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## Emergency Vehicle SCR and DEF Inducement Guidelines 2010 EPA Engine Emissions Control Requirements Roger Lackore

Mike Power May 18, 2010

Background After extensive consultations with the Envir onmental Protection Agency (EPA), the Fire Apparatus Manufacturers Association (FAM A), the Ambulance Manufacturers Division of the National Truck Equipment Manuf acturers Association (AMD), and the International Association of Fire Chiefs (IAFC), believe we have reached an understanding with EPA regarding an appr oach to Diesel Emission Fluid (DEF) inducement strategies for emergency ve hicles. Beginning in 2010, routine DEF replenishment is considered a critical emi ssion-related engine maintenance requirement under EPA regulations; however, engine safety c oncerns that are particular to emergency vehicles permit manufacturer s of emergency vehicles to employ less severe vehicle inducement measures than those applicable to typical commercial vehicles.

Inducements perform two functions. One is to ensure that vehicle operators are disciplined enough to plan for adequate DEF s upply just as they must plan for adequate fuel supply. The second function is to ensu re any mechanical faults in the emission control system are remedied quickly, assuring that any vehi cle in service complies with EPA emissions standards. This approach will ensure an emergency vehicle that runs low on DEF or experiences a mechanical fault is subjected to an inducement sufficient to ensure proper SCR system maintenance w ithout undue risk of damage to emergency vehicles and without jeopardizing the ability of the ve hicle to complete its emergency response mission.

Inducements for Emergency Vehicles After consultations with EPA, we believe that the following inducement strategies for emergency vehicles that are aligned to the f unction these vehicles perform and the critical nature of their use for public safety will meet requirements for ensuring that scheduled maintenance is performed in use. The inducement strategy should adhere to the following criteria: 1. Emergency vehicles will employ graduate d driver warning signals previously established by engine manufacturers w ith respect to SCR systems. 2. Emergency vehicles will employ an “initia l” driver inducement that limits the vehicle speed to 55 mph. 3. Emergency vehicles will employ a “last re sort” driver inducement that limits vehicle speed to 25 mph. This speed limitation will be sufficiently onerous to induce emergency vehicle operators to pe rform the required maintenance quickly,2 but still allow them to transport a patient or reach the scene of an emergency, albeit at a significantly reduced speed. 4. Inducements for emergency vehicles will not be required to limit engine torque. This will avoid the situation where an emergency vehicle would be unable to climb a grade that it can normally ascend. 5. Fire apparatus inducements may be postpone d while the apparatus is operating in PTO mode. If the appara tus drops out of PTO mode to reposition, the 25 mph limit may be employed, but may be disconti nued temporarily prior to the engine being shut off. This will assure that e ssential functions such as pumping operation or aerial operation can con tinue uninterrupted while fi ghting a fire or conducting other operations at the scene of an emergency. 6. At the conclusion of the emergency even t, the “last resort” inducement (25 mph speed limit) and well as cessation of PTO operation will be employed and will continue until DEF has been added.

FAMA Believes That These Inducement St rategies Will Meet the EPA Emissions Regulations

Strategies 1 and 2 fit with the general industry inducement strategies employed by onhighway vehicles to meet 2010 emissions sta ndards using selective catalytic reduction technologies. Although the 25 mph “last reso rt” vehicle speed limita tion is higher than the typical level of 5 mph employed for commer cial vehicles, this limit in conjunction with the a limit on PTO operation is suffici ently onerous to induce emergency vehicle operators and fleet managers to take immediate action to maintain an effective SCR system. Any emergency vehicle limited to a top speed of 25 mph will represent a significant liability to the fi re fighting or care provider organization. Any organization that does not either remedy the situation or rem ove the vehicle from service at the earliest safe opportunity would be vulnerable to serious legal liability claims.

Inducement strategies 4 and 5 are provisions that are meant to mitigate risk of damage to the vehicle engaged in emergency operations. In addition these provisions mitigate the risk of harm to the vehicle operator and th e public. These strategies are allowed under EPA regulations since protection from vehicl e damage is one of the allowed uses of Auxiliary Emissions Control Devices as prescribed by the definition of a defeat device in 40CFR 86.004-2.

The nature of fire fighting ofte n requires the apparatus be plac ed close to structure fires, or in the path of wild fires. Shifts in wind or other changes in the situation will require the apparatus to be moved quickly to protec t the vehicle against damage. This damage can result from heat or open flame, or ma y be caused by the ingestion of excessive amounts of soot or burning embers into the engine.

