Cummins strongly supports the Diesel Emissions Reduction Act of 2005. There are four major points that Cummins would like to present to the Committee:
1. New diesels are getting cleaner, but are very durable and the population that is in service today will be in use for years to come.
2. Retrofits of aftertreatment devices in the exhaust and engine replacements can clean up these in-service diesels and provide cost effective, immediate benefits to the environment.
3. The Diesel Emissions Reduction Act will support state and community efforts to achieve the new national ambient air quality standards (NAAQS) by funding cost- effective retrofits and engine replacements that provide the greatest benefit to the environment – particularly in environmentally sensitive and areas of high populations.
4. Ultra low sulfur diesel fuel is essential to realizing the full benefits of the Diesel Emissions Reduction Act and to achieving enormous reductions in older and newer diesel-powered engines.
ABOUT CUMMINS INC.
Cummins Inc., a global power leader, is a corporation of complementary business units that design, manufacture, distribute and service engines and related technologies, including fuel systems, controls, air handling, filtration, emission solutions and electrical power generation systems. Headquartered in Columbus, Indiana, (USA) Cummins serves customers in more than 160 countries and territories through its network of 550 Company-owned and independent distributor locations and more than 5,000 dealer locations. With more than 28,000 employees worldwide, Cummins reported sales of $8.4 billion in 2004. In 2005, Cummins was ranked #1 for corporate ethics by Business Ethics magazine.
Cummins Vision: Making people's lives better by unleashing the Power of Cummins.
That simple, yet ambitious, statement serves as the guiding vision for Cummins and its 28,000 employees. The Company takes pride in manufacturing engines, generators, filters and related products that serve the varied needs of its customers worldwide. To do that, Cummins unleashes the power of its employees: Their energy and commitment make it possible for the Company to maintain a leadership position in the markets it serves. Cummins also recognizes that with its role as a corporate leader comes a responsibility to help improve the communities in which employees work and live. It is a responsibility the Company brings to life through its actions and the activities of its employees.
NEW DIESELS ARE GETTING CLEANER AND CLEANER, BUT OLDER DIESELS ARE EXTREMELY DURABLE AND WILL BE IN SERVICE FOR YEARS TO COME.
Diesel engines truly are the workhorse of the American economy. EPA has finalized diesel fuel and new engine regulations that will reduce diesel emissions from new diesel buses and freight trucks by 99%, and non-road equipment by more than 80% from 2000 levels. EPA’s 2001 On-highway and 2004 Non-road Diesel Engine rules will greatly improve the environment and protect public health, but, according to EPA, the full benefits will not be realized until 2030 because of the durability of the 11 million engines already in service. A diesel engine used to power school buses, trucks, railroads, agriculture processes and emergency response vehicles will last for hundreds of thousands of miles over a lifetime of up to 30 years.
The Diesel Emissions Reduction Act addresses the issue of emissions from the higher-emitting engines that are currently in service and is an effective complement to EPA’s rules for new engines. Some of the technology that will be used on these new engines, along with ultra low sulfur diesel fuel, can be applied to older engines in order to significantly and immediately reduce various amounts of oxides of nitrogen (NOx) (a precursor to ozone), hydrocarbon and particulate matter (PM) emissions from these sources. The Diesel Emissions Reduction Act will enable the application of this technology to today’s in-service population and make a significant positive impact on the environment.
Retrofitting older engines with current emission reduction technology has an immediate, positive impact on the environment.
Aftertreatment exhaust devices (commonly referred to as diesel retrofit devices or “retrofits”) provide enormous benefits to air quality through significant emission reductions. Because older engines emit more particulate matter and oxides of nitrogen than newer engines, applying this technology to older vehicles can provide an even greater positive impact than when applying the technology to newer, lower emitting diesels.
