United States Air and Raaiafon EPA J20-P-97-007 y
Environmental Protection cebruary 1997
Agency
Office of Mobile Sources
&EPA Environmental
Fact Sheet
Proposed Emission Standards
For Locomotives
The Environmental Protection Agency (EPA) is proposing emission
standards for oxides of nitrogen (NOx), hydrocarbons (HC), carbon
monoxide (CO), paniculate matter (PM) and smoke for newly manufactured
and remanufactured diesel-powered locomotives and locomotive engines,
which have previously been unregulated. The proposed standards will
achieve approximately a two-third reduction in NOx emissions. This would
be equivalent to removing over thirty million passenger cars from the road.
HC and PM emissions will be reduced by 50 percent.
Overview of Rulemaking
This rulemaking is being proposed to achieve emissions reductions that will
be needed by states to comply with the National Ambient Air Quality Stan-
dards (NAAQS) for ozone and PM. The proposed rule is expected to be
finalized by the end of 1997 and take effect in 2000. Current unregulated
locomotives are estimated to contribute almost 5 percent of the total nation-
wide emissions of NOx, which is more than 10 percent of the nationwide
mobile source NOx emissions. This makes locomotives one of the largest
remaining unregulated sources of NOx emissions. Ultimately, when fully
phased-in, EPA expects the new standards will achieve approximately a two-
third reduction in NOx emissions. Standards are also being proposed that
would ultimately reduce locomotive HC and PM emissions in half. The
regulations that are being proposed would affect railroads, locomotive
manufacturers and locomotive remanufacturers.
U.S. £nvVofirne'ntal
Region 5, Library (PL- 12 J)
77 \V.2st Jackson Boulevard, 12th Floor
Chicago, 1L 60604-3590
Printed on Recycled Paper
-------
Health and Environmental Concerns
Emissions from diesel-powered locomotives, such as NOx, HC. and PM,
contribute to air pollution in both urban and rural areas, and have significant
health and environmental effects. NOx is a major component of smog and
acid rain. NOx emissions combine with HC in the atmosphere to form
ground-level ozone, the primary constituent of smog. Ozone is a highly '
reactive pollutant that damages lung tissue, causes congestion, and reduces
vital lung capacity, in addition to damaging vegetation. Acid rain damages
buildings and crops, and degrades lakes and streams. NOx also contributes
to the formation of secondary PM. PM causes headaches, eye and nasal
irritation, chest pain, and lung inflammation. Environmental impacts of PM
include reduced visibility and deterioration of buildings.
What are the Main Components of the Proposed Rule?
Since locomotive emissions have not been regulated before, it was necessary
for EPA to create a comprehensive program, including not only emission
standards, but also test procedures and a full compliance program. In
general terms, the overall program is similar to previously established
programs for heavy-duty highway engines and other nonroad engines. One
unique feature included for locomotives, however, is the regulation of the
engine remanufacturing process, including the remanufacture of locomotives
originally manufactured prior to the effective date of this rulemaking. Regu-
lation of the remanufacturing process is critical because locomotives are
generally remanufactured 5 to 10 times during their total service lives
(typically 40 years or more). Standards that only applied to locomotives
originally manufactured after the effective date of the rule would not achieve
significant emissions reductions in the near term, as those locomotives
slowly replaced the existing fleet.
Emission Three separate sets of emission standards are proposed, with applicability of
Standards the standards dependent on the date a locomotive is first manufactured. The
first set of standards (Tier 0) are proposed to apply to locomotives and
locomotive engines originally manufactured from 1973 through 1999, any
time they are remanufactured in calendar year 2000 or later. The second set
of standards (Tier I) apply to locomotives and locomotive engines originally
manufactured from 2000 through 2004. These locomotives and locomotive
engines would be required to meet the Tier, I standards at the time of original
manufacture and at each subsequent remanufacture. The final set of stan-
dards (Tier II) are proposed to apply to locomotives and locomotive engines
originally manufactured in 2005 and later. Tier II locomotives and locomo-
-------
Production
Line Testing
In-Use
Emissions
Testing
Emission
Averaging
Provisions
Preemption of
State
Programs
tive engines would be required to meet the applicable standards at the time
of original manufacture and at each subsequent remanufacture. Electric
locomotives, historic steam-powered locomotives, and locomotives origi-
nally manufactured before 1973 do not contribute significantly to the emis-
sions problem, and thus, are not included in this rulemaking.
