The Environmental Protection Agency (EPA) has been phasing in stricter and stricter emissions regulations for off-highway diesel engines since 1996. The cascading compliance deadlines for Tiers 1, 2, 3 and 4-interim have passed, and Tier 4 Final (T4F) regulations are in full effect for nonroad diesel engines.
Today, all newly manufactured off-highway diesel equipment (e.g., generators, air compressors, construction equipment) must be powered by a T4F-certified engine.
Even so, there’s still a sizeable population of in-service equipment powered by lower tier engines, and engines produced before the tiered regulations were introduced. As these in-service engines fail, they need to be replaced. And T4F engines don’t always work as like-for-like replacements due to their size and performance characteristics.
Knowing this, the EPA created an exception to T4F compliance.
In many situations, this exception allows fleet managers to extend the service life of legacy equipment by using previous-tier engines as drop-in replacements.
Here, we’ll cover:
- Why T4F engines don’t work as like-for-like replacements in every situation
- What the EPA exemption to T4F compliance is — and what its limitations are
- How our two EPA-compliant Engine Replacement Programs work
T4F engines aren’t always backward compatible
Early-tier engines relied on in-engine design improvements to achieve emissions reductions. Although the efficiency of the engines improved from Tier 1-3, there isn’t a significant size difference between them. In many cases, for example, a Tier 2 engine could fit in engine compartments originally housing a Tier 1 engine.
Tier 4-interim (T4i) and T4F engines saw the introduction of bulky aftertreatment systems to meet the EPA’s heightening emissions requirements. Because of the addition of emission control technologies like diesel particulate filters (DPF), selective catalytic reduction (SCR) and exhaust gas recirculation (EGR), these engines can’t always fit into the tight engine compartments of older equipment.
About the EPA’s replacement engine exemption
Codified in 40 CFR 1068.240, the EPA’s replacement engine exemption allows you to use previous-tier engines (Tiers 1, 2, 3 and 4i) to repower legacy equipment.
To qualify for the exemption, all criteria laid out in the rule must be met, including:
- The equipment in question is less than 40 years old if it’s mobile, according to 1068.240(a)(3).
- The equipment in question is less than 15 years old if it’s stationary, according to 40 CFR 60.4210(h)(i). The same criteria outlined in 40 CFR 1068.240 apply to stationary equipment.
- All characteristics (tight space claims, performance incompatibility or otherwise) that prohibit the use of a higher tier engine must be documented, according to 1068.240(b)(2)(iv). To use a Tier 2 engine, for example, you must justify the reasons why no Tier 4 Final, 4i or 3 models on the market will meet the needs of your equipment.
- Newly manufactured, previous-tier engines can only be installed as replacements for engines that are already in service. Once replaced, the old engine must be exported or destroyed, according to 1068.240(b)(3).
This exemption doesn’t introduce any new pieces of previous-tier equipment into the market, nor does it increase the overall emissions of the population of in-service equipment. In this way, the exemption lowers the burden of compliance for the industry without impeding the EPA’s primary goal of reducing harmful pollutants.
Upgrades (e.g., Tier 1 to Tier 3) are an easy, cost-effective way for owners to reduce the emissions of nitrogen oxides (NOx) and particulate matter (PM) for their equipment fleet. Even like-for-like replacements (e.g., Tier 1 to Tier 1) have a better-than-zero environmental impact, extending the service life of equipment that would otherwise be prematurely discarded.
An important caveat about the replacement engine exemption
State and local governments can mandate emissions regulations which are stricter than those set by the EPA federally. Certain locations (e.g., California, larger municipal areas, non-attainment zones) may require that equipment operating within their bounds be T4F-certified, or have certain features (e.g., diesel particulate filter) as part of a localized plan to improve air quality.
Depending on where you plan to operate your fleet, you may need to simply upgrade to T4F-certified equipment.
Two EPA-compliant options to repower your legacy equipment
Under this rule, CK Power offers two EPA-compliant programs for fleet managers and equipment owners:
- Engine Replacement / Swap Program
We’ll swap out your equipment’s existing engine for a new one that meets all current EPA requirements for your application. The engine will be new — not re-manufactured — and will come equipped with a factory warranty.
- Equipment Refurb / Replace Program
In addition to providing an EPA-compliant replacement engine, we’ll provide a scope of work to refurbish the entire piece of equipment. This means rebuilding or replacing old components to breathe new life into your assets for a fraction the cost of replacing your fleet.
We’ll work with you to determine whether you qualify for a previous-tier replacement engine under 40 CFR 1068.240. And if you do, we’ll help you compile the justifications and paperwork necessary to ensure compliance with all current EPA emissions regulations and recordkeeping requirements.
The value we provide during the engine replacement process
North America’s leading railroad company once called us on a Friday to replace an engine for a critical piece of maintenance equipment. They had exhausted all their other options — and if we didn’t (or couldn’t) replace the engine quickly, their schedule for track maintenance would be thrown off.
We had an engine in stock that, with major customizations, would work as a drop-in replacement for their piece of equipment. We disassembled the engine, reconfigured it to their specifications and, by Tuesday, the railroad company had their replacement engine.
Of course, lead times depend on availability and the needs of your particular application. But we keep a large inventory of replacement-label engines on-site, allowing for expedited lead times in many situations.
With in-house expertise across a wide range of engine brands, our team is capable of providing any compliant, drop-in engine replacement solution for any qualifying application. And as with all services and products under the CK name, we back your replacement engine with cradle-to-grave support.
Learn more about our Engine Replacement Programs here. Or, if you’re ready to get a quote to replace your engines and refurbish your equipment, reach out to our team today.