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2000 Town Center—Suite 1140, Southfield, MI 48075 • Phone 248.357.4717 • Fax 248.357.4740 • www.autoalliance.org

March 31, 2009 

Karl Simon 

Director, Compliance and Innovative Strategies Division 

U.S. EPA Office of Transportation and Air Quality 

2000 Traverwood Drive 

Ann Arbor, MI  48105 

­­ Delivered via email ­­  

RE: Request for approval of new scheduled maintenance under §86.1834­01(b)(7)(ii))

Dear Mr. Simon: 

The Alliance of Automobile Manufacturers (Alliance) requests that EPA approve as a "new 

scheduled maintenance" the refill of DEF (Diesel Exhaust Fluid) for SCR (Selective Catalytic 

Reduction) emission control systems. This request is an industry‐wide request for light‐duty 

and chassis certified vehicles for 2 model years (Model Years 2009 and 2010). 

This request is for maintenance which did not exist prior to the 1980 model year.  

We recommend that the maintenance category for DEF refill be emission‐related, critical 

maintenance.  

We further recommend that, for Model years 2009 and 2010, the technologically necessary 

SCR maintenance interval (i.e., DEF tank refill interval) should be set the same as the service 

interval (oil change interval) in miles. 

  

The following is our substantiation of this request: 

1) Background

On March 7, 2007, EPA issued a Dear Manufacturer guidance letter (CISD 07‐07) 

setting out its SCR vehicle certification requirements for light‐duty and heavy‐duty 

manufacturers. The guidance addressed 40 CFR §86.004‐25, §86.094‐25 & §86.1834‐
2 

01 Allowable Maintenance; and 40 CFR §86.094‐22 & §86.1833‐01 Adjustable 

Parameters.  

On February 18, 2009, EPA issued another Dear Manufacturer guidance letter (CISD‐

09‐04) providing additional guidance for HD truck manufacturers. The guidance set 

out minimum DEF tank sizes, and allowed a minimum DEF tank size of 2 times the fuel 

tank range if the vehicle is equipped with a DEF tank level indicator (2:1 refill interval). 

2) Reasons for why DEF refill is an emission­related, critical maintenance

EPA noted in CISD 07‐07 that since the SCR catalyst does not function without the use 

of a reducing agent, 40 CFR §86.1834‐01(b)(4)(ii)(F) and §86.004‐25(b)(4)(iii)(F) 

would apply to the SCR catalyst and all of the associated hardware, including but not 

limited to, the reducing agent, the reducing agent storage tank, the dosing valve, and all 

lines and hoses. We agree with EPA that DEF refill is an emission‐related, critical 

maintenance.  

3) Reasons for why the technologically necessary SCR maintenance interval should be

the same as the service interval for Model Years 2009 and 2010

The reasons for why the technologically necessary SCR maintenance interval should be 

the same as the service interval (oil change interval) are very much the same reasons 

that EPA found persuasive for determining the 2:1 heavy‐duty vehicle DEF refill 

interval. Namely, vehicles will be designed and equipped to ensure vehicle compliance 

with emission standards, DEF will be readily available and accessible to drivers, 

maintenance is likely to be performed and there is limited space available on vehicles 

for a large DEF tank.  

a) Vehicles will be designed and equipped to ensure compliance with emissions

standards

i) Driver Warning

Manufacturers will equip vehicles with an escalating audible and visual warning 

chain that provides adequate time to re‐fill the DEF. USCAR has developed a 

recommended practice for manufacturers to use as a standardized warning chain. 

