The American Trucking Associations has filed a petition asking the Environmental Protection Agency to reconsider the 2004 Heavy Duty Diesel Engine Rule – which goes into effect in October of this year

– in light of new information concerning reliability and maintenance issues, energy impacts, life-cycle costs, and their impacts on the anticipated emissions reductions.
The 2002 Consent Decrees signed by engine manufacturers with EPA in 1998 incorporate the emissions standards mandated by the 2004 Rule, "drawing forward" the new standards to October 2002. Only one engine maker, Cummins, has thus far obtained EPA certification for its '02 emissions engines; Caterpillar has said it won't be able to meet the deadline.
ATA says new information makes it clear that the EPA’s original estimates of the costs and benefits of the rule are inaccurate.
In the petition, the association says it believes EPA incorrectly estimated the costs of the engine itself, the fuel economy penalty associated with the new engine technology, increased maintenance costs, reliability problems, the reduction in the residual value of the truck, and the adverse economic impacts upon the trucking industry and small businesses.
For instance, ATA’s petition says the EPA originally estimated that the cost of the new engines would be about $800 more. The agency now estimates the increased cost of the new engines to be closer to $9,000. Similarly, EPA underestimated the increased life cycle costs – originally about $900, but up to nearly $16,000 in a more recent report.
A recent EPA report also estimates that the new engines will be 2.5 to 5 percent less fuel efficient; when the rules were written, it believed there would be little or no fuel consumption penalty.
The costs of training technicians on the new technology has not been included in the EPA’s estimates at all, ATA notes. Oil changes will be more frequent and more costly. No one knows yet what effect the hotter-burning new engines will have on engine and component life. ATA says EPA underestimated these and other maintenance costs.
Ironically, all these increased costs will likely end up negating the pollution benefits the EPA had projected in its rule writing process. Motor carriers are avoiding buying trucks with the new engines, by pre-buying trucks this year before the new standards take effect, buy buying used trucks, and by keeping their existing trucks in service longer. “The net effect of motor carrier fleets’ rational business decisions will be to slow the turnover of the heavy duty truck fleet to the lower-emitting technology engines,” says the ATA’s petition, “thereby reducing the forecasted emissions benefits.”
The petition says the cost increases could “potentially wreak havoc on the trucking industry, which is dominated by small businesses that are ill-equipped to absorb such enormous increases in operational costs.” This negative impact will be felt throughout the U.S. economy, ATA says.