Tiering Up

June 25, 2014

Twenty years ago, the Environmental Protection Agency established the first federal standards for new off-road diesel engines over 50 horsepower, to be phased in from 1996 to 2000. Until that time, diesel engine emissions had been regulated in the United States for almost 40 years, but the regulations pertained primarily to on-highway engines. Off-road engines include farm tractors, construction earthmovers, mobile generator sets on trailers, and other portable industrial engines used in temporary off-road applications.

Tier 1 resulted, in part, from the 1996 Statement of Principles signed by the EPA, the California Air Resources Bureau and engine manufacturers (Caterpillar, Cummins, Deere, Detroit Diesel, Deutz, Isuzu, Komatsu, Kubota, Mitsubishi, Navistar, New Holland, Wis-Con, and Yanmar), which led to a regulation two years later that introduced Tier 1 standards for equipment under 50 horsepower, reflecting the provisions of the SOP.

Twenty years ago, the Environmental Protection Agency established the first federal standards for new off-road diesel engines over 50 horsepower, to be phased in from 1996 to 2000. Until that time, diesel engine emissions had been regulated in the United States for almost 40 years, but the regulations pertained primarily to on-highway engines. Off-road engines include farm tractors, construction earthmovers, mobile generator sets on trailers, and other portable industrial engines used in temporary off-road applications. Tier 1 resulted, in part, from the 1996 Statement of Principles signed by the EPA, the California Air Resources Bureau and engine manufacturers (Caterpillar, Cummins, Deere, Detroit Diesel, Deutz, Isuzu, Komatsu, Kubota, Mitsubishi, Navistar, New Holland, Wis-Con, and Yanmar), which led to a regulation two years later that introduced Tier 1 standards for equipment under 50 horsepower, reflecting the provisions of the SOP. [text_ad] Tier 1 was followed by increasingly stringent Tier 2 and Tier 3 standards for all equipment, with phase-in dates from 2000 to 2008. Standards for the first three tiers were predominantly achieved through advanced engine design, improvements in the combustion process, and limited use of exhaust after-treatments. That changed in 2004, when the EPA signed the final rule introducing Tier 4 emission standards to be phased in from 2008 to 2015. Tier 4 emissions standards are another part of the Clean Air Act, a federal law to reduce air pollution. These standards require further reductions of emissions of particulate matter and nitrogen oxide by about 90%—reductions that have proved difficult for engine manufacturers to achieve. Advanced exhaust gas after-treatment similar to the control technologies used to help on-highway engines meet emission standards are now assisting the off-highway market. Effective as of Jan. 1, 2011, for all new, high-horsepower diesel engines, Tier 4i, or interim, the rule significantly cuts NOx emissions. Tier 4 interim engines must include a diesel oxidation catalyst and/or a diesel particulate filter as part of the design. Tier 4f (final) represents the highest level of clean air regulations proposed to date by requiring a significant reduction in PM. Not surprisingly, Tier 4 components will require new maintenance practices. Open crankcase ventilation filters need to be changed every 2,000 hours; diesel particulate filters should be changed every 5,000 hours. Additionally, belts, hoses, radiators, and alternators will require more frequent inspections, due to higher temperatures and operating pressures. Another change wrought by Tier 4 is that the EPA requires 15 ppm ultra-low sulfur diesel and a CJ-4 low-ash engine oil for Tier 4 machines. (During Tiers 1–3, the sulfur content in off-road diesel fuels was not limited by environmental regulations. The average in-use sulfur level was about 3,000 ppm. To enable sulfur-sensitive control technologies in Tier 4 engines—such as catalytic particulate filters and NOx adsorbers—the EPA mandated reductions in sulfur content in off-road diesel fuels.) According to the Air Resources Board, there is a sliding scale of compliance, with schedules adjusting according to the total horsepower of the fleet. However, regardless of fleet size, by January 1, 2029, 100% of all fleets will have to have at least Tier 2–compliant engines. Enforcement by local and state agencies is expected to be increased. Noncompliance penalties can include hefty fines and legal action. Decreased profit margins and potential job loss can result because many bid specifications and site permits require diesel emissions reductions. While it’s expensive to upgrade a fleet, some of the cost is expected to be offset by improved fuel efficiency. Tier 4 machines have been shown to be as much as 5% more fuel efficient than Tier 3 models. [text_ad] The Power of Procrastination But until they have to, many contractors won’t get the new Tier 4-compliant machines. Brian Heffron, product specialist with Omaha Standard Palfinger, hasn’t seen much turnover in fleets, likely due to the cost of equipment. “They’re stalling on new equipment, stretching the life [of equipment] beyond 5 to 8 years.” Not everyone is stalling. Omaha Standard Palfinger, which Heffron says is No. 1 in truck lifting and the 34th largest company in the world, has seen “huge increases in chassis customers over the last three years.” The manufacturer of truck bodies, service bodies, mechanic bodies, lift gates, bucket trucks and equipment has seen “nothing different” as a result of Tier 4, he says, although he notes that they’ve been adding a lot of sensors and wiring relay harnesses. “Our equipment runs off the truck or Miller Impact.” Miller Impact is a small diesel motor that runs hydraulics, power packs, air compressors, and other equipment, he explains. It ties into the diesel line, but doesn’t have to use DEF. “It’s a way to get around idling,” Heffron says. “It’s not a Tier 4 engine, so it’s not subject to Tier 4 restrictions [on idling].” DEF-initely Challenging DEF—or diesel exhaust fluid—is a colorless, nonhazardous, inflammable mixture of urea and ionized water (32.5% urea per 67.5% de-ionized water). It is used in selective catalytic reduction systems to break down emissions found in diesel engine exhaust. “It will become slush at 12 degrees Fahrenheit,” says Bryan Hayes, president of Valley Engineering. “We normally install heaters if a customer will experience temperatures below 18 degrees. It is metered into the selective catalyst converter. The ratio is about 4% to 8% of the diesel volume. Some manufacturers can meet Tier 4 requirements by using diesel particulate filters or diesel oxidation catalyst, or some combination of all three.” Valley Engineering manufactures fuel trailers and tanks. “We supply DEF tanks and equipment to fill equipment tanks to refill DEF tanks and to service equipment,” Hayes explains. Because the urea and water combination is very corrosive, DEF must be kept clean. Therefore, the 100-gallon tanks are made of stainless steel and most of the fittings are plastic. “We make the tanks, and choose pumps, reels, meters, special hoses, and dispensing handles made for DEF,” Hayes says. When refueling in the field, a separate nozzle is used for DEF. “You have to maintain two separate streams of fluid; you can’t use the same nozzle for fuel and DEF. It’s more complicated; you’re not just dumping it into the fuel tank.” Kept in a separate tank mounted on the frame, DEF is metered into the exhaust system, where a small amount is used to kill NOx. “It’s an additive that cools exhaust temperature,” Hayes elaborates. It puts a very small amount into the exhaust stream, he says. Use is based on the horsepower used. Hayes estimates it at 4% to 8% percent of diesel; in other words, for every 100 gallons of diesel, it uses 4 gallons of DEF. Most equipment has DEF: Cummins, Case IH, Deere… Hayes lists some of the major manufacturers. Not only is it new, but DEF is expensive. Because it freezes at 17 degrees Fahrenheit, the new Class 8 truck has a heater to heat it in the winter. “Tier 4 adds a lot of cost,” Hayes continues. “New equipment is expensive, plus you need equipment to service it. New trucks are $8,000 to $12,000. It’s a problem for guys with a lot of equipment.” Up to Standard Regardless of how they feel about it, every manufacturer of off-road equipment using high horsepower diesel engines will be using DEF to meet the EPA’s Tier 4 final emission requirements. “It’s been around for years in on-highway [applications],” says Jean Van Wyk, marketing specialist for Thunder Creek Equipment. But things are a little different for the