GETTING CLEAN AIR SOLUTIONSFOR LOCOMOTIVES ON TRACK

Smokestacks on Rails

Smokestacks on RailsGETTING CLEAN AIR SOLUTIONS

FOR LOCOMOTIVES ON TRACK

AUTHORSJanea Scott

Hilary Sinnamon

AcknowledgmentsWe would like to thank technical consultant Sandra Goodman, from E3 Ven-tures, for her detailed analysis of the health benefits of various locomotive pollu-tion control scenarios. We deeply appreciate the contributions and insightprovided by Jana Milford, Vickie Patton, and Nancy Spencer. We very muchappreciate the help of Sarah Barbrow, Emily Churg and Jordan Diamond forcompleting quickly and successfully numerous tasks involved in writing and pro-ducing the report. And last, but certainly not least, we extend our sincere appreci-ation to the many people who lent their knowledge, ideas, wisdom and experienceto reviewing several iterations of this report.

Environmental Defense does not endorse any particular air pollution controltechnology or method. This report factually describes air pollution control tech-nologies and methods based on published reports.

Our missionEnvironmental Defense is dedicated to protecting the environmental rights of allpeople, including the right to clean air, clean water, healthy food and flourishingecosystems. Guided by science, we work to create practical solutions that win last-ing political, economic and social support because they are nonpartisan, cost-effective and fair.

©2006 Environmental Defense

100% recycled (100% post-consumer) totally chlorine free paper

The complete report is available online at www.environmentaldefense.org.

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Executive summary iv

Introduction 1

Chapter 1: All aboard—trains carry freight and people across the 3United States

Chapter 2: Smokestacks on rails—locomotives’ impact on public health 7and the environment

Chapter 3: Federal delays in strengthening standards impose a heavy 11burden on human health

Chapter 4: Locomotives impose a heavy pollution burden on urban and 14rural areas across the nation

Chapter 5: Technology is on hand to curb locomotive emissions today 19

Chapter 6: “I think I can, I think I can”—successful emissions reduction 23programs

Chapter 7: National clean air solutions for locomotives 28

Appendix A: Methodology for estimating health benefits of locomotive 30emission reductions

Glossary 33

Notes 35

Contents

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Trains play a vital role in American com-merce. Every year, they move billions oftons of freight and millions of peoplethroughout the nation. However, theyalso deliver pollution, contributing sig-nificantly to air quality problems acrossthe country. Many of today’s locomotivesare powered by high-polluting dieselengines. Diesel exhaust is made up of:

• particulate matter (PM), implicated ina host of respiratory problems and tensof thousands of premature deathsevery year;

• smog-forming oxides of nitrogen (NOx);

• sulfur dioxide (SO2), which formsharmful particulate pollution and fallsback to earth as acid rain;

• a noxious brew of toxic chemicals thattogether pose a cancer risk greater thanthat of any other air pollutant; and

• greenhouse gases that contribute toglobal warming.

Executive summary

In 2004, the U.S. EnvironmentalProtection Agency (EPA) repeatedlycommitted to strengthen federal cleanair standards for locomotives. Indeed,EPA publicly announced plans to issueproposed national emission standards in2005 and to finalize those standards bymid-2006. But EPA has failed to act.This report documents the serioushealth impacts associated with each yearof delay in federal action to clean upthese smokestacks on rails.

Diesel locomotive emissionspollute our air and harm publichealthThe use of these dirty diesel locomotiveengines to transport freight has risendramatically in the past 35 years fromnearly 800 million ton-miles in 1970 tomore than 1.6 billion ton-miles in 2004(see Figure 1), and is projected tocontinue at a brisk pace. In fact, the

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FIGURE 1U.S. freight rail in ton-miles 1970–2004

Source: Bureau of Transportation Statistics, Table 1-46a: U.S. Ton-Miles of Freight. http://www.bts.gov/publications/national_transportation_statistics/html/table_01_46a.html.

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amount of freight carried by rail isexpected to increase by another 50% by2030. Currently, locomotives moveabout 42% of our nation’s freight asmeasured in ton-miles.

As a result, these diesel enginescontribute significantly to nationalair pollution. EPA estimates that in2006 locomotives will emit 930,000tons of ozone-forming oxides ofnitrogen (NOx)—as much as 120 coal-fired power plants. Locomotives arealso responsible for more than 32,000tons of particulate pollution; theseparticles, which can be inhaled deepinto the lungs, are probable carcino-gens. The particulate pollution fromlocomotives is comparable to theemissions from more than 70 coal-firedpower plants.1

Table 1 takes a closer look at thesmog-forming pollution from loco-

motive engines in six major U.S. citieshard hit by ground-level ozone. Theextensive locomotive NOx pollutionlevels in these communities are com-pared with automobiles, based on thesmog limits in effect for today’s newmotor vehicles.

Using EPA’s methodology, Envi-ronmental Defense estimates that the2006 particulate and NOx emissionsfrom locomotives will be associatedwith more than 3,000 premature deathsthis year (Table 2).2 Exposure to thispollution may also contribute to, amongother health effects, more than 4,000non-fatal heart attacks, approximately61,000 cases of acute bronchitis andexacerbated asthma in children, andnearly 290,000 lost workdays. Theeconomic impact of these adversehealth effects will total over $23 billionthis year.

TABLE 1Smog-forming emissions from locomotives in six major cities andcomparable number of today’s new automobilesa

Locomotive NOx emissions Equivalent numberUrban area (tons/year) of automobilesb

Los Angelesc 12,000 13,000,000Dallas-Fort Worth 4,500 4,900,000Houston-Galveston 6,500 7,000,000Chicago 23,000 25,000,000Detroit 2,100 2,300,000Baltimore 2,600 2,800,000a Emissions data for Houston and Dallas is from 2002. Emissions data from the other cities is from 2003.b Calculations based on Tier 2 NOx emissions standard (0.07gNOx/mile) for highway vehicles and 12,000 vehicle miles/

year. Bureau of Automotive Repair, Engineering and Research Branch, State of California, “Methodology for Calcu-lating Vehicle Miles Traveled (VMT)”, September 30, 2000, Report 2000-06, available at http://www.epa.gov/otaq/regs/im/vmt.pdf

c Emissions data is for the South Coast Air Quality Management District

TABLE 2Adverse health effects associated with 2006 locomotive pollution

Premature deaths 3,400Non-fatal heart attacks 4,400Acute bronchitis and asthma exacerbations in children 61,000Lost work days 290,000Total economic impact of adverse health effects $23.2 billion

EPA estimatesthat locomotiveswill release930,000 tons ofsmog-formingNOx this year,comparable to120 coal-firedpower plants.

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Each year of EPA delay hasserious health effectsEPA has found that locomotive dieselengines can be designed to use the samehigh-efficiency exhaust emission con-trols now being developed for largehighway and nonroad diesel engines.These technologies will allow loco-motive engines to reduce NOx andparticulate matter emissions by 90%.In 2004, when EPA publicly announceda new initiative to strengthen pollutioncontrols for locomotives, EPA also indi-cated new clean air standards could beimplemented beginning in 2011.

Table 3 shows the estimated healthbenefits in the year 2030 associated withimplementing new locomotive emissionstandards that are 90%, 75% or 50%more protective than today’s tighteststandard (Tier 2).3 Our analysis indi-cates a 90% reduction implementedin a 2011 compliance schedule wouldannually prevent over 2,000 prematuredeaths, approximately 2,600 non-fatalheart attacks, 36,000 bronchitis andasthma exacerbations, and nearly170,000 lost work days and wouldrealize more than $13 billion in healthbenefits by 2030.4

By comparison, Table 3 also shows thatconsiderably lower health protectionsare realized from slower and less pro-tective federal standards. For example,standards to limit locomotive pollutionfrom new engines by 50% beginning in2013 would, upon advanced implementa-tion in 2030, allow an estimated 900more deaths, 1,200 more non-fatal heartattacks, 16,000 more cases of bronchitisand asthma exacerbations, and about75,000 lost work days over rigorousstandards that take effect in 2011. Theywould forego some $6 billion in healthbenefits annually. In short, our analysisdemonstrates that delays in EPA actionor weak standards will impose a heavyburden on human health.

Clean air solutions are on tracktodayStates and localities across the UnitedStates are working to meet nationalhealth-based air quality standards forozone and particulates—a problem towhich locomotive pollution is a major con-tributor. And science points overwhelm-ingly to the need for more protectivenational standards for particulates and

TABLE 3Projected health benefits in 2030 with stricter NOx and PM2.5 locomotive emissions standards

Children’sPercentage bronchitiscleaner than Year new Annual Non-fatal Respiratory and asthma

current standards health benefits Premature heart attacks hospital visits exacerbations Work loss daysTier 2 would in billions deaths avoided avoided avoided avoided avoided

standards take effect of dollars annually annually annually annually annually

90% 2011 13.7 2,000 2,600 870 36,000 170,0002013 12.5 1,800 2,400 800 33,000 150,0002015 11.3 1,700 2,100 720 30,000 140,000

75% 2011 11.7 1,700 2,200 750 31,000 140,0002013 10.7 1,600 2,000 680 28,000 130,0002015 9.7 1,400 1,800 620 25,000 120,000

50% 2011 8.3 1,200 1,600 530 22,000 100,0002013 7.7 1,100 1,400 490 20,000 95,0002015 7.0 1,000 1,300 450 18,000 87,000

Delays in EPAaction or weakstandards willimpose a heavyburden onhuman health.

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ozone and the imperative for greaterprogress in communities across thecountry in safeguarding human health.

The good news is the foundation forcleaner locomotives is at hand. Ultra lowsulfur diesel fuel is being delivered topumps across America today. Lowersulfur levels enable the state of the arttechnologies that can significantlyreduce the level of pollution comingfrom these engines. Indeed, manufac-turers have been developing technolo-gies to reduce locomotive emissions. Forexample, hybrid switcher engines, calledGreen Goats, use a combination ofrechargeable batteries and a low-emis-sions diesel engine to cut emissions by80–90% and reduce fuel use by 40–70%.And to reduce idling, various technolo-gies have been introduced, includingauxiliary power units, which keepengines warm while they are turned off.

Furthermore, communities across thecountry have set up pilot projects to curblocomotive emissions and reduce fuelconsumption. For example, in Chicagoan anti-idling project saved over 14,000gallons of fuel and in Texas, more than a

dozen hybrid-diesel Green Goat trainshave been deployed. While these volun-tary pilot programs play an importantrole in incubating new technologies,they are often limited in scope.

National leadership is essentialto clean up the smokestacks onrailsEnvironmental Defense calls on EPAto fulfill its public commitment tostrengthen the nation’s clean air stan-dards for these smokestacks on rails.The demands on the nation’s freightsystem have steadily risen over the past35 years. At the same time, haulingfreight by rail is more efficient thantruck transport. Timely cleanup of thenation’s fleet of locomotive enginescould help clear the way for extensivehuman health and environmental bene-fits by lowering soot, smog and globalwarming pollution while also reducinghighway and roadway congestion. Fed-eral leadership is essential to keep thesefar-reaching clean air solutions for loco-motive engines on the right track.

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Locomotives perform many vital tasksin our busy society. Passenger trains,such as Amtrak, usher people from cityto city and coast to coast. Freight car-riers, like Union Pacific and BurlingtonNorthern Santa Fe, haul cargo longdistances. Line-haul freight trainstransport containers full of merchandise,food and other cargo between ports andinland cities. Specialized trains calledswitchers assemble and disassembleother trains and transfer freight betweenships, line-haul trains and trucks. How-ever, as crucial as locomotives are to oureconomic health, they also present asignificant threat to public health andthe environment.

While some commuter rail is electric,many locomotives are powered by dieselengines. Exposure to diesel pollution isassociated with a wide range of adversehealth effects including cancer, neuro-logical damage, a weakened immunesystem, respiratory disease and cardio-vascular disease.5 Diesel particulate

Introduction

matter (PM) is especially harmful andcan lead to premature death. In addi-tion, diesel engines emit smog-formingoxides of nitrogen (NOx) that contributeto unhealthy ozone levels and more than40 toxic compounds, and large quanti-ties of global warming pollutants.

Many cities already suffering fromunhealthy levels of air pollution arefinding that locomotives are a signifi-cant contributor to that pollution. Afew, including Chicago and Houston,have taken steps to reduce those emis-sions in the absence of protective federalstandards. Successful programs helpfund the implementation of newtechnologies like hybrid “Green Goat”engines and anti-idling devices. Whilevoluntary programs play an importantrole in incubating new technologies anddemonstrating the feasibility and effec-tiveness of emissions controls, they areoften limited in scope. These types ofprograms are too beneficial and im-portant not to implement nationally.

Diesel freightlocomotives.

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Without comprehensive federal emis-sion standards for locomotives, stateand local leaders have limited means toachieve needed pollution reductions intheir communities. In fact, while manyother diesel powered motor vehicles,including heavy duty trucks and buses,farm, construction, mining and industrialequipment are subject to advancedfederal emissions standards that helpprotect public health from the deleteri-ous effects of diesel exhaust, locomotivesare not yet subject to today’s rigorousstandards and continue to be a threatto public health across the nation.

