When a fleet is choosing what technology to use in 2010, as well as what engine to buy, it's important to think about your application and making sure that the engine you chose is what is right for your application and not just what the OEM has to offer.

While there are no confirmed EPA regulations on the books, we do expect the EPA to put out a proposed notice of rule making by June. What that's going to mean is that by the end of 2010 there's likely to be a new regulation on the books. That regulation is going to be focused on CO2 and will most likely be in effect by as early as 2014. This new regulation is likely to be a two-level process where 2014 will bring about the first phase of the new regulation, with the second coming around 2018.

With upcoming regulations focused on CO2 emissions, and because CO2 is a direct result of the amount of fuel burned by a vehicle, it's clear that the most fuel efficient technology today will be the one that drives us into the future regulations.

For engine OEMs using SCR technology, in order to get certification from the EPA, they also need to be certified with their OBD (on-board diagnostics). This means that fleets need to understand that the OBD will control the vehicle if it becomes outside of compliance. In other words, if the vehicle does not have diesel exhaust fluid or has a component failure within the after-treatment device, the vehicle will see d-rates but will never be completely shut down. So that means that the vehicle will always be in compliance with emissions when running down the road.

A driver will be notified of any of these d-rates by way of lights on the dash. These could be either indicator lamps that show the DEF is low, or malfunction indicator lamps or if it gets to a severe d-rate, an actual stop engine light. These different lights will indicate what type of service needs to be done on the vehicle.

There are two technologies that can meet 2010 emissions regulation requirements; the first is exhaust gas recirculation. This technology essentially increases the amount of EGR from the current engine that's available today (2007), and that the engine is going to be re-circulating more exhaust gases. This make the engine run a little less efficient, making fuel economy somewhat of an issue for this technology. However, the fact that there's no need for any additional components in terms of after-treatment devices is a strength, as well as the fact that it doesn't require the use of DEF, or diesel exhaust fluid, which is also a strength for this technology.

With SCR technology, or selective catalytic reduction, because the emissions are cleaned up down stream of the engine, it allows the engine to run more efficiently. In order to do this, the SCR technology does require some additional hardware in the after-treatment device, in addition to the use of DEF, which needs to be added to the vehicle as an additional fluid.

The engines to be certified have to go through several rigorous tests run by the OEM themselves. The first one is the deterioration testing, which essentially shows the useful life of the engine, as well as the emissions points throughout that life. The second is the actual certification test. This also is run by the OEM themselves, and submitted to the EPA for their approval. Once those tests are done, the OEM decides at what level they want to be certified at. This can be the actual regulation level, something below that if they want to have a buffer, or something above that if the OEM has accrued credits. So the OEM knows going into their certification at what limit they're going to be certified at.

The emissions level that an engine is certified at makes a difference for a fleet when talking about how "green" the engine is. If the fleet chooses to use an engine that relies on credits, they're going to be a little bit of a dirtier engine than one that doesn't, and that is all within the realm of the EPA regulation.

The process of certifying an engine with the EPA or the ARB happens on an annual basis, but in years like 2010, where there's an emissions regulations change, that process is a little bit more cumbersome. It's a process that starts about twelve months in advance of actually getting the certification. The engine OEMs work closely with the EPA and ARB throughout the year to make sure that the engine technology is going to meet the required specifications of the regulation.