xvEPA
United States
Environmental Protection
Agency
Office of Transportation EPA420-B-09-037
and Air Quality October 2009
Guidance for Quantifying and
Using Long Duration Switch
Yard Locomotive Idling
Emission Reductions in State
Implementation Plans
> Printed on Recycled Paper
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EPA420-B-09-037
October 2009
Guidance for Quantifying and Using
Long Duration Switch Yard Locomotive
Idling Emission Reductions in
State Implementation Plans
Transportation and Regional Programs Division
Office of Transportation and Air Quality
and
Air Quality Strategies and Standards Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Updated October 2009
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TABLE OF CONTENTS
Page
Section A: Background Information
1. What is the purpose of this guidance? 1
2. How does this guidance relate to existing Clean Air Act requirements? 1
3. What are switchyard locomotive idling emissions? 1
4. What is an idle reduction technology? 1
5. What are the benefits from using technologies to reduce switch yard locomotive idling
emissions? 2
Section B: Basic Requirements for Long Duration Switch Yard Locomotive Idling Emission Reductions
6. What are the basic requirements for using emission reductions in SIPs? 2
7. What are the types of operational requirements that would generate emission reductions? 4
Section C: Specific Requirements for Using Long Duration Switch Yard Locomotive Idling Emission
Reductions
8. Are switch yard locomotive idling emissions part of the state's emission inventory? 6
9. How can the estimated emission reductions be used for SIP purposes? 6
Section D: Quantifying Long Duration Switch Yard Locomotive Idling Emission Reductions
10. How do you quantify emission reductions from the use of an idle reduction technology? 7
11. How do you quantify emission reductions for other criteria air pollutants or precursors? 11
Section E: Verification and Penalties
12. What are the monitoring, record keeping, and reporting requirements for including long
duration switchyard locomotive idling emission reductions in SIPs? 11
13. What kind of validation and reconciliation is required for emission reductions in SIPs? 11
14. What types of penalties can be assessed for not complying with Clean Air
Act requirements? 12
Section F: The SIP Process for Using Long Duration Switch Yard Locomotive Idling Emission
Reductions Emissions
15. What must a state submit to EPA to meet the requirements for incorporating a
source specific control measure in a SIP? 12
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Section G: Contact Information
16. Who should you contact for additional information? 12
Appendix A: Definitions 13
Appendix B: NOX and PM Emission Factors for Long Duration Idling Switch Yard Locomotives 14
Appendix C: Quantification Summary 15
Appendix D: Example Quantification 16
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LIST OF ABBREVIATIONS
AC Air Conditioning
APU Auxiliary Power Unit
CAA Clean Air Act
g/bhp-hr Grams per brake horsepower hour
g/kW-hr Grams per kilowatt hour
g/hr Gram per hour
hp Horsepower
hr Hour
Ibs Pounds
NOX Nitrogen Oxides
PM Paniculate Matter (2.5 and 10)
RPM Revolutions per minute
RFP Reasonable Further Progress
ROP Rate of Progress
SIP State Implementation Plan
SYL Switch Yard Locomotive
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Guidance for Quantifying and Crediting Locomotive Idling Emission Reductions
(Note: As used in this document, the terms "we", "us" and "our" refer to EPA. The terms "you" and "your"
refer to a state air pollution control agency.)
Section A: Background Information
1. What is the purpose of this guidance?
The purpose of this document is to provide you with guidance on quantifying emission reductions
from technologies which reduce long duration switch yard locomotive (SYL) idling emissions. You may
wish to use the emission reductions resulting from implementing an idling reduction technology for
meeting emission reduction requirements such as an RFP/ROP, attainment or maintenance SIP.
2. How does this guidance relate to existing Clean Air Act requirements?
This document provides guidance to state air pollution control agencies and the general public on
how control measures to reduce truck idling emissions may be used to meet SIP requirements. SIP
requirements can be found in Sections 110(a)(2) and 172(c) of the CAA. This document does not
substitute for those provisions, nor is it a regulation itself. Unless otherwise indicated, it does not impose
binding, enforceable requirements on any party. Further, it does not assure that EPA may approve all
instances of its application, and thus the guidance may not apply to a particular situation based upon the
circumstances. The EPA and state decision makers retain the discretion to adopt approaches on a case-by-
case basis that differ from this guidance where appropriate. Any decisions by EPA regarding a particular
SIP demonstration will only be made based on the statute and applicable regulations, and will only be made
following notice and opportunity for public review and comment. Therefore, interested parties are free to
raise questions and objections about the appropriateness of the application of this guidance to a particular
situation; EPA will, and states should, consider whether or not the recommendations in this guidance are
appropriate in that situation. This guidance is a living document and may be revised periodically without
public notice. The EPA welcomes public comments on this document at any time and will consider those
comments in any future revisions of this guidance document.