off-road market. It’s corrosive, but it’s also sensitive to chemical impurities and is easily contaminated. Just a small concentration of trace elements that’s otherwise harmless in fuels and other fluids can contaminate an entire tank of DEF. “Contamination is a bigger factor in off-highway,” Van Wyk confirms. Non-spec containers can harm DEF, which can harm the SCR system. Even improper cleaning of an approved container can introduce contamination. She tells a story of one customer who cleaned a stainless steel tank with tap water, which introduced contaminants. “[Any one of] six things can happen if it gets contaminated,” Van Wyk says. It increases DEF consumption, is less effective at removing emissions, can cause the SCR system to malfunction, can cause the engine to shut down, can damage the engine or can void the manufacturer’s warranty. The right equipment will maintain purity, Van Wyk states. Thunder Creek, which provides fuel and service trailers, including standalone DEF delivery solutions, offers products made of 304-grade stainless steel, EPDM, and other materials that resist corrosion and help prevent contamination and meet ISO standard 22241. To further reduce the risk of contamination, Thunder Creek recommends using a closed-loop system to prevent airborne contact. To help with that, the company’s patent-pending, two-in-one pumping system allows you to fill and empty the trailer’s DEF tank using just one pumping system. In addition to preventing contamination, the proprietary system saves money by eliminating the need to purchase a transfer pump, which typically costs $1,500–$2,000. But the real value, Van Wyk says, in it is its simplicity. Looking Up For some, Tier 4 has made a positive impact. “We’ve been inundated with business,” says Rick Johnson, manager of Fleetwest Transferable Truck Bodies. “It’s had a huge impact; there’s been a huge increase in business. It’s driving sales.” Fleet West distributes fully transferable service bodies made of steel and fiberglass composite. “Our bodies fit older and new trucks,” Johnson says, explaining that “some are hanging onto old equipment and looking for ways to use it.” Because many contractors are choosing to “keep stuff running longer than in the past because they don’t want to upgrade,” Johnson says “service guys are busier and need tool boxes.” A popular service body that’s light enough for half-ton pickup trucks is Fleet West’s Load’N’Go ST-2000. Fully transferable with “no-holes-drilled” installation, the ST-2000 features a solid fixed top for added security, durable spray-in bed liner for a heavy-duty floor and a “barn door” configuration with double panel doors for easy access to supplies. The transferable aspect needs to be emphasized. Johnson mentions a customer in Indiana whose truck was involved in an accident. “He called on Friday; we delivered a new service body on Monday. They put it in an old truck so they were not waiting 8 to 10 weeks for repair [of the crashed truck]. Don’t buy an additional vehicle; drop this in another vehicle while the truck is being serviced. Productivity is important. We are the solution.” There is interest from fleets, he reports. “They need an alternative. They want the maintenance guy to use them because the downtime savings are huge.” Johnson extols the benefits of using half-ton trucks, which now provide the towing capacity and horsepower of their heavy-duty counterparts, and have the added benefit of better fuel economy. In addition, he points out, pickup trucks have higher resale than utility trucks. Alternative Ending Another impact of Tier 4 is more focus on CNG and alternative fuels, Johnson believes. “There’s been a huge resurgence in interest in CNG models.” In addition to the added cost and reduced power of diesel-powered equipment and the fact that tax advantages (section 179 tax deduction: depreciation) expire soon, he says CNG offers such benefits as the ability to refill in the field. “There are more refueling stations.” The benefits of CNG have been promulgated as providing a cleaner environment, cleaner-burning vehicle, lower fuel bills, and less dependence on foreign oil. Additional infrastructure enables more fleets to take advantage of the savings. When cities like New York City offer grants for clean tech vehicles, fleet managers can save even more by earning incentives up to $40,000 per clean fuel truck. In anticipation of increased use of CNG-powered vehicles, Fleetwest introduced the Durashell 170 for CNG pickup trucks. Cutout and emergency cutoff access for CNG tanks take up only 35% of the bed’s cargo area. The Durashell includes such standard features as abundant cargo space that is easily accessible through side access or rear barn-style doors. Its construction of lightweight fiberglass composite contributes to fuel savings. The California Rule CNG may be on the rise in restrictive areas, where stringent state requirements or lack of recharging (for electric) or refueling (for diesel) outlets aren’t conducive to other options. [text_ad] Most of the 35 air districts in California follow the California Air Resources Board rules for emissions regulations, which, in turn, are closely aligned with the EPA’s Tier 4 regulations. (The federal Clean Air Act Amendments of 1990 preempt California’s authority to control emissions from new farm and construction equipment under 175 horsepower [CAA Section 209(e)(1)(A)] and require California to receive authorization from the federal EPA for controls over other off-road sources [CAA Section 209 (e)(2)(A)].) Rules on emissions apply to all engine categories in the state, for diesel and gasoline alike: trucks and buses, off-road equipment, and portable equipment, which includes generators. As part of the clean air initiative, the EPA proposed New Source Performance Standards to define acceptable levels of emissions in large stationary generator sets. NSPS standards are intended to regulate national emissions as they become progressively stricter over time, toward the goal of achieving a steady rate of air quality improvement without unreasonable economic impact. All engines must be registered with CARB and given a certificate of compliance. There is no grandfathering exception. Contractors working in California must sign contracts certifying that all equipment is in compliance, including equipment used by subcontractors or acquired from a rental company. Fleetwest’s Johnson says that many truck drivers don’t go to California because of the rules. “It increased the cost of shipping out of California.” There are also complaints that older equipment can’t be sold in California because it doesn’t meet the new requirements. That’s forcing contractors to upgrade their fleets, whether they’re ready or not. With manufacturers passing on the costs of the new technology, it’s tough on fleet managers. “It’s too early to see all of the unintended consequences,” says Johnson. “Will costs go down in time? You can’t count on it. Volume sales may not happen soon.” One unintended consequence may be noncompliance. He maintains that because so many are waiting for the final product or are postponing costly replacements, much of the current equipment nationwide is noncompliant. “Hospitals and buildings with diesel backup power are not compliant.” One question no one seems to be asking is what happens to all the outdated machinery. Cash for clunkers? “It’s hard to speculate,” Johnson muses. “The interaction between the markets is so complex.” The good news is that Tier 4f should be the final rules change until at least 2020, so a new equilibrium should be established, stabilizing costs. The other good news—the reason behind the regulations—is that the EPA estimates that 12,000 premature deaths will be prevented annually by 2030, thanks to these standards. Annual emission reductions, once all off-road engines are replaced by Tier 4 engines, are predicted to reach 738,000 tons of NOx and 129,000 tons of PM. When the rule went into effect in 1998, the EPA estimated that NOx emissions would be reduced by a million tons per year by 2010—the equivalent of taking 35 million cars off the road—at a cost of $600 per ton of NOx reduced. The EPA estimates the cost of added emission controls at 1% to 3% of the total equipment price. Their example is a 175-horsepower bulldozer costing $230,000. It would cost up to $6,000 to add the advanced emission controls and design the bulldozer to accommodate the modifications. Finally, the EPA estimated the average cost increase for 15-ppm S fuel would be 7 cents per gallon. That figure can be reduced to 4 cents due to anticipated savings in maintenance cost because of the low sulfur diesel.

