Draft Regulatory Impact Analysis:
   Control of Emissions of Air Pollution
   from Locomotive Engines and Marine
   Compression-Ignition Engines Less than
   30 Liters per Cylinder
United States
Environmental Protection
Agency

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      Draft Regulatory Impact Analysis:
 Control of Emissions of Air Pollution from
            Locomotive Engines and
    Marine Compression-Ignition Engines
       Less than 30 Liters per Cylinder
                Assessment and Standards Division
                Office of Transportation and Air Quality
                U.S. Environmental Protection Agency
United States
Environmental Protection
Agency
EPA420-D-07-001
  March 2007

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Table of Contents




Executive Summary  ES-1




Chapter 1: Industry Characterization




Chapter 2: Air Quality, Health and Welfare




Chapter 3: Inventory




Chapter 4: Technological Feasibility




Chapter 5: Cost/Cost per Ton




Chapter 6: Benefits




Chapter 7: Economic Impact Analysis




Chapter 8: Alternatives

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        List of Acronyms

um            Micrometers
(bext)          Light-Extinction Coefficient
jig             Microgram
(ig/m3          Microgram per Cubic Meter
AAR          Association of American Railroads
ABT           Average Banking and Trading
ACS           American Cancer Society
AEO           Annual Energy Outlook (an EIA publication)
AESS          Automatic Engine Stop/Start System
AIM           2-28
AIRS          Aerometric Information Retrieval System
APHEA        Air Pollution and Health: A European Approach
AQ            Air Quality
AQCD         Air Quality Criteria Document
AQMTSD      Air Quality Modeling Technical Support Document
ARE           (California) Air Resources Board
ASLRRA       American Short Line and Regional Railroad Association
ASPEN        Assessment System for Population Exposure Nationwide
AT AC         Average Total Cost
avg            Average
BenMAP       Benefits Mapping and Analysis Program
bhp            Brake Horsepower
BNSF          Burlington Northern Santa Fe
BSFC          Brake Specific Fuel Consumption
BTS           Bureau of Transportation
C              Celsius
Cl             Category 1
C2             Category 2
C3             Category 3
CA            California
CAA          Clean Air Act
CAIR          Clean Air Interstate Rule (CAIR) (70 FR 25162, May 12, 2005)
CAMR         Clean Air Mercury Rule
CAND         Clean Air Nonroad Diesel rule (69 FR 38957, June 29, 2004)
CARD         California Air Resources Board
CASAC        Clean Air Scientific Advisory Committee
CAVR         Clean Air Visibility Rule
CB            Chronic Bronchitis
CCV           Closed Crankcase Ventilation
CDC           Centers for Disease Control
CDPF          Catalyzed Diesel Paniculate Filter
CEA           Cost Effective Analysis
CES           Constant Elasticity of Substitution
CFR           Code of Federal Regulations
CI             Compression Ignition (i.e., diesel engines)
CI             Confidence Interval
CIMT          Carotid Intima-Media Thickness
CITT          Chemical Industry Institute of Toxicology
CMAQ         Community Multiscale Air Quality
CMB          Chemical Mass Balance
CN            Canadian National Railroad
CO            Carbon Monoxide
CO2           Carbon Dioxide
COI           Cost of Illness
                                                    in

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COPD          Chronic Obstructive Pulmonary Disease
CPI-U          Consumer Price Index - All Urban Consumers
C-R           Concentration Response
CSS           Coastal Sage Scrub
CUA           Cost Utility Analysis
cyl             Cylinder
D              Demand
DE             Diesel Exhaust
DEM           Domestic Engine Manufacturer
diff            Difference
disp           Displacement
DOC           Diesel Oxidation Catalyst
DOE           Department of Energy
DOT           Department of Transportation
DPF           Diesel Paniculate Filter
DPM           Diesel Paniculate Matter
DR            Discount Rate
DRIA          Draft Regulatory Impact Analysis
DV            Design Values
EAC           Early Action Component
EC             Elemental Carbon
EF             Emission Factor
EGR           Exhaust Gas Recirculation
EIA           Energy Information Administration (part of the U.S. Department of Energy)
EIA           Economic Impact Analysis
EIM           Economic Impact Model
EMD           Electromotive Diesel
EMS-HAP      Emissions Modeling System for Hazardous Air Pollution
EO             Executive Order
EPA           Environmental Protection Agency
EPAct          Energy Policy Act of 2005
ESPN          EPA speciation network
F              Fahrenheit
FEM           Foreign Engine Manufacturer
FEV           Functional Expiratory Volume
FR             Federal Register
FRA           Federal Railroad Administration
FRM           Final Rulemaking
FRP           Fiberglass-Reinforced Plastic
g              Gram
g/bhp-hr        Grams per Brake Horsepower Hour
g/kW-hr        Grams per Kilowatt Hour
gal             Gallon
GAO           Government Accountability Office
GDP           Gross Domestic Product
GEOS          Goddard Earth Observing System
GETS          General Electric Transportation Systems
GIS            Geographic Information System
H2             Hydrogen Gas
HAD           Diesel Health Assessment Document
HAP           Hazardous Air Pollutant
HC            Hydrocarbon
HD            Heavy-Duty
HEI           Health Effects Institute
HEP           Head End Power
HES           Health Effects Subcommittee
                                                    IV

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hp             Horsepower
hp-hrs          Horsepower Hours
hrs             Hours
IARC          International Agency for Research on Cancer
ICD           International Classification of Diseases
IMO           International Maritime Organization
IMPROVE      Interagency Monitoring of Protected Visual Environments
IRIS           Integrated Risk Information System
ISCST3        Industrial Source Complex Short Term Model
ISORROPIA    Inorganic Aerosol Thermodynamic Model
JAMA         Journal of the American Medical Association
K              Kelvin
k              Thousand
km             Kilometer
kW            Kilowatt
kWH           Kilowatt Hour
L              Liter
Ib              Pound
LM            Locomotive and Marine
LRS           Lower Respiratory Symptoms
LSD           Low Sulfur Diesel fuel
m3             Cubic Meters
MARAD       U.S. Maritime Administration
MARPOL      The International Convention for the Prevention of Pollution of Ships
MC            Marginal Cost
MCIP          Meteorology-Chemistry Interface Processor
MECA         Manufacturers of Emission Controls Association
mg             Milligram
MI             Myocardial Infarction
MILY          Morbidity Inclusive Life Years
min            Minute
MM           Million
MM-1          Inverse Megameter
MOBILE6      Vehicle Emission Modeling Software
MRAD         Minor Restricted Activity Days
MSAT         Mobile Source Air Toxic
MS AT 1        2001 Mobile Source Air Toxics Rule
MSB           Major Shipbuilding Base
MVUS         Merchant Vessels of the U. S.
MW           Megawatt
MW-hrs        Megawatt Hours
N              Nitrogen
N2             Nitrogen Molecule
NA            Not Applicable
NAAQS        National Ambient Air Quality Standards
NAICS         North American Industry Classification System
NAS           National Academy of Sciences
NASA         National Aeronautics and Space Administration
NATA         National Air Toxic Assessment
NBER         National Bureau of Economic Research
NCDC         National Clean Diesel Campaign
NCI           National Cancer Institute
NCLAN        National Crop Loss Assessment Network
NEI           National Emissions Inventory
NESCAUM     Northeast States for Coordinated Air Use Management
NESHAP       National Emissions Standards for Hazardous Air Pollutants
                                                    v

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NH3           Ammonia
NIOSH         National Institute of Occupational Safety and Health
NLEV         National Low Emission Vehicle
NMHC         Non-Methane Hydrocarbons
NMIM         National Mobile Inventory Model (EPA software tool)
NMIM2005     National Mobile Inventory Model Released in 2005
NMMA        National Marine Manufacturers Association
NMMAPS      National Morbidity, Mortality, and Air Pollution Study
NO            Nitrogen Oxide
NO2           Nitrogen Dioxide
NOAA         National Oceanic and Atmospheric Administration
NONROAD     EPA's Non-road Engine Emission Model
NONROAD2005 EPA's Non-road Engine Emission Model Released in 2005
NOx           Oxides of Nitrogen
NPRM         Notice of Proposed Rulemaking
NPV           Net Present Value
NRC           National Research Council
NREC         National Railway Equipment Co
NRLM         Nonroad, Locomotive and Marine diesel fuel
NRT4          Nonroad Tier 4 Rule
NSTC          National Science and Technology Council
NTE           Not To Exceed
O&M          Operating and maintenance
O3             Ozone
OAQPS        Office of Air Quality Planning and Standards
OC            Organic Carbon
°CA           Degree Crank Angle
OEHHA        Office of Environmental Health Hazard Assessment
OEM          Original Equipment Manufacturer
OMB          Office of Management and Budget
OTAQ         Office of Transportation and Air Quality
P              Price
PAH           Polycyclic Aromatic Hydrocarbons
PCB           Polychlorinated Biphenyls
PGM          Platinum Metals Group
PM            Paniculate Matter
PM AQCD      EPA Paniculate Matter Air Quality Criteria Document
PM/NMHC     Paniculate Matter to Non-Methane Hydrocarbon Ratio
PM10          Coarse Paniculate Matter (diameter of 10 um or less)
PM2.5         Fine Paniculate Matter (diameter of 2.5 um or less)
PMM          Post-Manufacturer Marinizer
PMNAAQS     Paniculate Matter National Ambient Air Quality Standards
POM          Polycyclic Organic Matter
ppb            Parts per Billion
PPI            Producer Price Index
ppm           Parts per Million
psi             Pounds per Square Inch
PSR           Power Systems Research
Q              Quantity
QALY         Quality Adjusted Life Years
R&D          Research and Development
RfC           Reference Concentration
RFA           Regulatory Flexibility Analysis
RFS           Renewable Fuels Standard
RIA           Regulatory Impact Analysis
rpm           Revolutions per Minute
                                                    VI

