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Technical Issues
EPA Compression Ignition Emission Regulation Focus of Action
AEM notes it
is imperative for the continuation
of the nonroad markets that new emission regulations are developed that demonstrate commercial viability of the diesel emissions reduction technology at
a sustainable price. |
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In response to the U.S. Environmental Protection Agency (EPA) “Nonroad Diesel Emissions Standards – Staff Technical Paper” issued in fall 2001, AEM has submitted comments on EPA’s preliminary findings as an overdue action to minimize the uncertainty associated with the next phase of a compression ignition (typically diesel) engine emission regulation. The importance for AEM having submitted such detailed comments to EPA was to provide the foundation for possible future legal action. Without such comments, AEM would have a weakened legal basis to potentially challenge EPA.
Delays Jeopardize Industry Compliance
AEM urged EPA to finalize its Tier 3/Tier 2 regulatory timetable as soon as possible, explaining that equipment manufacturers are positioned at the end of the development chain in that the emissions regulation applies to the engine, and thus equipment manufacturers can only begin to deal with the machinery redesign issues after their engine supplier(s) has established the technology path to conformity.
Any further indecision or delays could seriously jeopardize the equipment industry’s ability to meet the published effective dates (as finalized in 1998), noted AEM. Moreover, any additional diesel emission compliance provisions still under consideration should be deferred to a separate rulemaking process.
Economic Feasibility
AEM urged
EPA to finalize its Tier 3/Tier 2 regulatory timetable.
Any further indecision or delays could seriously jeopardize the equipment industry’s ability to meet the published effective dates, according
to AEM. |
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Another major concern that AEM expressed to EPA is to have assurance that the control technology for emissions reduction is commercially feasible from a technical viewpoint with sufficient leadtime for redesign, and that it is economically viable in the nonroad equipment marketplace.
The new lower-emissions machines must be economical for purchase and put into service to replace older, higher-emissions machines in order to address ambient air quality issues, according to AEM.
Customer Perceptions Key
The customer must perceive enhanced value in the new low-emissions machine for a positive buying or renting decision to be made. Therefore, it is imperative for the continuation of the nonroad markets that new emission regulations are developed that demonstrate commercial viability of the diesel emissions reduction technology at a sustainable price.
In addition, EPA must allow a sufficient period of stability between changes in emission standards to allow manufacturers to recoup the substantial investments devoted to redesigning and developing the new product lines and understand that there is a finite resource base available to address these issues.
Looking Ahead
AEM emissions experts will be busy in 2002 continuing to address these issues as EPA moves forward with the compression ignition rulemaking process. For more information contact AEM's Darrin Drollinger at 312-321-1470.
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