Emissions Admissions
The Price of Entry into the Latest Engine Tier
By Jason Morgan
For contractors focused on their daily work and next job, emissions regulations seemed like distant legislation when the Environmental Protection Agency’s (EPA) Clean Air Act required more stringent emissions requirements for all new off-road diesel engines starting in 1996. Fourteen years later, Tier 4 Interim (the last Tier requirement being Tier 4 Final) is here, and while that comes as no surprise to engine manufacturers who have been working toward this goal, the emissions requirements can be quite a shock for contractors.
Last year, the California Air Resources Board (CARB) launched the first major offensive against off-road emissions by requiring contractors to register their in-use equipment with CARB, including the model year, rated horsepower, engine emissions certification level and any other emissions-reduction modifications (repower and retrofit) that have been made to the machine; remember that the term “in-use” refers to existing engines that are already in contractors’ equipment fleets. CARB then issued an equipment identification number for each vehicle, which is used to label the vehicle within 30 days of receipt.
The goal was to make contractors meet an annual fleet emissions average level or to have the best available control technology (BACT) by turning over 8 to 10 percent of their fleet’s horsepower per year if the fleet doesn’t meet the nitrogen oxide (NOx) requirement and retrofit 20 percent of the fleet’s horsepower per year if the fleet doesn’t meet the particulate matter (PM) requirements.
Strict requirements like these are the effect of the Tier requirements and these type of regulations aren’t likely to stay put in California — Illinois and New York are beginning to adopt similar legislation.
“With drastically varying programs in each state, equipment owners will need to work with their local regulatory authorities to determine how specific local programs will affect them or consult with their local dealer,” says Glen Chrusciel, Program Manager, Repower and Retrofit for John Deere Power Systems. “John Deere dealers are actively engaged with their local regulators to fully understand the requirements of local retrofit programs. They are delivering a suite of emission reduction solutions including engineered tier-up repowers, retrofit after-treatment, machine replacement and short- or long-term machine rentals.”
Where We Are Now
Your heart is racing, your stomach is growling and your mouth has gone dry. You’ve just thought about what emissions regulations could do to your operations. Don’t panic. The more you understand about engines, the less scary all these changes seem. So let’s take a look at where we’re at right now.
Tier 3 regulations are in full swing, while Tier 4 Interim is just gearing up. You’ve likely heard of Tier 3 when bidding projects. Nearly all new machines on the market today are powered by a Tier 3 engine. Any machine that hasn’t been purchased new in the past year (give or take a year depending on the manufacturer) is likely behind the curve. But as technology tends to do, Tier 3 is already yesterday’s news.
Last month at Bauma, the largest construction industry trade show in world held every three years in Munich, Germany, Tier 4 Interim engines were making headlines with everyone from Perkins and John Deere to Caterpillar, Cummins and Komatsu.
A bit of background — in 2004, the EPA published the final rule introducing Tier 4 emissions standards, which are to be phased in over the period of 2008 to 2015. The Tier 4 standards require that emissions of PM and NOx be further reduced by about 90 percent.
Tier 4 began in 2008 for all engines under 19 kilowatts (kW), and for those greater than or equal to 19 kW but less than 56 kW. For engines in the 130- to 560-kW category, and those in the category for above 560 kW, Tier 4 Interim applies in 2011. Finally, for the 56- to 130-kW category, Tier 4 Interim applies in 2012. Tier 4 Final standards generally are applicable three years after the Tier 4 Interim start date.
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| Behold! The first Caterpillar machine that meets Tier 4 Interim standards — the 336E Caterpillar excavator. With Tier 4 getting into full swing in 2011, expect a lot more of these machines to hit jobsites. |
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Tier 4 Interim regulations begin in 2011 for most power categories and Tier 4 Final is phased in beginning in 2014. Tier 4 Interim is intended to enable a gradual phase in to final regulations for manufacturers. Tier 4 Final regulations require additional reductions in NOx. Alternative phase-in periods from Interim to Final are intended to provide time to transfer technology from highway engines to off-road engines.
The difference between Tier 4 Interim and Final? An additional 50 percent reduction in NOx emissions. That’s no small potatoes. But what does it mean to you? It means that new technology is going to be coming down the pike in the next couple of years with new requirements in and of themselves. For example, Tier 4 Interim products all require the use of ultra-low sulfur diesel (ULSD) fuel containing a maximum of 15-ppm sulfur as opposed to current low-sulfur diesel (LSD), which contains 500-ppm sulfur maximum. By law, ULSD must be widely available in the United States by June 2010.