Readers of this document are cautioned not to regard statements recommending the use of certain
procedures as either precluding other procedures or information or providing guarantees that using these
procedures will result in actions that are fully approvable. As noted above, EPA cannot assure that actions
based upon this guidance will be fully approvable in all instances, and all final actions may only be taken
following notice and opportunity for public comment.
3. What are switch yard locomotive idling emissions?
SYL engines are designed or used solely for the purpose of propelling railroad cars a short distance
within a confined area. They usually idle their engines when not in use, and they idle for a variety of
reasons, such as maintaining engine operating temperature during cold weather to avoid engine freezing
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(most locomotive engines do not have anti-freeze). Other reasons for idling include immediate engine
availability, preventing start-up engine damage, maintaining air brake pressure, and in some cases,
company policy or habit.
4. What is an idle reduction technology?
An idle reduction technology consists of the use of an alternative energy source in lieu of using the
main SYL engine or a device designed to reduce long duration idling. Some of these technologies are
mobile and attach onto the SYL (mobile auxiliary power units (APUs)), and provide heat or electrical
power.
Another technology involves electrifying SYL parking spaces (stationary locomotive parking
electrification) and modifying the SYL. In general, this involves installing electric powered heating
systems on SYL which connect to the electrical grid and provide energy to operate on-board equipment.
This guidance addresses emission reductions generated from both mobile and stationary
technologies. EPA maintains a list of commercially available idle reduction technologies on its web site
at the following address: http://www.epa.gov/otaq/retrofit/idlingtech.htm. This list is for informational
purposes only, is not an endorsement or verification of any specific idle reduction technology, and is not
intended as a complete list of all available idle reduction technologies.
5. What are the benefits from using technologies to reduce SYL idling emissions?
The primary purpose of this guidance is to quantify emission reductions in criteria air pollutants
and their precursors. This guidance specifically addresses emission reductions of NOX and PM25 and
PMj,,.1 In addition, there are other important benefits associated with reductions in long duration SYL
idling emissions including:
• Reductions in the emissions of toxic air pollutants such as formaldehyde, and trace metals
such as nickel.
• Reductions in emissions of carbon dioxide.
Reductions in fuel consumption, decreased maintenance costs, and longer engine life
which results in cost savings to the locomotive owner.
• Reductions in noise levels.
• Decreased dependency on oil imports.
Local communities near switch yards, some of which are comprised of low income and minority
populations, may benefit from the reduced pollution and noise levels as will SYL operators and switch
yard staff.
1 Based on data collected, almost all diesel PM is submicron in size. Therefore, we
believe it is reasonable to use the same idling emission factor for both PM2 5 ajid PM .
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Section B: Basic Requirements for Long Duration Switch Yard Locomotive Idling Emissions
Reductions
6. What are the basic requirements for using emission reductions in SIPs?
In order to be approved as a measure which provides additional emission reductions in a SIP, a
control measure reducing long duration SYL idling emissions cannot interfere with other requirements
of the CAA, and would need to be consistent with SIP attainment, maintenance, or RFP/ROP
requirements. In addition, the control measure must provide emission reductions that meet the
requirements described below.
(A) Quantifiable - The emission reductions from a control measure to reduce long duration SYL idling
emissions are quantifiable if they can be reliably and replicably measured. Emission reductions must be
calculated for the time period for which the reductions will be used. Section D of this document
provides you with a method acceptable to us for quantifying emission reductions. You can also submit
your own quantification protocol which we will review and make a decision as to the appropriateness of
its use on a case-by-case basis.
(B) Surplus - Emission reductions are generally surplus and can be used as long as they are not
otherwise relied on to meet other applicable air quality attainment and maintenance requirements. In the
event that the measure to reduce long duration SYL idling emissions are relied on by you to meet such
air quality related program requirements, they are no longer surplus and may not be used for additional
credit. In addition, to be considered surplus the emissions from long duration SYL idling must be a part
of the SIP's emissions inventory.
(C) Federally Enforceable - Depending on how the emission reductions are to be used, control measures
to reduce long duration SYL idling emissions must be enforceable through a SIP or SIP revision. Where
the emission reductions are part of a rule or regulation, they are considered federally enforceable if they
meet all of the following requirements:
• They are independently verifiable.
Violations are defined, as appropriate.
• You and EPA have the ability to enforce the measure if violations occur.
Those liable for violations can be identified.
• Citizens have access to all the emissions-related information obtained from the
responsible party.
• Citizens can file suits against the responsible party for violations.
Violations are practicably enforceable in accordance with EPA guidance on practicable
enforceability.
A complete schedule to implement and enforce the measure has been adopted by the
implementing agency or agencies.
