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 the 
vehicle 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 fire 
suppression 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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