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RPO           Regional Planning Organization
RRF           Relative Reduction Factors
RV            Revision
RVP           Reid Vapor Pressure
S              Sulfur
S              Supply
SAB           Science Advisory Board
SAB-HES      Science Advisory Board - Health Effects Subcommittee
SAE           Society of Automotive Engineers
SAPS          Sulfated-Ash, Phosphorus, and Sulfur Content
SBA           Small Business Administration
SBREFA       Small Business Regulatory Enforcement Fairness Act
SCC           Source Classification Code
SCR           Selective Catalyst Reduction
SI             Spark Ignition
SIC            Standard Industrial Classification
SiC            Silicon Carbide
SMAT         Speciated Modeled Attainment Test
SO2            Sulfur Dioxide
SOx           Oxides of Sulfur
SOA           Secondary Organic Carbon Aerosols
SOF           Soluble Organic Fraction
STB           Surface Transportation Board
SVOC         Semi-Volatile Organic Compound
SwRI          Southwest Research Institute
TEN           Total Base Number
TCC           Total Compliance Cost
TCM          Total Carbon Mass
TDC           Top Dead Center
TFM           Transportation Ferroviaria Mexicana
THC           Total Hydrocarbon
TSD           Technical Support Document
TVCC         Total Variable Compliance Cost
ULSD         Ultra Low Sulfur Diesel fuel
UP            Union Pacific Railroad
URS           Upper Respiratory Symptoms
USD A         United States Department of Agriculture
UV            Ultraviolet
UV-b          Ultraviolet-b
VOC           Volatile Organic Compound
VOF           Volatile Organic Fraction
VSL           Value of Statistical Life
WLD          Work Loss Days
WTP           Willingness-to-Pay
$2,005         U.S. Dollars in calendar year 2005
                                                    vn

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                                                    Executive Summary
                        Executive Summary
       The Environmental Protection Agency (EPA) is proposing a comprehensive
three-part program to reduce emissions of particulate matter (PM) and oxides of
nitrogen (NOX) from locomotives and marine diesel engines below 30 liters per
cylinder displacement. Locomotives and marine diesel engines designed to these
proposed standards would achieve PM reductions of 90 percent and NOX reductions
of 80 percent, compared to engines meeting the current Tier 2 standards. The
proposed standards would also yield sizeable reductions in emissions of nonmethane
hydrocarbons (NMHC), carbon monoxide (CO), and hazardous compounds known as
air toxics.

       This proposal is part of EPA's ongoing National Clean Diesel Campaign
(NCDC) to reduce harmful emissions from diesel engines of all types. The
anticipated emission reductions will significantly reduce exposure to harmful
pollutants and also provide assistance to  states and regions facing ozone and
particulate air quality problems that are causing a range of adverse health effects,
especially in terms of respiratory impairment and related illnesses.

       This Regulatory Impact Analysis provides technical, economic, and
environmental analyses of the proposed emission standards. Chapter 1 provides
industry characterization for both the locomotive and marine industry. Chapter 2
presents air quality modeling results and describes the health and welfare effects
associated with particulate matter (PM),  ozone, and air toxics. Chapter 3 provides our
estimates of the current emission inventories and the reductions that can be expected
from the proposed standards.  Chapter 4  contains our technical feasibility justification
for the emission limits, and Chapter 5 contains the estimated costs of complying with
those standards. Chapter 6 presents the estimated societal benefits of the proposed
rulemaking. Chapter 7 contains our estimates of the market impacts of the proposed
standards and the distribution of costs among stakeholders.  Finally, Chapter 8
contains our analysis of several alternative control scenarios we considered during the
development of this proposal.

1. Proposed Emission Standards

       The proposed program addresses emissions from all types of diesel
locomotives, including line-haul, switch, and passenger rail, and all types of marine
diesel engines below 30 liters per cylinder displacement (collectively called "marine
                                    ES-1

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Draft Regulatory Impact Analysis
diesel engines. ").A  These include marine propulsion engines used on vessels from
recreational and small fishing boats to super-yachts, tugs and Great Lakes freighters,
and marine auxiliary engines ranging from small gensets to large generators on
ocean-going vessels. Each of these markets is described in Chapter 1.

       We are proposing a comprehensive three-part emission control program for
locomotives and for marine diesel engines that will dramatically reduce the emissions
from these sources. The standards and our technical feasibility justification are
contained in Chapter 4.

       The  first part consists of near-term engine-out emission standards, referred to
as Tier 3 standards, for newly-built locomotives and marine diesel engines. These
standards reflect the application of engine-out PM and NOX reduction technologies
and begin to phase in starting in 2009. The second part consists  of longer-term
standards, referred to as Tier 4 standards, for newly-built locomotives and marine
diesel engines.  These standards phase in over time, beginning in 2014. For most
engines, these standards are similar in stringency to the final standards included in the
2007 highway diesel and Clean Air Nonroad Diesel programs and are expected to
require the use of high-efficiency aftertreatment systems to ensure compliance. These
standards will be enabled by the availability of ultra-low sulfur diesel fuel (ULSD.
Third, we are proposing to tighten emission standards for existing locomotives when
they are remanufactured.  Also included in our proposal are provisions to eliminate
emissions from unnecessary locomotive idling, and we are requesting comment on
applying standards to certain existing marine diesel engines when they are
manufactured.

Locomotive  Standards

       The  proposed standards for newly-built line-haul, passenger, and switch
locomotives and for existing 1973 and later Tier 0, Tier 1, and Tier 2 locomotives are
set out in Tables 1 and 2. With some exceptions, these standards would apply to all
locomotives that operate extensively within the United States. Exceptions include
historic steam-powered locomotives and locomotives powered solely by an external
source of electricity. The regulations also generally do not apply to existing
locomotives owned by railroads that are classified as small businesses. In addition,
engines used in locomotive-type vehicles with less than 750 kW (1006 hp) total
power (used primarily for railway maintenance), engines used only for hotel power
(for passenger railcar equipment), and engines that are used in self-propelled
passenger-carrying railcars, are excluded from these regulations. The engines used in
 ^
  In this RIA, "marine diesel engine" refers to compression-ignition marine engines below 30 liters per
cylinder displacement unless otherwise indicated. Engines at or above 30 liters per cylinder are being
addressed in separate EPA actions.
                                     ES-2

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                                                       Executive Summary
these smaller locomotive-type vehicles are generally subject to our nonroad engine
requirements (40 CFR Parts 89 and 1039).

 Table ES-1 - Proposed Standards for New and Existing Line-Haul and Passenger Locomotives
                                    (g/bhp-hr)
STANDARDS
APPLY TO:
Remanufactured
Tier 0 & 1
Remanufactured
Tier 2
New Tier 3
New Tier 4
DATE
2008 as available,
20 10 required
2008 as available,
20 13 required
2012
PMandHC2015
N0x2017
PM
0.22
0.10
0.10
0.03
NOX
7.4 a
5.5
5.5
1.3
HC
0.55 a
0.30
0.30
0.14
(a) For Tier 0 locomotives originally manufactured without a separate loop intake air cooling system,
these standards are 8.0 and 1.00 for NOX andHC, respectively.
    Table ES-2 - Proposed Standards for New and Existing Switch Locomotives (g/bhp-hr)
SWITCH
LOCOMOTIVE
STANDARDS
APPLY TO:
Remanufactured
TierO
Remanufactured
Tier 1
Remanufactured
Tier 2
New Tier 3
New Tier 4
DATE
2008 as available,
20 10 required
2008 as available,
20 10 required
2008 as available,
2013 required
2011
2015
PM
0.26
0.26
0.13
0.10
0.03
NOX
11.8
11.0
8.1
5.0
1.3
HC
2.10
1.20
0.60
0.60
0.14
Marine Standards

       The proposed standards for newly-built marine diesel engines are set out in
Tables 3,4,5, and 6. The Tier 3 standards would apply to all marine diesel engines
with per cylinder displacement up to 30 liters. The Tier 4 standards would apply only
to commercial marine diesel engines above 600 kW and recreational marine diesel
engines above 2,000 kW.
                                      ES-3

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Draft Regulatory Impact Analysis
       For the purposes of this emission control program, Category 1 marine diesel
engines are those with per cylinder displacement up to 7 liters.  Category 2 marine
diesel engines are those with per cylinder displacement from 7 to 30 liters. High
power density engines are those with a power density above 35 kW/liter).