Retrofits provide an immediate positive impact on the environment by reducing emissions from diesel-powered vehicles. Many of these emission-reduction devices are direct replacements for the existing vehicle muffler; other systems are more extensive (Attachment I). When an emission reduction device is installed, the benefits are immediately recognized. Depending on the pre-retrofit engine emissions levels, the duty cycle of the application and the type of retrofit device that is applied, retrofits can provide significant reductions in PM, NOx, carbon monoxide and hydrocarbons. Here are some examples. When a diesel oxidation catalyst is applied, particulate matter will be reduced by at least 20%, and carbon monoxide and hydrocarbons will be reduced by at least 70%. When a diesel particulate filter is applied, at least 85% of PM and 90% of carbon monoxide and hydrocarbons will be reduced. When Lean NOx catalysts and diesel particulate filter combinations are applied, at least 25% NOx and 85% PM are reduced (Attachment II). Many of these retrofit technologies exist today and have been in service for many years and can be confidently applied to engines that are in service. We do not have to wait until lower emitting engines are purchased in new vehicles to realize the benefits of applying this technology.
Re-powering existing vehicles with newer, cleaner engines is also a viable, cost-effective approach to improving the environment.
There are some older engines that are not ideal candidates for retrofits. Re-powering those vehicles with new engines can be a more appropriate solution to reducing emissions. The Diesel Emission Reduction Act would also support re-powering existing diesels with either new or re-manufactured engines. Re-manufactured engines, such as Cummins ReCon engines, can be a cost-effective alternative. Factory re-manufactured engines and parts are not just repaired or rebuilt. These engines are re-manufactured to the original engine specifications. Every part is completely torn down and each component goes through a controlled process, which includes cleaning, inspection, salvage, new part replacement, re-assembly and testing. The Cummins re-manufacturing business was the first in the engine industry and Cummins has remained a leader in the re-manufacturing industry by meeting rigorous quality standards required of our customers. In all cases, our re-manufactured engines meet – and sometimes exceed – the emissions standards of the original engine specification.
Diesels continue to get cleaner and cleaner, and by 2010 will produce almost negligible amounts of NOx, PM and Hydrocarbons.
From the inception of the Clean Air Act in the 1970s to the present, Cummins has reduced the NOx emissions by 90% and PM emissions by 73% from our heavy-duty, on-highway engines in the United States. Similar reductions of NOx and PM emissions have also been demonstrated in Europe and Asia.
In 2001, EPA moved forward with its rule to make heavy-duty trucks and buses run even cleaner. This rule requires reductions in PM and NOx in three steps in 2004 (pulled ahead to 2002), 2007 and 2010. By October 2002, Cummins had introduced the first complete line-up of engines to comply with EPA’s 2004 step-down in emissions. EPA’s emissions requirements will change dramatically for heavy-duty trucks between 2007 and 2010. Using ultra low sulfur diesel fuel and advanced technologies, NOx and PM from on-highway diesel engines will decline by 90% from 2004 levels. Specifically, NOx must be reduced from the current 2.5g grams/hp-hr to 0.2-grams/hp-hr by 2010. The particulate standard will drop to 0.01-g/hp-hr PM beginning in 2007 (Attachment III).
As Cummins develops products for 2010, our goal is to meet or exceed the emissions targets while retaining the performance, fuel economy and reliability desired by our customers.
THE DIESEL EMISSIONS REDUCTION ACT
The Diesel Emissions Reduction Act establishes voluntary national and state-level grant and loan programs to promote the reduction of diesel emissions. The legislation authorizes $1 billion over 5 years ($200 million annually). The bill directs that 70% of the funds are distributed by EPA, 20% of the funds go directly to states to develop retrofit programs, and the additional 10% is available as an incentive for states to match the federal dollars.
The Diesel Emissions Reduction Act recognizes the clean air challenges ahead of states and communities and puts in place a mandate-free and flexible system to help address these challenges. In order to help states and communities meet the more stringent national ambient air quality standards, the Diesel Emissions Reduction Act establishes a voluntary diesel retrofit initiative to facilitate the reduction of emissions from our older diesel fleets. This program builds on proven state and local programs that have used new technology to “retrofit” or replace older engines. In doing so, cost-effective emissions reductions can be provided for these fleets, and environmental benefits can be immediately realized.