Because of the long life of a trainengine, often up to 40 years, any delayin establishing strengthened standardsprolongs adverse human health andenvironmental impacts. A meaningfulprogram must address new and existinglocomotives to help relieve the burdenimposed on millions of people exposedto unhealthy locomotive exhaust. AndEPA can maximize the human healthbenefits by acting swiftly to put a newrule in place.

The technical foundation for clean-ing up locomotives is at hand. Cleaner

ultra low sulfur diesel fuel (15 parts permillion of sulfur or less) is available forhighway vehicles and will be mandatoryfor locomotives by 2012. Meanwhile,the same technologies designed toreduce diesel emissions from highwayand nonroad diesel engines are beingredesigned for application on loco-motives.6 Similarly, new technologies,like the Green Goat hybrid traindesigned especially for locomotives,are in use, have been tested, and showsignificant emissions reductions.

In this report, we review the serioushealth and environmental threats posedby diesel exhaust. We examine thepublic health consequences of failure toimplement strong federal standards fordiesel locomotives as well as the healthimpacts resulting from further delaysin federal action. We also evaluate thehealth effects specific to particular citiesand regions across the nation; we describeavailable technologies that significantlyreduce locomotive emissions; and, finally,we highlight promising and successfulprograms that currently use these tech-nologies—programs that are the provingground for decisive federal action.

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Locomotives were invented in the1820s.7 Since then, five major types—including the steam engine—havehauled people and freight. Today’s mostprevalent locomotive type is the diesel-electric locomotive. Unlike the gasoline-powered car, which uses a transmissionto change gears, a train’s large dieselengine runs at a constant speed. Itsengine drives an electric generator thatsends power to motors at each axle,which, in turn, drive the wheels. Typicaldiesel locomotive engines are more than20 times larger than the V-8 enginesin pickup trucks and SUVs. However,because train engines run at a relativelyconstant speed, they only have about

CHAPTER 1All aboard—trains carry freight and people across theUnited States

10 times the horsepower of a typicallight truck.8

Currently, more than 22,000 freightand 270 passenger locomotives operatein the United States and approximately100,000 miles of track crisscross thecountry.9 As illustrated in Figure 2,trains run through every state in thenation, although the density of the railnetwork is far from uniform. Rail linesand yards tend to cluster around citycenters where populations are thedensest, as do the nation’s 3,300passenger train stations.10

Two types of locomotives movefreight: line-haul and switcher engines.Line-haul engines carry freight across

FIGURE 2Map of U.S. rail crossings

The U.S. national rail system serves both freight and passenger carriers. A map of rail crossings—points where roads and highways cross the rail lines—creates a nearly identical image of the overallrail system. Intense clusters of rail lines are apparent surrounding the nation’s larger cities. Manysuch clusters coincide with areas that have poor air quality, such as Baltimore on the east coast;Chicago, IL and Detroit, MI in the Midwest; Houston and Dallas, TX in the south; and Los Angeles inthe far west. Source: U.S. Department of Transportation

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the country. Switcher engines stay inrail yards and ports, assembling and dis-assembling the train cars that line-haulengines pull. Together, these loco-motives move 42% of our nation’sfreight, as measured in ton-miles.However, many of the heaviest goods

are shipped by train, so measurements inton-miles are somewhat biased towardstrains. Locomotives haul everythingfrom gravel to automobiles, lumber tovegetables and paper to grain. In 2004,coal accounted for 42% of all tonnageand 20% of revenue for Class 1 railroads,

Long haul trains movemillions of tons ofcargo across thenation each year

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Source: Bureau of Transportation Statistics, Table 1-46a: U.S. Ton-Miles of Freight. http://www.bts.gov/publications/national_transportation_statistics/html/table_01_46a.html.

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making it one of the most significantcommodities for railroads. And railtransport represents the largest portionof the intercity freight market at 47%—more than trucks or marine vessels.11

The use of locomotives as freight trans-port is on the rise. The United StatesDepartment of Transportation (DOT)estimates that rail carried 1.95 billiontons of freight in 1998 and that by 2030the industry will transport nearly 3 mil-lion tons, an increase of about 50%.12 InCalifornia alone, freight shipments byrail are expected to double in the sametimeframe.13 As Figure 3 illustrates, rail-road transport, in terms of ton-miles, hasmore than doubled in the last 35 yearsfrom nearly 800 million in 1970 to morethan 1.6 billion in 2004.

Over the last decade, intermodaltraffic (the movement of trailers orcontainers by rail and at least one othermode of transportation, usually trucksand/or marine vessels) has been thefastest growing rail traffic segment. Injust over 20 years, rail intermodal traffichas more than tripled from 3.1 millioncontainers in 1980 to 11.7 millioncontainers in 2005. In 2003, intermodalsurpassed coal as the leading revenuesource for Class 1 railroads.14

Trains versus trucks: finding themost efficient long-haulLocomotives currently present a win-dow of opportunity for national andregional reductions in NOx, particulatesand global warming-causing pollutantslike CO2. Making these reductions willnot only improve our air quality butcould also make rail one of the cleanestmodes of freight transport.

Trucks produce about 4–9 timesmore pollution than trains, and theyare responsible for fewer ton-miles offreight transportation: in 2003, loco-motives accounted for 36.8% of freight

ton-miles, while trucks accounted for29% (see Figure 4). Locomotives are themost energy efficient transporters offreight.15 This is because trains are threetimes more fuel efficient than trucksbased on the number of miles a ton offreight can be hauled on one gallon offuel. Trains are inherently more efficientbecause they move with less rolling andwind resistance on smooth steel rails,with each train carrying an average ofover 3,000 tons of cargo—equivalent toapproximately 280 to 500 trucks,depending on the type of cargo.16

There are important opportunities tofurther increase the fuel efficiency of railand reduce locomotive contributions toglobal warming pollution. Freight trans-port accounts for 25% of transportation-related carbon emissions17 and for 6.3%of total heat-trapping carbon dioxideemissions in the United States.18 Freighttransportation uses 36 billion gallons offuel each year, with freight trucks con-suming the majority of fuel.19 Freight railis three times more fuel efficient thanfreight trucks,20 so increased investmentin intermodal freight infrastructure can

Other34%

Rail37%

Trucks29%

FIGURE 4Transportation freight ton-miles,2003

Source: Bureau of Transportation, National Transporta-tion Statistics (2003), Table I-46b, available at www.bts.gov/publications/national_transportation_statistics/html/table_01_46b.html.

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produce sizeable cuts in fuel use andcarbon dioxide emissions. Shifting 10%of the intercity freight moved byhighway to rail would save the U.S.approximately 1 billion gallons of fuelper year,21 a 3% annual reduction in fueluse, and would lower overall carbondioxide by freight transportation.22

With superior ton-miles per gallonand energy efficiency, and equally strin-gent emissions standards, the morefreight that is shifted off of trucks andonto trains the greater the environ-mental and economic savings. Accord-ing to the Union Pacific Railroad, if 25%of truck freight were diverted to rail by2025 it would lead to: almost 800,000fewer tons of air pollution, 16 billiongallons of fuel saved, and 2.8 billionfewer traveler-hours lost in congestedtraffic.23 Although these numbers do notinclude additional congestion that maybe caused at rail crossings while longertrains go by, they do demonstrate thepotential for moving freight more effi-ciently. Boosting the fuel efficiency oflocomotives could thus form part of anational strategy to reduce overall green-house gas emissions in transportation.

Furthermore, the timely cleanup ofU.S. freight railroad vehicles could not

only protect public health, but alsoopen the door to important oppor-tunities for addressing other trans-portation and environmental problems.For example, in Switzerland, Austria,and Germany, truck tolls have recentlybeen introduced to help pay forinvestments in improved freightmobility systems, including betterrailways, thereby curbing pollutionand global warming, and also reducinghighway congestion. Similar strategiesmight help states and metropolitanareas accomplish the objectives ofsupporting the mobility of peopleand goods and encouraging economicdevelopment, while minimizing fueluse and emissions, as required by thenew 2005 federal transportation law,SAFETEA-LU.

Therefore, if EPA adopts a rigorousand comprehensive pollution plan forlocomotives to reduce PM and NOx

emissions, a move away from truckstoward rail freight may result in publichealth benefits, less traffic congestionand reduced impacts on global warming.A smarter, cleaner and faster freighttransportation system is possible, andcleaner locomotives have a significantrole to play in its realization.

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Locomotives and air pollutionin the United StatesLocomotives crisscross the country,pausing to load and unload cargo inurban and industrial centers. Theycontribute significantly to the nationalemissions inventory for the transporta-tion sector and pollute densely popu-lated areas already suffering fromunhealthy air. EPA estimates that, in2006, locomotives will emit about930,000 tons of ozone-forming oxidesof nitrogen (NOx)—the same amount asemitted from more than 120 coal-firedpower plants. Locomotives will also beresponsible for more than 32,000 tons ofharmful particulate pollution (PM2.5)—comparable to the emissions from morethan 70 coal-fired power plants.24

Rail also contributes to global warm-ing: EPA estimates that it was respon-sible for 2% of total transportationgreenhouse gas emissions in 2003,

CHAPTER 2Smokestacks on rails—locomotives’ impact on publichealth and the environment

which is an increase of 18% from 1990levels.25 Rising global temperatures areexpected to raise sea levels and changeprecipitation and other local climateconditions. Changing regional condi-tions will alter forests, crop yields andwater supplies, threatening humanhealth, animals and diverse ecosystems.26

There are several reasons why loco-motives are currently such significantpolluters. First, locomotive engines areincredibly large. Their engines can be20 times larger than the V-8 enginesin pickup trucks and SUVs.27 Second,these engines use an older, more anti-quated engine design. Many loco-motives are two-cycle engines whichhave greater power density and are lesscostly to manufacture, but have con-siderably higher emissions than their4-cycle counterparts. Third, becausethese engines represent major mone-tary investments, operators tend to

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FIGURE 5Growing locomotive contribution to national mobile source NOx and PM2.5

emission inventories, 1996 and 2030

Source: 69 Fed. Reg. 39,276 (June 29, 2004). EPA PowerPoint presentation by Don Kopinski presented to California AirResources Board Locomotive Emissions Meeting, “EPA’s Rulemaking for Clean Diesel Locomotives,” July 13, 2006.

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“remanufacture,” or rebuild diesel loco-motive engines every five to seven years,often keeping heavy emitters in opera-tion for 40 years or more. Lastly, theyrun for a great portion of their lives—locomotive engines do not use anti-freezeand must idle whenever the temperatureapproaches 40 degrees Fahrenheit or belowto keep them from freezing. Indeed, aswitcher engine may spend up to 75%of its time idling. Nationwide, switcheridling wastes about 60 million gallons ofdiesel fuel annually and emits 12,000 tonsof NOx, 500 tons of particulate matterand 750,000 tons of carbon dioxide.28

Locomotives’ share of national mobilesource emissions is on the rise. EPAestimated that in 1996, locomotives

were responsible for 7.2% of NOx and5.6% of PM2.5 emissions from the trans-portation sector.29 By 2030, EPA esti-mates that, if more stringent standardsare not put in place, those numbers willclimb to 18.5% and 33% of NOx andPM2.5 mobile emissions respectively(Figure 5).30 Locomotives’ growingshare of total mobile-source emissions isa result of the combined effects of weakemissions standards and the projectedincrease in rail-hauled freight.

Diesel pollution harms publichealth and the environmentMany trains in the United States arepowered by diesel engines. Diesel

Railroad workers: a vulnerable subpopulationAn evaluation of lung cancer mortality in approximately 55,000 railroad workersbetween 1959 and 1996 revealed that those regularly exposed to diesel exhaust,defined as working as either engineers or conductors, had a higher risk of dyingfrom lung cancer than unexposed workers (clerks and signal maintainers). Lungcancer mortality was significantly associated with being a member of a dieselexhaust-exposed job group, although risk did not increase with years of exposure.31

These findings are being studied further by the National Institute for Occupa-tional Safety and Health (NIOSH).

Railroad workers are exposed to the harmful diesel emissions from locomotives.

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exhaust occurs as a mix of gas, liquidsand solids resulting from diesel fuelcombustion in a compression-ignitionengine, and it is one of the nation’s mostdangerous and pervasive sources of airpollution. Its components include:

• Fine particulate matter (PM2.5). Par-ticulate matter can aggravate respira-tory conditions such as asthma andchronic bronchitis and has beenassociated with cardiac arrhythmias(heartbeat irregularities), heart attacksand premature deaths. People withheart or lung disease, the elderly andchildren are at highest risk fromexposure to particulate pollution.32

• Smog-forming nitrogen oxides (NOx).In warm weather, NOx combines withvolatile organic compounds undercertain atmospheric conditions tocreate ozone. Ozone causes coughing,throat irritation and congestion inhealthy adults, and the severity andfrequency of asthma cases are exacer-bated by ozone smog, especially inchildren.33 Ozone is also associatedwith premature death.34 In addition,NOx contributes to the formation offine particulate matter, acid rain andeutrophication.

• Sulfur dioxide (SO2), which formsharmful particulate pollution and fallsback to earth as acid rain;

• A noxious brew of toxic chemicals thattogether with diesel particulate pollu-tion pose a cancer risk greater thanthat of any other air pollutant.