Tier 1 was followed by increasingly stringent Tier 2 and Tier 3 standards for all equipment, with phase-in dates from 2000 to 2008. Standards for the first three tiers were predominantly achieved through advanced engine design, improvements in the combustion process, and limited use of exhaust after-treatments.

That changed in 2004, when the EPA signed the final rule introducing Tier 4 emission standards to be phased in from 2008 to 2015. Tier 4 emissions standards are another part of the Clean Air Act, a federal law to reduce air pollution. These standards require further reductions of emissions of particulate matter and nitrogen oxide by about 90%—reductions that have proved difficult for engine manufacturers to achieve. Advanced exhaust gas after-treatment similar to the control technologies used to help on-highway engines meet emission standards are now assisting the off-highway market.

Effective as of Jan. 1, 2011, for all new, high-horsepower diesel engines, Tier 4i, or interim, the rule significantly cuts NOx emissions. Tier 4 interim engines must include a diesel oxidation catalyst and/or a diesel particulate filter as part of the design.

Tier 4f (final) represents the highest level of clean air regulations proposed to date by requiring a significant reduction in PM.

Not surprisingly, Tier 4 components will require new maintenance practices. Open crankcase ventilation filters need to be changed every 2,000 hours; diesel particulate filters should be changed every 5,000 hours. Additionally, belts, hoses, radiators, and alternators will require more frequent inspections, due to higher temperatures and operating pressures.

Another change wrought by Tier 4 is that the EPA requires 15 ppm ultra-low sulfur diesel and a CJ-4 low-ash engine oil for Tier 4 machines. (During Tiers 1–3, the sulfur content in off-road diesel fuels was not limited by environmental regulations. The average in-use sulfur level was about 3,000 ppm. To enable sulfur-sensitive control technologies in Tier 4 engines—such as catalytic particulate filters and NOx adsorbers—the EPA mandated reductions in sulfur content in off-road diesel fuels.)

According to the Air Resources Board, there is a sliding scale of compliance, with schedules adjusting according to the total horsepower of the fleet. However, regardless of fleet size, by January 1, 2029, 100% of all fleets will have to have at least Tier 2–compliant engines.

Enforcement by local and state agencies is expected to be increased. Noncompliance penalties can include hefty fines and legal action. Decreased profit margins and potential job loss can result because many bid specifications and site permits require diesel emissions reductions.

While it’s expensive to upgrade a fleet, some of the cost is expected to be offset by improved fuel efficiency. Tier 4 machines have been shown to be as much as 5% more fuel efficient than Tier 3 models.

