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 2 2 , 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) an d the Ambulance Manufacturers Division (AMD) of the National Truck Equip ment 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 1 15 member companies throughout North America . AMD is the voice of the ambulance industry, represent ing 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.

Th is 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 Reliabili ty 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 lon g 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 o nly 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 figh ting 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 lo w 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 w ell 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.



## Emerge ncy Vehicles must use SCR

The use of SCR in 2010 as a means of reducing truck emissions and therefore improving air q uality is an established path for all US engine and truck manufacturers except for

Navistar. The emergency vehicle industry must either pr oduce 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 pre scribe that the driver is provided with a warning when the DEF tank is getting low. Emergency vehicles should confo rm 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 pre scribe performance degradation strategies that are

“ sufficiently onerous ” , and that will “ disable the commerci al 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 Vehic les

While these inducements may be reasonable for vehicles in commercial operation, a ny 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 n ormal operations, keeping the DEF tank full should be no

m

ore difficult than keeping the d iesel 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 emergencyFire 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 plan n ed for ahead of time. The following examples are hypothetical situations where DEF inducements that “ disable the commercial mission of

the vehicle ” would be undesirab le :


## Examples of Situations Involving I ncreased 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 operat ion 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 strate gies 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 resp ond 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 appa ratus 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 ins ide 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 jurisdiction al and geographic borders when dictated by identified threats and risk assessments. ” The guidelines stress the need for support acr oss local, state, and tribal bo rders. 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 th e 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 ha ve not yet experi enced 2010 apparatus may be

loan ed 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 r isk 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 veh icle the increased risk could jeopardize the success of the em ergency 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 NO x 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 a lso a concern around intermittent faults, which may not be fully resolved by vehicle service and could

drive inducement

. 

## Emergency Vehicle Industry Proposal

I n place of the EPA guidelines that include engine shut

- down or de powering 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 tha t will sound if the tank drops to the 1/8 mark.



### Operator Inducements
• Indicator lamp illuminates w hen the DEF tank level drops to 1⁄4 full. • Unpleasant alarm buzzer sounds continuously when the DEF tank level dro ps to 1/8 full

.



### DEF Tank Size
• Emergency vehicle DEF tanks must provi de sufficient capacity from the full

mark to the 1⁄4 full mark to e qual the range (in miles or hours) of the vehicle ’ s fuel capacityFire 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 al arm 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 w ill work with the

standards se tting 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 operatio ns in the emergency response community. By adding SCR inducement requirements in to these standards the desired requirements will be codified into the industry and will instill the importance of DEF replenishment in the emergency response community.

Addit ions 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 discret ion

.



## 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

dir ty 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