2 July 2002

According to press reports, Caterpillar submitted a “pull-ahead” October ’02 engine for EPA certification. The engine, equipped with a diesel oxidation catalyst, presumably represents the Caterpillar’s ACERT technology. It is not clear what is the emission level the engine is going to be certified to. Caterpillar has indicated the ACERT technology was not likely to meet the 2004 NOx+NMHC standard of 2.5 g/bhp-hr by October 2002. If the engine is certified to a NOx+NMHC emission level exceeding 2.5 g, Caterpillar will be subject to non-conformance penalties payable for each engine it sells.

In the meantime, the American Trucking Association (ATA) petitioned the EPA and president Bush to reopen the 2004 heavy-duty diesel emission rule. The petition is based on an analysis of fleet emission reductions and the cost-effectiveness of the 2004 rule and the 2002 “pull-ahead” provision, “based on new information concerning reliability and maintenance issues, energy impacts, life-cycle costs, and their impact upon the anticipated emissions reductions,” submitted by the ATA.

The ATA argues that the cost-effectiveness for 2004-2006 implementation of the 2004 rule would be $5,238 (in 2001 dollars) per ton of NOx+NMHC reduced. This figure is more than 20 times worse than the $200 per ton as estimated by the EPA at the time of promulgation of the original rule in 1997. The ATA claims the cost effectiveness of the 2004 rule is disproportionately high compared to EPA’s other mobile source regulations, thus warranting the Agency reconsideration.

Under the “pull-ahead” provision, a part of the consent decrees signed between engine manufacturers, the EPA and the Department of Justice in 1998, most manufacturers made a commitment to meet the 2004 emission standards by 2002 October 15 months ahead of time. Manufacturers who are unable to meet the October deadline face stiff penalties for each engine sold. The ATA petition has potentially more serious repercussions, as reopening the 2004 rule by the EPA would also affect the October “pull-ahead” deadline.

The emission reduction effectiveness of the pull-ahead provision is further reduced by the massive “pre-buy” of pre-October engines by US trucking companies. Engine users fear that the post-October engines will be more expensive, more fuel consuming, more maintenance intensive, and less reliable. Most 2004-compliant engines (with the exception of Caterpillar’s ACERT) will use cooled EGR (exhaust gas recirculation) technology to reduce NOx emissions. Since only one engine is currently certified to the 2004 standard, the information on performance and reliability of these engines is still limited.

ATA petition

Source: Transport Topics