               Table ES-3 - Proposed Tier 3 Standards for Marine Diesel Cl
RATED KW
<19kW
19-<75kW
75 - 3700 kW
L/CYLIND
ER
<0.9
<0.9a
<0.9
0.9- <1. 2
1.2-<2.5
2.5-<3.5
3.5-<7.0
PM
G/BHP-HR
0.30
0.22
0.22 b
0.10
0.09
0.08 c
0.08 c
0.08 c
NOX+HC
G/BHP-HR
5.6
5.6
3.5 b
4.0
4.0
4.2
4.2
4.3
MODEL
YEAR
2009
2009
2014
2012
2013
2014
2013
2012
(a) <75 kW engines at or above 0.9 L/cylinder are subject to the corresponding 75-3700 kW standards.
(b) Option: 0.15 PM/ 4.3 NOX in 2014.
(c) This standard level drops to 0.07 in 2018 for <600 kW engines.
  Table ES-4 - Proposed Tier 3 Standards for Marine Diesel Cl Recreational and Commercial
                                  High Power Density
RATED KW
<19kW
19-<75kW
75 - 3700 kW
L/CYLIND
ER
<0.9
<0.9a
<0.9
0.9- <1. 2
1.2-<2.5
2.5-<3.5
3.5-<7.0
PM
G/BHP-HR
0.30
0.22
0.22 b
0.11
0.10
0.09
0.09
0.09
NOX+HC
G/BHP-HR
5.6
5.6
3.5 b
4.3
4.3
4.3
4.3
4.0
MODEL
YEAR
2009
2009
2014
2012
2013
2014
2013
2012
(a) <75 kW engines at or above 0.9 L/cylinder are subject to the corresponding 75-3700 kW standards.
(b) Option: 0.15 PM/4.3 NOX+HC in 2014.
                                        ES-4

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                                                        Executive Summary
               Table ES-5 - Proposed Tier 3 Standards for Marine Diesel C2
RATED KW
=<3700 kW
L/CYLIN
DER
7-<15
15-<20
20-<25
25-<30
PM
G/BHP-HR
0.10
0.20 a
0.20
0.20
NOX+HC
G/BHP-HR
4.6
6.5 a
7.3
8.2
MODEL
YEAR
2013
2014
2014
2014
(a) For engines at or below 3300 kW in this group, the PM / NOX+HC Tier 3 standards are 0.25 / 5.2.
            Table ES-6 - Proposed Tier 4 Standards for Marine Diesel Cl and C2
RATED KW
>3700 kW
1400 - 3700 kW
600 -< 1400 kW
PM
G/BHP-HR
0.09 a
0.04
0.03
0.03
NOX
G/BHP-HR
1.3
1.3
1.3
1.3
HC
G/BHP-HR
0.14
0.14
0.14
0.14
MODEL
YEAR
2014
2016 b
2016 c
2017 b
(a) This standard is 0.19 for engines with 15-30 liter/cylinder displacement.
(b) Optional compliance start dates are proposed within these model years; see discussion below.
(c) Option for engines with 7-15 liter/cylinder displacement: Tier 4 PM and HC in 2015 and Tier 4 NOX in 2017.
2. Projected Inventory and Cost Impacts

       Our analysis of the projected impacts of the proposed standards can be found
in Chapter 2 (air quality impacts), Chapter 3 (inventory impacts) and Chapter 6
(benefits).

Inventory Reductions

       A discussion of the estimated current and projected inventories for several key
air pollutants are contained in Chapter 3. Nationally, in 2007 these engines account
for about 20 percent of mobile source NOX emissions and 25 percent of mobile source
diesel PMz.s emissions. Absent new emissions standards, we expect overall emissions
from these engines to remain relatively flat over the next 10 to 15 years due to
existing regulations such as lower fuel sulfur requirements and the phase-in of
locomotive and marine diesel Tier 1 and Tier 2 engine standards but starting in about
2025 emissions from these engines would begin to grow.  Without new controls, by
                                       ES-5

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Draft Regulatory Impact Analysis
2030, these engines would become a large portion of the total mobile source
emissions inventory constituting 35 percent of mobile source NOX emissions and 65
percent of diesel PM emissions.

       We estimate that the proposed standards would reduce annual NOX emissions
by about 765,000 tons andPM2.5 and  28,000 tons in 2030.  Table 7 shows the
emissions reductions associated with  today's proposal for selected years, and the
cumulative reductions through 2040 discounted at 3 and 7 percent. These reductions
in PM and NOX levels would produce nationwide air quality improvements.

  Table ES-7 - Estimated Emissions Reductions Associated with the Proposed Locomotive and
                            Marine Standards (Short tons)
YEAR
2015
2020
2030
2040
NPV at 3%
NPV at 7%
PM2.5
7,000
15,000
28,000
38,000
315,000
136,000
PMioA
7,000
15,000
29,000
40,000
325,000
140,000
NOX
84,000
293,000
765,000
1,123,000
7,869,000
3,188,000
NMHC
14,000
25,000
39,000
50,000
480,000
216,000
a Note that, PM2.5 is estimated to be 97 percent of the more inclusive PMio emission inventory. In
Section II we generate and present PM2.5 inventories since recent research has determined that these
are of greater health concern. Traditionally, we have used PMio in our cost effectiveness
calculations. Since cost effectiveness is a means of comparing control measures to one another, we
use PMio in our cost effectiveness calculations for comparisons to past control measures.
Engineering Costs

       The engineering cost analysis for the proposed standards can be found in
Chapter 5. The total engineering costs associated with today's proposal are the
summation of the engine and equipment compliance costs, both fixed and variable,
the operating costs, and the costs associated with the locomotive remanufacturing
program.  These costs are summarized in Table 8.

              Table ES-8 - Total Engineering Costs of the Proposal (SMillions)
YEAR
2011
2012
2015
2020
2030
2040
NPV at 3%
NPV at 7%
ENGINE
COSTS
$99
$55
$100
$87
$105
$104
$1,678
$883
EQUIPMENT
COSTS
$0
$0
$25
$10
$8
$8
$141
$71
OPERATING
COSTS
$11
$13
$25
$187
$407
$611
$4,039
$1,596
COSTS OF
REMANUFACTURING
PROGRAM
$97
$75
$31
$15
$85
$153
$1,374
$682
TOTAL
COSTS
$207
$142
$181
$250
$605
$876
$7,233
$3,231
                                      ES-6

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                                                     Executive Summary
       These engineering costs are allocated to NOX and PM reductions in Table 9.
About half of the costs of complying with the program are operating costs, with the
bulk of those being urea-related costs associated with SCR technology.  Since SCR is
a technique for reduce NOX emissions, this means that most of the operating costs
and, therefore, the majority of the total engineering costs of the program are
associated with NOX control.

          Table ES-9 - Total Engineering Costs, Allocated by Pollutant (SMillions)
YEAR
2011
2012
2015
2020
2030
2040
NPV at 3%
NPV at 7%
PM COSTS
$93
$62
$93
$836
$159
$218
$2,222
$1,068
NOX COSTS
$113
$80
$88
$164
$446
$658
$5,011
$2,163
Cost per Ton of Reduced Emissions

       Using the inventory and engineering cost information, we can estimate the
cost per ton of pollutant reduced as a result of the proposed standards. Table  10
contains the  estimated cost per ton of pollutant reduced based on the net present value
of the engineering costs and inventory reductions from 2006 through 2040. This
estimate captures all of the engineering costs and emissions reductions including
those associated with the locomotive remanufacturing program.  Table 10 also
presents the  estimated cost per ton of pollutant reduced for 2030 using the annual
costs and emissions reductions in that year alone. That estimates includes
engineering  costs and emission reductions that will occur from the new engine
standards and locomotive remanufacturing program in that year.

                Table ES-10 - Proposed Program Cost per Ton Estimates
POLLUTANT
NOX+NMHC
PM
2006 THRU 2040
DISCOUNTED LIFETIME
COST PER TON AT 3%
$600
$6,840
2006 THRU 2040
DISCOUNTED LIFETIME
COST PER TON AT 7%
$630
$7,640
LONG-TERM COST
PER TON IN 2030
$550
$5,560
                                     ES-7

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Draft Regulatory Impact Analysis
3. Estimated Benefits and Economic Impacts

Estimated Benefits

       We estimate that the requirements in this proposal will result in substantial
benefits to public health and welfare and the environment, as described in Chapter 6.
The benefits analysis performed for this proposal uses sophisticated air quality and
benefit modeling tools and is based on peer-reviewed studies of air quality and health
and welfare effects associated with improvements in air quality and peer-reviewed
studies of the dollar values of those public health and welfare effects.