Exposure to diesel exhaust has beenassociated with a wide range of healtheffects including cancer, neurologicaldamage, a weakened immune system,respiratory disease and cardiovasculardisease.35

To examine the current impact dieselexhaust from locomotives is having onpublic health, Environmental Defenseconducted an analysis to quantify ad-verse health instances and correspond-ing economic effects resulting fromlocomotive NOx and PM2.5 emissions(Table 4). We estimate that PM2.5 emis-sions, together with the contribution ofNOx emissions to PM2.5, will cause morethan 3,000 premature deaths in 2006.36

Exposure to these emissions will alsolead to, among other things, more than4,000 non-fatal heart attacks, over60,000 cases of acute bronchitis andexacerbated asthma in children, andnearly 290,000 lost workdays. Based onthe methodology EPA used in the non-road rule, the economic impact of theseadverse health effects totals over $23 bil-lion. Appendix A describes the method-ology used to derive these estimates.

In sum, our analysis highlights howcrucial it is to address the harmful emis-sions from locomotives. We can protectpublic health and the environment byaggressively reducing diesel locomotivepollution as much and as soon as possible.

TABLE 4Adverse health effects associatedwith 2006 locomotive pollution

Adverse health effect Instances

Premature death 3,400Chronic bronchitis 1,600Non-fatal heart attacks 4,400Hospital admissions 1,500Acute bronchitis in children 4,000Asthma exacerbations in children 57,000Lower respiratory symptoms 47,000Upper respiratory symptoms 35,000in childrenLost work days 290,000Minor restricted activity days 1,700,000Total economic impact of $23.2 billionadverse health effects

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Reducing pollution fromlocomotive engines can helpcommunities restore healthy air Locomotives are significant contributorsto both the NOx and PM2.5 emissioninventories. More than half of theAmerican population live in commu-nities out of compliance with thenation’s health-based ambient air qualitystandards for ozone and particulatepollution.37 States and localities acrossthe United States are working to cleanthe air and protect the health of their

citizens. Cleaning up the pollution fromlocomotive engines will help states andlocal governments restore healthy air.

Additionally, the science pointsoverwhelmingly to the need for tighternational health standards for particulatepollution and ozone. As the proportionof locomotive emissions grows com-pared to other sources in the trans-portation sector, communities workingto achieve and maintain healthy air willincreasingly look to locomotives forcost-effective reductions.

PM2.5 onlyPM2.5 and 8-hour ozone8-hour ozone only

Designated nonattainment

FIGURE 6Communities out of compliance with 1997 national health-based standardsfor particulate pollution and ozone

Several counties have only a portion of their county designated nonattainment. These counties arerepresented as whole counties on this map. Source: EPA Greenbook website at: http://www.epa.gov/oar/oaqps/greenbk/mappm25o3.html

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The United States needs strong newemissions standards to address the sig-nificant problem of locomotive pollu-tion. Recognizing this urgent need, inJune 2004, EPA published a notice ofintent to propose new emissions stan-dards for locomotives and ships by themiddle of 2005, with final rules set forthe middle of 2006.38 However, at thetime of this report’s writing, EPA hadstill not issued new standards—eitherproposed or final. In order to protect pub-lic health and reduce local air pollutionin communities across the country, it isimperative that EPA promptly fulfill itscommitment to strengthen the nation’sclean air standards for locomotives.

Despite the high levels of pollutionemitted from these powerhouses, onlymodest national standards are currentlyin place to protect the public from theirharmful diesel exhaust. Federal emissionlimits to curb locomotive emissions have

CHAPTER 3Federal delays in strengthening standards impose a heavyburden on human health

lagged far behind those of other mobilesources (see Figure 7), including highwayvehicles, diesel freight trucks and nonroaddiesel vehicles like farm and constructionequipment. Rules for locomotives issuedby EPA in 1998, and phased in from 2001to 2005 do not reflect the capacity ofavailable modern exhaust emission con-trol devices to dramatically lower par-ticulate and smog-forming pollution.39

In contrast, EPA adopted a compre-hensive clean-up strategy for other newdiesel engines, including trucks, busesand nonroad engines, such as construc-tion and farming equipment, that callsfor approximately a 95-percent reductionin PM emissions and a 90-percent reduc-tion in emissions of NOx over previousstandards. There is no reason to delayimplementing similar protective standardsfor locomotives. In fact, EPA expects “thatsimilar levels of NOx and PM reduc-tions could be achieved by applying

1991 trucks

1990 trucks 1988 trucks

2007–2010 trucks

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FIGURE 7Comparison of established standards for locomotives and diesel trucks

Source: Slide 4, http://www.arb.ca.gov/railyard/ryagreement/071306epa.pdf

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these technologies to locomotives” andinitially suggested an implementationdate of 2011 for these reductions.40

New standards for locomotives canbe modeled after the same advancedemissions control technologies on whichthe recent “Tier 4” standards for land-based nonroad diesel engines are based.41

Many of these technologies have alreadybeen redesigned for locomotive enginesand show emissions reductions of up to90% (see Chapter 5). These technolo-gies are enabled by ultra-low sulfurdiesel (ULSD), which is already avail-able for highway vehicles, and whichwill be required in all off road engines,including locomotives, by 2012.

The slow turnover of diesel loco-motive engines makes it even moreurgent that EPA not hesitate in imple-menting tougher emissions standards.Like many other nonroad engines, diesellocomotive engines can run for 40 yearsor more. Every five to seven years loco-motive engines are typically remanu-factured to “as new” condition, resultingin a slow turnover of dirty engines.42

Therefore, any new EPA emission stan-dards should address the heavy pollutionburden from existing engines by requir-ing rebuilt/remanufactured engines tomeet the same rigorous standards as“new” engines and applying clean airprotections to all existing engines.

Environmental Defense recently con-ducted an analysis to assess the health

benefits that would result from timelyimplementation of emissions standardsfor new locomotive engines that are90% more stringent than existing stan-dards. We also looked at the healthimpacts of emissions standards thatwould achieve only 75% or 50% reduc-tions from today’s standards, as well asthe effect of delaying meaningful stan-dards by an additional 2 or 4 years. Ouranalysis is based on an emissions reduc-tion scenario that assumes (1) a newTier 3 standard that is 90%, 75% or 50%lower than Tier 2, and (2) Tier 0 andTier 1 standards that are raised to Tier 2levels. See Table 5 for more detail on theTier 0, 1, and 2 emission standards.

Our analysis clearly illustrates thesignificant benefit in avoiding serioushealth instances as a result of more pro-tective emission standards. For example,Table 6 shows that implementing a Tier3 standard that is 90% more protectivethan the existing Tier 2 standard, andraising emission standards for Tier 0and Tier 1 engines to Tier 2 levels,would result in more than $13 billion inhealth benefits annually beginning in2030, and would prevent over 2,000premature deaths, about 2,600 non-fatalheart attacks, 36,000 bronchitis andasthma exacerbations, and nearly170,000 lost work days each year.

On the other hand, implementinga somewhat less protective Tier 3 stan-dard—50% lower than Tier 2 in 2013—

TABLE 5Current federal exhaust emission standards for line-haul locomotives

Current locomotiveemission standards Age of locomotive fleet PM (g/br-hpr) NOx (g/br-hpr)Tier 3 Originally proposed for 2011 — —Tier 2 2005 and after 0.20 5.5Tier 1 2002–2004 0.45 7.4Tier 0 1973–2001 0.60 9.5Uncontrolled Pre-1973 — —

Source: 40 CFR 92, July 1 2000 as reported in 2005 Bureau of Transportation Statistics, Table 4.35

CURRENT EMISSION STANDARDSFOR LINE-HAUL LOCOMOTIVES

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would realize less than $8 billion in healthbenefits each year, annually preventing1,100 premature deaths, 1,400 non-fatalheart attacks, 20,000 bronchitis andasthma exacerbations in children, andabout 95,000 lost work days. Whilethese benefits are still significant, theyfail to capture the full potential ofhuman health benefits that could beachieved by federal adoption of rigorousand timely standards. These numbersshow that delays in implementationimpose a heavy burden on human healthand that interim standards are crucial to“making up” missed health benefits.

Timely and meaningful federalemission standards are essential toprotect public health from the harm-ful effects of diesel locomotive emis-sions. States, environmental groupsand public health agencies have alreadycalled on the EPA to adopt more pro-tective standards.43 Moreover, stringentemission standards would finally putclean air standards for diesel loco-motive engines on par with require-ments for other onroad and nonroaddiesel engines—truly helping to elimi-nate that puff of black smoke associatedwith dirtier diesel engines.

TABLE 6Projected health benefits in 2030 with stricter NOx and PM2.5 locomotive emissions standards

Children’sPercentage bronchitiscleaner than Year new Annual Non-fatal Respiratory and asthma

current standards health benefits Premature heart attacks hospital visits exacerbations Work loss daysTier 2 would in billions deaths avoided avoided avoided avoided avoided

standards take effect of dollars annually annually annually annually annually

90% 2011 13.7 2,000 2,600 870 36,000 170,0002013 12.5 1,800 2,400 800 33,000 150,0002015 11.3 1,700 2,100 720 30,000 140,000

75% 2011 11.7 1,700 2,200 750 31,000 140,0002013 10.7 1,600 2,000 680 28,000 130,0002015 9.7 1,400 1,800 620 25,000 120,000

50% 2011 8.3 1,200 1,600 530 22,000 100,0002013 7.7 1,100 1,400 490 20,000 95,0002015 7.0 1,000 1,300 450 18,000 87,000

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Locomotives travel all over the nation,but the pollution from trains tendsto be concentrated in rail yards, trainsstations, and ports where trains gatherand wait to load and unload cargo.These concentrated emissions imposea heavy pollution burden on urban andrural areas. This chapter examinessome of the communities and rail yardsaround the country that are hard hit bylocomotive emissions.

Instead of relying on EPA’s nationalemissions inventory for locomotives, thecities and rail yards outlined in thischapter conducted their own localemissions inventories and studies tofurther investigate the health and envi-ronmental impacts of nearby locomotiveemissions. Table 7 takes a closer look atthe smog-forming pollution from loco-motive engines in some of these citiescompared to today’s automobiles.

Southern CaliforniaAir quality in southern California farexceeds the federal, health-based

CHAPTER 4Locomotives impose a heavy pollution burden on urbanand rural areas across the nation

ambient air quality standards for ozoneand particulates.44 Diesel air pollution isa major contributor to the region’s highozone and particulate pollution, andis responsible for more cancer risk insouthern California than any othersingle airborne contaminant.

Diesel locomotives have a significantrole in these serious pollution problems.Further, the number of locomotivesmoving through the areas near theports of Los Angeles and Long Beachis expected to double or triple by 2025to accommodate an increased numberof imported cargo containers.45 In theSouth Coast Air Basin, home to bothof these ports, diesel locomotives emitabout 33 tons of NOx pollution per day.That exceeds the combined emissionsfrom the area’s 350 largest oil refineries,power plants, chemical plants and otherindustrial facilities.46

The Port of Los Angeles recentlycompleted its own emissions inventory.Not only are locomotive emissionsprevalent within the Port boundaries,but emissions from trains going to and

TABLE 7Smog-forming emissions from locomotives in six major cities andcomparable number of today’s new automobilesa

Locomotive NOx emissions Equivalent numberUrban area (tons/year) of automobilesb

Los Angelesc 12,000 13,000,000Dallas-Fort Worth 4,500 4,900,000Houston-Galveston 6,500 7,000,000Chicago 23,000 25,000,000Detroit 2,100 2,300,000Baltimore 2,600 2,800,000a Emissions data for Houston and Dallas is from 2002. Emissions data from the other cities is from 2003.b Calculations based on Tier 2 NOx emissions standard (0.07gNOx/mile) for highway vehicles and 12,000 vehicle

miles/year. Bureau of Automotive Repair, Engineering and Research Branch, State of California, “Methodology forCalculating Vehicle Miles Traveled (VMT),” September 30, 2000, Report 2000-06, available athttp://www.epa.gov/otaq/regs/im/vmt.pdf

c Emissions data is for the South Coast Air Quality Management District.

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from the Port pollute surroundingneighborhoods. The study found that,in 2001, locomotives within the portemitted nearly 450 tons of NOx.47 Thoseemissions are equivalent to the pollutionfrom more than 480,000 of today’scleanest cars, more than all the carsregistered in the state of Delaware.48

Locomotives are responsible for 13%of all NOx pollution at the Port and 7%of the Port’s PM2.5 emissions.49

The California Air Resources Board(CARB) conducted a further study ofthe diesel particulate exposure at thePorts of Los Angeles and Long Beach.The study found that locomotives at thetwo Ports were responsible for 18 tonsper year of particulate matter and con-tribute to elevated risks of cancer innearby neighborhoods.50

Roseville, California Central California also suffers fromsome of the worst air quality in thecountry. Locomotives are a significantcontributor to this pollution problem,especially near rail yards. In 2004,CARB completed a health risk assess-ment of PM emissions from loco-motives at the Union Pacific J.R. DavisYard, a busy hub for railcar switching inRoseville, California. Roseville, locatedin the Central Valley near Sacramento,is a fast-growing suburb and the pastseveral years have brought increasedresidential development in close prox-imity to the rail yard. The yard is situ-ated near the heart of Roseville and isthe largest service and maintenance railyard in the West, with over 30,000locomotives visiting annually.