This warning chain has also been adopted as an SAE industry‐wide recommended 

practice. SAE has also standardized the DEF indicator symbol. Manufacturers will 

use an escalating mix of DEF level indicator, messages in the instrument cluster, 

engine shutdown lamp, or audible warnings to warn the driver of low DEF levels. 

ii) Driver Inducement

Manufacturers will equip vehicles with escalating and sufficiently onerous levels of 

inducement to ensure that the DEF is refilled. This escalating inducement also 

includes identification of incorrect reducing agent. 
3 

iii)Tamper Resistant Design

Manufacturers will design the SCR system to be tamper resistant consistent with 

the EPA’s March 27, 2007 guidance letter. The actions listed below will trigger 

illumination of a warning lamp:

• Disconnected DEF tank level sensor

• Blocked DEF line or dosing valve

• Disconnected DEF dosing valve

• Disconnected DEF pump

• Disconnected SCR wiring harness

• Disconnected NOx sensor (that is incorporated with the SCR system)

• Disconnected DEF quality sensor

iv) Freeze Protection

Manufacturers will design and equip vehicles with DEF Dosing Freeze Protection 

Systems which will prevent or minimize SCR performance degradation due to 

freezing of DEF. This can include DEF tank heaters, line heaters, and location of 

tank within a heated space. 

b) DEF will be readily available and accessible to drivers

i) DEF is available at dealerships, gas stations and truck stops

The manufacturers of SCR vehicles have worked with franchised dealerships to 

supply DEF to their customers. Several of these manufacturers have agreements 

with gasoline station chains to ensure availability of DEF at those refill stations. In 

addition, several truck stops have announced publicly their intention to stock DEF. 

To further ensure the quality of DEF at these retail locations, the American 

Petroleum Institute will be conducting a quality control program with the support 

of distributor and retailer licensing agreements. 

ii) An organized industry­wide SCR Stakeholder Group is ensuring wide

availability of DEF

DEF infrastructure development is making significant progress. Industry‐wide 

standards for DEF infrastructure, a necessary enabler for the widespread 

availability of DEF, have been put in place, including ISO DEF specifications, API's 

DEF quality standard, SAE DEF specifications, and USCAR and SAE warning chain 

standards. The SCR Stakeholder Group has established itself as a focal point for   

infrastructure development discussions by   producers, suppliers, distributors and 

users of DEF.  

iii) Drivers can locate DEF through locator website

DOE/NREL has established a locator website for drivers to use to locate supplies of 

DEF. 
4 

iv) Public awareness of availability is increasing through DEF public relations 

activities 

Numerous press releases and public relations activities have been distributed 

related to the development of DEF infrastructure. Announcements of new truck 

stops planning to add DEF and new industry DEF websites have been released. 

Attached please find three recent examples of press releases: Pilot Travel Centers 

LLC, TravelCenters of America LLC, and Cummins Filtration. 

c) Maintenance is likely to be performed on schedule 

There are a number of reasons why the DEF refill maintenance is likely to be 

performed. Vehicles will be equipped with an escalating warning chain which will 

audibly and visually signal that the maintenance needs to be performed. In the unlikely 

event that the warnings are not heeded and the maintenance is not performed, the 

performance of the vehicle will be noticeably and significantly degraded. 

d) There is limited space available on light duty vehicles for a large DEF tank 

Light duty vehicles are constrained in the amount of space that can be dedicated to a 

DEF tank. For example, one SCR light duty vehicle in current production must find 

space to accommodate an 8 gallon DEF tank in addition to the separate fuel tank of 21 

gallons. Furthermore, the addition of weight from a large quantity of DEF reduces the 

fuel economy of vehicles. 

For these reasons, the Alliance requests that EPA approve a new scheduled maintenance 

interval of DEF refill for light-duty and chassis certified vehicles for Model years 2009 and 

2010 that coincides with the manufacturer's service interval (oil change interval). 

Sincerely, 

Giedrius Ambrozaitis 

Director, Environmental Affairs 

cc: Linc Wehrly, Compliance and Innovative Strategies Division 

Laura Baker, Compliance and Innovative Strategies Division 

Attachments 
Pilot Travel Centers LLC Provides Details about Diesel Exhaust 

Fluid Availability 

Knoxville, TN – February 8, 2009 – Pilot Travel Centers LLC has announced 

the details and scheduled rollout for Diesel Exhaust Fluid (DEF) availability at its 

North American truck stops. DEF is a required fluid for 2010 selective catalytic 

reduction (SCR) systems that reduce Nox through a catalytic process in the 

exhaust stream. 