       EPA typically quantifies PM- and ozone-related benefits in its regulatory
impact analyses  (RIAs) when possible. In the analysis of past air quality regulations,
ozone-related benefits have included morbidity endpoints and welfare effects such as
damage to commercial crops. EPA has not recently included a separate and additive
mortality effect for ozone, independent of the effect associated with fine particulate
matter.  For a number of reasons, including 1) advice from the Science Advisory
Board (SAB) Health and Ecological Effects Subcommittee (HEES) that EPA consider
the plausibility and viability of including an estimate of premature mortality
associated with short-term ozone exposure in its benefits analyses and 2) conclusions
regarding the scientific support for such relationships in EPA's 2006 Air Quality
Criteria for Ozone and Related Photochemical Oxidants (the CD), EPA is in the
process of determining how to appropriately characterize ozone-related mortality
benefits within the context of benefits analyses for air quality regulations.  As part of
this process, we  are  seeking advice from the National Academy of Sciences (NAS)
regarding how the ozone-mortality literature should be used to quantify the reduction
in premature mortality due to diminished exposure to ozone, the amount of life
expectancy to be added and the monetary value of this increased life expectancy in
the context of health benefits analyses associated with regulatory assessments.  In
addition, the Agency has sought advice on characterizing and communicating the
uncertainty associated with each of these aspects in health benefit analyses.

       Since the NAS effort is not expected to conclude until 2008, the agency is
currently deliberating how best to characterize ozone-related mortality benefits in its
rulemaking analyses in the interim. For the analysis  of the proposed locomotive and
marine standards, we do not quantify an ozone mortality benefit. So that we do not
provide an incomplete picture of all of the benefits associated with reductions in
emissions of ozone precursors, we have chosen not to include an estimate of total
ozone benefits in the proposed RIA. By omitting ozone benefits in this proposal, we
acknowledge that this analysis underestimates the benefits associated with the
proposed standards. Our analysis, however, indicates that the rule's monetized PM2.s
benefits alone substantially exceed our estimate of the costs.

       The range of benefits associated with the proposed program are estimated
based on the risk of several sources of PM-related mortality effect estimates, along
with all other PM non-mortality related benefits information. These benefits are
presented in Table ES-11.  The benefits reflect two different sources of information
                                     ES-8

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                                                          Executive Summary
about the impact of reductions in PM on reduction in the risk of premature death,
including both the American Cancer Society (ACS) cohort study and an expert
elicitation study conducted by EPA in 2006. In order to provide an indication of the
sensitivity of the benefits estimates to alternative assumptions, in Chapter 6 of the
RIA we present a variety of benefits estimates based on two epidemiological studies
(including the ACS Study and the Six Cities Study) and the expert elicitation.  EPA
intends to ask the Science Advisory Board to provide additional advice as to which
scientific studies should be used in future RIAs to estimate the benefits of reductions
in PM.  These estimates are in year 2005 dollars.

Table ES-11- Estimated Monetized PM-Related Health Benefits of the Proposed Locomotive and
                               Marine Engine Standards

TOTAL BENEFITSA'B'C'D (BILLIONS 2005$)
2020
2030
PM mortality derived from the ACS cohort study; Morbidity functions from epidemiology literature
Using a 3% discount rate
Confidence Intervals (5th - 95th %ile)
Using a 7% discount rate
Confidence Intervals (5th - 95th %ile)
$4.4+B
($1.0 -$10)
$4.0+B
($1.0 -$9.2)
$12+B
($2.1 -$27)
$11+B
($1.8 -$25)
PM mortality derived from lower bound and upper bound expert-based result;6 Morbidity functions from
epidemiology literature
Using a 3% discount rate
Confidence Intervals (5th - 95th %ile)
Using a 7% discount rate
Confidence Intervals (5th - 95th %ile)
$1.7+B-$12+B
($0.2 -$8.5) -($2.0 -$27)
$1.6+B-$11+B
($0.2 -$7.8) -($1.8 -$24)
$4.6+B-$33+B
($1.0 -$23)- ($5.4 -$72)
$4.3+B-$30+B
($1.0 -$21)- ($4.9 -$65)
a Benefits include avoided cases of mortality, chronic illness, and other morbidity health endpoints.
b PM-related mortality benefits estimated using an assumed PM threshold of 10 jig/m3. There is
uncertainty about which threshold to use and this may impact the magnitude of the total benefits
estimate.  For a more detailed discussion of this issue, please refer to Section 6.6.1.3 of the RIA.
c For notational purposes, unquantified benefits are indicated with a "B" to represent the sum of
additional monetary benefits and disbenefits. A detailed listing of unquantified health and welfare
effects is provided in Chapter 6 of the RIA.
d Results reflect the use of two different discount rates: 3 and 7 percent, which are recommended by
EPA's Guidelines for Preparing Economic Analyses and OMB Circular A-4. Results are rounded to
two significant digits for ease of presentation and computation.
e The effect estimates of nine of the twelve experts included in the elicitation panel fall within the
empirically-derived range provided by the ACS and Six-Cities studies. One of the experts fall below
this range and two of the experts are above this range. Although the overall range across experts is
summarized in this table, the full uncertainty in the estimates is reflected by the results for the full set
of 12 experts. The twelve experts' judgments as to the likely mean effect estimate are not evenly
distributed across the range illustrated by arraying the highest and lowest expert means.  Likewise the
5th and 95th percentiles for these highest and lowest judgments of the effect estimate do not imply any
particular distribution within those bounds. The distribution of benefits estimates associated with each
of the twelve expert responses can be found in Tables 6.4-3 and 6.4-4 in the RIA.

       We estimate that the annual emission reductions associated with the proposed
standards would annually prevent 1,500 premature deaths (based  on the ACS cohort
study), 170,000 work days lost, and 1,000,000 minor restricted-activity days. Using
the ACS-based estimate of PM-related premature mortality incidence, we estimate
that the monetized benefits of this rule in 2030 would be approximately $ 12  billion,
                                         ES-9

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Draft Regulatory Impact Analysis
assuming a 3 percent discount rate (or $11 billion assuming a 7 percent discount rate).
Using the range of results derived from the expert elicitation, we estimate that the
monetized benefits in 2030 would range from approximately $4.6 billion to $33
billion, assuming a 3 percent discount rate (or $4.3 to $30 billion assuming a 7
percent discount rate). These estimates would be increased substantially if we were
to adopt the remanufactured marine engine program concept. The annual cost of the
program  in 2030 would be significantly less, at approximately $600 million.

Economic Impact

       We also performed an economic impact analysis to estimate the market and
social welfare impacts of the proposed standards. This analysis can be found in
Chapter 7.  According to this analysis, the average price of a locomotive in 2030 is
expected to increase by less than three percent as a result of the proposed standards.
The average price of a commercial marine diesel engine in 2030 is expected to
increase by about 8.5 percent for Category 1 engines above 800 hp and about 19
percent for Category 2 engines above 800  hp.B The average price of a marine vessel
using those engines is expected increase by about 1 percent for vessels using
Category 1 engines above 800 hp (about $16,000) and about 3.6 percent for vessels
using Category 2 engines above 800 hp (about $142,000).  Increases in engine and
vessel prices for commercial engines below 800 hp and recreational engines are
expected to be negligible.

       Overall, producers and consumers  of rail  and marine transportation services
are expected to bear the majority of the social costs of the program, in large part
because they bear the operating (urea) and remanufacturing costs that make up most
of the compliance costs of the  proposal.  Providers of those transportation services are
expected to bear about 42 percent of the social costs of the rule, and users are
expected to bear about 50 percent.  However, the price of rail and transportation
services is expected to increase by less than 1 percent.  Locomotive, marine diesel
engine, and marine vessel manufacturers will bear the remainder of the social costs.

4. Alternative Program Options

       In the course of designing our proposed program, we investigated several
alternative approaches to both  the engine and fuel programs. Chapter 8 contains a
description of these alternatives and an analysis of their potential costs and benefits.
B Marine diesel engines are divided into three categories for the purposes of EPA's standards.
Category 1 are engines above 50 hp and up to 5 liters per cylinder displacement. Category 2 are
engines from 5 to 30 liters per cylinder. Category 3 are engines at or above 30 liters per cylinder. See
40 CFR 94.2. Note that we are proposing to change the definition of Category 1 and Category 2
engines to reflect a 7 liter per cylinder cut-off.
                                     ES-10

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                                  Chapter 1: Industry Characterization
CHAPTER 1: INDUSTRY CHARACTERIZATION
1.1 MARINE	1-2
1.1.1 INTRODUCTION	1-2
1.1.2 MARINE DIESEL ENGINE MANUFACTURERS	1-6
1.1.3 MARINE VESSEL MANUFACTURERS	1-24
1.2 LOCOMOTIVE	1-44
1.2.1 CURRENT EMISSION REGULATIONS	1-45
1.2.2 SUPPLY: LOCOMOTIVE MANUFACTURING AND
REMANUFACTURING	1-46
1.2.3 DEMAND: RAILROADS	1-56
1.2.4 EXISTING REGULATIONS	1-70
1.2.5 FOREIGN RAILROADS IN US	1-72
                               1-1

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Draft Regulatory Impact Analysis
CHAPTER 1: Industry Characterization

       In order to assess the impacts of emission regulations upon the affected
industries, it is important to understand the nature of the industries impacted by the
regulations.  The industries affected by these regulations include marine diesel engine
manufacturers and marinizers, the manufacturers of marine vessels which have
marine diesel marine engines installed on them, the manufacturers of locomotives and
locomotive engines, the owners and operators of locomotives (i.e., railroads), and
remanufacturers of locomotives and locomotive engines. This chapter provides
market information for each of these affected industries, and is provided for
background purposes.