The Roseville study concluded thatdangerous concentrations of ultra-fineparticulates from the rail yard extendout over a now-populated landscapeand effect residents for miles around.Specifically, diesel exhaust from the railyard increases the estimated cancer riskat a rate of 100–500 cases per millionresidents across an area in which be-tween 14,000 and 26,000 people live,and at a rate of 10–100 cases per millionpeople across a larger region with acurrent population of 140,000–155,000.Cancer risks posed to workers in theimmediate area of the switching yard areeven higher. The study concluded thatthe cancer risk associated with dieselemissions at the rail yard were substan-tially higher than the risk posed bydiesel emissions on the adjacent inter-state highway, I-80, which is itself a sig-nificant source of harmful pollutants.51

Houston and DallasTwenty-three counties in Texas cur-rently do not meet health-based airquality standards for ozone established

The J.R. Davis Yard inRoseville, California

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by EPA, and several more are on theverge of violating these standards.52

Houston is the tenth largest city in theUnited States,53 has some of the mostunhealthy ozone concentrations in thecountry and is located in one of themost populated regions in the nation.

Texas is also home to significantnational rail hubs, as ships deliver cargoto the many ports and harbors scatteredalong the state’s long coastline to befurther transported inland by truck andrail. And the freight carried by trains inTexas is expected to grow from 282 mil-lion tons in 1998 to 473 million tons by2020—a nearly 68% increase.54

In June 2005, the Texas Commissionon Environmental Quality (TCEQ)finalized a locomotive emissions in-ventory for Houston-Galveston andDallas–Fort Worth, the two metro-politan areas with the state’s heaviestrailway traffic, and both out of compli-ance with EPA’s health-based air qualitystandards for ozone.55 The study esti-mated that in 2003, locomotives inTexas emitted approximately 51,400tons of NOx and 2,000 tons of particu-late pollution. Collectively, the Dallas–Fort Worth and Houston–Galvestoncounties accounted for approximately20% of Texas locomotive emissions.56

Moreover, the TCEQ concluded thatthe inventory likely underestimated thestate’s actual total locomotive emissions.57

ChicagoChicago is the busiest rail freight gate-way in the United States, and the onlycity where six of the seven major U.S.and Canadian Class I railroads cometogether to interchange freight. Thisincludes the two major western U.S.railroads, Burlington Northern andUnion Pacific, the two major easternU.S. railroads, CSX and NorfolkSouthern, and the two major Canadian

railroads, Canadian National andCanadian Pacific. A remarkable one-third of all long-haul rail traffic in thecountry passes through Chicago, andthe largest U.S. rail yard, the Belt RailYard, is located there.

Chicago handles more than 37,500rail freight cars each day and 20 yearsfrom now, that number is expected tonearly double to 67,000 freight cars perday.58 More freight carried by locomotivespasses in and out of Illinois than anyother state. In 1998, 371 million tons ofcargo was transported by freight inIllinois. By 2020, the U.S. Departmentof Transportation estimates that numberwill rise dramatically to about 600 mil-lion tons.59 Meanwhile, Cook County,the home of Chicago, violates the fed-eral health-based standards for bothozone and particulate pollution. 60

Due to the high volume of railfreight, Chicago has more NOx andPM emissions from locomotives thanany other city in the United States.In 2002, trains emitted some 23,212tons of NOx and 792 tons of particulatesinto Chicago’s air. Of that, 18% of theNOx and 32% of the particulates wasfrom switchyard locomotive activityalone. 61 The NOx emissions fromlocomotives in Chicago are equal tothe emissions of more than 25 millionof today’s new cars, more than 5 timesthe number of cars registered in theentire state of Illinois.62

DetroitThe Detroit metropolitan area, whichincludes seven Michigan counties, isalso out of compliance with the federalhealth-based ozone standard. Detroithas a regional economy dominated byautomobile manufacturing and rail-truck intermodal transfer facilities arecritical to the automobile industry’sinventory processing. Detroit also serves

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as an important freight gateway toCanada, Chicago and the Midwest.

Approximately 4.2 million tons ofrail freight are imported through theDetroit region annually—17% of totalinterregional freight tonnage. Basedon commodity flow data, an estimated300,000 loaded rail cars cross betweenCanada and southeast Michiganannually, or more than 800 loaded railcars per day. The locomotives that pullthis freight emit some 2,106 tons ofNOx and 58 tons of PM each year.63

BaltimoreMore than a dozen counties in Maryland,including the counties surroundingBaltimore, violate the federal health-based ozone standard, and nearly adozen of those same counties fail tomeet the national PM2.5 ambient airquality standard.64 In 2002, locomotiveswere responsible for more than 2,600tons of NOx and over 70 tons of coarseparticulate matter in Baltimore. Ofthose emissions, more than half werefrom switcher engines in rail yards. The

contribution of switcher engines toregional locomotive emissions is higherin Baltimore than any of the otherlocalities examined here.65 Addressinglocomotive emissions from Baltimore’surban rail yards would have a significantbenefit for public health and help thestate come in line with federal air qual-ity standards.

Powder River Basin, WyomingWhile most locomotive rail yards andhubs are located in densely populatedcities, there are important exceptions,such as Wyoming’s Powder River Basin(PRB). The Powder River Basin experi-ences a tremendous amount of railtraffic because of regional low-sulfurcoal deposits, which are mined andtransported by train to eastern utilitiesacross the nation. The largest coalshipments are from the PRB to powerplants in Illinois, Texas and Missouri.66

Because the Powder River Basinis the nation’s largest supplier of coal,Wyoming experiences the secondlargest quantity of cross-border rail

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An inbound empty coaltrain meets a loadedoutbound coal train atLogan Hill, Wyoming,in the Powder RiverBasin.

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freight of any state, following onlyIllinois.67 Recent studies show thatPRB coal production has degradedthe air quality and visibility at BadlandsNational Park. After release from loco-motives and other sources, sulfur dioxide(SO2) and NOx typically react to formhaze-causing sulfate and nitrate par-ticles. A study of Badlands from 1989 to1998 found that nitrate concentrations

had increased by 20%, resulting indecreased visibility. The study alsodetermined that transport of coal byrail was responsible for as much as18% of the overall nitrate increases.The study determined that the mosteffective means of improving thePark’ sair quality would be to controldiesel emissions from mine equipmentand locomotives.68

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As illustrated above, locomotive pollu-tion has far-reaching impacts on humanhealth and the environment. And loco-motives, like many other nonroadengines, can last for 40 years or more,resulting in slow turnover of dirtyengines.69 The good news is that avail-able technology can significantly reduceemissions from existing locomotives andhelp power newer, cleaner ones. More-over, the ultra low sulfur diesel fuel(15 parts per million of sulfur or less)that enables these technologies is widelyavailable today and will be mandatoryfor all locomotives in 2012.

Some advanced emissions controltechnologies currently in use in highwayand nonroad engines have already beensuccessfully redesigned for applicationto locomotive engines, and new tech-nologies are being designed specificallyfor locomotives. The implementation ofthese technologies can help make strictfederal emissions standards, as well aslocal and regional emissions reduction

CHAPTER 5Technology is on hand to curb locomotive emissions today

programs, successful in cost-effectivelycontrolling pollution.

HybridsRailpower Technologies of Vancouver,British Columbia manufactures hybridlocomotive switcher engines called“Green Goats” to help reduce emis-sions in urban switching yards. GreenGoats are powered with large banksof long-life recyclable batteries. Whenenergystored in thebatteries isdepleted to apre-set level, a low-emissions dieselengine automatically starts to powera generator that recharges the batteries.These new hybrid switcher enginesare designed to cut air emissions by80–90% and reduce diesel fuel use by40–70% compared to the 500–2,000horsepower engine that runs a con-ventional switcher.70

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Green Goat reductionsEmissions 80-90%Fuel 40-70%

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In addition, General Electric isdeveloping the GE Transportation Rail,a hybrid technology to be used in line-haul locomotives. The GE locomotive isdesigned to capture energy dissipatedduring braking and store it in a series ofsophisticated batteries. That storedenergy could then be used on demandby the crew, reducing fuel consumptionand emissions by up to 15% whencompared to GE’s current series oflocomotives.71

Gen-setWith funding from Union Pacific, theNational Railway Equipment Corpora-tion hasdevelopedanother typeof cleanerswitcher engine. Their new Gen-SetSwitcher (GSS) technology replaces thetraditional switcher engine with three700 horsepower generator sets that meet

EPA Tier 3 standards for nonroadengines. The combination of smallerengines meets the energy needs of theswitcher locomotives while meetingemissions standards more protectivethan the ones currently in place forlocomotives. The multi-engine approachallows the switcher to reduce emissionsof NOx and particulate matter by up to80% and achieve a 40% reduction in fuelconsumption over existing, unregulatedswitchers. It is the first emissions reduc-ing rail technology being developed bya rail company itself, with funding fromthe Texas Emissions Reduction Plan’snew technology and research develop-ment program, and signals that theindustry is starting to recognize thebenefits of improving efficiency andreducing emissions.72

Anti-idling technologyEngine idling is one of the top factorscontributing to high locomotive

Gen-set reductionsNOx and PM 80%Fuel 40%

The dual fuel consumption and pollution impacts from idlingMoving freight accounts for 20% of all energy consumed in the transportationsector. As the carrier of more than 40% of all US freight,73 locomotives consumednearly 5 billion gallons of diesel fuel in 2001.74 A large portion of fuel burned bylocomotives occurs during idling. Train operators idle their engines to protectthem during cold weather since most locomotive engines do not use antifreeze.They also idle to maintain the fuel, oil and water warmth as well as the batterycharge and the temperature inside the cab.75

Switcher engines spend almost 60% of their time idling while long-haulengines idle approximately one-third of the time.76 While idling is most prevalentin urban rail yards where switchers sort out rail cars from inbound trains andassemble outbound trains, it is also a significant source of pollution from long-haul freight transport. EPA estimates that truck and locomotive idling consumesover 1 billion gallons of diesel fuel annually.

Engine idling is one of the top contributing factors to high locomotive emis-sions. EPA estimates that idling of switchyard locomotives produces 13,000 tonsof NOx, 430 tons of PM, and 750,000 tons of CO2 each year.77

Fortunately, idling is something that can be addressed through new tech-nology and well-designed policy. Anti-idling technology has been successful ina Chicago pilot project (see Chapter 6). A rigorous national program to requiresuch technology on all new and existing locomotives would not only reduceharmful emissions but also realize significant reductions in fuel consumption.

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emissions. There are at least three tech-nologies on the market that successfullyreduce idlingtime andemissions.Auxiliarypower units(APUs) use a small fuel-saving auxiliarydiesel engine and generator set to poweron-board electrical and environmentalsystems instead of idling the locomotive’smain engine continuously. The SouthwestResearch Institute (SwRI) tested thistechnology and determined that APUscan achieve a 91% reduction in NOx andan 84% reduction in PM compared tomain-engine idling emissions.78 SwRIalso found APUs reduce fuel consump-tion during idling by 83%, which trans-lates into a savings of approximately22,000 gallons of fuel per year for eachswitcher locomotive. At today’s diesel

prices, that translates into an annual sav-ings of over $65,000 for the operator.79

Another technology automaticallymonitors a locomotive’s battery, enginetemperature and other important gaugesduring idling operation and safely stopsand restarts the engine to conserve fueland reduce air and noise pollution. Testshave shown that these stop/start tech-nologies can reduce emissions by 50%.80

Additionally, Kim Hotstart idling reduc-tion systems use electric and small diesel-powered heating units to maintaindesired engine temperatures in bothcoolant and lube oil while the loco-motive is shut down.81

Advanced exhaust emissioncontrol technologiesProven emissions-reducing technologieshave been and are being further adapted

APU reductionsNOx 91%PM 84%Fuel 83%

Adapting highway and nonroad diesel pollution controltechnologies to locomotivesWhile some technologies, like the Green Goat, have been designed specifically toreduce locomotive emissions, other technologies are being adapted from high-way and nonroad diesel engine applications. Locomotive engines share someimportant design features with highway and land-based nonroad vehicleengines, making it feasible to adapt these technologies, which include exhaustemission-control devices typically retrofitted onto existing locomotives to reduceemissions and advanced exhaust emission control technologies like dieseloxidation catalysts and active particulate filters.

Manufacturers have faced challenges in adapting highway and nonroad tech-nologies to locomotives and are continuing to refine technologies for broaderdeployment. These challenges include scaling technologies up to fit the largesize of locomotive engines; scaling up the advanced exhaust emission controlsystems to large horsepower sizes; and retooling to maintaining high exhausttemperatures. For example, low exhaust gas temperatures may compromisediesel particulate filters (DPF) and diesel oxidation catalysts (DOC) performance.In addition, the engine compartments on a train are very compact because trainsneed to be able to fit through tunnels and other small spaces, requiring cabredesign to fit DPFs and DOCs. EPA has found that these challenges to not “posea barrier to setting standards based on implementing these technologies...”82

Moreover, as described in this chapter, many of these technologies have alreadybeen successfully implemented on locomotives in the U.S.A. and in Europe. Newfederal emissions standards for locomotives would not only help protect publichealth but would also drive the advancement of new, important technologies.