Inducement strategy 4 ensures th at an apparatus operator attempting to move the vehicle away from rapidly approaching flames will be able to do so. Engine torque derates could prevent the apparatus from ascending a grade at any speed and approaching flames, heat, or soot could envelope and damage a vehicle wi thout sufficient engine torque to escape.3 Inducement strategy 5 ensures a fire fighti ng vehicle may continue to perform fire suppression operations in close proximity to an approaching fire, or eminent structure collapse. Rapid repositioning and subseque nt re-engagement of the pumping function during an emergency event is necessary to move the vehicle out of harms way, while permitting the vehicle operator to continue suppression operations to protect the vehicle from damage consistent with EPA regulations.

Emergency Vehicle Definition These inducement strategies may only apply to emergency vehicles. EPA will require engine OEM’s to demonstrate to EPA that these strategies will only be available to vehicles that meet the limited definition of emergency vehicle – to include automotive fire apparatus, wildland fire apparatus, or ambulances meeting one of the following criteria: 1. Fire apparatus shall meet the scope and application of National Fire Protection 1901 Standard for Automotive Fire Appa ratus – 2009 Edition and shall conform to one of the following definitions as f ound in that standard: Pumper Apparatus; Initial Attack Apparatus; Mobile Water S upply Apparatus; Aerial Fire Apparatus; Quint Fire Apparatus; Special Service Fi re Apparatus; or Mobile Foam Fire Apparatus. 2. Wildland fire apparatus shall meet th e scope and application of NFPA 1906 Standard for Wildland Fire Apparatu s – 2006 Edition and shall conform to wildland fire apparatus defin ition found in that standard. 3. Ambulances shall meet the scope an d definition of General Services Administration KKK-A-1822F “Federal Spec ification for the Star of Life Ambulance” and shall conform to one of the following definitions: Type I Ambulance; Type I - AD (Additional Duty) Ambulance; Type II Ambulance; Type III Ambulance; or Type III - AD (Additional Duty) Ambulance.

General Inducement Strategies The following tables describe general strate gies appropriate for emergency vehicles, reflecting the revised emergenc y vehicle inducements. Fluid levels are provided only as general guidelines. The specific progression of lamp colors and flash patterns is determined by the engine OEM and described to the EPA.

DEF Keep-Fill Inducement Strategy Condition Warning Lamps Inducement Fluid Level Above 10% None None Fluid Level 5% to 10% First Warning Lamp None Fluid Level below 5% Additional Lamp Actions 55 mph Speed Limit DEF Tank Empty Additional Lamp Actions 55 mph Speed Limit Tank empty and ignored after one of the following events: refueling, parking or restart.* Additional Lamp Actions 25 mph Speed Limit and no PTO operation after emergency event

Inducement mode is exited by adding DEF to the tank.4 DEF Quality Inducement Strategy Condition Warning Lamps Inducement Incorrect DEF Fluid Detected First Warning Lamp None

Engine has run for several hours after detection Additional Lamp Actions 55 mph Speed Limit

Engine has run for many hours after detection and after one of the following events: refueling, parking or restart.* Additional Lamp Actions 25 mph Speed Limit and no PTO operation after emergency event

Inducement mode is exited by replacing fluid with proper DEF

SCR Fault Inducement Strategy Condition Warning Lamps Inducement SCR Fault Detected First Warning Lamp None Engine has run for several hours after detection Additional Lamp Actions 55 mph Speed Limit

Engine has run for many hours after detection and after one of the following events: refueling, parking or restart.* Additional Lamp Actions 25 mph Speed Limit and no PTO operation after emergency event

Inducement mode is exited by re pairing the cause of the fault *The inducement strategy should use one of th ese trigger events (refueling, parking, or restart).

Engine OEM Reporting Details of the exact inducement strategy must be presented by each engine OEM and approved the EPA. The EPA will expect to be provided with answers to the following questions:

 What is the exact inducement st rategy for emergency vehicles?

o How is each inducement entered?

o How is each inducement exited?

 What control does the OEM have in place to ensure that engines with emergency vehicle inducement strategies are sold only for use in emergency vehicles?

For questions regarding this document contact: Roger Lackore FAMA Chassis Technical Committee Chair 920 832 3249 rlackore@piercemfg.com