If a SIP revision is approved under EPA's Voluntary Measures Policy, the state is responsible for
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assuring that the reductions credited in the SIP occur. The state would need to make an enforceable SIP
commitment to monitor, assess and report on the emission reductions resulting from the voluntary
measure and to remedy any shortfalls from forecasted emission reductions in a timely manner. Further,
the total of all voluntary measures (including the idle emission reduction measures) may not exceed 3%
of the total reductions needed to meet any requirements for RFP/ROP, attainment or maintenance. In the
circumstance where the actual emission reductions achieved are more than the amount estimated in the
SIP, you may take credit for the additional emission reductions provided it does not exceed the 3% cap
on voluntary measures and meets the other requirements of the Voluntary Measures Policy. If you wish
to have a SIP revision approved under the Voluntary Measures Policy consult that policy for further
information.2
(D) Permanent - The emission reduction must be permanent throughout the term that the emission
reduction is used.
(E) Adequately Supported - The state must demonstrate that it has adequate funding, personnel, and
other resources to implement the control measure on schedule.
7. What are the types of operational requirements that would generate emission reductions?
To generate emission reductions the following requirements should be met (or similar
requirements capable of insuring accurate measurements and implementation of the emission reductions
to our satisfaction):
(A) Use a commercially available idle reduction technology to provide SYL needs (such as engine and
oil heat), and/or reduce idling during the operator's long duration rest or wait period, in lieu of idling the
main locomotive engine;
(B) Use an idle reduction technology that is equipped with a non-resettable meter, data logger, or
computerized data acquisition system capable of measuring total hours it operated;
(C) Comply with all necessary monitoring, recordkeeping, reporting, validation, and reconciliation
requirements as described in Section E of this guidance.
(D) In the case of mobile idle reduction technologies:
(1) Ensure the SYL engine is located in a nonattainment or maintenance area for the pollutant or
precursor for which emission reductions are generated;
(2) If any SYL that is included in the idle reduction project leaves the nonattainment or
maintenance area, the responsible party should notify you of this occurrence so the emission
2 For a description of this policy consult the following web site:
http://www.epa.gov/otaq/transp/traqvolm.htm.
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reductions are adjusted appropriately to reflect this change;3 and
(3) Prior to quantifying emission reductions, determine the historic idling activity for each SYL
that will be generating emission reductions.4 This information should include sufficient
documentation, such as data from an event recorder to determine the following information:
(a) The historic number of hours the SYL idled per day for an average summer weekday
for the past year (if pursuing NOX emission reductions in an ozone
nonattainment/maintenance area); or
(b) The historic number of hours the SYL idled per day for an average annual weekday
for the past year (if pursuing PM or NOX emission reductions in a PM nonattainment or
maintenance area).5
(3) Prior to generating emission reductions, you will need the following information for the
mobile idle reduction technology only: the manufacturer and manufacture date of the idle
reduction technology, its engine model, and average daily horsepower load for the time period for
which you will be generating emission reductions.
(E) In the case of stationary idle reduction technologies:
(1) Ensure the technology is located in a nonattainment or maintenance area for the pollutant or
precursor for which emission reductions are generated; and
(2) Prior to quantifying emission reductions, determine the historic idling activity for each SYL
location that will be generating emission reductions. This information should include sufficient
documentation, such as survey or direct observation methods to determine the following
information:
(a) Number of SYLs operating at the location throughout the year;
3 If any SYL leaves due to routinely scheduled maintenance and will return to the same
rail yard (or another rail yard within the same nonattainment or maintenance area), the
responsible party should not have to notify you. In this case, the meter or logger should account
for the engine time period not operating.
4 The historic idling activity will be used to estimate the idling emission reductions to be
achieved from the use of an idle reduction technology. This estimate will be compared with the
actual emission reductions achieved after the monitoring period, as discussed in Section E.
5 If dealing with large numbers of vehicles, you can use fleet idling averages to determine
the historic idling activity.
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(b) Of the number in (a) above, the percentage of those SYLs which idle for a long
duration (defined as 15 consecutive minutes or more at idle); and
(c)(l) Of the SYLs in (b) above, the historic number of hours the SYLs idled per day for
an average summer weekday for the past year (if pursuing NOX emission reductions in an
ozone nonattainment/maintenance area); or
(c)(2) Of the SYLs in (b) above, the historic number of hours the SYLs idled per day for
an average annual weekday for the past year (if pursuing PM or NOX emission reductions
in a PM nonattainment or maintenance area).6
Section C: Specific Requirements for Using Long Duration Switch Yard Locomotive Idling
Emission Reductions
8. Are SYL idling emissions part of the state's emission inventory?
You must demonstrate that the emissions from the SYLs (from which the emission reductions
will take place) are accurately included in the SIP emissions inventory. In addition, the crediting of the
emission reductions must also be consistent with the assumptions in the emission inventory upon which
the attainment or maintenance demonstration is based. If they are not already in the SIP inventory, no
credit can be given for idling emission reductions unless the SIP inventory baseline is reassessed to
include such emissions at its current level.