EPA is proposing a production line testing (PLT) program that would re-
quire manufacturers and. in some cases, remanufacturers of locomotives to
perform production line testing of newly manufactured and remanufactured
locomotives as they leave the point where the manufacture or remanufacture
is completed. The PLT program for freshly manufactured units would be
based on actual testing, while the PLT program for remanufactured units
would be based on an audit of the remanufacture kit's installation, with EPA
having the ability to require testing if in-use data indicates a possible prob-
lem with production.
A critical element in the success of the proposed locomotive program is
ensuring that manufacturers and remanufacturers produce locomotives that
continue to meet emission standards beyond certification and production
stages, during actual operation and use. EPA is proposing to adopt an in-use
compliance program with two distinct components. The first program
would require the manufacturers and remanufacturers to test representative
locomotives from all engine families using the full Federal Test Procedure
(FTP). This testing would occur at about 75 percent of useful life. Actual
repair in the event of a determination of noncompliance or recall action.
however, would apply to all locomotives of that family, regardless of
whether the locomotives have exceeded their useful lives. Second. EPA is
proposing to require that Class I railroads annually test 10 percent of their
locomotives which have met or exceeded their useful lives using a modified
version of the FTP.
EPA is proposing averaging, banking and trading (ABT) provisions to allow
manufacturers and remanufacturers the flexibility to meet overall emissions
goals at the lowest cost, while allowing EPA to set emissions standards at
levels more stringent than they would be if each and every engine family
had to comply with the standards. ABT is also designed to encourage early
introduction of cleaner engines, which would secure emissions benefits
earlier than would otherwise be the case.
EPA is proposing regulations that would codify and clarify Clean Air Act
preemption of certain state and local requirements relating to the control of
emissions from new locomotives and new locomotive engines. This pre-
emption was included in the Clean Air Act because of the inherent interstate
-------
nature of the railroad industry. Moreover, EPA believes that a strong federal
program that addresses manufacturing, remanufacturing and in-use compli-
ance is the best way to achieve the necessary emissions reductions.
How Does the Proposed Rule Provide Flexibility to
Industry?
• The proposed rule codifies the Clean Air Act's preemption of state and
local emission requirements, which is intended to prevent inappropriate
burdens on interstate commerce.
• The flexibility provided by ABT lowers the costs to manufacturers and
makes it easier to meet the technological challenges posed by the new
standards.
• EPA is also proposing to exempt the smallest railroads from compli-
ance with the Tier 0 standards, with some restrictions.
How Much Will the Proposed Rule Cost?
Lifetime cost components consist of initial equipment costs;
remanufacturing costs; fuel economy costs; and certification, production
line and in-use testing costs. EPA estimates that the lifetime cost per loco-
motive will be approximately $80,000 for the Tier 0 standards, $118,000 for
the Tier I standards and $86,000 to $266,000 for the Tier II standards (the
estimated cost for Tier II locomotives drops from $226,000 to $86,000 after
manufacturers recover their research and development costs). The average
annual cost of this program is estimated to be $76 million per year. This
would be about 0.2 percent of the total freight revenue for railroads in 1995.
The average cost-effectiveness of the proposed standards is expected to be
about $170 per ton of NOx and PM.
What Are the Environmental Benefits?
The primary focus of this rulemaking is on reducing NOx and PM emis-
sions, although there are also reductions in HC and CO. NOx emissions
from locomotives will be reduced almost 60 percent by 2040, compared to
1990 baseline levels. This would be about 600,000 tons per year. Most of
these reductions will come early in the program (e.g., 39 percent reduction
by 2010), due to the standards that apply to pre-2000 locomotives when they
-------
are remanufactured. In addition to the NOx benefits of the proposed rule.
the proposal will provide some PM benefits through the Tier II standards. A
PM reduction of 42 percent is expected by 2040. compared to 1994 baseline
levels. This reduction is over 10,000 tons per year, and amounts to over one
percent of national PM emissions from mobile sources.
