Tuesday, April 24, 2018

CARB eyes changing compliance guidelines for SCR 2011 technology and beyond; engine battle continues


Tuesday, September 7, 2010
by DOROTHY COX

ANNETTE HEBERT (Courtesy: CARB)
ANNETTE HEBERT (Courtesy: CARB)

SACRAMENTO, Calif. — The California Air Resources Board (CARB) and the federal Environmental Protection Agency are considering changing the guidelines for OEMs to certify compliance for 2011 and future SCR (selective catalytic reduction) engines, says a CARB spokesman.

“As presented in the July [SCR] workshop” with CARB, the federal EPA and SCR OEMs, “the focus is on tightening up or shortening time or mileage that a vehicle would be allowed to operate when out of diesel exhaust fluid (DEF), using improper DEF [fluid] such as water or tampering with their [DEF] systems,” said Karen Caesar, an information officer for CARB.

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“We’re working with the EPA to make sure we’re consistent … to come up with the same types of expectations … to minimize noncompliance,” explained Annette Hebert, CARB’s division chief of mobile source operations.

“We’re working together to come up with new guidelines for the future. EPA’s comment period is still open as is ours. We’re talking one-on-one with manufacturers, the engine manufacturer’s association.

“At the workshop we heard two different viewpoints. Navistar thought the guidelines were too loose, that the guidelines for 2010 let [SCR] vehicles operate too long without DEF” (Navistar is the only OEM using Exhaust Gas Recirculation (EGR) instead of SCR for 2010 emissions technology).

“With the SCR camp, they said ‘you gave us the guidelines and we followed them,’” said Hebert. “They feel they can prevent this [noncompliance] from happening.”

CARB is currently “taking into consideration the comments we received at the workshop and afterwards as we move forward,” Caesar said. 

“However, it’s still unclear at this time whether we will actually put out new guidelines for the next model year.”

She said the 2010 heavy-duty engine standards were “harmonized” between the federal EPA and CARB “and for the first year followed similar guidelines for engine certification.”

She said CARB “often does implement rules and/or guidelines that differ from EPA if we feel it is more beneficial to the state while not being overly burdensome to manufacturers.”

Any regulatory efforts require approval from CARB, which is part of the California Environmental Protection Agency. “However, in this instance we are talking about guidelines, which are not regulatory so Board approval is not needed,” Caesar said.

Navistar had filed suit against EPA, charging that guidance given during SCR implementation constituted a rule and that rulemaking procedure wasn’t followed.

When EPA said it would look into the situation and come up with new guidelines, Navistar dropped the suit. At the July workshop proposals for new guidelines were discussed.

Navistar contended there were “loopholes” in SCR technology in that when liquid urea isn’t present it has little or no effect on vehicles’ performance, and it said that means the engines are polluting when the SCR NOx emissions control, which relies on liquid urea or DEF, isn’t engaged.

SCR proponents wanted to know why, after they had shown compliance and completed millions of testing miles, this is coming up halfway into the compliance year.

“We question the need to make modifications to SCR strategies just six months after SCR products were brought to market,” said Steve Berry, director of government relations, Volvo Powertrain, at the July workshop.

“These strategies were thoughtfully developed in good faith by EPA, CARB, and EMA applying their collective best judgment to balance SCR operation with other critical issues, not the least of which is safety.”

He said they also found it “very unsettling that the requirements the Air Resources Board has proposed in the notice for this workshop were agreed to in the context of litigation with a non-SCR manufacturer without any review by the regulated entity, the manufacturers of SCR-based products.”

He said there is also much concern over the precedent this might be setting “whereby the regulated provisions by which a technology is to be deemed acceptable for production are being driven by a competitor using alternative technology.”

John Mies, vice president, corporate communications with Mack and Volvo, said Mack and Volvo trucks with 2010 SCR engines already run cleaner than a Navistar truck without a tightening of DEF compliance measures.

And, he noted that despite the technical challenges the introduction of the 2010 SCR technology “is probably the smoothest the industry has ever seen.” Plus, “every single thing we’ve done, including the DEF inducement strategy [to make sure the DEF is maintained properly] was done with the full cooperation, knowledge and approval of both the EPA and CARB,” largely “because of concerns being raised by a single competitor.”

In an open letter to the industry, Daimler Trucks North America claimed that “Navistar is selling thousands of pre-2010 engines, while the rest of the industry is selling EPA 2010-certified products. Navistar apparently has no EPA-compliant emissions technology for 2010 and beyond, at least nothing that does not use credits to achieve compliance.”

Hebert told The Trucker that “Navistar’s 2010 engines are compliant. The difference is that they are using credits to fully comply.

“The bottom line is that the Navistar EGR engine comes in at 0.5 NOx while the SCR engines can meet the 0.2 flat standard,” she said. “Both routes are legit and considered compliant. Navistar gained credits by selling cleaner engines earlier than required previously.”

A DTNA spokesman said that it and most other SCR OEMs “are working with CARB and EPA to determine if any changes could be helpful and if so, how much lead time would be required to do so.”

However, she said, “We understand that this wouldn't be retroactive and any future changes will be implemented with reasonable lead time.”

The spokesman said it’s DTNA’s understanding that there won’t be any changes that “will impact customers who comply with the requirement to refill their urea tanks when necessary,” something that Hebert echoed.

“Carriers should just buy it [the SCR-equipped truck] and put DEF in and not tamper with the system,” she said. “As long as they do that there shouldn’t be any issues. If they tamper that’s were they will run into undesirable consequences … it’s only when there’s tampering that you’ll see a difference between 2010 and 2011 [in that] maybe they’ll shut down sooner.”

DTNA noted that “With a proven track record over 30 million miles, including several million miles driven by real customers on real roads across North America, customers have made this [SCR] the preferred technology solution by choice.

“Almost everyone in the trucking industry has collaborated with the EPA and CARB to ensure we protect the environment and serve our truck industry customers in the most efficient and effective manner possible. We are committed to continuing to do so.”

What kind of enforcement teeth would new guidelines have?

Obviously the biggest “trigger” to the trucker would be the engine derating when the DEF tank isn’t properly maintained, Hebert said, adding: “We could procure a vehicle and let it run out of DEF or put water in. As far as s truck getting stopped the DEF tank could be checked.”

Dorothy Cox of The Trucker staff can be reached for comment at dlcox@thetrucker.com.

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