The "other" emissions: LSI engines move toward Tier 1: large spark-ignited engines hit Tier 1 in January; complex regulation extends deeply into the aftermarket; a harbinger? - special report - emissions regulations for large spark-ignited engines

Diesel Progress North American Edition, August, 2003 by Mike Osenga

Somewhat lost among all the news about diesel engine exhaust emissions regulations, another smaller, but in some ways more complex regulatory compliance battle is being played out. It is also a regulation with some interesting glimpses into possible future regulatory thinking.

On Jan. 1, nonroad, spark-ignition engines, called LSI (for large spark-ignited) by EPA, begin their first tier of exhaust emissions regulations. A second, more stringent set of LSI regulations are scheduled for implementation in 2007. The accompanying tables spell out the requirements of the 2004 LSI regulations and the additional requirements for 2007. The final rule is expected to be published this month.

The North America LSI engine market is estimated at about 150,000 units annually (in good years), between 1 and 4 L displacement, with about 75,000 to 90,000 of that being noncaptive engine sales, according to industry sources.

The engines involved, which must be certified on a yearly basis and when new engine families are developed, are mostly natural gas-fueled engines over 19 kW (25.48 hp) used in a variety of off-highway applications including sweepers, forklifts, aerial lifts and some construction equipment. Almost all will use aftertreatment to meet these regulatory requirements.

The regulation does not include recreational or competition engines, generator sets or "portable (or transportable) engines operating for at least one-year periods without moving through its lifetime." The new LSI regulation also covers marine auxiliary engines. There are other, more narrowly drawn exemptions and exclusions contained within the regulation.

There are also special provisions in this new regulation for severe-duty engines used in such applications as concrete saws and concrete pumps, as well as high-load engines and engines using noncommercial fuel.

Further, nonroad spark-ignition engines under 1 L displacement, but with outputs between 19 and 30 kW (25 and 40 hp) are not included in this LSI regulation and instead have to meet the small SI or lawn and garden-type engine standards. Natural gas engines over 250 kW (335 hp) are also not included and must meet nonroad diesel standards.

One of the reasons this standard is somewhat more complex and is causing some confusion in the marketplace is defining exactly who is responsible and liable for emissions compliance.

The marketplace is served primarily by gasoline engine manufacturers such as GM, Ford and Nissan. These base engines are typically fitted with natural gas or propane fuel systems from such companies as Impco, Woodward, Zenith, Teleflex/GFI and others.

In most cases, except for Ford, the engine and fuel system are packaged together and sold by a third party, a systems integrator.

This leads to the key question raised by the LSI regulation: who has the emissions responsibility for these engines? The engine manufacturer who doesn't make the fuel system? The fuel systems manufacturer who doesn't make the engine? The systems integrator who manufactures neither? Or the equipment manufacturer in whose machines these engines are installed?

Most equipment manufacturers have said, in essence, this is a situation the engine suppliers must work out for themselves, with the end result being a fully compliant engine being supplied to the equipment OEM, like the diesel engine markets. The counterpoint from the engine manufacturers is that there needs to be greater OEM involvement, as in most cases the engine compartment must be redesigned to include aftertreatment devices.

Toward this end, Ford has said that it will be the manufacturer of record (MOR) for its own engines. This has resulted in the formation of Zenith Power Systems LLC, now the U.S. and Canadian distributor for Nissan spark-ignited, industrial engines from 1.3 L through 4.2 L. These engines will use Zenith's Electronic Engine Management System (ZEEMS) to attain emissions compliance.

The key part of this announcement was: "Zenith Power Products will be responsible for the emissions certification of the current Nissan industrial engine line, as well as assuming the role of MOR for both EPA and CARB compliance."

It is expected that other MOR-related announcements will be forthcoming as the industry moves closer to Jan. 1. Thus, is it the corporate entity, the MOR, whoever that might be, that assumes the emissions responsibility?

Well, kind of.

One point that came through very clearly in a seminar EPA conducted on the LSI standard was that, reflecting the somewhat disparate supply chain involved with these engines, that the engine installation and maintenance manuals, in essence now become legal documents under this regulation.

If the equipment manufacturer does not follow the MOR's installation and maintenance requirements as spelled out in these manuals, and the engines are found to be out of compliance, the liability can fall to the equipment OEM. The installation manuals must spell out the placement of the catalyst, evaporative system and other emissions-related components. Further, the original certification procedure must also identify any high-cost warranty parts.