Twenty years ago, the Environmental Protection Agency established the first federal standards for new off-road diesel engines over 50 horsepower, to be phased in from 1996 to 2000. Until that time, diesel engine emissions had been regulated in the United States for almost 40 years, but the regulations pertained primarily to on-highway engines. Off-road engines include farm tractors, construction earthmovers, mobile generator sets on trailers, and other portable industrial engines used in temporary off-road applications. Tier 1 resulted, in part, from the 1996 Statement of Principles signed by the EPA, the California Air Resources Bureau and engine manufacturers (Caterpillar, Cummins, Deere, Detroit Diesel, Deutz, Isuzu, Komatsu, Kubota, Mitsubishi, Navistar, New Holland, Wis-Con, and Yanmar), which led to a regulation two years later that introduced Tier 1 standards for equipment under 50 horsepower, reflecting the provisions of the SOP. [text_ad] Tier 1 was followed by increasingly stringent Tier 2 and Tier 3 standards for all equipment, with phase-in dates from 2000 to 2008. Standards for the first three tiers were predominantly achieved through advanced engine design, improvements in the combustion process, and limited use of exhaust after-treatments. That changed in 2004, when the EPA signed the final rule introducing Tier 4 emission standards to be phased in from 2008 to 2015. Tier 4 emissions standards are another part of the Clean Air Act, a federal law to reduce air pollution. These standards require further reductions of emissions of particulate matter and nitrogen oxide by about 90%—reductions that have proved difficult for engine manufacturers to achieve. Advanced exhaust gas after-treatment similar to the control technologies used to help on-highway engines meet emission standards are now assisting the off-highway market. Effective as of Jan. 1, 2011, for all new, high-horsepower diesel engines, Tier 4i, or interim, the rule significantly cuts NOx emissions. Tier 4 interim engines must include a diesel oxidation catalyst and/or a diesel particulate filter as part of the design. Tier 4f (final) represents the highest level of clean air regulations proposed to date by requiring a significant reduction in PM. Not surprisingly, Tier 4 components will require new maintenance practices. Open crankcase ventilation filters need to be changed every 2,000 hours; diesel particulate filters should be changed every 5,000 hours. Additionally, belts, hoses, radiators, and alternators will require more frequent inspections, due to higher temperatures and operating pressures. Another change wrought by Tier 4 is that the EPA requires 15 ppm ultra-low sulfur diesel and a CJ-4 low-ash engine oil for Tier 4 machines. (During Tiers 1–3, the sulfur content in off-road diesel fuels was not limited by environmental regulations. The average in-use sulfur level was about 3,000 ppm. To enable sulfur-sensitive control technologies in Tier 4 engines—such as catalytic particulate filters and NOx adsorbers—the EPA mandated reductions in sulfur content in off-road diesel fuels.) According to the Air Resources Board, there is a sliding scale of compliance, with schedules adjusting according to the total horsepower of the fleet. However, regardless of fleet size, by January 1, 2029, 100% of all fleets will have to have at least Tier 2–compliant engines. Enforcement by local and state agencies is expected to be increased. Noncompliance penalties can include hefty fines and legal action. Decreased profit margins and potential job loss can result because many bid specifications and site permits require diesel emissions reductions. While it’s expensive to upgrade a fleet, some of the cost is expected to be offset by improved fuel efficiency. Tier 4 machines have been shown to be as much as 5% more fuel efficient than Tier 3 models. [text_ad] The Power of Procrastination But until they have to, many contractors won’t get the new Tier 4-compliant machines. Brian Heffron, product specialist with Omaha Standard Palfinger, hasn’t seen much turnover in fleets, likely due to the cost of equipment. “They’re stalling on new equipment, stretching the life [of equipment] beyond 5 to 8 years.” Not everyone is stalling. Omaha Standard Palfinger, which Heffron says is No. 1 in truck lifting and the 34th largest company in the world, has seen “huge increases in chassis customers over the last three years.” The manufacturer of truck bodies, service bodies, mechanic bodies, lift gates, bucket trucks and equipment has seen “nothing different” as a result of Tier 4, he says, although he notes that they’ve been adding a lot of sensors and wiring relay harnesses. “Our equipment runs off the truck or Miller Impact.” Miller Impact is a small diesel motor that runs hydraulics, power packs, air compressors, and other equipment, he explains. It ties into the diesel line, but doesn’t have to use DEF. “It’s a way to get around idling,” Heffron says. “It’s not a Tier 4 engine, so it’s not subject to Tier 4 restrictions [on idling].” DEF-initely Challenging DEF—or diesel exhaust fluid—is a colorless, nonhazardous, inflammable mixture of urea and ionized water (32.5% urea per 67.5% de-ionized water). It is used in selective catalytic reduction systems to break down emissions found in diesel engine exhaust. “It will become slush at 12 degrees Fahrenheit,” says Bryan Hayes, president of Valley Engineering. “We normally install heaters if a customer will experience temperatures below 18 degrees. It is metered into the selective catalyst converter. The ratio is about 4% to 8% of the diesel volume. Some manufacturers can meet Tier 4 requirements by using diesel particulate filters or diesel oxidation catalyst, or some combination of all three.” Valley Engineering manufactures fuel trailers and tanks. “We supply DEF tanks and equipment to fill equipment tanks to refill DEF tanks and to service equipment,” Hayes explains. Because the urea and water combination is very corrosive, DEF must be kept clean. Therefore, the 100-gallon tanks are made of stainless steel and most of the fittings are plastic. “We make the tanks, and choose pumps, reels, meters, special hoses, and dispensing handles made for DEF,” Hayes says. When refueling in the field, a separate nozzle is used for DEF. “You have to maintain two separate streams of fluid; you can’t use the same nozzle for fuel and DEF. It’s more complicated; you’re not just dumping it into the fuel tank.” Kept in a separate tank mounted on the frame, DEF is metered into the exhaust system, where a small amount is used to kill NOx. “It’s an additive that cools exhaust temperature,” Hayes elaborates. It puts a very small amount into the exhaust stream, he says. Use is based on the horsepower used. Hayes estimates it at 4% to 8% percent of diesel; in other words, for every 100 gallons of diesel, it uses 4 gallons of DEF. Most equipment has DEF: Cummins, Case IH, Deere… Hayes lists some of the major manufacturers. Not only is it new, but DEF is expensive. Because it freezes at 17 degrees Fahrenheit, the new Class 8 truck has a heater to heat it in the winter. “Tier 4 adds a lot of cost,” Hayes continues. “New equipment is expensive, plus you need equipment to service it. New trucks are $8,000 to $12,000. It’s a problem for guys with a lot of equipment.” Up to Standard Regardless of how they feel about it, every manufacturer of off-road equipment using high horsepower diesel engines will be using DEF to meet the EPA’s Tier 4 final emission requirements. “It’s been around for years in on-highway [applications],” says Jean Van Wyk, marketing specialist for Thunder Creek Equipment. But things are a little different for the off-road market. It’s corrosive, but it’s also sensitive to chemical impurities and is easily contaminated. Just a small concentration of trace elements that’s otherwise harmless in fuels and other fluids can contaminate an entire tank of DEF. “Contamination is a bigger factor in off-highway,” Van Wyk confirms. Non-spec containers can harm DEF, which can harm the SCR system. Even improper cleaning of an approved container can introduce contamination. She tells a story of one customer who cleaned a stainless steel tank with tap water, which introduced contaminants. “[Any one of] six things can happen if it gets contaminated,” Van Wyk says. It increases DEF consumption, is less effective at removing emissions, can cause the SCR system to malfunction, can cause the engine to shut down, can damage the engine or can void the manufacturer’s warranty. The right equipment will maintain purity, Van Wyk states. Thunder Creek, which provides fuel and service trailers, including standalone DEF delivery solutions, offers products made of 304-grade stainless steel, EPDM, and other materials that resist corrosion and help prevent contamination and meet ISO standard 22241. To further reduce the risk of contamination, Thunder Creek recommends using a closed-loop system to prevent airborne contact. To help with that, the company’s patent-pending, two-in-one pumping system allows you to fill and empty the trailer’s DEF tank using just one pumping system. In addition to preventing contamination, the proprietary system saves money by eliminating the need to purchase a transfer pump, which typically costs $1,500–$2,000. But the real value, Van Wyk says, in it is its simplicity. Looking Up For some, Tier 4 has made a positive impact. “We’ve been inundated with business,” says Rick Johnson, manager of Fleetwest Transferable Truck Bodies. “It’s had a huge impact; there’s been a huge increase in business. It’s driving sales.” Fleet West distributes fully transferable service bodies made of steel and fiberglass composite. “Our bodies fit older and new trucks,” Johnson says, explaining that “some are hanging onto old equipment and looking for ways to use it.” Because many contractors are choosing to “keep stuff running longer than in the past because they don’t want to upgrade,” Johnson says “service guys are busier and need tool boxes.” A popular service body that’s light enough for half-ton pickup trucks is Fleet West’s Load’N’Go ST-2000. Fully transferable with “no-holes-drilled” installation, the ST-2000 features a solid fixed top for added security, durable spray-in bed liner for a heavy-duty floor and a “barn door” configuration with double panel doors for easy access to supplies. The transferable aspect needs to be emphasized. Johnson mentions a customer in Indiana whose truck was involved in an accident. “He called on Friday; we delivered a new service body on Monday. They put it in an old truck so they were not waiting 8 to 10 weeks for repair [of the crashed truck]. Don’t buy an additional vehicle; drop this in another vehicle while the truck is being serviced. Productivity is important. We are the solution.” There is interest from fleets, he reports. “They need an alternative. They want the maintenance guy to use them because the downtime savings are huge.” Johnson extols the benefits of using half-ton trucks, which now provide the towing capacity and horsepower of their heavy-duty counterparts, and have the added benefit of better fuel economy. In addition, he points out, pickup trucks have higher resale than utility trucks. Alternative Ending Another impact of Tier 4 is more focus on CNG and alternative fuels, Johnson believes. “There’s been a huge resurgence in interest in CNG models.” In addition to the added cost and reduced power of diesel-powered equipment and the fact that tax advantages (section 179 tax deduction: depreciation) expire soon, he says CNG offers such benefits as the ability to refill in the field. “There are more refueling stations.” The benefits of CNG have been promulgated as providing a cleaner environment, cleaner-burning vehicle, lower fuel bills, and less dependence on foreign oil. Additional infrastructure enables more fleets to take advantage of the savings. When cities like New York City offer grants for clean tech vehicles, fleet managers can save even more by earning incentives up to $40,000 per clean fuel truck. In anticipation of increased use of CNG-powered vehicles, Fleetwest introduced the Durashell 170 for CNG pickup trucks. Cutout and emergency cutoff access for CNG tanks take up only 35% of the bed’s cargo area. The Durashell includes such standard features as abundant cargo space that is easily accessible through side access or rear barn-style doors. Its construction of lightweight fiberglass composite contributes to fuel savings. The California Rule CNG may be on the rise in restrictive areas, where stringent state requirements or lack of recharging (for electric) or refueling (for diesel) outlets aren’t conducive to other options. [text_ad] Most of the 35 air districts in California follow the California Air Resources Board rules for emissions regulations, which, in turn, are closely aligned with the EPA’s Tier 4 regulations. (The federal Clean Air Act Amendments of 1990 preempt California’s authority to control emissions from new farm and construction equipment under 175 horsepower [CAA Section 209(e)(1)(A)] and require California to receive authorization from the federal EPA for controls over other off-road sources [CAA Section 209 (e)(2)(A)].) Rules on emissions apply to all engine categories in the state, for diesel and gasoline alike: trucks and buses, off-road equipment, and portable equipment, which includes generators. As part of the clean air initiative, the EPA proposed New Source Performance Standards to define acceptable levels of emissions in large stationary generator sets. NSPS standards are intended to regulate national emissions as they become progressively stricter over time, toward the goal of achieving a steady rate of air quality improvement without unreasonable economic impact. All engines must be registered with CARB and given a certificate of compliance. There is no grandfathering exception. Contractors working in California must sign contracts certifying that all equipment is in compliance, including equipment used by subcontractors or acquired from a rental company. Fleetwest’s Johnson says that many truck drivers don’t go to California because of the rules. “It increased the cost of shipping out of California.” There are also complaints that older equipment can’t be sold in California because it doesn’t meet the new requirements. That’s forcing contractors to upgrade their fleets, whether they’re ready or not. With manufacturers passing on the costs of the new technology, it’s tough on fleet managers. “It’s too early to see all of the unintended consequences,” says Johnson. “Will costs go down in time? You can’t count on it. Volume sales may not happen soon.” One unintended consequence may be noncompliance. He maintains that because so many are waiting for the final product or are postponing costly replacements, much of the current equipment nationwide is noncompliant. “Hospitals and buildings with diesel backup power are not compliant.” One question no one seems to be asking is what happens to all the outdated machinery. Cash for clunkers? “It’s hard to speculate,” Johnson muses. “The interaction between the markets is so complex.” The good news is that Tier 4f should be the final rules change until at least 2020, so a new equilibrium should be established, stabilizing costs. The other good news—the reason behind the regulations—is that the EPA estimates that 12,000 premature deaths will be prevented annually by 2030, thanks to these standards. Annual emission reductions, once all off-road engines are replaced by Tier 4 engines, are predicted to reach 738,000 tons of NOx and 129,000 tons of PM. When the rule went into effect in 1998, the EPA estimated that NOx emissions would be reduced by a million tons per year by 2010—the equivalent of taking 35 million cars off the road—at a cost of $600 per ton of NOx reduced. The EPA estimates the cost of added emission controls at 1% to 3% of the total equipment price. Their example is a 175-horsepower bulldozer costing $230,000. It would cost up to $6,000 to add the advanced emission controls and design the bulldozer to accommodate the modifications. Finally, the EPA estimated the average cost increase for 15-ppm S fuel would be 7 cents per gallon. That figure can be reduced to 4 cents due to anticipated savings in maintenance cost because of the low sulfur diesel.

