Truck 

### & Engine 

# emo Manufacturers

Association ° Bringing Cleaner Power to the World Since 1968 ® 333 West Wacker Drive, Suite 810 Chicago, Illinois 60606 T®I: (312) 929-1970 1 Fax: (312) 929-1975 www.truckandenginemanufacturers.org

- - ­ J

Jed R. Mandel (312)929-1960 jmandel@emamail.ors


### August 22, 2014

Ms. Janet McCabe Acting Assistant Administrator Office of Air and Radiation U.S. Environmental Protection Agency William Jefferson Clinton Building 1200 Pennsylvania Avenue, NW Mail Code: 6101A Washington, DC 20460

Dear Janet:

I am writing to see if the Truck and Engine Manufacturers Association (EMA) and its members can be of assistance to you in taking action to allow manufacturers of stationary source diesel engines to give operators the means to obtain short-term relief from the inducements associated with the use of selective catalytic reduction (SCR) emission control technology while operating in emergency situations, such as those where operation of the stationary source diesel engine is needed to protect human life.

I believe that you generally are familiar with the need for this relief, and the surrounding issues, as EPA has just published a final rule providing such relief for nonroad mobile source engines. 

### (See 79 Fed. Reg. 46356, August 8, 2014). Further, I understand that the Office of Air Quality Planning and Standards (OAQPS) has briefed your staff on EMA's request to provide the same short-term relief for stationary sources. As you know, the vast majority of the relevant engines are "dual certified" and sold for both mobile and stationary applications. Engine and equipment manufacturers, dealers and distributors, customers, and, indeed, EPA's own certification personnel, need to maintain the cost-savings and efficiencies associated with dual certiffcation.

Even more important, all stationary source stakeholders need the substantive relief that the Agency has afforded to nonroad mobile sources. Without it, the public run the risk of having lifesaving pumps and generators shutting down because of regulatory imposed inducements. And, it will not be possible to explain how backhoes and front-end loaders are able to override inducements to save lives, but pumps and generators are not. I wish to note, by the way, that the stationary diesel engines with SCR technology (the only ones that require the inducement) are the cleanest, lowest emitting engines available. That inducement, and the potential to have the engine shutdown during an emergency, is an impediment to purchasing the cleanest technology available (Tier 4). Our members, and their customers, are interested in removing that potential impediment which, otherwise, incentivizes them to purchase higher emitting previous Tier 2 or 3 engines.

A Non Governmental Organization in Special Consultative Status with the Economic and Social Council of the United NationsMs. Janet McCabe

August 22, 2014 Page 2

We have been working with OAQPS on these issues (while continuing to keep OTAQ in the loop). We have had excellent cooperation and do not believe that there are any disagreements as to how to proceed. The only issue is timing... and the industry's strong sense of urgency to bring stationary diesel engines in line with their nonroad diesel engine counterparts as soon as possible.

I am happy to meet with you to discuss this issue further and to offer any assistance we can to facilitate the action we are requesting.

I look forward to hearing from you. Best regards.

Ver truly yours,

Jed ,'R Mandel President

cc: Thomas Powers Peter Tsirigotis Melanie King Chris Grundler Byron Bunker