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from highway, nonroad and stationarydiesel engines for use on locomotiveengines. These exhaust control tech-nologies can be applied to new enginesor retrofitted onto existing engines toachieve immediate reductions in NOx

and PM emissions.Some of these technologies include

diesel oxidation catalysts (DOCs) andactively regenerating diesel particulatefilters (DPFs) for particulate emissionsreductions, and engine rebuild kits andselective catalytic reduction (SCR)catalysts for reducing NOx emissions.These technologies have been successfulin reducing up to 90% of NOx andPM2.5 emissions from highway, nonroadand stationary engines and these typesof technologies are already being suc-cessfully tested and applied to loco-motive engines. 83 In October 2006, theManufacturers of Emission ControlsAssociation (MECA) released a reportpointing to the numerous test programsacross the nation that have successfullyapplied these technologies to new andexisting locomotive engines.84

For example, in 2006 Union Pacific,with the help of U.S. EPA, is testing theuse of a DOC and a DPF on two of

their existing engines. The SouthwestResearch Institute will perform EPAlocomotive emissions tests to verify howmuch particulate matter is removedfrom the locomotive’s exhaust.85 Andbeginning in 2004, as part of the Loco-motive Demonstration Project, theMassachusetts Bay TransportationAuthority began testing a diesel oxida-tion catalyst (DOC) on a diesel poweredcommuter rail locomotive.

In addition, of the 113 diesel pow-ered locomotives used to move freightin Switzerland, 73 new, low horsepowerunits have been fitted with DPFs, while6 of the 40 existing units have been retro-fitted with DPFs. And in California, thePlacer County Air Pollution ControlDistrict, which encompasses the Rose-ville rail yard near Sacramento, hasinitiated a project to employ selectivecatalytic reduction (SCR) technology onlocomotives operating at the Rosevillerail yard. As confirmed by MECA, thegrowing experience base with DOCs,DPFs, and SCR on locomotive enginesindicates that these technologies arefeasible for use on new locomotiveengines to comply with stringentnational emission standards.86

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Chapter 4 examined cities and rail yardswhere locomotive emissions are concen-trated and contribute significantly tolocal air pollution problems. Chapter 5reviewed new and redesigned technolo-gies available today that can reduceharmful diesel locomotive emissions.This chapter takes a look at programsthat leverage technology to reduce pol-lution. These initiatives, and others, area proving ground for a comprehensivenational emissions reduction program.

The EPA SmartWay TransportPartnershipThe SmartWay Transport Partnership isa voluntary collaboration between thefreight industry and EPA designed toincrease energy efficiency while reduc-ing air pollution. Launched in February2004, the Partnership includes majorfreight shippers, trucking companies,railroads and logistics companies. Thesegroups work together to implementefficiency measures that reduce emis-sions and bring cost savings to freightoperators. All seven major freight rail-roads have joined the Partnership, andeach has committed to develop a planto identify fuel savings and emissionsreduction strategies that include reduc-ing idling, improving aerodynamics,applying new fuel-saving technologiesand installing emissions control devices.87

Because ton-mile for ton-mile, rail isan efficient mode of transportation, theSmartWay Program also encouragestechnical innovation to increase railefficiency and highlight opportunitieswhere rail could be better utilized. By2012, the initiative aims to reducebetween 33 and 66 million metric tonsof CO2 emissions per year, as many as

CHAPTER 6“I think I can, I think I can”—successful emissionsreduction programs

200,000 tons of NOx emissions per year,and to achieve fuel savings of up to 150million barrels of fuel per year.88 Recentreports show that, since its inception inFebruary 2004, SmartWay projects,including truck and rail, have saved283.6 million gallons of fuel per year.EPA estimates that, by 2007, the fuelsavings will have yielded annual reduc-tions of 3.1 million tons of CO2, 22,000tons of NOx, and 800 tons of PM emis-sions. The emissions reductions and fuelsavings achieved in the two years ofSmartWay’s existence translate into theequivalent of emissions from nearly550,000 cars or about 390,000 homesheated in the United States.89

Chicago’s Anti-idling ProgramIn order to address the growing impactof locomotives in Chicago, EPA and theCity of Chicago sponsored a locomotiveidling reduction demonstration projectin 2002 and 2003. The governmentsrecruited Burlington Northern RailwayCompany, the Wisconsin SouthernRailroad Company and the KimHotstart Company, a manufacturerof idling reduction systems, as partnersin the project. Seven locomotives wereoutfitted to reduce idling in the winter,when engines are typically left runningto keep the engine and cab warm.The start/stop systems were also usefulin the summer to shut down idlingengines left on by conductors who idleout of habit.90

The project resulted in an 80% reduc-tion in idling time, an annual fuel savingsof over 14,000 gallons and an annualNOx reduction of 2.4 tons.91 Based onthe successful performance of idlingreduction systems in Chicago, EPA

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estimates that anti-idling retrofits at atypically sized rail yard with five switch-ing engines would eliminate 12.5 tons ofNOx at a cost of $1,420 per ton of NOx

reduced.92 This is equivalent to taking13,500 of today’s cars off the road in theareas surrounding each switching yard.

Because of the success of the Chicagoproject, and the fuel savings from thevarious anti-idling technologies, rail-road companies have begun to retrofitsome of their older locomotives withstop/start mechanisms and APUs.Union Pacific has now equipped 20%of its fleet with automatic stop/startidling reduction technology.93 As ofJuly 2004, the Burlington NorthernSanta Fe Railroad had retrofitted 38of the approximately 400 switchingengines it operates in 28 states andtwo Canadian provinces with KimHotstart systems.

Chicago’s successful idling reduc-tion program shows how technologyand policy innovation can be used toreduce harmful diesel emissions fromlocomotives.

Texas Emissions Reduction PlanIn response to the large number of Texascounties out of compliance with thefederal health-based ozone standard, theTexas Emissions Reduction Plan(TERP) was established to reduceozone-forming NOx emissions. TERPhas committed almost $20 million toreduce locomotive emissions in theHouston–Galveston area, which suffersfrom the highest ozone levels and themost locomotive emissions in the state.94

The TERP program funds projectsin nonattainment counties for purchaseof new locomotives; replacement ofold locomotives; repowering or replace-ment of engines; and retrofitting oradding emissions control technology.In each case, the repowered, retro-

fitted or replaced locomotive must becertified to emit 25% less NOx thanthe engine it replaces, or if new, 25%less NOx than the current federalstandard for that engine.95 The Houstonlocomotive projects include replace-ment of old switching engines andrepowering locomotives with cleanerhybrid technology.

TERP officials expect these projectsto reduce NOx emissions by more than3,300 tons, at an average cost of about$5,900 per ton. TERP has funded fourGreen Goats for Burlington NorthernSanta Fe (BNSF), two for Kansas CitySouthern (KCS) and ten for UnionPacific Railways, and it continues toprocess applications.96

California Clean Air InitiativesCalifornia suffers from some of the mostunhealthy and far-reaching air pollutionproblems in the nation. One of its cam-paigns to address harmful air pollutionlevels aims to reduce emissions from themovement of goods. Intermodal trans-port of goods includes trains, trucksand marine vessels, and is on the risein California and around the nation.

As part of this broad strategy, theCalifornia Air Resources Board (CARB)established the California Rail YardEmission Reduction Project. In 1998,CARB reached an agreement withUnion Pacific and Burlington NorthernRailways, the two Class 1 operators inCalifornia, to reduce NOx emissionsfrom locomotives. The agreement alsoprovides for all intrastate locomotives touse ultra-low sulfur diesel, with a sulfurcontent of 15ppm or less, by 2007—afull five years before ULSD is federallymandated to be in national circulationfor locomotives.

On June 30, 2005, CARB and UnionPacific Railroad Company and BNSFRailway Company entered into a second

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voluntary agreement providing for UPRRand BNSF to reduce locomotive andassociated diesel particulate emissions inand around California’s rail yards.97 Inaddition, the railroads have committedto studying and reducing pollution risksat 17 designated rail yards. The Rose-ville risk assessment mentioned inChapter 4 is the first of those studies.

The agreements encourage theserailways to implement new emissionsreducing technologies. Union Pacificand BNSF have agreed to phase outnon-essential idling and install idlingreduction devices on all California-based locomotives, identify and repairlocomotives with excessive smoke,maximize the use of ULSD by 2007,and prepare a progress report on plansto implement feasible mitigationmeasures at the 17 major rail yards inCalifornia. The program is expected toachieve a 20% reduction in locomotivediesel particulate matter emissions nearrail yards by 2008, when all the programelements are fully phased in.98

Currently, more than a third of the430 intrastate locomotives (switchersand local locomotives) in Californiahave been equipped with idling reduc-tion devices, which is more than twicethe rate of installations that have oc-curred to date in the rest of the country.99

In addition, Union Pacific recently spent$8.2 million on ten new Green Goatlocomotives for its Southern Californiarail operations to help meet the agree-ment. The first two have been receivedand have been put into service at the UPrail yard in Mira Loma. The remainingGreen Goats are expected to arrive andbe put into service in 2006.100 UnionPacific expects to spend a total of$20 million implementing the program.BNSF has one Green Goat switcher inthe Los Angeles area and four liquefiednatural gas (LNG) locomotives inservice elsewhere in the area.101

The Health Risk Assessments willevaluate emissions of toxic air contami-nants and criteria pollutants fromemissions sources at each DesignatedRail Yard including resident and transientlocomotives, on- and off-road equip-ment, and stationary equipment, andwill identify the associated health riskfrom on-site activities. The HRAs willestimate potential cancer and non-cancer risks to the public from exposureto airborne contaminants inventoriedfrom the Designated Rail Yards. Com-pletion of nine of these HRAs is ex-pected by the end of 2006, with the finalseven concluding in 2007.102

The South Coast Air Quality Man-agement District (SCAQMD), whichincludes the counties of Los Angeles,Orange, San Bernardino and Riverside,is deploying additional measures toaddress locomotive emissions in andaround the Los Angeles air basin. TheSCAQMD recently adopted two rulesrequiring railroads in the region toeliminate unnecessary locomotiveidling. Under Rule 3501, railroadswill be required to keep records of allidling over 30 minutes. The informationwill be used to identify ways to reduceidling and associated pollution. Rule3502 prohibits unattended locomotivesfrom idling for more than 30 minutesunder certain circumstances. This goesfarther than the CARB agreement,which targets idling over 60 minutes. Inaddition, these rules are mandatory incontrast to the CARB agreement, whichis voluntary. A SCAQMD analysispredicts the railroads will realize a netsavings of more than $3 million overthe next four years as a result of the twocombined rules.103

California’s Carl Moyer ProgramBecause many of the dirtiest dieselengines on the road today can be in use

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for decades, and federal regulations oftendo not apply to them, the Carl MoyerProgram was started in California toprovide incentive funds to retrofit oldengines or to retire them for newer,cleaner engines. The Program covers theincremental costs of obtaining cleaner-than-required engines and equipment.Eligible projects include cleaner on-road, off-road, marine, locomotive andstationary agricultural pump engines,as well as engines in forklifts, airportground support equipment and auxiliarypower units. Each air district in the stateis allotted a portion of the Moyer Fundsand disperses them to the projects thatcan make the greatest reductions.

With support from the Carl MoyerProgram, the San Joaquin Valley Air

Pollution Control District (SJVAPCD)has created the Heavy-Duty EngineEmission Reduction Incentive Program,which provides funds to help publicagencies, companies and individualsretrofit their locomotive engines orreplace them with new, cleaner enginesthat run on diesel or alternative fuels.104

Provisions for the SJV program statethat retrofits must reduce emissions by15% compared to applicable EPAstandards for a similar engine. Thisprogram has provided funding to aidBNSF in the purchase of one GreenGoat and is under contract to help withan additional five.105 The San Joaquinprogram has also helped fund theinstallation of anti-idling technology infour BNSF trains. SJVAPCD estimatesthat the Green Goat will reduce 120tons of NOx over the next eight years,at a cost of $700,000, resulting in a cost-benefit ratio of only about $5,800 perton reduced. The anti-idling technologyis estimated to reduce annual NOx emis-sions in the Valley by 1.53 tons andreduce fuel consumption by 38 gallonsper day.106 Combined, these reductionswill be the equivalent of removing morethan 140,000 of today’s cars from theSan Joaquin Valley’s roads.

The Carl Moyer Program has alsohelped fund projects in the South CoastAir Quality Management District(SCAQMD), the Port of Los Angeles,and other areas around the state ofCalifornia.