In the near future, states must revise or develop state implementation plans (SIP’s) to reduce PM and ozone emissions in order to meet the new national ambient air quality standards. These states and communities must have the opportunity and flexibility to design programs to fit their own needs. The Diesel Emissions Reduction Act will be a critical tool to help states bring areas into attainment by encouraging the retrofitting or replacement of diesel engines currently in service.
Under this legislation, the Federal and state government authorities awarding the grants will see a wide range of proposals on how to address air quality challenges. The proposals will specifically quantify emission reductions, the geographic area that will be impacted, population densities and whether there are private or state funds available to match government funds. This legislation recognizes that there is not a common emission reduction solution that it best for every circumstance. There are a number of technologies that can be implemented to modernize existing diesel fleets. Furthermore, the bill recognizes retrofitted aftertreatment systems and remanufactured or new engine replacement as applicable options for funds.
Cummins also strongly supports the provisions in the bill that help bring tomorrow’s technologies into the marketplace. There are many emerging technologies under development that may provide more dramatic reductions in emissions or may prove to be more cost effective than current technologies. The bill provides a mechanism to utilize these emerging technologies on a controlled basis, providing certain conditions are met.
The Diesel Emissions Reduction Act represents a sound use of taxpayer dollars. Diesel retrofits have proven to be one of the most cost-effective emissions reductions strategies. Retrofits can provide immediate emission reductions after installation, and can be particularly important in metropolitan areas where high volumes of heavy-duty trucks and equipment are in service and/or where major construction projects are underway for long periods of time. According to EPA, the Diesel Emissions Reduction Act would leverage existing funding, and if fully utilized, could result in a reduction of approximately 70,000 tons of PM over 30 years. EPA estimates that 70% of those reductions come in the first 10 years of the program, and 94% come in the first 20 years.
The ultimate goal in environmental policy is a “win-win;” that is, a policy solution that cleans the environment and allows the economy to flourish. The Diesel Emissions Reduction Act will not only clean the air, but allow the economy to flourish by preserving and increasing domestic manufacturing jobs that produce after treatment devices, engines and other emissions reductions alternatives.
Cummins wants to congratulate Sens. Voinovich and Carper on their efforts to unite our industry with the environmental community on this legislation. This legislation serves as a model for finding solutions to environmental problems. It is our hope that the process that Sens. Voinovich and Carper put together to craft this legislation, can also serve to advance the use of high technology clean diesel power. With the enormous strides in emissions reductions and the dramatic fuel-efficiency benefits, clean diesel should be given serious consideration as a key component to a national energy policy. When using ultra low sulfur diesel fuel, SUVs in 2007 have the potential to experience a fuel efficiency increase greater than 30% (over a gasoline-powered vehicles) and meet EPA’s Tier II emissions standards.
ULTRA LOW SULFUR DIESEL FUEL IS KEY TO IT ALL
Ultra low-sulfur diesel fuel is essential to realizing the full benefits of the Diesel Emissions Reduction Act, meeting EPA’s 2007 and 2010 standards and helping clean up older, non-retrofitted diesel engines.
To meet EPA’s regulations and the marketplace’s demands, the diesel industry has and will continue to invest billions to advance cleaner burning and more fuel-efficient engines. To achieve reductions in the existing and future fleets, we must develop highly integrated systems, which include engine and aftertreatment technologies. These technologies will result in near zero emissions by 2010. A key to enabling this new technology is ultra low-sulfur diesel (ULSD) fuel. That is, diesel fuel with a sulfur content of 15 parts per million (ppm). There has been discussion that some parties would like to alter or delay the ULSD fuel standard. The White House and EPA have assured Cummins that they are fully committed to going forward with the fuel standards and the regulations. Cummins requests that Congress make every effort to ensure these ultra low sulfur diesel standards are not compromised. Because new, high- technology diesel emissions systems rely on ultra low sulfur diesel fuel, any change in the 15 ppm standard would undo EPA’s rules and severely hamper the effectiveness of the Diesel Emissions Reduction Act.