1.1 Marine

1.1.1 Introduction

       The regulations for marine diesel engines will directly impact three industries.
These industries are the manufacturers of marine diesel engines, diesel engine
marinizers, and the manufacturers of vessels which have marine diesel engines
installed on them. Each of these industries is discussed in more detail in the
following sections. Much  of this marine industry characterization was taken from a
report done for us by RTI,  International.1

1.1.1.1 Marine Diesel Market Overview

       Marine diesel engines include both engines used for propulsion on marine
vessels, and those used for marine vessel auxiliary power needs. Diesel marine
engines are generally derived from engines originally designed and manufactured for
land-based nonroad applications. These nonroad engines are then adapted for use in
marine applications through the process of marinization, either by the original engine
manufacturer, or by a post-manufacturer marinizer (PMM).  The marinization process
is discussed in further detail in section 1.1.2.2.2.

        Propulsion engines can vary dramatically in size and power, from the
smallest engines used in recreational sailboats, to very large engines used in ocean-
going commercial vessels.  Similarly, auxiliary engines cover a very broad range of
sizes and rated power.  Auxiliary engines can be used for a variety of purposes,
including primary or emergency electrical power generation, and the powering of
onboard equipment such as pumps, winches, cable and pipe laying machinery, and
dredging equipment. A description of the various engine categories used for
regulatory purposes is  contained in section 1.1.2.1.

       As with marine diesel engines, marine vessels include a very broad range of
vessel sizes and types. These include small recreational vessels, as well as
commercial vessels such as tow and tug boats,  patrol boats,  commercial fishing
vessels, research vessels, passenger vessels tour boats and ferries), offshore support
                                      1-2

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                                          Chapter 1: Industry Characterization
vessels which service offshore drilling platforms, and a variety of other specialized
commercial vessels.

       Figure 1-1 shows the links between the various market segments of the marine
diesel engine industry and the marine vessel industry, as discussed further in the
following sections.

                 Figure 1-1 Marine Diesel Market Segment Flow Chart
                                  Coffsumers
                          Transportation » Fishing »Industrial
                           • Government • Recreational Use
                          Marine Diesel Vessel Markets
                       • Recreational Single Engine * Recreational
                      Twin Engine • Tug/Tow  * Ferries  • Fishing •
                       Coast Guard • Cargo * Research • Offshore
                                  Support- Military
             Imports
           * Recreational
             Vessels
           Marine Diesel
             Engines
Marine Vessel
Manufacturers
Marine Vessel
 and Engine
   Repair
 Businesses
                           larine Diesel Engine Markets
                              •Small * Recreational C1
                           Commercial C1 • Commercial C2
Mann kali on
Performed by
Engine
Manufacturer
1
i
i
i
i
i
i
. j
Propulsion and
Auxiliary Engine
Marinizers
jt
Automotive, Marine, and Generator
Engine Manufacturers
1.1.1.2 Current Emission Regulations

       The first standards to take effect for commercial marine diesel engines are the
Tier 1 emission standards, which were adopted in 2003, and became effective with
the 2004 model year (68 FR 9746, February 28, 2003). These N0x-only standards
apply to commercial marine diesel engines with a per-cylinder displacement of
greater than 2.5 liters per cylinder.  As shown in Table 1-1 the standards vary
depending on the rated speed of the engine.
                                      1-3

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Draft Regulatory Impact Analysis
 Table 1-1 Tier 1 Standards for Commercial Marine Diesel Engines over 2.5 Liters per Cylinder
Rated engine speed (rpm)
<130
130-2000
>2000
NOX (g/kW-hr)
17
45 X rpm u "
9.8
       We adopted Tier 2 emission standards for Category 1 (Cl) marine diesel
engines over 37 kW and for Category 2 (C2) marine diesel engines in 1999 (64 FR
73300, December 29, 1999). These standards are shown in Table 1-2.
  Table 1-2 Tier 2 Emission Standards for Cl (over 37 kW) and C2 Commercial Marine Diesel
                                   Engines.
Category
1
2
Displacement
(liters/cylinder)
Power >37 kW, disp. <0.9
0.9 < disp. < 1.2
1.2
3300 kW
20.0 < disp. < 25.0
25. 0< disp. < 30.0
Starting
Date
2005
2004
2004
2007
2007
2007
2007
2007
2007
NOX+THC
(g/kW-hr)
7.5
7.2
7.2
7.2
7.8
8.7
9.8
9.8
11.0
PM
(g/kW-
hr)
0.40
0.30
0.20
0.20
0.27
0.50
0.50
0.50
0.50
CO
(g/kW-
hr)
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
       We applied the Tier 2 emission standards for Cl engines shown in Table 1-2
to recreational marine diesel engines, but with applicable dates two years behind
those for the corresponding commercial marine diesel engines (67 FR 68242,
Novembers, 2002).

       There are currently no emission regulations specifically  for marine diesel
engines less  than 37 kW.  Rather, these engines are covered by the Tier 2 standards
for nonroad compression ignition (Cl) engines, as shown in Table 1-3 (63 FR 56968,
October 23,  1998).
                                     1-4

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                                             Chapter 1: Industry Characterization
Table 1-3 Tier 2 Emission Standards for Marine Diesel Engines Below 37 kW
Engine Power
kW<8
8
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Draft Regulatory Impact Analysis
requirement is relaxed for DMB and DMC grades, which are then pegged to the
15,000 ppm SECA limit. That requirement applies to fuels placed on the market
during that period. From January 1, 2008 to December 31, 2009, the fuel sulfur limit
for DMA and DMX grades falls to 1,000 ppm.  Finally, beginning January 1, 2010, a
fuel sulfur limit of 1,000 ppm applies to all marine gas oils (DMA, DMB, DMC, and
DMX) placed on the market, and to all types of marine fuels used by ships at berth in
EU ports and by inland waterway vessels. These last limits apply to any fuel used
onboard a vessel.  Exemptions apply for ships that spend less than 2 hours at berth,
ships that use shore-side electricity while at berth, and hybrid sea-river vessels while
they are at sea.

       In this proposal we are not considering similar programs for the fuels used by
vessels while operating in U.S. territorial waters. We believe that the best approach
for addressing emissions from auxiliary engines on foreign vessels that visit US ports
is through the adoption of international standards that would reduce both NOX and
PM emissions from these engines.  We will continue to participate in discussions for
the next tier of international standards at the International Maritime Organization,  as
part of the U.S. negotiating team.  We will also reconsider this issue as part of our
future Category 3 marine diesel engine action.

1.1.2 Marine Diesel Engine Manufacturers

       Diesel (compression-ignition) engines are designed to be quite robust in order
to withstand the very high temperatures and pressures associated with  compression-
ignition.  As a result, they tend to be very reliable and have very long service lives.
Their energy efficiency and simple design result in low operating  and maintenance
costs. As a result, diesel engines tend to dominate commercial marine applications,
where cost and reliability are key purchase decisions for the vessel operator. Diesel
engines account for only a small portion of the recreational marine market, however,
as  their initial purchase price is high relative to gasoline (spark-ignition) engines.  The
benefits of lower operating costs are not nearly as important in the recreational
market, where engines tend not to get much use as compared to commercial
applications.

       The terms "commercial" and "recreational" are defined in 40 CFR Part 94,
Control of Emissions for Marine Compression-Ignition Engines (Code of Federal
Regulations, 2006). The definitions in section 94.2 state that a commercial  engine is
an engine installed on a commercial vessel.  Likewise, a recreational engine is an
engine installed on a recreational vessel. Recreational vessel is defined as a vessel
that is intended by its manufacturer to be operated primarily for pleasure purposes,
although such a vessel could be chartered, rented or leased. Further, a recreational
vessel should be less than 100 gross registered tons, should carry fewer than six
passengers, and cannot be used solely for competition.