9. How can the estimated emission reductions be used for SIP purposes?
For your SIP RFP/ROP, attainment or maintenance strategy, you can use the emission reductions
which are, or expected to be, generated from the idling reduction technology by applying the following
criteria:
(A) Based on the historic idling hours as determined in question 7(D)(3) and 7(E)(2) above, the
estimated and actual emission reductions per day from the idle reduction project should be a
percentage of the historic idling hours per day. In the circumstance where the estimated or actual
hours idled exceeds the historic idling hours, you will need to provide an explanation as to the
reason for the difference if you decide to seek credit for the additional amount (that is, the actual
amount). We will evaluate the reason for the difference and make a decision as to the quantity of
the emission reduction available on a case-by-case basis.7
6 If dealing with large numbers of SYLs, you can use fleet idling averages to determine
the historic idling activity.
7 For both mobile and stationary idle reduction technologies, determining the historic
idling hours forms the basis for estimating the potential emission reductions. Differences
between the historic idling hours and estimated or actual idling hours may occur due to, for
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(B) Where required, emission reductions must account for seasonality. For example, if your SIP
only credits those reductions which take place during the summer ozone season, then only
reductions in idling emissions which take place during that season may be credited.
(C) The total emission reductions from all controls on long duration SYL idling for each criteria
pollutant or precursor is not to exceed the amount in the state's air emissions inventory for SYL
emissions in the year or years the emission reductions are relied upon.
Section D: Quantifying Long Duration Switch Yard Locomotive Idling Emission Reductions
The following steps describe how to estimate the emission reductions from a proposed idle
reduction project. In addition, these same steps can be used to determine the actual emission reductions
achieved from the project. Step 1 establishes the historic idling activity from which you will estimate an
emission reduction. Steps 2 and 3 describe how to estimate the SYL emissions that are reduced when
using an idle control technology. Step 4 describes how to estimate the emissions associated with the idle
reduction technology (this step is usually not necessary if using a stationary idle reduction technology).
Steps 5 and 6 describe how to estimate the net reduction in emissions for the entire project. Finally,
Steps 7 and 8 describe how to determine how much of the net reduction is creditable in a SIP. Appendix
C provides a summary of Steps 1-6. Appendix D provides a quantification example for a mobile
technology.
10. How do you quantify emission reductions from the use of an idle reduction technology?
Step 1: Determine the historic idling activity of the SYLs involved in the project.
For each SYL using a mobile idle reduction technology, determine the historic idling hours as
described in question 7(D)(3). Likewise, for each SYL space which will have a stationary idle reduction
technology installed, determine the historic idling hours as described in question 7(E)(2).8
Step 2: Select the emission factor for the criteria air pollutant or precursor.
In Appendix B, we provide emission factors for NOX and PM. These emission factors represent
average emissions from a long duration idling SYL. For NOX emissions, the emission factor is 800 g/hr
(2 stroke engine) or 620 g/hr (4 stroke engine). For PM emissions, the emission factor is 26 g/hr (2
stroke engine) or 32 g/hr (4 stroke engine). Consult Appendix B for a full explanation of the basis for
the emission factors. In the future, we may update the emission factors or include other criteria air
pollutants or precursors.
example, warmer or colder temperatures than the historic time period.
8 If dealing with large numbers of SYLs, you can use fleet idling averages to determine
the historic idling activity.
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Step 3: Multiply the emission factor in Step 2 by the number of hours per day the idle reduction
technology is estimated to be used.
You must estimate the average number of hours per day of idling emissions to be eliminated by
the use of the idle reduction technology. The estimated hours should be a percentage of the historic
idling activity as determined in Step 1. In the case of mobile technologies, estimate the number of hours
that the technology will reduce long duration idling for each SYL while in the
nonattainment/maintenance area. For stationary technologies, estimate the number of hours that the
technology will reduce long duration idling for each parking space. When determining the actual
emission reductions from an existing project, using a mobile or stationary technology, use the actual
hours the technology was used.
When estimating the number of reduced hours of idling per day you need to consider the
particular pollutant or precursor and how the idling may vary by season or annually (for example,
average summer weekday or average annual weekday) as described in question 7(D)(3) and 7(E)(2).
Thus, to determine the emissions (g/day) from an individual SYL prior to the use of an idle
reduction technology use the following equation:
Emission Per Day = EFBASE * AL^
Where,
EFBASE = SYL baseline emission factor (NOX or PM in g/hr) (See Appendix B)
ALIRT = Estimated hours of use of idle reduction technology (hr/day)
Step 4(a): Determine emission factor for the mobile idle reduction technology.