Pollution reduction strategiesfor the Ports of Los Angeles andLong BeachWith well-designed policies and theuse of advanced technologies, trains canbecome a cleaner mode of transporta-tion, replacing trucks and therebyreducing traffic congestion and regionalair pollution.C

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The Ports of Los Angeles and LongBeach recently reached a voluntary agree-ment with Pacific Harbor Lines (PHL),a private company that since 1998 hasprovided railroad-switching services toboth Ports, to replace all 18 of its exist-ing switcher locomotives—some morethan 50 years old. The agreement, whichwas signed in August 2005, specifiesthat 16 of the replacement locomotiveswill be equipped with new diesel enginesthat exceed EPA Tier 2 standards. Theadditional two will be alternative-fuellocomotives—one using liquefied naturalgas and the other a Green Goat hybridengine from Railpower Technologies.Each of the two ports will contribute$5 million toward the estimated $23 mil-lion cost to replace the PHL locomotivefleet, with the balance coming fromPHL and a $3.2 million Carl Moyergrant. The use of these replacementlocomotives will result in a 53% reduc-tion in NOx emissions and a 45% reduc-tion in PM emissions per locomotive,

and the removal of an estimated163 tons of NOx per year and 3 tonsof annual PM from the two ports.107

These NOx reductions are equivalentto eliminating more than 175,000 oftoday’s cleanest cars from the streets ofLos Angeles and Long Beach.

In addition to buying new loco-motives, the ports are taking furthersteps to reduce emissions. The agree-ment provides incentives to PHL toblock street crossings for fewer than10 minutes so as to reduce road con-gestion and motor vehicle idling. It alsorequires that all locomotives be equippedwith automatic shut-down devices thatwill kick in if a locomotive idles formore than 15 minutes. In addition,PHL will use cleaner-burning emulsi-fied diesel fuel in all of its new loco-motives. And because the turnover ofall 18 locomotives will take some time,PHL has also agreed to use the emulsi-fied diesel in the existing fleet, which willresult in immediate air quality benefits.108

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As described in Chapter 6, local officialsare taking steps to reduce emissions fromlocomotives. While these programs havean important role in incubating newtechnologies and demonstrating theefficacy of emissions controls, they arelimited in scope. EPA leadership isessential to put comprehensive nationalclean air solutions in place for diesellocomotives. This will help communitiesacross the country achieve the health-based national ambient air qualitystandards (NAAQS) for particulatepollution and ozone, and address theserious cancer risk of diesel emissions.

Environmental Defense respectfullyrecommends the following essentialsteps to cut the harmful air pollutionfrom diesel locomotives.

1. We call on EPA to issue, withoutfurther delay, new protective loco-motive emission standards. To protecthuman health and the environmentnationwide, Environmental Defense callsfor EPA to fulfill its public commitmentto strengthen the nation’s clean airstandards for these harmful smokestackson rails. EPA’s failure to finalize newstandards in mid-2006, as the Agencyhad publicly committed, will likely delaycompliance deadlines when EPA doestake action. Each year of delay risks livesand imposes a cascade of health effectsthat could be prevented with solutionsavailable today. Environmental Defensestrongly recommends that this newpolicy adopt the following standards:

• Require, by 2013, a 90% reduction incurrent particulate pollution and NOx

emissions from all new and remanu-factured locomotive engines, consistentwith EPA’s 2004 emission standardsfor heavy-duty nonroad diesel engines.

CHAPTER 7National clean air solutions for locomotives

• Establish protective PM and NOx

emissions standards for the existinglocomotive fleet to be achievedimmediately to secure important near-term pollution reductions.

• Provide for widespread utilization ofanti-idling technologies to help reducelocomotive emissions, noise, and fuelwaste while saving operators money.

2. Update national locomotiveemissions inventories. EPA shouldreview and update the emissions inven-tory for locomotives. Diesel pollutionfrom locomotives imposes a heavyburden on public health and the envi-ronment. Local and national policyleaders need up-to-date, comprehensivedata regarding the number of loco-motives, their emissions and projectedgrowth trends. The current EPA emis-sions inventory has many shortfalls: itdoes not account for the effect of gradeor elevation on locomotive emissions; ituses only railroad distillate fuel con-sumption data as an indicator of loco-motive growth;109 and it cites onlynational estimates, neglecting geo-graphic allocation. It is important thatEPA work with local air pollutioncontrol agencies, other technical expertsand the rail companies to develop amore comprehensive set of emissionsfactors for locomotives and gather dataon a county level so that policymakersare aware of local and regional loco-motive emissions hotspots.

3. Establish incentive programsdesigned to encourage faster turnoverof dirty switcher engines. The turnoverfor switcher engines tends to be moresluggish than for long-haul engines.Because long-haul trains cover suchlong distances each year, owners have

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a business incentive to buy newer, morefuel-efficient trains that will not breakdown and are less expensive to operate.Switcher engines, by contrast, never leavethe rail yard, and there are few operationalincentives for replacing or updating theseengines. This leaves the oldest, dirtiestengines operating in busy urban centerswhere many people can be exposed totheir pollution. Therefore, a protectivenational program must include emissionstandards for existing switcher enginestogether with well-designed economicincentives to encourage faster turnoverof switcher engines. Tailored incentivescould have economic benefits for oper-ators and speed the transition to cleanerlocomotive engines, rail yards, andhealthier communities.

4. Full funding of existing federalprograms will help lower harmfulpollution from diesel engines on theroad today. Programs like the Texas

Emission Reduction Program, Cali-fornia’s Carl Moyer program, theCongestion Mitigation Funds underfederal transportation legislation(SAFETEA-LU), and the federalDiesel Emissions Reduction Act existto hasten the transition to new, cleanerengines. Retrofitting diesel engines withpollution control technology is a cost-effective way of reducing NOx and par-ticulate pollution and protecting humanhealth—in fact every dollar spent canreap at least $12 in health benefits. TheDiesel Emissions Reduction Act wasadopted with overwhelming bipartisansupport but has received only meagerappropriations. The federal governmentcan help address the health burden fromdiesel engines on the road today by fullyfunding diesel clean-up programs with-out taking money away from other cleanair programs. State and local govern-ments can leverage federal funds bysetting up their own incentive programs.

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This report presents technical analysis ofthe estimated health benefits associatedwith reducing emissions of PM2.5 andNOx by adopting new national emissionsstandards for diesel locomotives. In 2004the EPA issued an Advance Notice ofProposed Rulemaking (ANPRM) thatannounced the agency’s intent to pro-pose new standards for diesel loco-motives modeled after the 2007/2010highway and Tier 4 nonroad dieselengine programs.110 Although the EPAstated that it would issue a Final Ruleby mid-2006, it has not yet proposednew standards for diesel locomotives.

This analysis estimates the benefits ofPM2.5 and NOx reductions over a rangeof scenarios that consider differentemissions standards for new diesel loco-motives (expressed in grams per brakehorsepower-hour or g/bhp-hr) and dif-ferent years in which the new standardswould become effective. The estimatedhealth and monetary benefits are basedon EPA estimated benefits of the Non-road Diesel Engine Rule.111

Estimating diesel locomotivePM2.5 and NOx emissions EPA is revising its estimates of PM2.5

and NOx emissions from diesel loco-

APPENDIX AMethodology for estimating health benefits of locomotiveemission reductions

motives. The revised estimates are ex-pected to be significantly higher thanthe emissions considered in the ANPRM.Accordingly, the estimated PM2.5 andNOx emissions used in this analysis arebased on EPA draft model results asillustrated in the agency’s July 13, 2006presentation to the California AirResources Board (CARB) and shownin Table A1.112 To maintain consistencywith the EPA benefits analysis for theNonroad Diesel Engine Rule, the cur-rent analysis focuses on PM2.5 and NOx

reductions in the year 2030.Due to data constraints within the

presentation of EPA draft model resultsand the Association of American Rail-roads’ (AAR) estimates of in-servicelocomotives, this analysis considersemissions from Class 1 railroad loco-motives only, and excludes emissionsfrom switcher, passenger and Class 2and 3 locomotives.113 Therefore, theanalysis produces a conservative estimateof the health benefits of tighter emis-sions standards for diesel locomotives.

Existing emissions standards for diesellocomotives are shown in Table A2. Be-cause EPA has not yet announced Tier 3emissions standards for new diesel loco-motives, this analysis assumes alternativeTier 3 standards that represent 50%, 75%

TABLE A1Estimated annual PM2.5 and NOx emissions from diesel locomotives in 2030(tons per year)

Locomotive category PM2.5 NOx

Switchers, passenger, Class 1 & 2 3,500 140,000Uncontrolled (pre-1973 fleet) 100 5,000Tier 0 (1973–2001 fleet) 2,800 50,000Tier 1 (2002–2004 fleet) 2,000 20,000Tier 2 (2005 and after fleet) 18,000 625,000Total 26,400 840,000

Source: USEPA, EPA Rulemaking for Clean Diesel Locomotives, CARB presentation, July 2006

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and 90% emissions reductions from exist-ing Tier 2 standards. The analysis assumesthat the new Tier 3 standards will be-come effective in 2011, 2013 or 2015and that Tier 0 and Tier 1 standards willconform with Tier 2 levels when thenew Tier 3 standards become effective.

Under existing emissions standards,all locomotives built or rebuilt between2005 and 2030 must comply with Tier 2standards. Under the proposed standardsdiscussed in the ANPRM, locomotivesbuilt after 2011 would be required tomeet new Tier 3 standards, while loco-motives built between 2005 and 2010would remain subject to Tier 2 standards.

The health benefits of new emissionsstandards for diesel locomotives are

based on reductions in PM2.5 and NOx

emissions under the new standards fromthe emissions that would occur underthe existing standards. Within thisanalysis, emissions reductions for Tier 3locomotives were estimated by applyinga 90%, 75% or 50% reduction to theemissions that would have been emittedunder Tier 2 standards. The analysisalso assumed that unit-level emissionsfrom Tier 2 locomotives would notchange under the new standards butoverall levels of PM2.5 and NOx (tonsper year) emitted by Tier 2 locomotiveswould fall because fewer locomotivesare included in this category. Emissionreductions for Tier 1 and Tier 0 loco-motives were estimated by applying

TABLE A2Emissions standards for diesel locomotives

PM emissions standard NOx emissions standard(g/bhp-hr) (g/bhp-hr)

Emissions standard Currenta Assumed Currenta Assumed

Uncontrolled (pre-1973 fleet)Tier 0 (1973–2001 fleet) 0.60 0.20 9.50 5.50Tier 1 ( 2002–2004 fleet) 0.45 0.20 7.40 5.50Tier 2 (2005 and after fleet) 0.20 0.20 5.50 5.50Tier 3 (2011 and after fleet)90% reduction from Tier 2 - 0.02 0.5575% reduction from Tier 2 - 0.05 1.3850% reduction from Tier 2 - 0.10 2.75

Source: 40 CFR 92, July 1, 2000 as reported in Bureau of Transportation Statistics, Table 4-35: Federal ExhaustEmission Standards for Diesel Locomotives. a Current emissions standards for line-haul locomotives.

TABLE A3Estimated emissions reductions (tons per year) achieved by new diesellocomotive emissions standards—alternative Tier 3 standards andimplementation years

Year new Tier 3 standard become effective

PM2.5 NOx

Reduction in Tier 3 standards from Tier 2 standards 2011 2013 2015 2011 2013 2015

90% 15,439 14,193 12,947 458,880 415,611 372,34275% 13,362 12,324 11,285 386,765 350,707 314,64925% 9,901 9,209 8,516 266,572 242,534 218,495

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the lower emissions standards, also ex-pressed as a percent reduction from theexisting standard, to the emissions thatwould otherwise be emitted.

Emissions reductions within eachtier were summed to estimate totalPM2.5 and NOx reductions under alter-native Tier 3 standards and imple-mentation dates. The results of thisanalysis are summarized in Table A3.

Benefit estimatesEstimation of the health benefits associ-ated with new diesel locomotive emis-sions standards is based on PM2.5 andNOx emissions reductions, health bene-fits and monetary benefits associatedwith the Nonroad Diesel Engine Ruleas reported in Chapter 9 of the FinalRegulatory Analysis: Control of Emis-sions from Nonroad Diesel Engines.As part of this RIA, EPA conducteda rigorous analysis of the emissionsreductions and benefits associated withthe proposed rule (preliminary scenario),which included deeper emissions reduc-tions than the final rule. In order toavoid the scaling adjustments EPAapplied to the final Nonroad DieselEngine Rule, this analysis is based onthe preliminary EPA scenario.

Our analysis of the health benefitsassociated with new locomotive emis-sions standards applies the ratio of PM2.5

and NOx emissions reductions undereach scenario illustrated in Table A2to the emissions reductions and healthbenefits achieved under the NonroadDiesel Engine Rule. The analysis ap-plies several simplifying assumptions.Although the health benefits associatedwith lower emissions from diesel loco-motives span several years, future bene-fits that occur in later years are not

discounted. Although there is a time lagbetween reductions in PM2.5 concentra-tions and decreases in the occurrence ofadverse health effects, this analysisassumes full realization of reductions inPM2.5 concentrations and reductions inadverse health impacts. Our analysisfurther assumes that the dispersionmodeling conducted to support thenon-road rule applies to locomotives.

The current analysis estimates themonetary value of the health benefitsassociated with tighter emissions stan-dards for diesel locomotives by applyingthe unit values used for economicvaluation of the PM-related healthendpoints reported in the NonroadDiesel Engine Rule RIA to the (health)incidence reductions associated witheach Tier 3 standard/implementationyear scenario. All monetary values areexpressed in 2000 dollars. PM-relatedhealth endpoints include prematuremortality, chronic bronchitis, non-fatalheart attacks, respiratory hospitaladmissions, acute bronchitis, asthmaexacerbations, upper and lower respira-tory symptoms, work loss days andminor restricted activity days.

