Fire Apparatus Manufacturers’ Association

P.O. Box 397, Lynnfield, MA 01940-0397, (781)334-2911

Ambulance Manufacturers Division of the National Truck Equipment Association 

37400 Hill Tech Drive, Farmington Hills, MI 48331-3414, (248)489-7090

in

Ms. Khesha Jennings October 22, 2009

Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, DC 20460

RE: Emergency Vehicle DEF Inducement Concerns

Dear Ms. Jennings

The Fire Apparatus Manufacturers’ Association (FAMA) and the Ambulance 

Manufacturers Division (AMD) of the National Truck Equipment Association (NTEA) 

formally request the EPA to reconsider their stance on DEF driver inducements with 

respect to Emergency Vehicles. 

FAMA is a non-profit trade association with the goal of advancing and protecting the 

interests of the fire and emergency services industry. The FAMA organization includes

representatives from over 115 member companies throughout North America. AMD is 

the voice of the ambulance industry, representing over 90% of all North American 

ambulance production. FAMA and AMD representatives have been inundated with 

questions from the customers we serve, expressing their concern over the use of driver 

inducements and the safety hazard they will create. 

This correspondence describes the nature of the concern, the urgency of the matter, and 

proposes a compromise solution that will benefit air quality without compromising public 

safety. We urge you to consider the concerns we present here.

Engine Reliability for Emergency Vehicles Cannot be 

Compromised.

Emergency Vehicles save lives only if they arrive on the scene of an emergency quickly, 

continue to function while at the scene, and/or can transport patients safely between the 

scene and a medical facility. Engine failure or de-rate at any time during an emergency 

response has the potential to place emergency workers, the public, and medical patients at 

risk of injury, exacerbated medical conditions, or death.
Fire Apparatus Manufacturers’ Association

P.O. Box 397, Lynnfield, MA 01940-0397, (781)334-2911

Ambulance Manufacturers Division of the National Truck Equipment Association 

37400 Hill Tech Drive, Farmington Hills, MI 48331-3414, (248)489-7090

Fire apparatus are required to operate for long durations at multiple alarm fires, wildland 

fires, and natural disasters. Loss of pump pressure due to engine depowering as the DEF 

begins to run low will compromise the safety of firefighters working on hand-lines inside 

burning buildings where their only protection from death may be the wall of water 

supplied by that pump. If the operator shuts the engine off, the 5 mph inducement will 

effectively remove that piece of equipment from pump operations, reducing or 

eliminating the ability to continue fighting the fire.

EMS workers rely on their ambulance to function at peak performance when transporting 

patients to medical facilities. At a time when the difference between the life and death is 

counted in seconds, engine depowering as the DEF tank runs low is unconscionable. 

Diesel Power is the Only Practical Option.

Given the current state of transportation technology, diesel engines are the only viable 

option for producing vehicles to meet the needs of the public that respond to fire 

protection, rescue operations, and patient transport. The power and torque capacity of 

gasoline engines is insufficient for the needs of fire fighting. The ambulance industry 

experienced serious safety issues with gasoline engines and their reliance on diesel 

engines is well established. The use of alternative fuels such as natural gas or 

compressed natural gas is not practical due to a lack of fuel delivery infrastructure at this 

time, and insufficient power and torque capacities of currently available products. 

Emergency Vehicles must use SCR

The use of SCR in 2010 as a means of reducing truck emissions and therefore improving 

air quality is an established path for all US engine and truck manufacturers except for 

Navistar. The emergency vehicle industry must either produce vehicles using SCR 

technology, or accept a state of monopoly. Members of the Fire Apparatus 

Manufacturers’ Association (FAMA) and the Ambulance Manufacturers Division (AMD) 

of the National Truck Equipment Association are fully committed to producing vehicles 

that comply with EPA regulations and promote cleaner air.

DEF Trigger Inducement Strategies Produce Risk

Proper functioning of the SCR system requires a consistent supply of DEF in the tank. 

Since the diesel engine can run without a DEF supply it is essential that emergency 

vehicles have inducements for the operator to replenish the DEF tank as required.