The Power of Procrastination
But until they have to, many contractors won’t get the new Tier 4-compliant machines. Brian Heffron, product specialist with Omaha Standard Palfinger, hasn’t seen much turnover in fleets, likely due to the cost of equipment. “They’re stalling on new equipment, stretching the life [of equipment] beyond 5 to 8 years.”

Not everyone is stalling. Omaha Standard Palfinger, which Heffron says is No. 1 in truck lifting and the 34th largest company in the world, has seen “huge increases in chassis customers over the last three years.” The manufacturer of truck bodies, service bodies, mechanic bodies, lift gates, bucket trucks and equipment has seen “nothing different” as a result of Tier 4, he says, although he notes that they’ve been adding a lot of sensors and wiring relay harnesses. “Our equipment runs off the truck or Miller Impact.”

Miller Impact is a small diesel motor that runs hydraulics, power packs, air compressors, and other equipment, he explains. It ties into the diesel line, but doesn’t have to use DEF. “It’s a way to get around idling,” Heffron says. “It’s not a Tier 4 engine, so it’s not subject to Tier 4 restrictions [on idling].”

DEF-initely Challenging
DEF—or diesel exhaust fluid—is a colorless, nonhazardous, inflammable mixture of urea and ionized water (32.5% urea per 67.5% de-ionized water). It is used in selective catalytic reduction systems to break down emissions found in diesel engine exhaust.

“It will become slush at 12 degrees Fahrenheit,” says Bryan Hayes, president of Valley Engineering. “We normally install heaters if a customer will experience temperatures below 18 degrees. It is metered into the selective catalyst converter. The ratio is about 4% to 8% of the diesel volume. Some manufacturers can meet Tier 4 requirements by using diesel particulate filters or diesel oxidation catalyst, or some combination of all three.”

Valley Engineering manufactures fuel trailers and tanks. “We supply DEF tanks and equipment to fill equipment tanks to refill DEF tanks and to service equipment,” Hayes explains.

Because the urea and water combination is very corrosive, DEF must be kept clean. Therefore, the 100-gallon tanks are made of stainless steel and most of the fittings are plastic. “We make the tanks, and choose pumps, reels, meters, special hoses, and dispensing handles made for DEF,” Hayes says. When refueling in the field, a separate nozzle is used for DEF. “You have to maintain two separate streams of fluid; you can’t use the same nozzle for fuel and DEF. It’s more complicated; you’re not just dumping it into the fuel tank.”

Kept in a separate tank mounted on the frame, DEF is metered into the exhaust system, where a small amount is used to kill NOx. “It’s an additive that cools exhaust temperature,” Hayes elaborates. It puts a very small amount into the exhaust stream, he says. Use is based on the horsepower used. Hayes estimates it at 4% to 8% percent of diesel; in other words, for every 100 gallons of diesel, it uses 4 gallons of DEF.

Most equipment has DEF: Cummins, Case IH, Deere… Hayes lists some of the major manufacturers.

Not only is it new, but DEF is expensive. Because it freezes at 17 degrees Fahrenheit, the new Class 8 truck has a heater to heat it in the winter. “Tier 4 adds a lot of cost,” Hayes continues. “New equipment is expensive, plus you need equipment to service it. New trucks are $8,000 to $12,000. It’s a problem for guys with a lot of equipment.”

Up to Standard
Regardless of how they feel about it, every manufacturer of off-road equipment using high horsepower diesel engines will be using DEF to meet the EPA’s Tier 4 final emission requirements. “It’s been around for years in on-highway [applications],” says Jean Van Wyk, marketing specialist for Thunder Creek Equipment. But things are a little different for the off-road market.

