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 Drive

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 on 

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 can 
you 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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