We hear that the EPA has been asking questions. In sum, what it seems to be trying to find out are the costs of compliance at EPA 10.
Why should it be doing so? On the basis that it isn't looking for neutral K Street dinner party conversation, we can only conclude that it may be trying to assess the penalties that will be levied against any market participant that fails to comply with the 2010 legislation - either via a combination of SCR and EGR, or, alternatively, by using EGR and EPA Credits - which, of course, diminish with every engine sold after 1st January next year.
It is going to be interesting to see what figures turn up here. Given that CAT was given a very easy ride in a similar situation a few years ago, we suspect that all concerned will looking provide the EPA with some very significant numbers. Daimler's HDEP engine, for example, cost reported $1.5 billion to develop, and, given that DD13, 15 and 16 are the first manifestations of the global range, we can only assume that Daimler will offer up this number for starters, plus a few bob for its inconvenience. A general trend may well be to think of a number, and to keep doubling it.
Should any OEM fail to attain EPA 10 compliance - or should that compliance end as a result of a lack of Credits - then we have to assume that the penalty likely to be levied will be little short of eye-watering. Of course, a smart move here would be to make friends with the EPA; quite how far levying accusations of almost criminal conspiracy against it will go in terms of creating a warm feeling remains to be seen.