It’s corrosive, but it’s also sensitive to chemical impurities and is easily contaminated. Just a small concentration of trace elements that’s otherwise harmless in fuels and other fluids can contaminate an entire tank of DEF. “Contamination is a bigger factor in off-highway,” Van Wyk confirms. Non-spec containers can harm DEF, which can harm the SCR system. Even improper cleaning of an approved container can introduce contamination. She tells a story of one customer who cleaned a stainless steel tank with tap water, which introduced contaminants.

“[Any one of] six things can happen if it gets contaminated,” Van Wyk says. It increases DEF consumption, is less effective at removing emissions, can cause the SCR system to malfunction, can cause the engine to shut down, can damage the engine or can void the manufacturer’s warranty.

The right equipment will maintain purity, Van Wyk states. Thunder Creek, which provides fuel and service trailers, including standalone DEF delivery

solutions, offers products made of 304-grade stainless steel, EPDM, and other materials that resist corrosion and help prevent contamination and meet ISO standard 22241.

To further reduce the risk of contamination, Thunder Creek recommends using a closed-loop system to prevent airborne contact. To help with that, the company’s patent-pending, two-in-one pumping system allows you to fill and empty the trailer’s DEF tank using just one pumping system.

In addition to preventing contamination, the proprietary system saves money by eliminating the need to purchase a transfer pump, which typically costs $1,500–$2,000. But the real value, Van Wyk says, in it is its simplicity.

Looking Up
For some, Tier 4 has made a positive impact. “We’ve been inundated with business,” says Rick Johnson, manager of Fleetwest Transferable Truck Bodies. “It’s had a huge impact; there’s been a huge increase in business. It’s driving sales.”

Fleet West distributes fully transferable service bodies made of steel and fiberglass composite. “Our bodies fit older and new trucks,” Johnson says, explaining that “some are hanging onto old equipment and looking for ways to use it.” Because many contractors are choosing to “keep stuff running longer than in the past because they don’t want to upgrade,” Johnson says “service guys are busier and need tool boxes.”

A popular service body that’s light enough for half-ton pickup trucks is Fleet West’s Load’N’Go ST-2000. Fully transferable with “no-holes-drilled” installation, the ST-2000 features a solid fixed top for added security, durable spray-in bed liner for a heavy-duty floor and a “barn door” configuration with double panel doors for easy access to supplies.

The transferable aspect needs to be emphasized. Johnson mentions a customer in Indiana whose truck was involved in an accident. “He called on Friday; we delivered a new service body on Monday. They put it in an old truck so they were not waiting 8 to 10 weeks for repair [of the crashed truck]. Don’t buy an additional vehicle; drop this in another vehicle while the truck is being serviced. Productivity is important. We are the solution.”

There is interest from fleets, he reports. “They need an alternative. They want the maintenance guy to use them because the downtime savings are huge.”

Johnson extols the benefits of using half-ton trucks, which now provide the towing capacity and horsepower of their heavy-duty counterparts, and have the added benefit of better fuel economy. In addition, he points out, pickup trucks have higher resale than utility trucks.

Alternative Ending
Another impact of Tier 4 is more focus on CNG and alternative fuels, Johnson believes. “There’s been a huge resurgence in interest in CNG models.” In addition to the added cost and reduced power of diesel-powered equipment and the fact that tax advantages (section 179 tax deduction: depreciation) expire soon, he says CNG offers such benefits as the ability to refill in the field. “There are more refueling stations.”

The benefits of CNG have been promulgated as providing a cleaner environment, cleaner-burning vehicle, lower fuel bills, and less dependence on foreign oil. Additional infrastructure enables more fleets to take advantage of the savings. When cities like New York City offer grants for clean tech vehicles, fleet managers can save even more by earning incentives up to $40,000 per clean fuel truck.

In anticipation of increased use of CNG-powered vehicles, Fleetwest introduced the Durashell 170 for CNG pickup trucks. Cutout and emergency cutoff access for CNG tanks take up only 35% of the bed’s cargo area. The Durashell includes such standard features as abundant cargo space that is easily accessible through side access or rear barn-style doors. Its construction of lightweight fiberglass composite contributes to fuel savings.

The California Rule
CNG may be on the rise in restrictive areas, where stringent state requirements or lack of recharging (for electric) or refueling (for diesel) outlets aren’t conducive to other options.

