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 Nations 
Ms. 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, 

,'R Mandel Jed 

President 

cc: Thomas Powers 

Peter Tsirigotis 

Melanie King 

Chris Grundler 

Byron Bunker