Tier 4 Engines Are Here. Now What?

Originally Presented at the 32nd Annual Conference and Annual Meeting

March 2-3, 2014Tuscany Suites and Casino

Las Vegas, NV

Topics For Discussion Today

• Introduction dates for Tier 4 Interim (T4I) and Tier 4 Final (T4F).

• Tier 4 “Compliant” is not the same as Tier 4 “Certified”.– Know the difference.

• Project Owners are driving early introduction of Tier 4 Equipment.– Your projected equipment life expectancy doesn’t

count.

Introduction Dates for Tier 4 Interim (T4I) and Tier 4 Final (T4F)

EPA Non-Road Emission Regulations

Exhaust After

Treatment Required

Exhaust After

Treatment Required

T4I / T4F Availability

T4I/T4F Emission Standards(175-750 hp)

Pollutant Tier 4 Interim (g/bhp-hr) Tier 4 Final (g/bhp-hr)

Hydrocarbons 0.14 0.14

Nitrogen Oxides (NOX) 1.5 0.3

Carbon Monoxide (CO) 2.6 2.2

Particulate Matter (PM) 0.015 0.015

T4F Emission Reductions

• Comparison of Tier 1 Emission Standards to Tier 4 Final Emission Standards.

Pollutant Tier 1 (g/bhp-hr) Tier 4 Final (g/bhp-hr) Recent Reduction (%)

Hydrocarbons 1 0.14 86

Nitrogen Oxides (NOX) 6.9 0.3 96

Carbon Monoxide (CO) 8.5 2.2 74

Particulate Matter (PM) 0.4 0.015 96

T4I / T4F Availability

• Implications for transition from T4I to T4F:– T4F will become Best Available Control Technology

(BACT), restricting the ability to get air quality permits for portable equipment and stationary engines.

– Generally, permitting requirements don’t impact off-road self-propelled equipment.

– Local construction policies will shift to Tier 4.

Transition to Tier 4

• Excerpt from LA County Metro’s Green Construction Policy.

Tier 4 “Compliant” is not the same as Tier 4 “Certified”

Certified vs. Compliant

• Engine Certifications.– Engine Certifications are obtained by the

manufacturer.– An In-Use engine cannot be re-certified to a higher

tier level.• “Flex” or “Transition” Engines.

– These are lower-tier engines which EPA and CARB allow to be installed in a current model year machine.

Certified vs. Compliant

• A Tier 4 “Certified” engine meets the Tier 4 Emission Standards.

• A Tier 4 “Compliant” engines satisfies EPA’s phase in allowance, and;– Is legal to sell in the United States, and;– Is legal to operate in the United States, but;– Is not certified to the Tier 4 Emission Standards

(it’s likely Tier 3).

Certified vs. Compliant

– Purpose is to prevent product availability disruptions when the tier standards change.

– Allowances to produce these engines are provided to manufacturers based on their sales history.

– Special labels are affixed to these engines that reference the flex provisions.

– Indicated by the reference to 40 CFR 1039.625 and 13 CCR 2423(d) on the engine emissions label.

Compliant Engine Labels

Project Owners are Driving Early Introduction of Tier 4 Equipment

Early Introduction of Tier 4 Equipment

• These Permit Conditions are from a Permit issued by EPA Region 1.

These conditions generally require the use of Tier 2 and Tier 3 Engines.

However…

Early Introduction of Tier 4 Equipment

• The 226 ton NOX limit was not attainable using Tier 2 and Tier 3 equipment.

• The project owner requested that the Contractor use certified Tier 4 final equipment to maintain compliance with the 226 ton NOX limit.

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B. From the Phase 1 Start Date to the Phase 1 End Date, the Total OCS

Emissions of NOX shall not exceed 226 tons.

C. From the Phase 2 Start Date and continuing thereafter, Total OCS Emissions of NOX shall not exceed 49 tons per year in any rolling 12-month period.

Thank You For Attending

If you have any questions, please contact me:

Mike BuckantzAssociates Environmental

16882 Bolsa Chica Street, Suite 202Huntington Beach, CA 92649

(714) 625-7020 / (714) 362-9085 Faxmbuck@associatesenvironmental.com