Twenty years ago, the Environmental Protection Agency established the first federal standards for new off-road diesel engines over 50 horsepower, to be phased in from 1996 to 2000. Until that time, diesel engine emissions had been regulated in the United States for almost 40 years, but the regulations pertained primarily to on-highway engines. Off-road engines include farm tractors, construction earthmovers, mobile generator sets on trailers, and other portable industrial engines used in temporary off-road applications. Tier 1 resulted, in part, from the 1996 Statement of Principles signed by the EPA, the California Air Resources Bureau and engine manufacturers (Caterpillar, Cummins, Deere, Detroit Diesel, Deutz, Isuzu, Komatsu, Kubota, Mitsubishi, Navistar, New Holland, Wis-Con, and Yanmar), which led to a regulation two years later that introduced Tier 1 standards for equipment under 50 horsepower, reflecting the provisions of the SOP. [text_ad] Tier 1 was followed by increasingly stringent Tier 2 and Tier 3 standards for all equipment, with phase-in dates from 2000 to 2008. Standards for the first three tiers were predominantly achieved through advanced engine design, improvements in the combustion process, and limited use of exhaust after-treatments. That changed in 2004, when the EPA signed the final rule introducing Tier 4 emission standards to be phased in from 2008 to 2015. Tier 4 emissions standards are another part of the Clean Air Act, a federal law to reduce air pollution. These standards require further reductions of emissions of particulate matter and nitrogen oxide by about 90%—reductions that have proved difficult for engine manufacturers to achieve. Advanced exhaust gas after-treatment similar to the control technologies used to help on-highway engines meet emission standards are now assisting the off-highway market. Effective as of Jan. 1, 2011, for all new, high-horsepower diesel engines, Tier 4i, or interim, the rule significantly cuts NOx emissions. Tier 4 interim engines must include a diesel oxidation catalyst and/or a diesel particulate filter as part of the design. Tier 4f (final) represents the highest level of clean air regulations proposed to date by requiring a significant reduction in PM. Not surprisingly, Tier 4 components will require new maintenance practices. Open crankcase ventilation filters need to be changed every 2,000 hours; diesel particulate filters should be changed every 5,000 hours. Additionally, belts, hoses, radiators, and alternators will require more frequent inspections, due to higher temperatures and operating pressures. Another change wrought by Tier 4 is that the EPA requires 15 ppm ultra-low sulfur diesel and a CJ-4 low-ash engine oil for Tier 4 machines. (During Tiers 1–3, the sulfur content in off-road diesel fuels was not limited by environmental regulations. The average in-use sulfur level was about 3,000 ppm. To enable sulfur-sensitive control technologies in Tier 4 engines—such as catalytic particulate filters and NOx adsorbers—the EPA mandated reductions in sulfur content in off-road diesel fuels.) According to the Air Resources Board, there is a sliding scale of compliance, with schedules adjusting according to the total horsepower of the fleet. However, regardless of fleet size, by January 1, 2029, 100% of all fleets will have to have at least Tier 2–compliant engines. Enforcement by local and state agencies is expected to be increased. Noncompliance penalties can include hefty fines and legal action. Decreased profit margins and potential job loss can result because many bid specifications and site permits require diesel emissions reductions. While it’s expensive to upgrade a fleet, some of the cost is expected to be offset by improved fuel efficiency. Tier 4 machines have been shown to be as much as 5% more fuel efficient than Tier 3 models. [text_ad] The Power of Procrastination But until they have to, many contractors won’t get the new Tier 4-compliant machines. Brian Heffron, product specialist with Omaha Standard Palfinger, hasn’t seen much turnover in fleets, likely due to the cost of equipment. “They’re stalling on new equipment, stretching the life [of equipment] beyond 5 to 8 years.” Not everyone is stalling. Omaha Standard Palfinger, which Heffron says is No. 1 in truck lifting and the 34th largest company in the world, has seen “huge increases in chassis customers over the last three years.” The manufacturer of truck bodies, service bodies, mechanic bodies, lift gates, bucket trucks and equipment has seen “nothing different” as a result of Tier 4, he says, although he notes that they’ve been adding a lot of sensors and wiring relay harnesses. “Our equipment runs off the truck or Miller Impact.” Miller Impact is a small diesel motor that runs hydraulics, power packs, air compressors, and other equipment, he explains. It ties into the diesel line, but doesn’t have to use DEF. “It’s a way to get around idling,” Heffron says. “It’s not a Tier 4 engine, so it’s not subject to Tier 4 restrictions [on idling].” DEF-initely Challenging DEF—or diesel exhaust fluid—is a colorless, nonhazardous, inflammable mixture of urea and ionized water (32.5% urea per 67.5% de-ionized water). It is used in selective catalytic reduction systems to break down emissions found in diesel engine exhaust. “It will become slush at 12 degrees Fahrenheit,” says Bryan Hayes, president of Valley Engineering. “We normally install heaters if a customer will experience temperatures below 18 degrees. It is metered into the selective catalyst converter. The ratio is about 4% to 8% of the diesel volume. Some manufacturers can meet Tier 4 requirements by using diesel particulate filters or diesel oxidation catalyst, or some combination of all three.” Valley Engineering manufactures fuel trailers and tanks. “We supply DEF tanks and equipment to fill equipment tanks to refill DEF tanks and to service equipment,” Hayes explains. Because the urea and water combination is very corrosive, DEF must be kept clean. Therefore, the 100-gallon tanks are made of stainless steel and most of the fittings are plastic. “We make the tanks, and choose pumps, reels, meters, special hoses, and dispensing handles made for DEF,” Hayes says. When refueling in the field, a separate nozzle is used for DEF. “You have to maintain two separate streams of fluid; you can’t use the same nozzle for fuel and DEF. It’s more complicated; you’re not just dumping it into the fuel tank.” Kept in a separate tank mounted on the frame, DEF is metered into the exhaust system, where a small amount is used to kill NOx. “It’s an additive that cools exhaust temperature,” Hayes elaborates. It puts a very small amount into the exhaust stream, he says. Use is based on the horsepower used. Hayes estimates it at 4% to 8% percent of diesel; in other words, for every 100 gallons of diesel, it uses 4 gallons of DEF. Most equipment has DEF: Cummins, Case IH, Deere… Hayes lists some of the major manufacturers. Not only is it new, but DEF is expensive. Because it freezes at 17 degrees Fahrenheit, the new Class 8 truck has a heater to heat it in the winter. “Tier 4 adds a lot of cost,” Hayes continues. “New equipment is expensive, plus you need equipment to service it. New trucks are $8,000 to $12,000. It’s a problem for guys with a lot of equipment.” Up to Standard Regardless of how they feel about it, every manufacturer of off-road equipment using high horsepower diesel engines will be using DEF to meet the EPA’s Tier 4 final emission requirements. “It’s been around for years in on-highway [applications],” says Jean Van Wyk, marketing specialist for Thunder Creek Equipment. But things are a little different for the off-road market. It’s corrosive, but it’s also sensitive to chemical impurities and is easily contaminated. Just a small concentration of trace elements that’s otherwise harmless in fuels and other fluids can contaminate an entire tank of DEF. “Contamination is a bigger factor in off-highway,” Van Wyk confirms. Non-spec containers can harm DEF, which can harm the SCR system. Even improper cleaning of an approved container can introduce contamination. She tells a story of one customer who cleaned a stainless steel tank with tap water, which introduced contaminants. “[Any one of] six things can happen if it gets contaminated,” Van Wyk says. It increases DEF consumption, is less effective at removing emissions, can cause the SCR system to malfunction, can cause the engine to shut down, can damage the engine or can void the manufacturer’s warranty. The right equipment will maintain purity, Van Wyk states. Thunder Creek, which provides fuel and service trailers, including standalone DEF delivery solutions, offers products made of 304-grade stainless steel, EPDM, and other materials that resist corrosion and help prevent contamination and meet ISO standard 22241. To further reduce the risk of contamination, Thunder Creek recommends using a closed-loop system to prevent airborne contact. To help with that, the company’s patent-pending, two-in-one pumping system allows you to fill and empty the trailer’s DEF tank using just one pumping system. In addition to preventing contamination, the proprietary system saves money by eliminating the need to purchase a transfer pump, which typically costs $1,500–$2,000. But the real value, Van Wyk says, in it is its simplicity. Looking Up For some, Tier 4 has made a positive impact. “We’ve been inundated with business,” says Rick Johnson, manager of Fleetwest Transferable Truck Bodies. “It’s had a huge impact; there’s been a huge increase in business. It’s driving sales.” Fleet West distributes fully transferable service bodies made of steel and fiberglass composite. “Our bodies fit older and new trucks,” Johnson says, explaining that “some are hanging onto old equipment and looking for ways to use it.” Because many contractors are choosing to “keep stuff running longer than in the past because they don’t want to upgrade,” Johnson says “service guys are busier and need tool boxes.” A popular service body that’s light enough for half-ton pickup trucks is Fleet West’s Load’N’Go ST-2000. Fully transferable with “no-holes-drilled” installation, the ST-2000 features a solid fixed top for added security, durable spray-in bed liner for a heavy-duty floor and a “barn door” configuration with double panel doors for easy access to supplies. The transferable aspect needs to be emphasized. Johnson mentions a customer in Indiana whose truck was involved in an accident. “He called on Friday; we delivered a new service body on Monday. They put it in an old truck so they were not waiting 8 to 10 weeks for repair [of the crashed truck]. Don’t buy an additional vehicle; drop this in another vehicle while the truck is being serviced. Productivity is important. We are the solution.” There is interest from fleets, he reports. “They need an alternative. They want the maintenance guy to use them because the downtime savings are huge.” Johnson extols the benefits of using half-ton trucks, which now provide the towing capacity and horsepower of their heavy-duty counterparts, and have the added benefit of better fuel economy. In addition, he points out, pickup trucks have higher resale than utility trucks. Alternative Ending Another impact of Tier 4 is more focus on CNG and alternative fuels, Johnson believes. “There’s been a huge resurgence in interest in CNG models.” In addition to the added cost and reduced power of diesel-powered equipment and the fact that tax advantages (section 179 tax deduction: depreciation) expire soon, he says CNG offers such benefits as the ability to refill in the field. “There are more refueling stations.” The benefits of CNG have been promulgated as providing a cleaner environment, cleaner-burning vehicle, lower fuel bills, and less dependence on foreign oil. Additional infrastructure enables more fleets to take advantage of the savings. When cities like New York City offer grants for clean tech vehicles, fleet managers can save even more by earning incentives up to $40,000 per clean fuel truck. In anticipation of increased use of CNG-powered vehicles, Fleetwest introduced the Durashell 170 for CNG pickup trucks. Cutout and emergency cutoff access for CNG tanks take up only 35% of the bed’s cargo area. The Durashell includes such standard features as abundant cargo space that is easily accessible through side access or rear barn-style doors. Its construction of lightweight fiberglass composite contributes to fuel savings. The California Rule CNG may be on the rise in restrictive areas, where stringent state requirements or lack of recharging (for electric) or refueling (for diesel) outlets aren’t conducive to other options. [text_ad] Most of the 35 air districts in California follow the California Air Resources Board rules for emissions regulations, which, in turn, are closely aligned with the EPA’s Tier 4 regulations. (The federal Clean Air Act Amendments of 1990 preempt California’s authority to control emissions from new farm and construction equipment under 175 horsepower [CAA Section 209(e)(1)(A)] and require California to receive authorization from the federal EPA for controls over other off-road sources [CAA Section 209 (e)(2)(A)].) Rules on emissions apply to all engine categories in the state, for diesel and gasoline alike: trucks and buses, off-road equipment, and portable equipment, which includes generators. As part of the clean air initiative, the EPA proposed New Source Performance Standards to define acceptable levels of emissions in large stationary generator sets. NSPS standards are intended to regulate national emissions as they become progressively stricter over time, toward the goal of achieving a steady rate of air quality improvement without unreasonable economic impact. All engines must be registered with CARB and given a certificate of compliance. There is no grandfathering exception. Contractors working in California must sign contracts certifying that all equipment is in compliance, including equipment used by subcontractors or acquired from a rental company. Fleetwest’s Johnson says that many truck drivers don’t go to California because of the rules. “It increased the cost of shipping out of California.” There are also complaints that older equipment can’t be sold in California because it doesn’t meet the new requirements. That’s forcing contractors to upgrade their fleets, whether they’re ready or not. With manufacturers passing on the costs of the new technology, it’s tough on fleet managers. “It’s too early to see all of the unintended consequences,” says Johnson. “Will costs go down in time? You can’t count on it. Volume sales may not happen soon.” One unintended consequence may be noncompliance. He maintains that because so many are waiting for the final product or are postponing costly replacements, much of the current equipment nationwide is noncompliant. “Hospitals and buildings with diesel backup power are not compliant.” One question no one seems to be asking is what happens to all the outdated machinery. Cash for clunkers? “It’s hard to speculate,” Johnson muses. “The interaction between the markets is so complex.” The good news is that Tier 4f should be the final rules change until at least 2020, so a new equilibrium should be established, stabilizing costs. The other good news—the reason behind the regulations—is that the EPA estimates that 12,000 premature deaths will be prevented annually by 2030, thanks to these standards. Annual emission reductions, once all off-road engines are replaced by Tier 4 engines, are predicted to reach 738,000 tons of NOx and 129,000 tons of PM. When the rule went into effect in 1998, the EPA estimated that NOx emissions would be reduced by a million tons per year by 2010—the equivalent of taking 35 million cars off the road—at a cost of $600 per ton of NOx reduced. The EPA estimates the cost of added emission controls at 1% to 3% of the total equipment price. Their example is a 175-horsepower bulldozer costing $230,000. It would cost up to $6,000 to add the advanced emission controls and design the bulldozer to accommodate the modifications. Finally, the EPA estimated the average cost increase for 15-ppm S fuel would be 7 cents per gallon. That figure can be reduced to 4 cents due to anticipated savings in maintenance cost because of the low sulfur diesel.