In the case of stationary locomotive parking electrification project, for the purpose of this
guidance, it may be presumed that all emissions from power plants (including any increase in demand
resulting from a stationary project) will be accounted for in projections of, or limits on, overall power
plant emissions in the SIP's emission inventory. Therefore, related stationary project emissions at power
plants need not be considered when quantifying the emission reductions associated with a stationary
project.9
If a stationary project does not rely on energy from the electrical grid, but instead is using an
alternative source of electricity (for example, a portable generator), then you will need to provide data
9 To the extent that there may be a concern that the power plant emission increases
resulting from a stationary project are not otherwise reflected in the state's overall consideration
of power plant emissions, then the power plant increases in the nonattainment/maintenance area
from a stationary project, where quantifiable, should be considered when quantifying the amount
of emission reductions.
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that demonstrates the emissions associated with that energy source. The data should comply with EPA
regulations regarding the measurement of emissions from that energy source. If no regulations exist,
provide all emissions data available to you for the energy source. We will review this information and
determine its appropriateness for use on a case-by-case basis.
You will now determine the emission factor associated with the mobile idle reduction
technology used. If the mobile idle reduction technology is an EPA certified diesel fueled non-road
engine, as is the case with many APUs, use the emission factor provided for that engine family by the
manufacturer as part of its certification application under 40 CFR Part 89. This factor is in g/kW-hr or
g/bhp-hr and is publicly available (in Step 4(b) you will convert this factor to g/hr so the terms are
consistent with Step 3). You will need to know the engine manufacturer's name, year of manufacture,
and 12-character EPA engine family number. This information is available on the engine label. You
can obtain the emission data by contacting EPA's Office of Transportation and Air Quality
(Certification and Compliance Division) or consulting the certification data at
http://www.epa.gov/otaq/certdata.htm (search under "Non-Road Compression Ignition Engine" and
"Engine Family General Information" using the engine's manufacture date).
Step 4(b): Step 4(b): When using a mobile idle reduction technology, multiply emission factor from
4 (a) by the average daily horsepower load of the mobile idle reduction technology. Skip this step for a
stationary idle reduction technology.
Since the mobile idle reduction technology emission factor is usually in g/bhp-hr, you
should convert this emission factor to g/hr by multiplying by the average daily horsepower load.
This step involves determining the average daily horsepower load which refers to the power use
of the technology. This power use will differ during different times of the year depending on
power needs (AC or heat). For mobile auxiliary power units, the average daily horsepower load
ranges from 5-10 hp. You should contact the idle reduction technology manufacturer (not the
engine manufacturer) to determine the average daily horsepower load within this range for the
time period considered. If the technology emission factor is in g/ kW-hr, you should convert this to
g/hp-hr by multiplying the kW by 0.746. Multiplying the emission factor by the daily
horsepower load gives a gram per hour emission factor for the engine.
Step 4(c): When using a mobile idle reduction technology, multiply the g/hr factor by the number of
operating hours (per day) it is estimated to be used. Skip this step for a stationary idle reduction
technology.
Thus, to determine the emissions (g/hr) for the idle reduction technology you should follow the
following equation:
Idle Reduction Technology Emission = EF^ * HP * ALIRT
Where,
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EFjRj = Idle reduction technology emission factor (NO or PM in g/bhp-hr)
HP = Average daily HP load
j = Estimated hours of use of idle reduction technology (hr/day)
Step 5: Determine the net emission reduction for the mobile technology. Skip this step for a
stationary idle reduction technology.
To determine the net emission reduction, subtract the emissions associated with the idle
reduction technology as determined in Step 4 from the SYL emissions as determined in Step 3. The
equation is as follows:
NER = (EFBASE * ALIRT) - (EFKT * HP * ALIRT)
Where,
NER = Net emission reductions in grams per day
EFBASE = Baseline emission factor (NOX or PM in g/hr)
ALIRT = Estimated hours of use of the idle reduction technology (hr/day)
EF^ |= Idle reduction technology emission factor (NO or PM in g/bhp-hr)
HP = Average daily HP load
AL^ = Estimated hours of use of the idle reduction technology (hr/day)
Net average daily emission reductions can be converted from grams to pounds by dividing by
454. If necessary for estimating annual reductions of NOX or PM, average daily emissions reduced can
be converted to annual emissions reduced by multiplying by the number of days in the year it is
assumed the technology will be used.
Step 6: Sum all emission reductions for the project.
For a stationary project, the sum would include the emission reductions from the use of all the
electrified parking spaces. For mobile technologies, the sum would include the emission reductions
from all the participating SYLs.
Step 7: Make sure net average daily emissions reduced from the idling reduction project do not
exceed the historic idling activity of the SYLs involved in the project as determined in Step 1.
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The daily emission reductions per day from the idle reduction project should be a percentage of
the historic idling hours per day. For SIPs only, in the circumstance where the actual hours idled
exceeds the historic idling hours, you will need to provide an explanation as to the reason for the
difference to credit the additional reduction. We will evaluate the reason for the difference and make a
decision as to the quantity of the emission reduction available on a case-by-case basis. Where verified,
the additional emission reduction may be credited.