With the exception of non-fatal heartattacks, the Nonroad Diesel EngineRule RIA expresses the monetary valuesof health-related benefits associatedwith reduced ambient PM2.5 concentra-tions as point estimates. The monetarybenefits of reduced non-fatal heartattacks assume avoided illness costs andlost earnings in later years and are dis-counted at a 3% and 7% discount rate.The current analysis applies the 7% dis-count rate as it more closely reflects thesocial cost of capital. The economic valueof reduced work loss days was estimatedusing July 2006 average national earningsdata from the Bureau of Labor Statistics.

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Class 1 railroad: Class 1 railroads arethe largest freight railroads, as classi-fied by operating revenue. There areseven Class 1 railroads that operatein the United States: BurlingtonNorthern Santa Fe Railway (BNSF),CSX Transportation, Kansas CitySouthern (KCS), Union Pacific (UP),Norfolk Southern, Canadian Pacific(CP) and Canadian National (CN).Class 1 railroads typically operate inmany different states and concentratelargely on long-haul, high-densityintercity transport.

Class 2 railroad: Class 2 railroads areline-haul railroads with at least 350route miles and/or revenue between$40 million and the Class 1 threshold.They typically operate 400 to 650 milesin two to four states.

Class 3 railroad: Class 3 railroads, orlocal line-haul railroads, operate lessthan 350 route miles and earn less than$40 million. They generally performpoint-to-point services over short dis-tances. Most operate less than 50 milesof track and serve a single state.

Freight transport vs. passengertransport: Freight transport involvesmoving goods or produce, while passen-ger transport involves the movement ofpeople. All Class 1 railroads are used forfreight transport.

Idling: An engine is idling when it isrunning while the train is stationary.

Intermodal: Intermodal transportinvolves more than one mode oftransport. For example, moving goodsby ship then by train is described asintermodal.

Glossary

Line-haul trains: Locomotives canperform two different types of opera-tions: line haul (or long haul) and switch(or yard). In the line-haul operations,locomotives generally travel betweendistant locations. In the switch opera-tions, locomotives are primarily respon-sible for moving railcars within aparticular railway yard.

National Ambient Air Quality Standards(NAAQS): The Clean Air Act providesfor two types of national ambient airquality standards. Primary standardsare requisite to protect public healthwith an adequate margin on safety.Secondary standards are requisite toprotect public welfare from anyknown or anticipated adverse effectsincluding effects on climate, soils,water, crops, vegetation, wildlife andvisibility.

Nonattainment Area: Any area of thecountry that does not meet, or thatcontributes to ambient air quality ina nearby area that does not meet, thenational primary or secondary ambientair quality standard for a pollutant.

Oxides of nitrogen (NOx): The genericterm for a group of highly reactivegases, all of which contain nitrogenand oxygen in varying amounts. NOx

combines with volatile organic com-pounds to create ground-level ozone,or smog. It also can combine withammonia to create particulate matter.In addition, NOx contributes to acidrain and eutrophication of waterbodies.

Ozone: Ground-level ozone is notemitted directly into the air, but iscreated by chemical reactions between

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oxides of nitrogen (NOx) and volatileorganic compounds (VOC) in thepresence of sunlight.

PM: Particulate matter is a complexmixture of extremely small particles andliquid droplets. Particle pollution ismade up of a number of components,including acids (such as nitrates andsulfates), organic chemicals, metals, andsoil or dust particles. PM2.5, or fineparticles, refers to tiny particles ordroplets in the air that are two and onehalf microns or less in width. Fineparticles, such as those found in smokeand haze, can be directly emitted fromsources such as forest fires, or they canform when gases emitted from power

plants, industries and automobiles reactin the air.

Switcher trains: Rather than travelinglong distances like long-haul trains,switcher locomotives perform pick-upand delivery services within a rail yard,or switchyard. They are used to assem-ble and disassemble trains, move rail-road cars around the yard, and transfercargo to and from long-haul trains.

Switchyard: An area where railroad carsare switched and trains assembled.

Ton-mile: A unit of freighttransportation equivalent to a ton offreight moved one mile.

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1 Power plant comparisons are based on0.25 lb/MWh of PM2.5 and 4.22 lb/MWhof NOx for power plants, which are theaverages for existing coal plants in thewestern U.S.

2 Estimated health impacts combine 2006Census population estimates and EPA’sestimated 2006 diesel locomotive emissionswith EPA’s methodology for estimating thehealth benefits of the non-road diesel rule,which is described in EPA’s RegulatoryImpact Analysis for the Clean Air NonroadDiesel—Tier 4 Final Rule, May 2004, andavailable at www.epa.gov/nonroad-diesel/2004fr.htm

3 Our analysis assumes that these new stan-dards (Tier 3) would apply to any new loco-motive manufactured after the start date ofthe program. We also assume that under anynew program, regardless of the strength ofthe new standard, all locomotives currentlysubject to Tier 0 and Tier 1 standards, wouldbe required to meet Tier 2 standards whenremanufactured.

4 Our analysis produced conservative resultsfor a number of reasons. Due to data con-straints, this analysis excludes the significantemissions from switcher locomotives. Also,our analysis focused on the health effects ofparticulates and NOx’s contribution to par-ticulates. Therefore, we did not include theimportant and significant ozone-relatedhealth benefits from NOx reductions andthe new science linking mortality to ozone.Finally, we did not include ecological bene-fits from particulate and NOx reductions.

5 U.S. Department of Health and HumanServices, “Tenth Report on Carcinogens,”National Toxicology Program, ResearchTriangle Park, NC, 2002. California Officeof Environmental Health Hazard Assess-ment and Air Resources Board, “ProposedIdentification of Diesel Exhaust as a ToxicAir Contaminant.”

6 Manufacturers of Emission ControlsAssociation, “Case Studies of the Use ofExhaust Emission Controls on Locomotivesand Large Marine Diesel Engines,” October2006.

7 See www.fatbadgers.co.uk/Britain/inventors.htm.

8 See www.howstuffworks.com.

Notes

9 U.S. Bureau of Transportation Statistics,“National Transportation Statistics,” 2006.www.bts.gov/publications/national_transportation_statistics/.

10 U.S. Bureau of Transportation Statistics,“National Transportation Statistics,” 2006.

11 IFC Consulting prepared for U.S. FederalHighway Administration, “Impacts ofFreight Movement on Air Quality,”January 26, 2005.

12 U.S. DOT Federal Highway Admin-istration’s Freight Analysis Framework.Available at: ops.fhwa.dot.gov/freight/freight_news/FAF/talkingfreight_faf.htm

13 U.S. DOT Federal Highway Admin-istration’s Freight Analysis Framework, StateProfile-California. Available at: ops.fhwa.dot.gov/freight/freight_analysis/state_info/california/profile_ca.htm.

14 Association of American Railroads, “Overviewof U.S. Freight Railroads” ( January 2006).

15 EPA Report, “Greenhouse Gas Emissionsfrom the U.S. Transportation Sector 1990–2003”, EPA-420-R-06-003, March 2006.

16 Association of American Railroads, “Over-view of U.S. Freight Railroads,” ( January2006).

17 U.S. Department of Energy, December2000. “Annual Energy Outlook, 2001.”Originally referenced by Ang-Olsen, J. &Schroeer, W. 2003.

18 U.S. Environmental Protection Agency,February 2005. “Draft Inventory Of U.S.Greenhouse Gas Emissions And Sinks:1990–2003,” adjusted by ICF Consulting toreflect freight as described in report.Available at http://www.fhwa.dot.gov/Environment/freightaq/chapter2.htm

19 EIA Annual Energy Outlook, 2006. “Table7.” Available at http://www.eia.doe.gov/oiaf/aeo/aeoref_tab.html

20 American Association of Railroads, January2006. “Railroads: Building a Cleaner Envi-ronment.” Available at: http://www.aar.org/getFile.asp?File_id=364

21 American Association of Railroads, January2006. “Railroads: Building a Cleaner Envi-ronment.” Available at: http://www.aar.org/getFile.asp?File_id=364

22 American Association of State Highway andTransportation Officials (AASHTO).

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“Freight-Rail Bottom Line Report,” pg. 29.Available at http://freight.transportation.org/doc/FreightRailReport.pdf

23 Union Pacific factsheet, “Union Pacific andthe Environment.” Available at: http://www.uprr.com/she/emg/attachments/whitepaper.pdf

24 EPA PowerPoint presentation by DonKopinski presented to California AirResources Board Locomotive EmissionsMeeting, “EPA’s Rulemaking for CleanDiesel Locomotives,” July 13, 2006. Powerplant comparisons are based on 0.25 lb/MWh of PM2.5 and 4.22 lb/MWh of NOx

for power plants, which are the averages forexisting coal plants in the western U.S.

25 EPA Report, “Greenhouse Gas Emissionsfrom the U.S. Transportation Sector 1990–2003”, EPA-420-R-06-003, March 2006.

26 EPA web site, “Global Warming Impacts.”yosemite.epa.gov/oar/globalwarming.nsf/content/impacts.html.

27 See www.howstuffworks.com.28 See www.epa.gov/smartway/idle-questions

.htm. U.S. EPA, Idle Free Corridors Imple-mentation Meeting Presentation, April 24,2004. Available at: http://www.epa.gov/region02/air/2004/bubbosh_background04_14_04.pdf

29 69 Fed. Reg. 39,276 ( June 29, 2004).30 EPA PowerPoint presentation by Don

Kopinski presented to California AirResources Board Locomotive EmissionsMeeting, “EPA’s Rulemaking for CleanDiesel Locomotives,” July 13, 2006.

31 Garshick, E.; Laden, F.; Hart, J.E.; Rosner,B.; Smith, T.J.; Dockery, D.W.; Speizer, F.E.(2004) “Lung Cancer in Railroad WorkersExposed to Diesel Exhaust.” EnvironmentalHealth Perspectives 112:1539–1543.

32 U.S. EPA. Particulate Matter: Nature andSources of the Pollutant.

33 R. McConnell et al. “Asthma in exercisingchildren exposed to ozone: a cohort study,”The Lancet, 359 (2002) 386–91.

34 Bell ML, Peng RD, Dominici F. “Theexposure-response curve for ozone and riskof mortality and the adequacy of currentozone regulations,” Environ HealthPerspective, April 2006;114(4):532–6. BellML, McDermott A, Zeger SL, Samet JM,Dominici F. “Ozone and short-term mor-tality in 95 US urban communities,1987–2000,” JAMA, Nov 17, 2004;292(19):2372–8. Levy JI, Chemerynski SM,

Sarnat JA. “Ozone exposure and mortality:an empiric bayes metaregression analysis,”Epidemiology, July 2005; 16(4):458–68.

35 U.S. Department of Health and HumanServices, “Tenth Report on Carcinogens,”National Toxicology Program, ResearchTriangle Park, NC, 2002. California Officeof Environmental Health Hazard Assess-ment and Air Resources Board, “ProposedIdentification of Diesel Exhaust as a ToxicAir Contaminant.”

36 Estimated health impacts combine 2006Census population estimates and EPA’sestimated 2006 diesel locomotive emissionswith the EAP’s methodology for estimatingthe health benefits of the non-road dieselrule.

37 EPA Office of Air Quality, Planning andStandards, Welcome to the Green Book—Nonattainment Areas for Criteria Pollutants.http://www.epa.gov/oar/oaqps/greenbk/

38 69 Fed. Reg. 39,276 ( June 29, 2004).39 63 Fed. Reg. 18,977 (April 16, 1998).40 69 Fed. Reg. 39,276 ( June 29, 2004). “[EPA

is considering emission standards for newlocomotives built as early as 2011, based onthe application of advanced emission controltechnologies. These technologies are cur-rently being developed for use in highwayand nonroad applications and will begin tosee widespread use in these applicationsstarting in 2007. In those programs, weestimated that NOx and PM emissions couldbe reduced by 90 percent or more fromemission levels in the exhaust leaving theengine through the use of NOx aftertreat-ment and PM filter technologies. We wouldexpect that similar levels of NOx and PMreductions could be achieved by applyingthese technologies to locomotives as well.”Page 39281–39282

41 “We believe that, given adequate develop-ment lead time and appropriate structuringof phase-in provisions, locomotive andmarine diesel engines could be designed tosuccessfully employ the same high-efficiencyexhaust emission control technologies nowbeing developed for highway and nonroadengine use.” 69 Fed. Reg. 39,276, 39280( June 29, 2004)

42 69 Fed. Reg. 39,276 ( June 29, 2004).43 69 Fed. Reg. 39,276 ( June 29, 2004).44 EPA website, “8-hour ground level ozone

designations.” Available at: http://www.epa.gov/ozonedesignations/regions/region9desig.htm; EPA website, “Fine particle designa-

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tions.” Available at: http://epa.gov/pmdesignations/regions/region9desig.htm

45 Southern California Occupational andEnvironmental Health Centers. (Spring,2004.) “Center Faculty Discuss Environ-mental Health Impacts of Ports at Instituteof Medicine Meeting.” Available at: http://www.coeh.ucla.edu/newsletter/S04Newsletter.pdf

46 South Coast Air Quality Management Dis-trict, “Fact Sheet: Locomotive Operationsand Air Pollution in Southern California,”February 2006. Available at: www.aqmd.gov/news1/2006/LocomotiveFactSheet2.html

47 Port of Los Angeles, Final Draft: Port-WideBaseline Air Emissions Inventory: ExecutiveSummary; June 2004.

48 US DOT Federal Highway Association,State Motor Vehicle Registrations 2004.Available at: http://www.fhwa.dot.gov/policy/ohim/hs04/htm/mv1.htm

49 Port of Los Angeles, Final Draft: Port-WideBaseline Air Emissions Inventory: ExecutiveSummary; June 2004.

50 California Air Resources Board, “DieselParticulate Matter Exposure AssessmentStudy for the Ports of Los Angeles andLong Beach,” Final Report; April 2006.