       This industry characterization is concerned with the U.S. market for marine
diesel engines, which encompasses all diesel marine  engines installed on marine
vessels to be flagged (registered)  in the United States. This includes engines made in
                                      1-6

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                                          Chapter 1: Industry Characterization
the U.S., engines imported for installation in vessels made in the U.S., and engines
included in vessels made overseas and imported into the U.S. Unless otherwise
noted, the production and engine characteristics data presented in the following
sections were obtained from the Power Systems Research OELink database.2

1.1.2.1 Engine Categories and Characteristics

       For the purposes of this industry characterization, we looked at four broad
categories of diesel marine engines, based on the categories that currently exist for
emission regulation purposes. These categories are shown in Table 1-4.
               Table 1-4 Diesel Marine Engine Categories and Applications
Category
Small
Recreational
Category 1
Commercial
Category 1
Commercial
Category 2
Commercial
Category 3
Power
<37kW
>37kW
>37kW
>37kW
>37kW
Displacement per
Cylinder
Any
< 5 liters
< 5 liters
> 5 liters and < 30 liters
> 30 liters
Applications
Auxiliary, Recreational Propulsion
Recreational Propulsion
Auxiliary, Commercial Propulsion
Auxiliary, Commercial Propulsion
Commercial Propulsion
       Given the broad range of commercial and recreational marine vessels types, it
is difficult to identify typical applications for each engine category.  Nonetheless, the
following paragraphs provide an overview of the general characteristics and typical
applications of engines in each category.

       Small: Engines in this category range from 4 to 43 horsepower (hp) and are
characterized by low costs and high sales volumes.  Most small engines are used for
auxiliary purposes on marine vessels or for propulsion on recreational sailboats.  In
2002 they accounted for approximately  26 percent of the marine diesel engines
produced or imported in the U.S. market. They are typically marinized land-based
nonroad diesel engines; we are not aware of any marine engines of this size made
solely for marine application.

       Category 1 (Cl) Recreational: Engines in this category range from 52 to
3,155 hp and are characterized by high power density (power to weight ratio) and low
annual hours of operation relative to commercial engines.  Such engines are typically
operated no more than 200 to 250 hours per year, and often less.  These engines are
used for propulsion in recreational vessels, which are designed for speed and planing
                                      1-7

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Draft Regulatory Impact Analysis
operation.  In 2002 they accounted for approximately 34 percent of the marine diesel
engines produced or imported in the U.S. market.

       Recreational vessels are designed primarily for speed, and this imposes certain
constraints on the type of engine they can use.  For a marine vessel to reach high
speeds, it is necessary to reduce the surface contact between the vessel and the water,
and consequently these vessels typically operate in a planing mode. However, the
accompanying high engine speeds are sustained for only short periods of time
compared to the total operation of the vessel  (i.e., long enough for the vessel to get up
on plane), and the duty cycle on which these  engines are certified reflects these
operations.

       Planing imposes two important design requirements. First, the vessel needs to
have a very high power, but lightweight, engine to achieve the speeds necessary to
push the vessel onto the surface of the water. Therefore, recreational engine
manufacturers have focused on achieving higher power output with lighter engines
(this is also referred to as high power density).  The tradeoff is less durability, and
recreational engines are warranted for fewer hours of operation than commercial
marine engines. The shorter warranty period is not a great concern, however, since
recreational vessels, and therefore their engines, are typically used for fewer hours per
year than commercial engines, and spend much less time operating at higher engine
loads.  Second,  the vessel needs to be as light as possible, with vertical and horizontal
centers of gravity carefully located to allow the hull of the vessel to be  lifted onto the
surface of the water. Therefore, recreational  vessel manufacturers have focused on
designing very lightweight hulls. They are typically made  out of fiberglass, using
precisely designed molds. The tradeoff is a reduced ability to  accommodate any
changes to the standard design.  For these reasons, recreational vessels are typically
designed around a specific engine or group of engines, and engines that are heavier or
that are physically larger cannot be used without jeopardizing  the vessel's planing
abilities or, in many cases, designing a new fiberglass mold for a modified hull.

       Category 1 (Cl) Commercial: Engines in this category are very similar to
engines in the C1 recreational category in displacement, but tend to have lower hp
ratings than recreational marine diesel engines  in order to provide increased durability
required in commercial applications.  In contrast to Cl recreational engines,  Cl
commercial engines are typically used 750 to 4,000 hours per year. They are
typically used for propulsion in vessels with displacement hull designs. They are also
used for a wide variety of auxiliary power needs on marine vessels. In 2002 they
accounted for approximately 39 percent  of the marine diesel engines  produced or
imported in the U.S. market.

       In contrast to recreational marine vessels, commercial vessels are typically
larger displacement hull vessels, and instead  of operating on the surface of the water,
for speed, they are pushed through the water. The speed at which a displacement
vessel can operate is limited by its hull design and above that limit, there are quickly
diminishing returns on power:  little vessel speed increase is achieved by increasing
power.  Because vessel speed is limited by the hull design,  there is little incentive to
                                      1-8

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                                          Chapter 1: Industry Characterization
over power the vessel, and engines on these types of commercial vessels tend to be
lower power when compared to recreational vessels of similar size.  Commercial
engines operate for long periods at about 80-90% of rated power and are designed
primarily with durability and fuel consumption in mind.

       Category 2 (C2): Engines in this category are typically derived from engines
originally designed for use in locomotives or for land-based stationary power
generation. Such engines typically operate 3,000 to 5,000 hours or more per year,
and are designed to be durable  and have a very long service life. Under our current
program, all C2 marine diesel engines are handled the same way; there is no
distinction between recreational or commercial engines in this category.  In 2002 they
accounted for approximately one percent of the marine diesel engines produced or
imported in the U.S. market.

       As we were developing this proposal, engine manufacturers brought to our
attention another category of marine diesel engines that do not fit neatly in the above
scheme.  These are high power-density marine diesel engines used in some
commercial vessels, including  certain kinds of crew boats, research vessels, and
fishing vessels. Unlike most commercial vessels, these vessels are built for higher
speed, planing operation, which allows them  to reach research fields, oil platforms, or
fishing beds more quickly.  These  engines may have smaller service lives because of
operation at these higher speeds.  Our current program does not distinguish between
these commercial engines and those used on displacement vessels with respect to
useful life periods. Further, this industry characterization does not specifically
address these engines as a unique group.

              A final category of marine diesel engines, Category 3 (C3) engines,
have displacements of 30 liters per cylinder or greater. Such engines are typically
only used in large ocean-going vessels,  and are not considered in this industry
characterization. Table  1-5 shows a summary of the general characteristics of
engines in each of the four categories considered in this industry characterization.
           Table 1-5 Engine Characteristics for the Considered Engine Categories

Cylinders
Horsepower
Engine Speed (rpm)
Weight (Ibs)
Cycle:
2
4
Configuration:
H-Block
Small
1-4
4.2-42.4
1,800-3,000
26-246

0.0%
100.0%

8.1%
Recreational
Category 1
3-16
52-3,155
1,800-3,000
156-7,491

10.2%
89.8%

0.0%
Commercial
Category 1
3-24
37.5-2,500
1,800-3,000
106-7,900

9.5%
90.5%

0.0%
Category 2
5-20
300-9, 190a
750-1,500
7,850-35,000

41.0%
59.0%

0.0%
                                      1-9

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Draft Regulatory Impact Analysis
Inline
V-Block
Cooling:
Air
Oil
Water
91.9%
0.0%

5.9%
0.0%
94.1%
65.3%
34.7%

0.0%
0.0%
100.0%
73.3%
26.7%

0.4%
0.1%
99.5%
33.7%
66.3%

0.0%
0.0%
100.0%
a. While the PSR database shows one C2 engine family with a 300 hp rating, C2 engines are generally
over 1000 hp at minimum.

       Table 1-6 shows the total number of engines in each category which were sold
in the United States in 2002.

          Table 1-6 Marine Diesel Engine Sales by Engine Category in 2002
Application Category
Small
Recreational Cl
Commercial Cl
Commercial C2
Total
Sales in 2002
10,761
13,952
15,826
277
40,816
Percent of Total
26.4%
34.2%
38.8%
0.7%

1.1.2.2 Supply Side

       Marine diesel engines are typically derived from land-based nonroad engines.
These engines are adapted for use in the marine environment through a process
known as marinization.  In this section we will discuss nonroad engine design,
production and costs, followed by descriptions of the marinization process and the
companies engaged in this activity. Finally we will discuss engine dressing and
rebuilding practices for marine diesel engines.

1.1.2.2.1 Nonroad Diesel Engine Design and Production

       Engine blocks are cast in a foundry, most often from gray iron.  Depending on
the size and complexity of the engine, the block may be formed by impression
molding or two-piece sand-casting. Smaller, more complex parts, including cylinder
heads, exhaust manifolds, and cylinder liners, are cast from ductile iron, typically
using sand cores to allow formation of the complicated shapes.  All castings must be
cleaned and deburred prior to further processing.  In addition, ductile iron parts will
also usually be heat treated to relieve  stress and harden the alloys. Table 1-7 lists the
materials and primary production  processes for various engine components.3

             Table 1-7 Engine Component Materials and Production Processes
Component
Block
Cylinder head
Intake manifold
Primary Materials
Iron, aluminum
Iron, aluminum
Plastic, aluminum
Primary Process
Casting
Casting, machining
Casting, machining
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                                          Chapter 1: Industry Characterization
Connecting rods
Pistons
Crankshaft
Valves
Exhaust systems
Powder metal, steel
Aluminum
Iron, steel, powder metal
Steel, magnesium
Stainless steel, aluminum,
iron
Molding, forging, machining
Forging, machining
Molding, forging, machining
Stamping, machining
Extruding, stamping
       The cast block, cylinder head, and cylinder liners, along with crankshafts,
gears, connecting rods, and other engine parts, are next machined to exact
specifications in a machining center.  Holes are drilled, parts reshaped, excess metal
removed, and the metal surfaces polished in the machining area. The operation of the
finished engine depends critically on the precision of the machining work at this
stage.