Step 8: Make sure the net average daily emission reductions from all idling reduction projects do not
exceed the total long duration idle emissions accounted for in the SIP's regional inventory analysis.
The net average daily emission reductions for all existing and new long duration SYL idling
reduction projects in a nonattainment or maintenance area should be summed to determine the total
reductions from all programs for a given year. The total reductions claimed for all programs is not to
exceed the emission estimate for SYLs for any criteria air pollutant or precursor used in the applicable
SIP inventory for the calendar year in question. See Section C for detailed discussion.
11. How do you quantify emission reductions for other criteria air pollutants or precursors?
To quantify emission reductions for other criteria air pollutants or precursors (such as
hydrocarbon emissions), you can follow the same steps outlined in this section, substituting an EPA
approved idling emission factor for that pollutant or precursor. Once we have identified an idling
emissions factor for use, similar to those listed or referenced in this document, it may subsequently
be used in the same manner without additional review by us. If no idling emission factor has been
identified, you can submit data supporting an idling emission factor and we will review this data on a
case-by-case basis and make a decision as to the appropriateness of its use.
Section E: Verification and Penalties
12. What are the monitoring, record keeping, and reporting requirements for including long
duration SYL idling emission reductions in SIPs?
(A) For each SYL or stationary location generating emission reductions, you are to record
and submit the following information for each time period for which an emission reduction is
generated (or other information capable of demonstrating the emission reductions to our
satisfaction):
(1) For mobile and stationary technologies, the number of hours the idle reduction
technology operated while the main SYL engine did not idle, recorded by a non-
resettable meter, data logger, or computerized data acquisition system capable of
recording total hours operated on each SYL.
(2) For mobile technologies only, demonstrate that the SYLs are located in a
nonattainment or maintenance area for the pollutant or precursor for which emission
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reductions determined in (1) above occurred in the nonattainment or maintenance
area.
(B) All information required to be recorded and submitted in accordance with this guidance
for existing SIP requirements is to be maintained by you for a period of no less than five
years.
13. What kind of validation and reconciliation should occur for emission reductions in SIPs
approved under the Voluntary Measures Policy?
The SIP submission for a voluntary measure should contain a description of the evaluation
procedures and time frame(s) in which the evaluation of SIP reductions will take place. Once the
voluntary control measure is in place emission reductions should be evaluated by you as required to
validate the actual emission reductions. You should submit the results of your evaluation to EPA in
accordance with the schedule contained in the SIP. If the review indicates that the actual emission
reductions are not consistent with the estimated emission reductions, then the amount of credit
should be adjusted appropriately and applicable remedial measures should be taken under the
Voluntary Measures Policy. See the EPA's Voluntary Measures Policy for further information
regarding validation and reconciliation requirements for such measures.
14. What types of penalties can be assessed for not complying with CAA requirements?
Use of this guidance does not relieve the responsible party of any obligation to comply with
all otherwise applicable CAA requirements, including those pertaining to the crediting of emission
reductions for your SIP, such as emission reductions for your attainment or maintenance strategy.
Violations of CAA requirements are subject to administrative, civil, and/or criminal enforcement
under Section 113 of the CAA, as well as to citizen suits under Section 304 of the CAA. The full
range of penalty and injunctive relief options would be available to the federal or state government
(or citizens) bringing the enforcement action.
Section F: The SIP Process for Using Long Duration SYL Idling Emission Reductions
15. What must a state submit to EPA to meet the requirements for incorporating a source specific
control measure in a SIP?
The state must submit to EPA a written document which:
(A) Identifies and describes the idle reduction project and its implementation schedule to
reduce long duration SYL idling emissions within a specific time period;
(B) Contains a quantification methodology to estimate the emission reductions from the
idle reduction project. You can follow the quantification methodology provided in
Section D of this document or you can submit your own. If you submit your own
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quantification methodology for quantifying the emission reductions, you must provide all
relevant technical support documentation, including the information and quantification
uncertainties used to calculate emission reductions. You must rely on the most recent
information available at the time the SIP is developed;
(C) Contains federally enforceable requirements to implement, track, and monitor the
measure as applicable;
(D) Under the Voluntary Measures Policy only, enforceably commits to monitor, evaluate,
and report the resulting emission reductions of the measure as applicable;
(E) Enforceably commits to remedy any SIP emission shortfall in a timely manner as
described above if the measure does not achieve estimated emission reductions; and
(F) Meets all other requirements for SIP revisions under sections 110 and 172 of the CAA.