51California Air Resources Board “RosevilleRail Yard Study,” Oct.14, 2004. Available at:www.arb.ca.gov/diesel/documents/rrstudy/rcexecsum.pdf.

52 EPA website, “8-hour ground level ozonedesignations.” Available at: http://www.epa.gov/ozonedesignations/regions/region6desig.htm

53 U.S. Census Bureau, 2000.54U.S. DOT Federal Highway Administration’s

Freight Analysis Framework, State Profile-Texas. Available at: ops.fhwa.dot.gov/freight/freight_analysis/state_info/texas/profile_tx.htm.

55 EPA website, “8-hour ground level ozonedesignations.” Available at: http://www.epa.gov/ozonedesignations/regions/region6desig.htm

56Memorandum to Karla Smith-Hardison(TCEQ) and David Hitchcock (HARC)from Richard Billings, Roger Chang, andHeather Perez, ERG. Texas RailroadEmission Inventory Model (TREIM) andResults, June 30, 2005. Available at:www.harc.edu/harc/Projects/AirQuality/Projects/ShowProject.aspx?projectID=32.

57 For the two metro areas, the TCEW studyreplaced U.S. Department of TransportationBureau of Transportation Statistics (BTS)data with data collected directly from BNSFand Union Pacific, the two largest railroadcompanies serving the metro areas. Com-paring data used in the study from BNSFand UP to data used by BTS, the TCEQfound that BTS data underestimated rail-road traffic in the two metropolitan areas byroughly 10%. And because TCEQ had touse BTS data to estimate the locomotiveemissions for all other counties in Texas, it islogical that statewide estimates also came inbelow true emissions levels. This is of greatimportance because the BTS estimates werethe result of a model used to estimate rail-road use nationwide. Therefore, it is likelythat the U.S. Department of Transportationhas underestimated locomotive use andemissions across the nation. Because of thelikely underestimation of national loco-motive emissions, it is important that otherPort and rail hubs invest in these updatedinventories to help Americans and theFederal government understand the signifi-cant impact locomotives have on regionalpollution and health.

Memorandum to Karla Smith-Hardison(TCEQ) and David Hitchcock (HARC)from Richard Billings, Roger Chang, andHeather Perez, ERG. Texas RailroadEmission Inventory Model (TREIM) andResults, June 30, 2005. Available at:www.harc.edu/harc/Projects/AirQuality/Projects/ShowProject.aspx?projectID=32.

58Chicago Region Environmental andTransportation Efficiency (CREATE)Program, Final Feasibility Plan, August2005. Available at: http://www.createprogram.org/PDF/final_feasibility_plan.pdf

59 U.S. DOT Federal Highway Administra-tion’s Freight Analysis Framework, StateProfile-Illinois. Available at: http://ops.fhwa.dot.gov/freight/freight_analysis/state_info/illinois/profile_il.htm

60 EPA website, “8-hour ground level ozonedesignations.” Available at: http://www.epa.gov/ozonedesignations/regions/region5desig.htm; EPA website, “Fine particle designa-tions.” Available at: http://epa.gov/pmdesignations/regions/region5desig.htm

61 Report prepared by IFC Consulting for theU.S. Federal Highway Administration,“Impacts of Freight Movement on Air

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Quality,” April 2005. www.fhwa.dot.gov/environment/freightaq/index.htm.

62 US DOT Federal Highway Association,State Motor Vehicle Registrations 2004.Available at: http://www.fhwa.dot.gov/policy/ohim/hs04/htm/mv1.htm

63 Report prepared by IFC Consulting for theU.S. Federal Highway Administration,“Impacts of Freight Movement on AirQuality,” April 2005. www.fhwa.dot.gov/environment/freightaq/index.htm.

64 EPA website, “8-hour ground level ozonedesignations.” Available at: http://www.epa.gov/ozonedesignations/regions/region3desig.htm; EPA website, “Fine par-ticle designations.” Available at: http://epa.gov/pmdesignations/regions/region3desig.htm

65 Report prepared by IFC Consulting for theU.S. Federal Highway Administration,“Impacts of Freight Movement on AirQuality,” April 2005. www.fhwa.dot.gov/environment/freightaq/index.htm.

66Federal Railroad Administration. FreightRailroads Background. Available at: www.fra.dot.gov/downloads/policy/freight5a.pdf.

67U.S. DOT Federal Highway Administration’sFreight Analysis Framework, State Profile-Wyoming. Available at: ops.fhwa.dot.gov/freight/freight_analysis/state_info/wyoming/profile_wy.htm.

68 McVehil, George E., Edward L. Addison,and Keith A. Baugues, Final ExecutiveSummary Report: Air Quality and VisibilityImpacts of Powder River Basin Coal Miningat Badlands National Park. ACMLRPProject WYDEQ 9550, February 2002.

69 69 Fed. Reg. 39,276 ( June 29, 2004).70 See Railpower Technologies web site at:

www.railpower.com/about.html.71 GE transportation web site at: https://www

.getransportation.com/general/locomotives/hybrid/hybrid_default.asp?SMSESSION=NO .

72 Union Pacific Railroad news release, “UnionPacific Acquiring 60 New GenerationEnvironmentally Friendly Locomotives forLos Angeles Basin Rail Yards,” Feb. 9, 2006.http://www.uprr.com/newsinfo/releases/environment/2006/0209_gensetbuy/shtml.

73 Association of American Railroads websiteat: http://www.aar.org/About_AAR/about_aar.asp

74 IFC Consulting prepared for U.S. FederalHighway Administration, “Impacts of

Freight Movement on Air Quality,”January 26, 2005.

75EPA SmaryWay website at: http://www.epa.gov/otaq/smartway/idle-questions.htm.

76 69 Fed. Reg. 39,276 ( June 29, 2004.)77U.S. EPA. (April 24, 2004.) Idle Free Corri-

dors Implementation Meeting Presentation.Available at: www.epa.gov/region02/air/2004/bubbosh_background04_14_04.pdf.

78Southwest Research Institute. SouthwestResearch Institute (SwRI) News: SwRI testingshows APUs reduce exhaust emissions fromlocomotives. October 28, 2002. Available at:www.swri.edu/9what/releases/2002/APU.htm.

79 EcoTrans Technologies, LLC Presentation,“K9 Auxiliary Power Unit (APU).” www.epa.gov/smartway/presentations/ecotrans-022604.pdf.

80U.S. EPA. (April 24, 2004.) Idle Free Corri-dors Implementation Meeting Presentation.Available at: www.epa.gov/region02/air/2004/bubbosh_background04_14_04.pdf.

81 See Kim Hotstart web site at: http://www.kimhotstart.com/kimhotstart/

82 69 Fed. Reg. 39,276 ( June 29, 2004)page 39,279.

83 69 Fed. Reg. 39,276 ( June 29, 2004).84 Manufacturers of Emission Controls Asso-

ciation, “Case Studies of the Use of ExhaustEmission Controls on Locomotives andLarge Marine Diesel Engines,” October 2006.

85 Union Pacific News Release, “Union PacificPilots Innovative Diesel Engine Technolo-gies,” April 17, 2006. http://www.uprr.com/newsinfo/releases/environment/2006/0417_emissions.shtml

86 Manufacturers of Emission Controls Asso-ciation, “Case Studies of the Use of ExhaustEmission Controls on Locomotives andLarge Marine Diesel Engines,” October2006.

87 EPA Smartway Transport Partnership website at: www.epa.gov/smartway/partners.htm#pagetop.

88 EPA Smartway Transport Partnership website at: www.epa.gov/smartway/swplan.htm.

89 EPA press release, “EPA, Freight IndustrySave Fuel and Help the Environment—Nominations sought for excellence awards,”February 13, 2006. Accessed at: yosemite.epa.gov/opa/admpress.nsf/a8f952395381d3968525701c005e65b5/9d1d0d1c717ee50685257114006c6f4f!OpenDocument.

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90EPA, “Case Study: Chicago Locomotive IdleReduction Project,” March, 2004, EPA420-R-04-003. Available at: www.epa.gov/smartway/documents/420r04003.pdf.

91 Acevedo, Fransisco. EPA powerpointpresentation, Chicago Locomotive IdleReduction Project, Idle Reduction Con-ference; Lebanon, Ohio, October 18, 2004.

92 EPA, “Case Study: Chicago LocomotiveIdle Reduction Project,” March, 2004,EPA420-R-04-003. See www.epa.gov/smartway/documents/420r04003.pdf. Lastaccessed September 16, 2005.

93 Union Pacific. (May, 2004.) Locomotive IdleReduction: Technology Issues—Presentation atNational Idling Reduction Planning Conference.

94 Texas Emissions Reduction Program:Guidelines for Emissions ReductionsIncentive Grants, accessed on September 6,2005 at www.tceq.state.tx.us/comm_exec/forms_pubs/pubs/rg/rg-388.html.

95 Texas Emissions Reduction Program:Guidelines for Emissions ReductionsIncentive Grants, www.tceq.state.tx.us/comm_exec/forms_pubs/pubs/rg/rg-388_202442.pdf.

96 Railway Age magazine, July 2005.97 See California Air Resources Board web site

at: www.arb.ca.gov/railyard/railyard.htm.98 CARB Fact Sheet, (August 2005). Reducing

Locomotive Emissions: New Actions Agreed toby UP and BNSF Railroads. www.arb.ca.gov/railyard/ryagreement/080805fs.pdf.

99CARB, Status Report on the Implementationof the 2005 ARB/Railroad StatewideAgreement, January 13, 2006. Available at:www.arb.ca.gov/railyard/ryagreement/012706sr.pdf.

100CARB, Status Report on the Implementa-tion of the 2005 ARB/Railroad StatewideAgreement, January 13, 2006. Available at:www.arb.ca.gov/railyard/ryagreement/012706sr.pdf.

101 BNSF Press Release, “BNSF to Expand Useof Environmentally Friendly “Green Goat,”’May 23, 2005. www.bnsf.com/media/news/articles/2005/05/2005_05_23a.html.

102CARB, Status Report on the Implementa-tion of the 2005 ARB/Railroad StatewideAgreement, January 13, 2006. Available at:www.arb.ca.gov/railyard/ryagreement/012706sr.pdf.

103 South Coast Air Quality ManagementDistrict, Press Release, “AQMD AdoptsRules to Reduce Pollution from Idling

Trains,” February 3, 2006. Last accessedFebruary 14, 2006 at: www.aqmd.gov/news1/2006/bs02_03_06.html.

104 San Joaquin Valley Air Pollution ControlDistrict. (December, 2000.) Locomotives.Retrieved July 26, 2004 from www.valleyair.org/transportation/Internet%20Locomotive%20handout.pdf.

105 Railway Age, July 2005106See San Joaquin Valley Air Pollution Control

District website at: www.valleyair.org.107The Port of Long Beach News Release,

“‘Clean Diesel’ Locomotives Coming toPorts,” August 26, 2005. Available at:www.anacostia.com/phl/ln050826.htm.

108The Port of Long Beach News Release,“‘Clean Diesel’ Locomotives Coming toPorts,” August 26, 2005. Available at:www.anacostia.com/phl/ln050826.htm.

109 Memorandum, “Inventory Issues forComment Related to Locomotives andMarine Vessels.” From Locomotive andMarine Rulemaking Team Assessment andStandards Division, Office of Transportationand Air Quality to Environmental Pro-tection Agency (EPA), Air Docket A-2000-03; E-DOCKET0 OAR-2003-0190.June 22, 2004.

110 40 CFR Parts 92 and 94, Control ofEmissions of Air Pollution from NewLocomotive Engines and New MarineCompression-Ignition Engines Less Than30 Liters per Cylinder; Proposed Rule.(pp 39276-39289) June 29, 2004.

111 Regulatory Impact Analysis, Clean AirNonroad Diesel—Tier 4 Final Rule, May2004, available at www.epa.gov/nonroad-diesel/2004fr.htm.

112 USEPA. EPA’s Rulemaking for CleanDiesel Locomotives, Don Kopinski, Cali-fornia ARB Locomotive Emissions Meet-ing, July 13, 2006, available at www.arb.ca.gov/railyard/ryagreement/071306epa.pdf.

113 Unit-level emissions from Tier 2 loco-motives estimated in this analysis are basedon the AAR’s estimated counts of Class Iin-service locomotives by age. The AAR’shistoric estimates of Class 1 locomotives arereported in Railroad Facts 2005 and currentfleet counts are estimated in the AAR’sRailroad Statistics monthly publication.

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