There is a strong correlation between the sulfur level in diesel fuel and PM emissions from diesel engines. All engines that use 15 ppm sulfur diesel fuel will emit less PM. For new engines produced after 2007, the 15 ppm cap fuel allows the efficient use of particulate filters reduce emissions by up to 90% from 2004 levels. For engines currently in service, the 15 ppm fuel reduces PM emissions immediately and allows the use of retrofit devices. Consequently, without 15ppm fuel, the expected emissions reductions from the clean diesel engine rule are in jeopardy, and it will be even more difficult for states to achieve attainment with ambient air quality standards. Lack of 15ppm diesel fuel would also severely hamper the effectiveness of the Diesel Emissions Reduction Act. For example, the diesel particulate filter (a popular retrofit option) used on the Washington Metropolitan Transit Authority bus, which was present at the unveiling of this legislation in June, will eliminate 90% of particulate matter, carbon monoxide and hydrocarbon emissions. But it requires ultra low sulfur diesel fuel for the technology to operate effectively.
In 2001, EPA published and President Bush approved an unprecedented final rule implementing clean diesel engine and fuel regulations. Those rules require engine manufacturers to invest billions of dollars to implement both PM and NOx aftertreatment technologies to achieve an overall 90% reduction in diesel engine emissions. As was and is recognized, those technologies and emission limits are only achievable with the corresponding requirement to reduce the sulfur content of diesel fuel to 15 ppm or less (down from 500 ppm).
During that 2001 rulemaking process, engine manufacturers argued that the sulfur content of diesel fuel should be at or near zero. However, as a compromise, engine manufacturers ultimately agreed to a 15 ppm cap. Without a maximum 15 ppm cap, engine manufacturers could not have successfully implemented aftertreatment technologies required to meet the stringent new exhaust emission levels in place for model year 2007.
There is no longer enough time to develop, test, manufacture and implement a new strategy based on increased sulfur levels in the fuel. Engine manufacturers have invested billions of dollars in new technology to meet the clean diesel engine standards, and the technologies selected are based on having 15 ppm cap sulfur fuel available. Any increase in the sulfur cap level required by the regulation will invalidate a basic assumption used by engine manufacturers and aftertreatment equipment providers in their design and development efforts to develop compliance strategies. EPA provided a long lead time to give all affected industries time to comply. Engine manufacturers have done their part by engineering and developing systems needed to meet the standards.
Recently, EPA offered a 45-day extension to the transition period to introduce ultra low sulfur diesel (from September 1, 2006 to October 15, 2006) into the market. EPA is expected to issue a direct final rule in the near future. With this extension, Cummins believes that every party involved in this rule has had more than ample time to plan and invest in complying with their portion of EPA’s rule. Cummins now looks forward to reaching 2007 so the environmental benefits of EPA’s rule can be achieved.
Cummins again congratulates Sens. Voinovich and Carper for their leadership on this legislation and thanks Sens. Inhofe, Clinton, Jeffords, Isakson, Ombama, Lautenberg, and Alexander for their support.
Cummins strongly supports the Diesel Emissions Reduction Act of 2005. While diesels are getting cleaner and cleaner, diesels are very durable and the population that is in service today will be in use for years to come. Retrofits and re-powers can clean up these in-service diesels and provide cost effective, immediate benefits to the environment. The Diesel Emissions Reduction will support state and community efforts to achieve the new national ambient air quality standards (NAAQS) by funding cost- effective retrofits and replacements that provide the greatest benefit to the environment – particularly in environmentally sensitive and areas of high populations. Ultra low-sulfur diesel is essential to realizing the full benefits of the Diesel Emissions Reduction Act and achieving enormous reductions in older and newer diesel-powered engines.
Cummins looks forward to working with you in helping older diesel engines run cleaner and ensuring the availability of ultra low sulfur diesel fuel, so that America can benefit from using clean and fuel efficient advanced diesel technologies.