       The third major step in engine manufacturing is assembly. This area is usually
physically isolated from the dirty upstream operations so that contaminants are not
introduced into the completed engines, thus affecting their operation or shortening the
engine's life. In a typical plant, subassemblies are first put together on separate lines
or in separate bays; then the subassemblies are brought together for final assembly.
The completed engines are visually inspected and then evaluated on-line on a test
bench or in a test cell to  ensure their performance will meet expectations.

1.1.2.2.2 Engine Marinization

       Land-based nonroad diesel engines generally need to be modified in some
ways to make them suitable for installation on marine vessels. The process by which
this is done is known as  marinization. The marinization process results in changes to
the emission characteristics of the nonroad engine.  For this reason, a marinized
nonroad engine must be  certified to marine diesel engine emission standards even
though the base nonroad engine is certified to the nonroad diesel engine emission
standards. Sometimes, land-based nonroad diesel engines can be adapted for use in
marine applications without changing the emission characteristics of the engine. This
process is called engine  dressing, and is discussed in section 1.1.2.2.5.  Marinization
typically involves three significant modifications: choosing and optimizing the fuel
management system, configuring a marine cooling system, and making other
peripheral changes. These changes are detailed in the following paragraphs.

       Fuel and Air Management:  High-performance engines are preferred for
most recreational and some light duty commercial applications. These engines are
built to maximize their power-to-weight ratio (provide more power with less added
weight), which is typically done by increasing power from a given cylinder
displacement.  This is usually accomplished by installing a new fuel injection system,
which injects more fuel directly into the cylinder to increase power.  This can require
changes to the camshaft, cylinder head, and the injection timing and pressure.
Currently, the design limits for increased fuel to the cylinder are smoke and
durability. Modifications made to the cooling system also help enhance performance.
By cooling the charge, more air can be forced into the cylinder. As a result, more fuel

                                     1-11

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Draft Regulatory Impact Analysis
can be injected and burned efficiently because of the increase in available oxygen. In
addition, changes are often made to the pistons, cylinder head components, and the
lubrication system. For example, aluminum piston skirts can be used to reduce the
weight of the pistons.  Cylinder head changes include changing valve timing to
optimize engine breathing characteristics.  Marinizers do not typically go as far as to
physically modify the cylinder head.

       Cooling System: To mitigate performance problems, engine manufacturers
historically used  cooling systems that cooled by circulating seawater through the
engine that was pumped from outside the boat. Even though many currently operating
marine diesel engines still use seawater to cool the engine, almost all newly built
engines use a closed cooling system that recirculates coolant through the engine
block. These engines still use raw seawater by using it to draw heat out of the engine
coolant. These closed systems help prevent corrosion and allow the engine to operate
at higher temperatures. As part of the cooling system, water-jacketed exhaust
manifolds, pumps, and heat exchangers are added. Marine diesel engines may also
have larger oil pans to help keep oil temperatures down.

       Other Additions and Modifications: Marine engines are often installed in
engine compartments without much air flow for cooling, which can result in a number
of exposed hot surfaces (leading to safety concerns) or performance problems from
overheating the engine. To address safety concerns and to comply with U.S. Coast
Guard regulations, marine diesel engines are designed to keep engine and exhaust
component (exhaust manifold, turbocharger and exhaust pipe) temperatures cool.
Recreational and light duty commercial engines can accomplish this by running cool
water through a jacket around the exhaust system components. Larger engines
generally use a thick insulation around the exhaust pipes.

       Marinization might also include replacing some engine parts with parts made
of materials more durable in a marine environment. These changes include  more  use
of chrome and brass to prevent corrosion.  Because of the unique marine engine
designs, marinizers also add their own front accessory drive assembly. Finally,
marine engines must also be coupled with the lower drive unit to be applicable to  a
specific vessel.

1.1.2.2.3 Nonroad Diesel Engine Costs of Production

       The U.S.  Census Bureau does not differentiate cost of production figures for
marine diesel engines (North American Industry Classification System [NAICS]
333618B106).  However, because small, recreational Cl, commercial Cl, and
commercial C2 engines are derived form nonroad diesel engines, costs of production
for nonroad engines could be used to illustrate costs of production of marine diesel
engines (NAICS  3336183).  Costs of production figures are  divided into major input
categories of labor, materials, and capital expenditures.  Of these categories,
purchased materials account for the largest share of total costs. Based on data from
the most recent Economic Census, costs of materials represent about 64 percent of the
value of shipments, followed by labor at about 11 percent and capital expenditures at
                                     1-12

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                                          Chapter 1: Industry Characterization
about 3 percent.  (These numbers correspond with the broader "other engine
manufacturing" category [NAICS 333618].)

       Table 1-8 lists the primary materials used in engine components.4 No
breakdown of cost of materials used in production is available from the 2002
Economic Census for the specific category of marine diesel engines (NAICS
333618B106) nor for nonroad diesel engines (NAICS 3336183), but based on the
broader "other engine manufacturing" category (NAICS 333618), cost of materials
are dominated by cast and formed metal. Iron and steel accounted for 13 percent of
material costs; aluminum  accounted for 7 percent; injection fuel pumps for 5.6
percent; pistons, valves, and piston  rings for 3.5 percent; and engine electrical
equipment for 3.5 percent. All other materials and components, parts, containers, and
supplies accounted for 52 percent; no single material accounted for more than 2
percent of material costs.

 Table 1-8 Nonroad and "Other Engine" Costs of Production and Materials Consumed in 2002
NAICS
3336 18 Other engine
equipment manufacturing

3336 183 Diesel, semi-
diesel and dual fuel
engines (except
automobile, highway truck,
bus, tank)
Materials Consumed by
333618
Iron and steelb
Aluminum0
Value of
Shipments
($106)
18,586

2,003

Cost($106)
1,449
770
Labor
($106)a
2,145
11.5%
215
10.7%
Share of
Cost of
Materials
13.1%
6.9%
Cost of
Materials
($106)a
11,800
63.5%
1,287
64.3%



Capital
Expenditures
($106)a
730
3.9%
59
2.9%



a      Percentages refer to the share of the total value of shipments.
b      NAICS codes 33211101,33151001,33120007,33120016,33120033.
c      NAICS codes 33152005, 33152003, 33631100.
1.1.2.2.4 Nonroad Diesel Engine Manufacturers and Marinizers

       As was previously discussed, marine diesel engines are typically derived from
similar size land-based diesel engines through the marinization process. Marinization
is normally performed by two types of firms, and has an impact on the engine's
emission characteristics.

       First, there are large engine manufacturers such as Cummins, Caterpillar, and
Deere that marinize their land-based nonroad engines. They are referred to as
                                     1-13

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Draft Regulatory Impact Analysis
domestic engine manufacturers (DEMs), and they are usually involved in every step
of the manufacturing process of a marine engine.  Foreign engine manufacturers
(FEMs) are similar to DEM, but they are owned by foreign parent companies (this
also pertains to DDC and EMD, which are owned by foreign investment companies
now). Production of marine engines begins on the nonroad production line; however,
at some stage of the production process, an engine is moved to a different assembly
line or area where production is completed using parts and processes specifically
designed for marine  applications.

       Second, postmanufacture marinizers (PMMs), or simply marinizers, are
smaller manufacturers that purchase complete  or semi-complete land-based engines
from engine manufacturers and complete the marinization process themselves using
specially designed parts, potentially modifying fuel and cooling systems.

       Table 1-9 lists DEM, FEM, and PMM  companies. Only four U.S.-based
engine manufacturers produce  and marinize their marine diesel engines. Cummins is
the only company involved in two types of production. In addition to marinizing
their own, Cummins (through its subsidiary Onan) produces generators using Kubota
engines and therefore is included in both the DEM and postmanufacture marinizers
categories.