What Opportunities Exist for Public Participation?
EPA desires full public participation in arriving at final rulemaking deci-
sions. EPA solicits comments on all aspects of the proposal from all inter-
ested parties. Wherever applicable, full supporting data and detailed analy-
ses should also be submitted to allow EPA to make maximum use of the
comments. Commenters are especially encouraged to provide specific
suggestions for changes to any aspects of the proposal that they believe need
to be modified or improved. A public hearing will also be held approxi-
mately 30 days after publication of the proposed rule in the Federal Regis-
ter.
For instructions on submitting written comments, please see the Federal
Register notice. It is available from the EPA Air and Radiation Docket by
calling 202-260-7548; please refer to Docket No. A-94-31. In addition, the
proposed rule is available electronically via the EPA Internet server via the
dial-up modem on the Technology Transfer Network (TTN), an electronic
bulletin board system (BBS).
World Wide Web:http//www.epa.gov/OMSWWW
TTN BBS: 919-541-5384 (1200-1440 bps, no parity. 8 data bits. 1
stop bit); voice helpline 919-541-5384.
For More Information
For further information on the proposed rule, please write to:
U.S. Environmental Protection Agency
Engine Programs and Compliance Division
2565 Plymouth Road
Ann Arbor, MI 48105
or call: (313)668-4333
-------
United States Air and Radiation EPA 420-F-97-OC8
Environmental Protection February 1997
Agency
Office of Mobile Sources
vvEPA Environmental
Fact Sheet
Federal Preemption of State
and Local Control of Locomotives
The Environmental Protection Agency (EPA) is proposing regulations to
implement section 209(e) of the Clean Air Act (CAA), which prohibits
certain state and local controls for locomotives. These regulations are
being proposed in conjunction with new emission standards for locomotives
and locomotive engines, which are being proposed under section 213 of
the CAA.
Clean Air Act Preemption Requirements
In section 209(e) of the CAA. Congress preempted state and local govern-
ments from adopting or enforcing "any standard or other requirement relat-
ing to the control of emissions from ...new locomotives or new engines used
in locomotives." (Given the nature of locomotive remanufacturing, EPA is
defining "new locomotives and new engines used in locomotives" to include
existing locomotives when they are remanufactured.) EPA is proposing
regulations that would implement this preemption consistent with Congres-
sional intent to prevent unreasonable burdens on interstate commerce.
Prohibited Controls
The proposed regulations would prohibit state and local governments from
adopting or enforcing any controls that significantly affect a locomotive
manufacturer's or remanufacturer's design. EPA also is proposing to define
by regulation a period during which state and local governments would be
i Printed on Recycled Paper
-------
explicitly prohibited from adopting three categories of controls that EPA has
determined would affect a manufacturer's or remanufacturer's design: 1)
emission standards (and related requirements), 2) non-federal in-use testing
programs, and 3) emission control retrofit requirements. This period would
be equivalent to 1.25 times useful life, where useful life is the average
period during which a locomotive is operated before it is remanufactured
(typically about 6 years). Locomotives would also be required to be in
compliance with the federal emission standards throughout the useful life.
Comparison to Other Mobile Sources
The preemption being proposed is based on the same principles applied to
other mobile sources. Most significantly, this preemption is based on a U.S.
District Court decision (Allway Taxi Inc. v. City of New York) that stated
that state controls on emissions of non-new motor vehicles are preempted by
the Clean Air Act if those controls have an effect on manufacturers of new
motor vehicles. Since the Clean Air Act preemption provisions for nonroad
vehicles and engines are similar to these for motor vehicles, EPA has consis-
tently applied this principle to other nonroad sources, although the applica-
tion of this principle varies somewhat from industry to industry. The pro-
posed regulations for locomotives do differ significantly from previous
regulations dealing with preemption in that they include a codification of the
principle outlined in the Allway court case (i.e., the explicit preemption
period for certain types of controls). This was done to provide more cer-
tainty to all parties involved, and because unique features of locomotives
and railroads made it appropriate.
Environmental Impacts of Preemption
The proposed preemption regulations would not have any adverse impacts
on the environment because of EPA's proposed aggressive control program
that is designed to achieve the maximum possible environmental benefits.