EPA guidance documents prescribe that the driver is provided with a warning when the 

DEF tank is getting low. Emergency vehicles should conform to this driver warning 

stage without exception as stated in the following excerpt from the EPA guidance letter:
Fire Apparatus Manufacturers’ Association

P.O. Box 397, Lynnfield, MA 01940-0397, (781)334-2911

Ambulance Manufacturers Division of the National Truck Equipment Association 

37400 Hill Tech Drive, Farmington Hills, MI 48331-3414, (248)489-7090

EPA guidance goes on to prescribe performance degradation strategies that are 

“sufficiently onerous”, and that will “disable the commercial mission of a vehicle”. The 

proscribed disabling inducements will all put the vehicle out of commission for some 

period of time and prevent it from being used for emergency response.

DEF Trigger Inducement Strategies Inappropriate for 

Emergency Vehicles

While these inducements may be reasonable for vehicles in commercial operation, any 

one of these inducements has the potential of placing emergency workers in harms way 

or hampering their duty to serve and protect the public.

During normal times and normal operations, keeping the DEF tank full should be no 

more difficult than keeping the diesel tank full. FAMA and AMD agree with the EPA 

that emergency vehicle operators must be instructed to only operate with sufficient DEF 

in the tank. Most emergency response situations are routine and can be handled by 

trained personnel who are able to plan for the regular servicing of their emergency 
Fire Apparatus Manufacturers’ Association

P.O. Box 397, Lynnfield, MA 01940-0397, (781)334-2911

Ambulance Manufacturers Division of the National Truck Equipment Association 

37400 Hill Tech Drive, Farmington Hills, MI 48331-3414, (248)489-7090

equipment, including the replenishing of the DEF tank. Some emergencies, however, are 

not normal or routine. By its very nature an emergency may present unique challenges to 

personnel that cannot be planned for ahead of time. The following examples are 

hypothetical situations where DEF inducements that “disable the commercial mission of 

the vehicle” would be undesirable:

Examples of Situations Involving Increased Risk

Natural Disaster Response – DEF in Short Supply or Unavailable

· Major natural disasters disrupt the supply of all essential commodities including 

fuel, oil, and other materials necessary for vehicle operation and maintenance. 

During Hurricane Katrina there is a known case where fire fighters broke into an 

abandoned diesel fuel tanker truck to keep their apparatus running when no other 

fuel was available. A 2010 fire apparatus with strong inducement strategies 

would have been useless to these fire fighters as soon as the DEF tank ran out.

Volunteer Personnel Training is Inadequate and DEF Filling Is 

Missed

· A significant percent of the nation is protected by volunteer fire fighters. These 

personnel may respond to only one or two calls per week, and the apparatus will 

be operated by whoever shows up first to the station. Volunteer apparatus acquire

low mileage and are therefore in service for many years. A station with many 

older apparatus and one 2010 apparatus presents the real possibility that not 

everyone who may operate the apparatus is aware of the DEF requirement on the 

one new rig that needs it. Any possibility that an apparatus becomes disabled 

during a mission where fire fighters are operating inside a burning building 

becomes a life-threatening situation.

Mutual Aid or Loaned Apparatus During Disasters

· The Department of Homeland Security in their National Preparedness Guidelines 

defines the need for planned interoperability. “Preparedness is the responsibility 

of every level of government, every department, and every agency consistent with 

its authorities. This includes coordinating preparedness activities among partners 

operating within their jurisdictional borders, as well as across jurisdictional and 

geographic borders when dictated by identified threats and risk assessments.” 

The guidelines stress the need for support across local, state, and tribal borders. 

Uniformity among states is particularly important given the specialized operating 

and design requirements of the relatively small number of vehicles.

· State and local governments, with the support of the federal government, are 

increasingly entering into mutual aid agreements that make equipment and 

personnel available to other states in the event of major emergencies. For 

example, many emergency vehicles were loaned to the City of New Orleans and 

other affected regions following Hurricane Katrina, and those vehicles remained 

in the region during the recovery.
Fire Apparatus Manufacturers’ Association

P.O. Box 397, Lynnfield, MA 01940-0397, (781)334-2911

Ambulance Manufacturers Division of the National Truck Equipment Association 

37400 Hill Tech Drive, Farmington Hills, MI 48331-3414, (248)489-7090

· Personnel from regions that have not yet experienced 2010 apparatus may be 

loaned newer equipment. Unfamiliarity with SCR and the need for DEF could 

lead to disabled apparatus during a disaster response.

Mechanical Failures

· The added complexity of SCR systems greatly increases the risk the some 

component failure could lead to a disabled vehicle. While this added risk is 

simply a cost issue with a commercial vehicle, with an emergency vehicle the 

increased risk could jeopardize the success of the emergency response mission. 

