By Charles Westhofen

Most of us in the equipment industry are aware of the EPA’s regulations for new engines.  We’ve all been working our way through Tier 1 to Final Tier 4.  Sometimes with headaches, sometimes not.  The good news is all new engines have Final Tier 4 emissions, all horsepowers.  More good news is I’ve heard no talk of moving to Tier 5 and beyond.  So we’re done with emissions issues.  Right?  Wrong.  Back in 2013, the EPA decided to regulate existing stationary engines also.  The regulation is called RICE NESHAP, meaning Reciprocating Internal Combustion Engine and New Emission Standards for Hazardous Air Pollutants.  While the actual legislation is 50+ pages, I’ll attempt to quickly summarize.  If you have a stationary engine (application does not matter, could be a generator, compressor or something else) and it’s over 500 HP and used in a non-emergency application (over 50 hours a year), you must meet Tier 3 emission standards, at a minimum. Like I said, that’s 50+ pages summarized in 1 sentence. I left out a lot of ifs & thens.  There are numerous subsections for special circumstances.  So how do you bring an old engine up to Tier 3 standards?  Add an emission filtration system.  Many companies offer aftermarket systems that meet the standard.

OK, but how does this impact a mobile piece of equipment?  It’s on wheels, it moves here and there, from customer to customer, from job to job.  The EPA thought of that too.  Here’s the summary, you can use any Tier engine, in a mobile application, for 364 days.  For 364 days, RICE NESHAP does not apply.  However, on day 365, the RICE NESHAP now says that engine is a stationary engine.  But it’s on wheels?  Doesn’t matter.  If that engine stays on site for 365 days, it’s now considered stationary and must meet RICE NESHAP.  But can’t we swap it for another engine?  Move it across the street?  Nope.  RICE NESHAP closes all these loopholes.  And guess what?  RICE NESHAP actually applied to that engine on day 1, not day 365.  The standard must be met on Day 1 for a long term application.

So how does this impact the rental industry & its customers?  As a rental company, RICE NESHAP doesn’t directly have impact.  The rental company doesn’t have to meet RICE NESHAP, but the renter does.  But a good rental company will work with their customers to ensure all regulations are met.  Is this a long term rental?  How many hours will it run?  The rental company should discuss RICE NESHAP’s implications with the customer on day 1 for any long term rental.  Rental companies want their customers to be in compliance and much as the customers want to be in compliance.

So what’s the solution for a long term (over 364 days) rental application?  Meet Tier 3, or greater, emissions on day 1.  Or better yet, use an electrically driven model. One customer worked with their local emissions specialist and agreed that taking an engine off site for 30 days would reset the RICE NESHAP clock.  I can’t say that will always work for all applications, but working with the local emission specialist is always the right thing to do.  Swapping unit A for unit B on day 364 doesn’t work.  Unit A needed to be compliant on day 1.  Swapping serial numbers does not reset the clock.  Moving it to the other side of the building also doesn’t work.  What does work for long term rentals?  Using the correct emission engine on day 1.  Tier 3 or greater.

The best advice is to always discuss with your site emissions expert as local rules may be stricter than what RICE NESHAP requires.  As your rental provider for help meeting RICE NESHAP also.  Remember, you can use / rent any emission engine you want for 364 days but the rules change on day 365.  Make sure you’re in compliance.