To: Steele, Lauren[steele.lauren@epa.gov] Cc: jmcdonald@gsa.gov[jmcdonald@gsa.gov]; Alexander, Elden[ealexand@blm.gov] From: Haston, David -FS Sent: Wed 12/18/2013 10:49:49 PM Importance: Normal Sensitivity: None Subject: RE: Revised EPA Definitions of Emergency Vehicle and Emergency Equipment Categories: EZ Record - Shared

Hi Lauren,

To confirm, we concur with the information provided by Elden Alexander below.

Dave Haston USDA Forest Service San Dimas Technology and Development Center (909)599-1267 x294 (909)260-5271 cell dhaston@fs.fed.us

From: Alexander, Elden [ mailto:ealexand@blm.gov] Sent: Wednesday, December 18, 2013 2:42 PM To: Steele, Lauren Cc: Haston, David -FS; jmcdonald@gsa.gov Subject: Re: Revised EPA Definitions of Emergency Vehicle and Emergency Equipment

Lauren,

Thank you for including Dave, John and I in these important discussions.

I spoke with Dave by phone and we both agree that we would prefer to use "fire apparatus" in place of "fire truck". Justification being we have other equipment involved in fire emergencies that meet your definition but are not necessarily "trucks". We utilize crew carriers that deliver fire fighters to the fire scene and function as critical vehicles on the fire-line supporting immediate operations as well as Helicopter Support vehicles and Water Tenders that are in service on the fireline. I can provide you with photos of the above vehicles if you think it will help. Might be splitting hairs but the term "truck" implies only one type of vehicle in the wildland community.

We also discussed the definition of emergency equipment in regards to the possibility (rather than certainty) it will be involved in emergency situations. The Department of Interior and US Forest Service vehicles that are funded by and purchased for fire service would fall into the "certainty" category for use in life-threatening situations where the emission control system would pose a serious threat to life and safety if thevehicle were to regenerate or de-rate the motor on the fireline.

We do have many support vehicles that respond to fire emergencies but they are not classified or funded by as fire apparatus.

I hope that helps. Dave and John can chime in and clarify anything as well.

Again, thank you for the opportunity to be involved in this process. Let me know what else I can do to help.

Happy Holidays.

================================ Elden Alexander BLM Fire Operations - NIFC National Fire Equipment Program Manager Office 208.387.5422 iPhone 208.870.2004

================================ On Fri, Dec 13, 2013 at 11:25 AM, Steele, Lauren < steele.lauren@epa.gov > wrote: Gentlemen,

This message is a follow up from our previous conversations about EPA ’ s definitions of emergency vehicle and emergency equipment in our recent rule. At this time, I am requesting your feedback on the DRAFT revised definitions. Please do not share this with others at this time, as we are in a deliberative phase of this rule.

In EPA ’ s 2012 rule, we allowed manufacturers of engines for emergency vehicles (onroad) and emergency equipment (off-road) to adjust the emissions controls to prevent reduced performance (due to engine-protection inducements, particulate trap plugging, or SCR system faults).

As you know, in that rule, our definition of emergency equipment covered only wildland fire apparatus and airport firefighting apparatus. As we ’ ve learned since then, most wildland fire apparatus are certified to on-road standards, thus our regulatory definition placing them in the off-road category was in error. We ’ ve also learned that some airport authorities own fire trucks that are certified to on-road standards. Third, we ’ ve learned more about what a slip-on firefighting module is, in part from conversations with you. Fourth, we ’ ve been asked to clarify whether fire plows are covered under this provision. As a result, we are preparing to finalize a revised definition of emergency equipment (for off-road engines).

We are also preparing to finalize a revised definition of emergency vehicle, expanding beyond on-road fire trucks and ambulances on a case-by-case basis. We don ’ t have any specific examples of other on-road vehicles that warrant this special treatment, but we are trying to be responsive to comments.If you have some time before December 23, I would greatly appreciate it if you could review these revised definitions and provide me with comments. If you are likely to have substantial comments and need additional time, please let me know and we can work something out.

Sincerely, Lauren Steele

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

DRAFT Revised Definitions:

___________________________________________ Emergency vehicle means one of the following: (1) For the greenhouse gas emission standards in §86.1818, emergency vehicle means a motor vehicle manufactured primarily for use as an ambulance or combination ambulance-hearse or for use by the United States Government or a State or local government for law enforcement. (2) For other provisions under this subpart, emergency vehicle means a motor vehicle that is: (i) An ambulance or a fire truck. (ii) A vehicle that we have determined will likely be used in emergency situations where emission control function or malfunction may cause a significant risk to human life. For example, we would consider a pickup truck that is certain to be retrofitted with a slip-on firefighting module to be an emergency vehicle, even though it was not initially designed to be a fire truck, or a mobile command center that is unable to manually regenerate its DPF while on duty. In making this determination, we may consider any factor that has an effect on the totality of the actual risk to human life. For example, we may consider how frequently a vehicle will be used in emergency situations or how likely it is that the emission controls will cause a significant risk to human life when the vehicle is used in emergency situations. We would not consider the pickup truck in the example above to be an emergency vehicle if there is merely a possibility (rather than a certainty) that the vehicle is to be retrofitted with a slip-on firefighting module.

Emergency equipment means any of the following types of equipment that is not a motor vehicle: (1) Specialized vehicles used to perform aircraft rescue and/or fire-fighting functions at airports, with particular emphasis on saving lives and reducing injuries coincident with aircraft fires following impact or aircraft ground fires. (2) Wildland firefighting equipment designed primarily to support wildland firesuppression operations. For example, a bulldozer designed with special features for fighting wildfires would be a piece of emergency equipment. (3) Any other equipment that we have determined will likely be used in emergency situations where emission control function or malfunction may cause a significant risk to human life. For example, we would consider nonroad equipment that is certain to be retrofitted with a slip-on firefighting module to be emergency equipment, irrespective of the equipment manufacturer ’ s original design. In making this determination, we may consider any factor that has an effect on the totality of the actual risk to human life. For example, we may consider how frequently the equipment will be used in emergency situations or how likely it is that the emission controls will cause a significant risk to human life when the equipment is used in emergency situations. We will consider to what extent the flexibility provisions of §1039.665 already address the risk. In the example above, we would not consider equipment to be emergency equipment if there is merely a possibility (rather than a certainty) that the equipment is to be retrofitted with a slip-on firefighting module.

Below are the current definitions, effective August 2012:

___________________________________________________________ Emergency vehicle means a vehicle that is an ambulance or a fire truck.

Fire truck means a vehicle designed to be used under emergency conditions to transport personnel and equipment and to support the suppression of fires and mitigation of other hazardous situations.

Ambulance means a vehicle used for emergency medical care that provides all of the following: (1) A driver’ s compartment. (2) A patient compartment to accommodate an emergency medical services provider and one patient located on the primary cot so positioned that the primary patient can be given intensive life-support during transit. (3) Equipment and supplies for emergency care at the scene as well as during transport. (4) Safety, comfort, and avoidance of aggravation of the patient’ s injury or illness. (5) Two-way radio communication. (6) Audible and visual traffic warning devices.

Emergency equipment means either of the following types of equipment: (1) Specialized vehicles used to perform aircraft rescue and fire-fighting functions at airports, with particular emphasis on saving lives and reducing injuries coincident with aircraft fires following impact or aircraft ground fires.(2) Wildland fire apparatus, which includes any apparatus equipped with a slip-on firefighting module, designed primarily to support wildland fire suppression operations.

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