Section H: Contact Information
16. Who should you contact for additional information?
State agencies, the regulated community and members of the public with questions
concerning a case-specific application of this guidance should contact the EPA Regional Office with
responsibility for air quality planning in the area where the switch yard is located. A contact list of
your EPA Regional Office is available at the following web address:
http://www.epa.gov/epahome/locate2. htm
For general questions regarding the quantification of SYL idling emissions reductions, please
e-mail your questions to the EPA SmartWay Transport Partnership at:
smartway_transport@epa.gov
or contact Anthony Erb of EPA's Office of Transportation & Air Quality at (202) 343-9259 or
David Solomon of EPA's Office of Air Quality Planning & Standards at (919) 541-5375.
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Appendix A
DEFINITIONS
For the purposes of this guidance only, the following definitions apply:
(A) ACTUAL IDLING EMISSION REDUCTIONS means the emission reductions achieved
from an idle reduction project.
(B) ESTIMATED IDLING EMISSION REDUCTIONS means the projected emission
reductions from an idle reduction project which is based on a percentage of the historic idling
activity.
(C) GLOBAL POSITIONING SYSTEM means a satellite-based radio navigation receiver
capable of providing the time, the date, and position of the switch yard locomotive.
(D) HISTORIC IDLING ACTIVITY means the demonstrated past long duration idling of a
switch yard locomotive, or past long duration idling from switch yard locomotives at a
particular location, in the nonattainment or maintenance area.
(E) IDLE REDUCTION TECHNOLOGY means a commercially available technology or
device that provides cab comfort or engine needs, or otherwise reduces the need for long-
duration switch yard locomotive idling.
(F) LOCOMOTIVE SWITCHER means a locomotive designed or used solely for
the primary purpose of propelling railroad cars a short distance.
(G) LONG DURATION IDLING means the operation of a switch yard locomotive's
propulsion engine for a period greater than 15 consecutive minutes at a time at which the
main drive engine is not engaged in gear.
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Appendix B
NOX and PM Emission Factors for Long Duration Switch Yard Locomotives
Two Stroke Locomotive Engines
NOxg/hr
800
PM g/hr
26
Four Stroke Locomotive Engines
NOxg/hr
620
PM g/hr
32
Emission factors listed above are derived from various sources.10 In some cases, multiple
trials or replicate measurements were reported for the idle mode for individual locomotives. Before
deriving the final means, all replicates for individual locomotives were averaged to give a single
mean for each locomotive, to give each locomotive equal weight in the resulting emission rate.
Throughout, measurements obtained for locomotives on "special settings" were not included.
Special settings included retarded timing and continuous throttle.
Measurements of particulate matter from Hare & Springer (1972) were not included in the
calculation of the PM emission rate. The apparatus used for particulate measurement in that study
was experimental, and the resulting measurements are not considered reliable.
10 Fritz, S.G., J.C. Hedrick, V.O. Markworth, M.B. Treuhaft, and J.F. Wakenell. Diesel
Fuel Specification and Locomotive Improvement Program: Tenth Research Phase Final Report.
AAR Report No. R-771. Engine and Vehicle Research Division, Southwest Research Institute.
San Antonio, TX. December, 1989; Fritz, S.G., V.O. Markworth and R.L. Mason. Locomotive
Exhaust Emission Field Tests: Phase 1, EMD SD40-2 and GE C40-8 Locomotives. Final Report,
AAR Report No. R-877, Association of American Railroads, Research and Test Department,
Washington, DC; SwRI Project No. 03-4171, Southwest Research Institute, San Antonio, TX.
October, 1994; Fritz, S.G. Emission Measurements for Locomotives: Final Report. SwRI 5374-
024. Southwest Research Institute, San Antonio, TX. August, 1995; Hare, C.T., and KJ.
Springer. Exhaust Emissions from Uncontrolled Vehicles and Related Equipment Using Internal
Combustion Engines: Final Report, Part I, Locomotive Diesel Engines and Marine
Counterparts. Contract No. EHS 70-108. Southwest Research Institute, Antonio, TX. October
1972.
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Appendix C
Quantification Summary
The purpose of this quantification summary is to provide a concise formula to calculate the
net emission reduction for long duration switch yard locomotive (SYL) idling. This summary is
intended to be consistent with the more detailed step-by-step process in Section D.
NER = (EFBASE * (ALIRT£CF /LBS)) - (EFIRT * HP * (ALIRT£CF /LBS))
Where,
NER = Net emission reduction
EFBASE = SYL baseline emission factor (NOX or PM in g/hr)
ALIRT = Estimated hours of use of the idle reduction technology (hr/day)
CFG/LBS = Conversion factor for grams to pounds which is 454
EFiRT = Idle reduction technology emission factor (NOX or PM in g/bhp-hr)
HP = Average daily horsepower load (ranges from 5-10 hp depending on the
technology; consult the technology manufacturer)
ALIRT = Estimated hours of use of the idle reduction technology (hr/day)
There are three essential parts to this formula. First, you determine the emissions from the
SYL by selecting the emission factor for the pollutant or precursor for reduction, multiply this factor
by the number of hours you estimate the technology will reduce long duration idling emissions. This
number is divided by the conversion factor to derive a grams per hour number. The second part is to
determine the emissions associated with the idle reduction technology (this step typically does not
apply to stationary idle reduction technologies). This requires determining the emissions associated
with the technology, multiplying this by the horsepower to derive a grams per hour number,
multiplying this number by the number of hours the technology will operate, and then dividing this
number by the conversion factor. The final part is simply subtracting the emissions from the second
part (idle reduction technology emissions) by the first part (switch yard locomotive's baseline
emissions) to arrive at the net emission reduction.