Pilot will rollout 25 bulk dispensing units per quarter, starting in Q3 2009 through 

Q2 2010. Ultimately, approximately 100 of Pilot’s locations will have bulk 

dispensing capabilities at the fuel island where it will be most convenient. All 328 

truck stops will have the packaged quantities available. The company will begin 

ordering the equipment for the bulk dispensing units within the next few weeks. 

The equipment will be state of the art and designed to store, pump, and transact 

DEF to customers in a wide variety of climates and conditions. 

“Many of our customers will be purchasing SCR-equipped trucks in 2010, so as 

they began coming to us to learn more about SCR and DEF, we did a lot of 

investigating. We determined there was a strong opportunity to not only fulfill our 

customers’ needs, but to be an industry leader,” said Patrick Deptula 

Director of Design and Construction, Pilot Travel Centers. “By working with 

Detroit Diesel and Daimler Trucks North America – who are also leaders with 

their BlueTec 2010 technology – we learned even more about the benefits of 

those systems.” 

Because a typical truck can go approximately 300 miles on just one gallon of 

DEF, Pilot’s 328 convenient locations – including the 100 bulk dispensing 

locations – are well situated for the periodic refills. 
“We will continually review our rollout plan for bulk dispensing locations to ensure 

we are meeting the needs of our customers every step of the way,” said Deptula. 

“This includes having convenient pay-at-the-pump transactions that can be 

simply completed while the driver is also filling up with diesel fuel. Our goal in 

the process is to make everything as seamless as possible for our customers.” 

Added Mark Lampert, senior vice president of sales for Daimler Trucks North 

America: “Our customers are excited to adopt BlueTec emissions technology in 

2010 to take advantage of all the fuel economy and performance benefits it 

delivers. But the only missing piece had been the convenient widespread 

availability of DEF. Thanks to Pilot’s bold and groundbreaking first step, as well 

as the rest of the DEF infrastructure supply chain coming together to prepare for 

SCR, this positions Daimler Trucks and our customers very well for 2010.” 

For a complete list of all North American Pilot Travel Centers, go to 

www.pilotravelcenters.com. 

### 
 

FOR IMMEDIATE RELEASE 

Contact: Tom Liutkus 

 TravelCenters of America 

 440-808-7364 

liutkus.tom@tatravelcenters.com

TA Shares Further DEF Supply Details 

 More options and convenience for customers 

Louisville, KY, March 19, 2009 -- TravelCenters of America LLC announced today further details 

of their plans distribution of diesel exhaust fluid, or DEF, in preparation for the SCR technology in 

use by most major truck manufacturers for the 2010 models. The announcement was made 

during the CEO Summit on SCR technology at the Mid American Truck Show in Louisville, 

Kentucky. The CEOs and Presidents of TravelCenters of America LLC, Daimler Trucks North 

America LLC, Volvo Trucks, Cummins Engine Business, Mack Trucks, and Terra Industries all 

participated in the summit, 

TravelCenters of America LLC is uniquely positioned as an important part of future DEF 

distribution infrastructure. Full service TA and Petro branded facilities will offer multiple supply 

solutions for virtually every need and for the convenience of our customers. DEF will be available 

in pre-packaged containers in the travel stores and fuel island buildings in 235 locations, in bulk 

quantities at key locations nationwide and in bulk quantities at substantially all TA and Petro:Lube 

truck maintenance facilities. In addition, the RoadSquad brand fleet of over 400 emergency 

roadside assistance vehicles will carry quantities of DEF to accommodate our customer’s over 

the road emergencies. 