EPA has called for SCR inducement in response to potential system tampering 

which include: disconnected DEF tank level sensor, blocked DEF line or dosing 

module, disconnected DEF dosing valve, disconnected DEF pump, disconnected 

SCR wiring harness, disconnected NOx sensor, and a disconnected DEF quality 

sensor. As the diagnostics that were developed to detect tampering are in some 

circumstances the same as those used to detect real system failures, it is not 

always possible to isolate system tampering. There is also a concern around 

intermittent faults, which may not be fully resolved by vehicle service and could 

drive inducement. 

Emergency Vehicle Industry Proposal

In place of the EPA guidelines that include engine shut-down or depowering strategies, 

FAMA and AMD propose the following approach to driver inducements:

Operator Inducements

The proposed inducements for emergency vehicle operators will encourage operators to 

keep the DEF tank replenished so that they are not subjected to the unpleasant alarm that 

will sound if the tank drops to the 1/8 mark.

Operator Inducements

• Indicator lamp illuminates when the DEF tank level drops to 1⁄4 full.

• Unpleasant alarm buzzer sounds continuously when the DEF tank level drops 

to 1/8 full.

DEF Tank Size

• Emergency vehicle DEF tanks must provide sufficient capacity from the full 

mark to the 1⁄4 full mark to equal the range (in miles or hours) of the vehicle’s 

fuel capacity
Fire Apparatus Manufacturers’ Association

P.O. Box 397, Lynnfield, MA 01940-0397, (781)334-2911

Ambulance Manufacturers Division of the National Truck Equipment Association 

37400 Hill Tech Drive, Farmington Hills, MI 48331-3414, (248)489-7090

DEF Tank Sizing

By providing the EPA recommended DEF tank capacity from the full to the quarter full 

mark, the operator will always have the opportunity to fill the DEF tank before the risk of 

the audible alarm sounds.

New DEF Inducement Requirements can be added to Emergency 

Vehicle Industry Standards Documents

Fire Apparatus, Hazmat apparatus, Command and Control apparatus, and Ambulances all 

are effectively governed by industry standards. FAMA and AMD will work with the 

standards setting committees to incorporate our proposed emergency vehicle inducement 

strategy into the following documents:

• Fire Apparatus

– NFPA 1901 Standard for Automotive Fire Apparatus

– NFPA 1906 Standard for Wildland Fire Apparatus

– NFPA 1500 Standard on Fire Department Occupational Safety and 

Health Program

• Ambulances

– KKK-A-1822 Federal Specification for the Star-of-Life Ambulance

– AMD Standards

Each of these standards documents heavily influence vehicle design and personnel 

operations in the emergency response community. By adding SCR inducement 

requirements into these standards the desired requirements will be codified into the 

industry and will instill the importance of DEF replenishment in the emergency response 

community.

Additions to the NFPA standards can be made quickly through the action of a Tentative 

Interim Amendment (TIA) which takes effect in the standards immediately upon 

publication. AMD standards are under the authority of the AMD and can be revised at 

their discretion.

Swift Action Required

As of the writing of this letter we are only a few months away from production of 2010 

emissions compliant apparatus. We believe we speak for the entire emergency response 

community in urging the EPA to adopt these alternative guidelines for DEF inducements 

on emergency vehicles, accepting an audible warning strategy in lieu of the engine 

depowering and limp-home requirements.
Fire Apparatus Manufacturers’ Association

P.O. Box 397, Lynnfield, MA 01940-0397, (781)334-2911

Ambulance Manufacturers Division of the National Truck Equipment Association 

37400 Hill Tech Drive, Farmington Hills, MI 48331-3414, (248)489-7090

We applaud the EPA for its work in moving the vehicle industry toward higher standards 

of air quality and believe that this proposal will not detract from this effort. By removing 

the risks that the current DEF inducements place on emergency responders we can ensure 

a greater acceptance of new clean-air apparatus, accelerating the replacement of older 

dirty vehicles, and protecting the public we all serve.

Sincerely,

Fire Apparatus Manufacturers’ Association Ambulance Manufacturers Division

James Roger Lackore, Jr. Randy A. Hanson

Chassis Technical Committee Chair AMD President

cc Mr. Cleophas Jackson

USEPA National Vehicle and Fuel Emissions Laboratory/OAR 

2565 Plymouth Road 

Mail Code: AAIO 

Ann Arbor, MI 48105

Mr. Greg Orehowsky

Environmental Protection Agency

1200 Pennsylvania Ave., NW

Washington, DC 20460