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Appendix D
Example Quantification
This example is for the purpose of illustrating the quantification steps only, and it does not
address the additional requirements necessary which must be met to credit the reductions generated.
In this example we will quantify the NOX long duration idling emission reductions from a two stroke
locomotive engine using a mobile idle reduction technology. In the nonattainment area, 10 SYLs
will use this technology 8 hours per day.
For the idle reduction technology, we will use an auxiliary power unit (APU). The APU
allows an idling SYL to be shut down by heating and circulating the coolant and oil, charging the
batteries and powering the cab heaters It is important to note that not all idling can be eliminated. In
certain circumstances, such as when the wait from active use to active use is not long, the operator
may decide to keep the SYL engine idling.
Per the steps outlined in this guidance document, the NOX emission reduction associated with
the use of the APU is calculated as follows:
Step 1: Determine the historic idling activity of the SYL involved in the project.
You should follow the discussion provided in question 7(D)(3) in this guidance to derive the
historic number of hours the SYL idled for an average summer weekday in the nonattainment or
maintenance area. In this example, we determined a SYL's long duration idling occurred an average
of 10 hours per day.
Step 2: Select the emission factor for the criteria air pollutant or precursor.
We are evaluating NOX emission reductions for a two stroke SYL so the emission factor is
800 grams per hour.
Step 3: Multiply the emission factor in Step 2 by the number of hours per day the idle reduction
technology is estimated to be used.
We estimated that the APU will reduce 8 of the 10 hours of long duration idling. Therefore,
the average daily emissions reduced is 800 grams/hr * 8 hours/day = 6,400 grams/day.
Step 4(a): Determine emission factor for the mobile idle reduction technology.
In this example, the APU uses a 2003 Lister Fetter engine (EPA engine family
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2L5XL1.86LWS )n which was certified under 40 CFR Part 89. By examining the certification data
for this engine family, we find the certified NOX emission level is 6.69 g/kW-hr.12
Step 4(b): When using a mobile idle reduction technology, multiply emission factor from 4 (a) by
the average daily horsepower load of the mobile idle reduction technology.
Since the emission factor is in kW, we begin by converting this to hp:
(6.69 g/kW-hr * .746 = 4.99 g/bhp-hr). According to the APU manufacturer, the average
daily hp load for this engine during typical summer weekdays is 8 hp. So the grams per hour emission
rate of the auxiliary power unit is 4.99g/bhp-hr * 8 hp = 40 g/hr.
Step 4(c): When using a mobile idle reduction technology, multiply the g/hr factor by the
number of operating hours (per day) it is estimated to be used.
As a result, the total average daily emissions of the APUs are 40 grams/hr * 8 hours/day =
320 grams/day.
Step 5: Determine the net emission reduction.
The estimated net emissions reductions from this program are 6,400 grams/day - 320 grams/day =
6080 grams/day or 13.4 Ibs/day.
Step 6: Sum all emission reductions for the project.
In this example, we estimate that all SYLs will operate in a similar manner. In practice, each SYL
could have its own idling emission reductions. We add the total amount of idling for all 10
participating SYLs in the project, which is 10 * 6080 = 60,800 grams/day or 134 Ibs/day.
Step 7: Make sure the net average daily emission reductions from the idling reduction project do
not exceed the historic idling activity of the SYLs involved in the project as determined in Step 1.
This step involves taking your estimate of idling activity (or the actual emission reduced) and
reconciling this estimate (or actual number) with your historic idling hours from Step 1 (following
11 For purposes of this example we have selected a specific engine model to better
illustrate the APU's emissions. The use of this engine model does not confer any endorsement of
this company or its products.
12 In some circumstances, the NOX emission factor is reported as a combined NOX + HC
emission factor. You will need to contact the engine manufacturer to determine the NOX only
value.
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question 7(D)(3)). If the estimate (or actual number) exceeds the historic idling hours, you will
need to explain this increase. In this example, the estimate does not exceed the historic idling
activity.
Step 8: Make sure the net average daily emission reductions from all idling reduction projects do
not exceed the total long duration idle emissions accounted for in the regional inventory used in the
SIP.
In this example, you will need to assess the total SYL NOX emissions projected in the
inventory for the year or years the emission reductions are to be relied upon, and ensure that the
estimated emission reductions do not exceed this amount.
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