TravelCenters of America LLC expects to roll out its distribution plans during the second quarter 

of 2009. Prepackaged and emergency quantities are expected to be available at all facilities 

before the end of the second quarter 2009. Bulk quantities are expected to be available in truck 

maintenance facilities and on-island locations beginning in the during the second half of 2009. 

About TravelCenters of America LLC

TravelCenters of America LLC (TA), headquartered in Westlake, Ohio is a leading travel center 

business in 41 states and Canada operating under the TravelCenters of America and Petro 

brands. With convenient locations on interstate exits, TA offers its customers diesel and gasoline 

fueling services, full and quick-service restaurants, heavy truck maintenance services, 24-hour 

convenience stores, electronic communication (WiFi) and other services --- all within large, high 

traffic facilities. For more information on TravelCenters of America, please visit 

www.tatravelcenters.com
Supply Option Illustrations 

 

Examples of options available for pre-packaged DEF. TA and Petro locations are expected to 

have containers of DEF throughout the U.S. by end of June 2009. 

TA and Petro also expect to offer an exclusive method of supply of DEF through TA and 

Petro:Lube truck service centers. TA and Petro:Lube branded locations include nearly 1,000 

service bays across the U.S. Trucks are expected to be able to fill-up or top off DEF conveniently 

during other routine maintenance or repair services. This service will be made available as early 

as the end of June 2009. TA has 164 and Petro:Lube has 67 truck service centers that service all 

makes and models of Class 8 trucks. TA and most Petro:Lube locations are ServicePoint® 

authorized light duty warranty repair centers for Freightliner and Western Star vehicles pursuant 

to TA’s long-standing agreement with Daimler North America LLC. 
TA and Petro locations expect to install at-island dispensers at selected high volume locations 

beginning in the second half of 2009. Lanes with DEF availability will be clearly marked for driver 

convenience. Several technologies will be tested to identify the most cost efficient and 

convenient solution for our customers. 
TravelCenters of America LLC operates its RoadSquad brand of emergency vehicles out of its TA 

and Petro branded locations. RoadSquad’s network of over 400 service vehicles will bring out 

DEF to refill on an emergency basis. RoadSquad service is available 24 hours a day, every day 

of the year by calling 1-800-824-7467. 

Note: 

Hi-resolution copies of all but the plastic container photos can be requested by contacting 

Jennifer Ina within TravelCenters of America LLC’s Advertising & PR Department, either by 

calling (440)808-3256 or by e-mailing her at Ina.jennifer@tatravelcenters.com
Diesel Progress – Online Edition 

Industry News 

DEF Availability Oct. 1 For Cummins 

March 18, 2009 

In an effort to address lingering concerns about the availability of diesel exhaust fluid (DEF) for its 2010 

engines, Cummins Inc. announced that as of Oct. 1 of this year, its Fleetguard branded DEF would be 

available at all of its engine distributors, as well as through most of its Cummins Filtration organization. 

In all, the company said the substance could be purchased at 20 Cummins distributors at more than 187 

locations throughout the U.S., Canada and Mexico. DEF will also be available through the Cummins 

Filtration network, which includes over 20,000 locations with nearly 8000 retailers in North America. 

Cummins Filtration has been providing DEF since 2003, formerly sold under the StableGuard Urea name. 

Fleetguard DEF product is currently available in several packaging options, including bulk, 330 gal. plastic 

totes, 275 gal. disposable totes and 55 gal. plastic drums. Smaller packaging sizes and dispensing 

equipment are expected to be available by mid-2009. 

“Customer needs will vary based on consumption, fueling procedures and other factors. Cummins 

Filtration is committed to offering dependable DEF supply solutions to meet these different customer 

needs,” said KC Hall, director of Diesel Exhaust Fluid Business Development. “While some customers will 

enjoy delivery of DEF product along with their other filtration products, other customers will opt for specific 

DEF supply arrangements to streamline their business processes.”