EPA is proposing emission standards that will apply both when a locomotive
or locomotive engine is originally manufactured and each time that it is
remanufactured. The new standards will achieve a two-third reduction in
NOx emissions. Standards are also being proposed that will ultimately
reduce locomotive hydrocarbon and particulate emissions in half. EPA is
proposing an extensive compliance program, including in-use testing, to
ensure that the projected emission reductions are achieved. Without pre-
emption, on the other hand, there is more of a potential for some shift of
freight traffic to more polluting forms of transportation that could occur if
-------
the costs of rail transportation increased significantly due to a patchwork of
state and local regulations. (For example, transport by rail causes about
one-third of the pollution as transport by truck per ton-mile of freight.)
Benefits of a Strong Federal Program
Given the inherent interstate nature of the railroad industry, EPA believes
that a strong federal program that addresses manufacturing, remanufacturing
and in-use compliance can best achieve the necessary emissions reductions.
This is especially true since many state governments lack the resources to
control emissions from locomotives. Since EPA is proposing such a strong
federal program, there would be little that any state could do to further
reduce locomotive emissions. Also, a patchwork of state and local regula-
tions would be inefficient, and could hinder EPA's ability to implement a
uniform national control program.
For More Information
Information on the proposed rule for locomotive standards is available
electronically via the EPA Internet server via the dial-up modem on the
Technology Transfer Network (TTN), an electronic bulletin board system
(BBS).
World Wide Web:hhtp//www.epa.gov/OMSWWW
TTN BBS: 919-541-5384 (1200-1440 bps, no parity. 8 data bits. 1
stop bit); voice helpline 919-541-5384.
For further information on the proposed rule, please write to:
U.S. Environmental Protection Agency
Engine Programs and Compliance Division
2565 Plymouth Road
Ann Arbor, MI 48105
or call: (31.3) 668-4333
-------
United States Air and Rad ration EPA 420-F-97-G09
Environmental Protection February 1997
Agency
Office of Mobile Sources
Environmental
Fact Sheet
Environmental Benefits of Proposed
Emission Standards for Locomotives
The Environmental Protection Agency (EPA) is proposing emission
standards for oxides of nitrogen (NOx), hydrocarbons (HC), carbon
monoxide (CO), paniculate matter (PM) and smoke for newly manufactured
and remanufactured locomotives and locomotive engines. The proposed
standards will achieve approximately a two-third reduction in NOx
emissions and will reduce HC and PM emissions by half.
Overview of Rulemaking
EPA is proposing emission standards for locomotives that will provide
significant emission reductions to help states comply with National Ambient
Air Quality Standards (NAAQS) for ozone and PM. The proposed rule is
expected to be finalized by the end of 1997 and take effect in 2000. Since
locomotive emissions have not been regulated before, it was necessary for
EPA to create a comprehensive program, including not only emission stan-
dards, but also test procedures and a full compliance program. Three sepa-
rate sets of emission standards are proposed, with applicability of the stan-
dards dependent on the date a locomotive is first manufactured. The first set
of standards (Tier 0) are proposed to apply to locomotives and locomotive
engines originally manufactured from 1973 through 1999, any time they are
remanufactured in calendar year 2000 or later. The second and third sets of
standards (Tier I and Tier II) will apply to locomotives and locomotive
engines originally manufactured on or after January 1, 2000 (Tier II stan-
i Printed on Recycled Paper
-------
dards will take effect on January 1. 2005). These locc nives and locomo-
tive engines will also be required to meet the same standards at each subse-
quent remanufacture. The Agency is also proposing a rigorous emission
testing program to make sure that locomotives comply with these standards
for the life of the locomotive.
Health and Environmental Concerns
Most locomotives in the U.S. are powered by diesel engines. Thus locomo-
tives have significant NOx emmissions, as well as HC and PM emissions, all
of which have significant health and environmental effects. NOx is a major
component of smog and acid rain. NOx emissions combine with HC in the
atmosphere to form ground-level ozone, the primary constituent of smog.
Ozone is a highly reactive pollutant that damages lung tissue, causes conges-
tion, and reduces vital lung capacity, in addition to damaging vegetation.