Availability of a fuel that, for all intents and purposes, doesn’t exist right now for the consumer aside, the cost of Tier 4 Interim engines is also going to be substantial.
“While the details have not yet been finalized, price actions associated with recovering the costs of Tier 4 Interim for our machines in the 130- to 560-kW power range may increase prices by as much as 12 percent over our Tier 4 Interim introduction time frame,” says Stu Levenick Caterpillar Group President. “We anticipate the first increase, starting January 1, 2011, to be about one-third of the 12 percent increase. Pricing for commercial engine applications, such as electric power, industrial and petroleum, will vary depending on product and power range. We plan to initiate broad-based emissions related price actions also starting January 1, 2011, for all products, including those utilizing transitional provisions.”
Going Retro
So where do you start? Head to your local dealer for a fleet assessment. From there, your dealer should be able to help you determine which local and/or state emissions requirements you must meet based on your iron and discuss strategies such as repowering, retrofitting or buying new equipment.
“Make sure your dealer has a designated [Tier 4] focus person responsible for spreading [Tier 4] expertise across the dealership organization,” says Joe Mastanduno, Product Marketing Manager for engines at John Deere. “Also, ask your dealer if he or she is part of a manufacturer’s ongoing emissions compliance training program that covers more than just [Tier 4] technology — you’ll want the benefits from a broad range of training, like knowledge of changing regulations and government funding resources.”
New equipment is always fun, but not if you’re strapped for cash and forced to make the purchase. Retrofitting and repowering is a viable option for newer in-use machines — Tier 1 and 2 — that don’t quite meet the current requirements. The most common after-treatment solution you’ll encounter will be the addition of diesel particulate filter (DPF). It’s a contraption that replaces your muffler and reduces your PM output.
Regardless of the system that works for your machine, these technologies must go through a verification process with CARB and/or the EPA. The verification process ensures that the device is suitable for off-highway applications and can reliably provide the advertised emissions reduction.
Retrofit programs will specify the amount of emission reduction required by the verified device, explains Chrusciel. In the case of PM reduction, there are three levels that can be specified — Level 1 (>25 percent), Level 2 (>50 percent) or Level 3 (>85 percent). Contractors should select aftermarket devices with the highest verification levels, like Level 3 PM, when retrofitting equipment to achieve best available retrofit technology (BART).
“It should be understood that some applications simply do not have the physical space to accommodate a Level 3 DPF solution, which can be up to three times larger than the muffler it replaces,” says Chrusciel. “Due to the significant proliferation of equipment and engine combinations across all horsepower ranges and applications, it is impossible to find after-treatment solutions that are universally applicable. After-treatment is not a one-size-fits-all proposition and should only be installed by highly-trained technicians.”
Reducing PM with a DPF is one thing, but reducing NOx is more complicated. Because Tier 3 and 4 Interim systems encapsulate more than just the engine, the sophisticated hardware that goes along with those systems often doesn’t fit inside older machinery, eliminating retrofitting as a viable solution. It is important for the after-treatment installer to review each application for not only operational considerations but also other important criteria such as line-of-sight and structural integrity. Some applications simply do not have the physical space to accommodate new technology. It doesn’t help that older Tier 0 and some Tier 1 engines output so much PM that, in some applications, DPFs are not a practical solution. Also, applications that are lightly loaded may also be bad applications for DPFs.
 In most cases, the dealer will select the verified device, taking into consideration the application profile of the machine, the overall installed cost and other operational specific considerations of the verified technology. But that is only half of the solution. The difficult work begins with the design and installation of the retrofit device.
The installation of the solution must be done carefully. Contractors can utilize the experience of their local dealer because no one understands the design and operation of construction machines like your local dealer.
When it comes down to it, the fleet decision-maker must evaluate the capital cost of the emissions-reduction action vs. the residual value and remaining life of the machine. Repowering or retrofitting may not always be the best emissions-reduction option. Sometimes machine replacement with the latest certified engine may make the most economic sense in the long run.
These emissions regulations come at a difficult time — the economy is still stagnating somewhere between recession and recovery and construction projects and funding are few and far between. It’s not easy making the call to buy new machines when you don’t have the money, but it’s a double-edge sword: Buy the new equipment and work or not be able to bid for jobs in areas where air quality is strictly enforced. These are regulations that aren’t going away and sooner or later every contractor is going to have to revaluate his or her fleet.
Jason Morgan is Associate Editor of Utility Contractor.
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