18, 2013 6:46 AM To: Fleming, Joseph D -FS Cc: Spears, Matthew; Haston, David -FS Subject: RE: Heavy emergency equipment and regulations

Joe,Thank you for your inquiry. During the comment period on our emergency vehicle rule last summer, EPA received comments about fire dozers from the Southern Group of State Foresters and the Northeastern Area Association of State Foresters. Both groups asked us to consider including fire dozers among the equipment eligible for provisions that would eliminate any performance de-rates related to the emission control system. Although EPA is in the process of developing a final rule to address these and other comments received last summer, some provisions have already become effective through a direct final rule. Today manufacturers are free to submit requests to EPA to approve devices for fire trucks, ambulances, and dedicated nonroad emergency equipment, which enable the engines to operate at full power through the demanding duty cycle of engines in emergency service.

EPA believes it could be reasonable to interpret our current definition of emergency equipment at 40 CFR 1039.801 to include dedicated wildfire suppression dozers. I have recently been in contact with David Frederick of the Southern Group of State Foresters about this issue, and we have made contact with two manufacturers of fire dozers on this issue as well. Under the provisions of the direct final rule, modifications to emergency equipment should only be made by manufacturer-authorized service centers, and only with EPA-approved devices. If you have equipment that is having performance issues related to the emission control system, we recommend you bring this to the attention of the engine manufacturer. We would be happy to discuss this with you on a call, as well as facilitate further discussions with the appropriate manufacturer on the available flexibilities of our direct final rule.

******************************************** Lauren P. M. Steele, P. E. US EPA Office of Transportation and Air Quality 2000 Traverwood Dri ve Ann Arbor, MI 48105 734-214-4788

From: Fleming, Joseph D -FS [ mailto:jdfleming@fs.fed.us ] Sent: Tuesday, September 17, 2013 1:47 PM To: Steele, Lauren Subject: Heavy emergency equipment and regulations

Lauren,

My Colleague, Dave Haston, referred you as a reliable source of information o n emergency equipment and possible exemptions from regulations at least during emergency operations. I ’ ve been asked if we will be able to override any automatic shut-downs, if such are in place as a means to meet emissions requirements, on equipment such as bulldozers used for firefighting operations. Any such de-rating of the machines ability to perform could have serious safety consequences. What canyou tell me about the regulations going forward as they relate to our equipment?

Joe Fleming Mechanical Engineering Technician US Forest Service San Dimas Technology & Development Center

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