Acid rain damages buildings and crops, and degrades lakes and streams.
NOx also contributes to the formation of secondary PM. PM causes head-
aches, eye and nasal irritation, chest pain, and lung inflammation. Environ-
mental impacts of PM include reduced visibility and deterioration of build-
ings.
Locomotive Emission Inventories
Locomotive NOx emission are estimated to represent about 4.7 percent of
NOx emissions from all mobile and stationary sources in the U.S. Locomo-
tive PM and HC emissions are both estimated to represent less than one-
quarter of one percent of total national emissions. Thus, the focus of the
proposed regulation is on NOx emission reductions. It should be noted that
in some urban areas that have very high rail traffic, such as Chicago or El
Paso, NOx emissions can represent nearly one-tenth of the total NOx inven-
tory.
Current National Locomotive Emission Inventories
NOx
PM-10
HC
Metric Tons Per Year
980,000
24,000
38,000
Percent of Total Inventory (All Sources)
4.7
0.1
0.2
-------
What Are the Environmental Benefits?
When fully phased-in. the proposed emission standards will reduce NOx
emissions from locomotives by nearly two-thirds, and HC and PM emissions
by half. However, they will also achieve very significant emission reductions
in the near term. These reductions, which are shown below, are being
heavily relied upon by those areas that have very high rail traffic, as well as
Southern California, which has moderately high rail traffic and very signifi-
cant air quality needs. To put these national NOx emission reductions into
context, the 348.000 ton per year reduction expected in 2005 would be
equivalent to removing about 20 million pasenger cars from the road. In
addition, NOx emission reductions will also lead to reductions in ambient
concentrations of secondary PM. It has been estimated that about 4 tons of
nitrate paniculate is formed from every 100 tons of NOx emitted. Thus, the
secondary PM reduction expected in 2005 is about 14,000 tons per year.
Projected National Emission Reductions (Metric Tons Per Year)
Year
NOx
PM
HC
Secondary PM*
2005
348,000
300
400
14,000
2010
382,000
1,700
2,500
15,000
2015
417,000
3,200
4,500
17,000
2020
45 1 .000
4,700
6,600
18,000
Assumes 4 tons of nitrate particulate formed for each 100 tons of NOx emitted.
Reductions from Existing Locomotive Fleet
The fact that so much of the NOx emission reduction will come early in the
program is due to the Tier 0 standards that apply to existing locomotives
when they are remanufactured. These standards are a unique feature of this
proposed regulation, and would represent the first time that EPA has regu-
lated the remanufacturing of an existing fleet on such a large scale. Such
regulation of the remanufacturing process is critical because locomotives are
generally remanufactured five to ten times during their total service lives
(typically 40 years or more). Standards that would only apply to locomotives
originally manufactured after the effective date of the rule would not achieve
significant emissions reductions until those future locomotives replaced a
significant number locomotives in the existing fleet. For the first 13 years of
the program, the majority of projected NOx emission reductions will be the
result of the Tier 0 emission standards that apply to existing locomotives.
U.S. Environmental Protection Agency
D.
77 \V^t Jcxkron Bouievard, 12th Floor
Cnicago, !L 60604-3590
-------
Projected NOx Emission Reductions From Locomotives iManufactured
Before and After January 1, 2000 (Metric Tons Per Year)
Year
TierO
(Pre-2000 Locomotives)
Tier I & II
(Later Locomotives)
2005
275.000
73,000
2010
234.000
148,000
2015
194,000
223,000
2020
153,000'
298.000
For More Information
Information on the proposed rule is available electronically via the EPA
Internet server via the dial-up modem on the Technology Transter Network
(TTN), an electronic bulletin board system (BBS).
World Wide Web:http//www.epa.gov/OMSWWW
TTN BBS: 919-541-5384 (1200-1440bps, no parity, 8 data bits,
1 stop bit); voice helpline 919-541-5384.
For further information on the proposed rule, please write to:
U.S. Environmental Protection Agency
Engine Programs and Compliance Division
2565 Plymouth Road
Ann Arbor. MI 48105
or call: (313) 668-4333.
------- |