Good morning. My name is Christine Vujovich. I am the Vice President for Environmental Policy and Product Strategy for Cummins Inc. Thank you, Mr. Chairman and Members of the Subcommittee, for the opportunity to appear here today to discuss the EPA's heavy-duty engine and diesel sulfur proposal. This is of great importance to Cummins, as well as to society at large due to its significant environmental and economic implications.
Cummins is the only independent diesel engine manufacturer in the United States and we are the world's largest producer of commercial engines over 200 horsepower. We share the goal of improving our air quality and we support the EPA's authority to regulate emissions from heavy-duty diesel engines. As a company, we are absolutely committed to pursuing technologies that benefit the environment. These technologies, however, must also provide the superior performance - including fuel economy - that our customers require.
This is why we have serious concerns about the rush to finalize the proposed rule by year's end. The schedule established by EPA is politically driven and does not allow time for the work that is necessary to assess the technical feasibility and commercial viability of technologies required to meet these standards.
We are urging EPA to provide an additional 18 to 24 months so that stakeholders can assess these issues, which are critical to the success of the ultimate rule. EPA can do this and still implement a rule for 2007. To proceed otherwise, however, would result in a rule that is unworkable and that undermines the important goal of reducing emissions and improving air quality.
For more than 20 years, my work at Cummins has revolved around the environment. It is a challenging job. We provide a technology essential to moving this nation's economy, but it is a technology that has environmental implications. That is why at Cummins we demand that everything we do lead to a cleaner, healthier and safer environment.
Our engineering and development budget each year is about 4 percent of our annual sales, and well over half of that goes directly toward environmental issues. This is a significant investment, but one that produces significant results.
I am proud to say that Cummins offers the largest portfolio of low emission and alternative fuel engines of any manufacturer. This includes building the first natural gas engine to be certified by the California Air Resources Board under its Low Emissions Transit Bus Standards and leading the industry in the provision of engines that are certified to meet EPA LEV and ULEV standards.
The work done at the transient emissions laboratory at the Cummins Technology Center is world-class, and our engineers are regularly called on to advise government experts worldwide, which we are pleased to do.
In the early 1980s, EPA developed its first transient test system based on the technology at Cummins' testing facility. When EPA needs to train its technical staff in the fundamentals of internal combustion, it turns to Cummins. Indeed, EPA researched the very rule we are here to discuss today on a Cummins six-liter engine.
Why is all of this important? While many of you in this room are familiar with Cummins, those of you who aren't don't know that it simply isn't our nature to say "NO." However, we are compelled in this instance to speak out loudly and to speak out strongly to say, "don't jeopardize the success of this rule in order to meet an arbitrary political deadline."
This rulemaking represents a lot of firsts.
This rule for the first time recognizes that fuel and engine technology must work together to achieve emissions reductions. And, for this, we applaud EPA, because ultra-low NOx and ultra-low particulate standards cannot be met without a significant reduction in diesel fuel sulfur.
These are the biggest percentage NOx and PM emission reductions of any proposed rulemaking. They come on top of already significant reductions.
Most importantly, this is the first time that proposed reductions cannot be achieved through in-cylinder and engine sub-system control technologies. This is very significant for two reasons. First, in order to achieve the proposed reductions, engine manufacturers will have to rely on technologies that we neither make nor install. Second, these technologies do not exist today.
Cummins' current best estimate of the system of aftertreatment devices necessary for compliance includes four components: a particulate trap, a sulfur trap, a NOx adsorber and an oxidation catalyst. These devices, however, are in varying stages of early development. Particulate traps are in limited production with more development required. Sulfur traps being developed, but are not developed yet. The NOx adsorber is currently in the lab, but is still years away from field-testing. And, finally the oxidation catalyst is in production, but on limited applications. (See attached diagram)
We can neither evaluate the pieces individually nor as an integrated system with the potential to achieve the proposed reductions. Moreover, we can only guess as to what impact the envisioned system of aftertreatment technologies will have on engine performance, fuel economy and cost.