Most of the 35 air districts in California follow the California Air Resources Board rules for emissions regulations, which, in turn, are closely aligned with the EPA’s Tier 4 regulations. (The federal Clean Air Act Amendments of 1990 preempt California’s authority to control emissions from new farm and construction equipment under 175 horsepower [CAA Section 209(e)(1)(A)] and require California to receive authorization from the federal EPA for controls over other off-road sources [CAA Section 209 (e)(2)(A)].) Rules on emissions apply to all engine categories in the state, for diesel and gasoline alike: trucks and buses, off-road equipment, and portable equipment, which includes generators.

As part of the clean air initiative, the EPA proposed New Source Performance Standards to define acceptable levels of emissions in large stationary generator sets. NSPS standards are intended to regulate national emissions as they become progressively stricter over time, toward the goal of achieving a steady rate of air quality improvement without unreasonable economic impact.

All engines must be registered with CARB and given a certificate of compliance. There is no grandfathering exception. Contractors working in California must sign contracts certifying that all equipment is in compliance, including equipment used by subcontractors or acquired from a rental company. Fleetwest’s Johnson says that many truck drivers don’t go to California because of the rules. “It increased the cost of shipping out of California.”

There are also complaints that older equipment can’t be sold in California because it doesn’t meet the new requirements. That’s forcing contractors to upgrade their fleets, whether they’re ready or not. With manufacturers passing on the costs of the new technology, it’s tough on fleet managers.

“It’s too early to see all of the unintended consequences,” says Johnson. “Will costs go down in time? You can’t count on it. Volume sales may not happen soon.” One unintended consequence may be noncompliance. He maintains that because so many are waiting for the final product or are postponing costly replacements, much of the current equipment nationwide is noncompliant. “Hospitals and buildings with diesel backup power are not compliant.”

One question no one seems to be asking is what happens to all the outdated machinery. Cash for clunkers? “It’s hard to speculate,” Johnson muses. “The interaction between the markets is so complex.”

The good news is that Tier 4f should be the final rules change until at least 2020, so a new equilibrium should be established, stabilizing costs.

The other good news—the reason behind the regulations—is that the EPA estimates that 12,000 premature deaths will be prevented annually by 2030, thanks to these standards. Annual emission reductions, once all off-road engines are replaced by Tier 4 engines, are predicted to reach 738,000 tons of NOx and 129,000 tons of PM.

When the rule went into effect in 1998, the EPA estimated that NOx emissions would be reduced by a million tons per year by 2010—the equivalent of taking 35 million cars off the road—at a cost of $600 per ton of NOx reduced.

The EPA estimates the cost of added emission controls at 1% to 3% of the total equipment price. Their example is a 175-horsepower bulldozer costing $230,000. It would cost up to $6,000 to add the advanced emission controls and design the bulldozer to accommodate the modifications.

Finally, the EPA estimated the average cost increase for 15-ppm S fuel would be 7 cents per gallon. That figure can be reduced to 4 cents due to anticipated savings in maintenance cost because of the low sulfur diesel.

About the Author

Lori Lovely

Winner of several Society of Professional Journalists awards, Lori Lovely writes about topics related to waste management and technology.

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