                      Table  1-9 Marine Engine Manufacturers
Domestic Engine
Manufacturers
Caterpillar
Cummins
Deere & Company
General Electric












Foreign Engine Manufacturers
Deutz
EQT (parent to DDC)
Greenbriar Equity, LLC (parent
to EMD)
MAN
Rumo
Volvo
Yanmar









Postmanufacture
Marinizers
Bombardier3
Brunswick
Cummins
Daytona Marine3
Fairbanks Morse3
Klassen
Kohler
Marine Corp. of America3
Marine Power
NREC Power Systems
Peninsular Diesel
Reagan Equipment3
Stewart & Stevenson
Sword Marine Technology
Valley Power Systems
(parent to Alaska Diesel)
Westerbeke
a. These companies' production is not included in the 2004 PSR database.
                                     1-14

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                                          Chapter 1: Industry Characterization
1.1.2.2.5 Marine Engine Dressing

       Marine engine dressing refers to the modifications made to a land-based
engine that enable it to be installed on a marine vessel.  Unlike PMMs, however, the
changes made by marine dressers do not affect the emission characteristics of the
engine. These modifications can be made by engine manufacturers or marine
dressing firms.  Modifications typically include installing mounting supports and a
generator (in the case of an auxiliary engine) or propeller gears (in the case of
propulsion  engines).  Other modifications consist of adding adaptors, water-cooled
exhaust manifolds, water tanks, electronic instrumentation, and alarm systems. There
are many manufacturers of this type. However, because these companies do not do
anything to the engines to change their emission characteristics, they are exempted
from the regulations. Thus, their coverage will be omitted in this profile.

1.1.2.2.6 Marine Engine Rebuilding

       Engines are often rebuilt to extend their service life. Engine rebuilding refers
to overhauling an engine or otherwise performing extensive renovation on the engine
(or on a portion of the engine or engine system).  This involves disassembling the
engine, inspecting and/or replacing many of the parts, and reassembling the engine in
a way that extends its service life.  Marine engines are typically rebuilt several times
of the course of their service lives.

       Many of these marine engine rebuilds are performed by machine shops. The
Engine Rebuilders Association lists over 2,500 machine shops in its member
database. In 2003, Engine Builder magazine surveyed these machine shops for their
2003 Machine Shop Market Profile.  According to their results, 53 percent of these
firms were  involved in marine engine rebuilding in 2002. The rebuilding of gas and
diesel marine engines  accounted for 5.1 percent of the total 1.13 million engines
rebuilt in 2002.5 Finally, a large number of engine rebuilds are performed by ship
and boat builders at their facilities.

1.1.2.3 Demand Side

       Marine diesel engines can be distinguished according to whether they are used
on commercial or recreational applications. As discussed above,  the basic difference
derives from the nature of the requirements on the engine in each application: more
power  density in recreational applications and more durability in  commercial
applications. In this section, we look at the characteristics of the four key segments
of this  industry; Recreational marine Cl and small (at or below 37 kW), Commercial
Cl, and C2 diesel engine markets.

       Table 1-10 Marine Diesel Engine Production by Application and Use Type
(2002) presents the total number of engines produced in and imported to the United
States broken down by application category. According to the data in the PSR
database, the largest single category is  marine engines produced for propulsion
purposes in recreational applications (17,954).  A slightly smaller number was
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Draft Regulatory Impact Analysis
produced for all auxiliary functions (16,377) and the rest for propulsion purposes in
commercial applications (6,524). Based on the engine category, the majority of the
engines produced or imported were classified as commercial Cl, followed by
recreational Cl and small. Category 2 is the smallest category with 277 engines
produced in 2002.

       Table 1-10 Marine Diesel Engine Production by Application and Use Type (2002)
Use Type
Commercial
propulsion
Marine auxiliary
Pleasure
propulsion
Total
Small (<37
kW)
NA
6,798
3,963
10,761
Cl Recreational
NA
NA
13,952
13,952
Cl Commercial
6,389
9,437
NA
15,826
C2
135
142
NA
277
1.1.2.3.1 Recreational Applications

       Recreational boats (especially the larger ones powered by diesel engines) are
generally considered discretionary goods; demand for them is typically price elastic

       There are several reasons why consumers might choose diesel engines over
gasoline engines for recreational applications.  First, diesel engines are more durable
and reliable.  Second, diesel engines have better fuel consumption.

       Based on the National Marine Manufacturers Association (NMMA) sales
data, there were approximately 5,760 diesel-powered (out of a total 10,200 diesel and
gas-powered inboard cruiser boats) recreational boats sold in 2002. NMMA also
estimated that among 10,200 boats, 92.2 percent had a twin engine.6 Under these
ratios, we estimated 11,070 recreational marine diesel engines were sold for
propulsion purposes in the United States in 2002.  This number differs from 13,952
engines imported or produced in the United States in 2002, as reported in the PSR
database. Some of the engines  produced  are used as the replacement engines;
however, the PSR OELink database is probably not entirely accurate. Because the
NMMA estimate is derived from surveying a large portion of the industry
stakeholders, their consumption estimate  seems more reliable.

       Not included in that estimate are small marine diesel engines.  PSR data
indicate that 10,761 small marine diesel engines were produced in 2002, with
approximately 64 percent of those being used for auxiliary purposes and the
remainder used as maneuvering engines on recreational applications and as cruising
engines on sailboats.
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                                         Chapter 1: Industry Characterization
1.1.2.3.2 Commercial Cl Applications

       Engines in this category are inputs into various commercial applications, such
as seasonal and commercial fishing vessels, emergency rescue vessels, ferries, and
coastal freighters.

       Commercial vessels are inputs into a wide range of production processes that
generate products and services. As a result, the demand for Cl engines is linked
directly to the demand for boats, and indirectly through the supply chain to the
demand for final products and services produced with commercial ships and boats.

       No data are readily available on the volumes of commercial boats produced
annually in the United States.  However, based on the 2004 Workboat Construction
survey of approximately 400 commercial boats scheduled to be delivered in 2005, we
estimate that 40 percent of them were Cl, 55 percent were C2, and 5 percent were C3
(Workboat, 2005). Using these estimates, we find that 160 Cl engine-powered
commercial vessels were produced in the United States in 2004. Once again, this
number does not correspond with 6,389 engines listed by PSR. More than likely
Workboat Construction journal's survey lists the largest commercial ships and boats,
and many smaller commercial boats are unaccounted for.

1.1.2.3.3 Commercial C2 Applications

       Commercial C2 engines might be used on crew and supply boats, trawlers,
and tug and tow boats. Many of the engines are also used as large auxiliary engines
on ocean-going vessels.  Based on the Workboat Construction survey estimate, there
were 220 C2 engine-powered commercial vessels built in the United States in 2004.7
This number is lower compared with 2002 production volume (277 engines) listed by
PSR.

       Like commercial Cl engines, commercial C2 engines are inputs in vessels,
which are in turn inputs in production processes that generate  products and services.
Therefore, demand for commercial C2 engines is linked directly to the demand for
commercial C2 vessels and indirectly to the demand for products and services
produced with these vessels.

1.1.2.4 Market Structure

       Recreational ApplicationsFigure 1-2 and Figure  1-3 present small and
recreational Cl marine diesel engine market breakdown by the type of a supplier.  In
2002, a majority of the small marine diesel engines (60 percent) were supplied by
engine marinizers, with about half of that value supplied by engine dressers, and only
11 percent by FEMs that oversee the entire production process.  No DEMs supplied
engines to this market. The situation is opposite for the recreational  Cl market,
where DEMs supply 45 percent of engines, and FEMs supply  26 percent. Marinizers
accounted for 28 percent, and dressers for less than 1 percent of the recreational Cl
market supply.
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Draft Regulatory Impact Analysis
       Table 1-11 details the top three engine manufacturers and marinizers in the
small (at or below 37 kW) and Cl recreational categories. The majority of the
engines in the small category are supplied by U.S.-based marinizer Westerbeke (48
percent). In 2002, Japanese manufacturer Yanmar and U.S.-based marinizer Kohler
both had approximately 10 percent of the market share. Cummins, a DEM, serves as
a marinizer in this market. Kubota engines, marinized by Cummins, accounted for
approximately 3.5 percent of small marine diesel engine market supply in 2002.

Figure 1-2 Small (<37 kW) Marine Diesel Engine Market Supply by Manufacturer Type (2002)
                                                  Dressers
                                                    28%
                 PMM
                 61%
                                                     FEM
                                                     11%
 Figure 1-3 Cl Recreational Marine Diesel Engine Market Supply by Manufacturer Type (2002)
                    PMM
                    28%
                      FEM
                      26%
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                                           Chapter 1: Industry Characterization
  Table 1-11 Top Three Small and Recreational Cl Marine Diesel Engine Manufacturers and
                                 Marinizers (2002)
                                              2002 Production
Market Share
Cl
Engine Manufacturers
Caterpillar
Cummins
Yanmar
Top 3 Firms' Production
Engine Marinizers
Westerbeke
Peninsular Diesel
Brunwick Corporation
Top 3 Firms' Production
Total Dressers
Total Cl Market
Small (<37 kW)
Engine Manufacturers
Yanmar
Engine Marinizers
Westerbeke
Valley Power Systems, Inc.
Kohler
Top 3 Firms' Production
Total Dressers
Total Small Market





9,524




2,800
23
13,952

(D)





7,136
2,000-3,000a
10,761





68.3%




20.1%
0.2%


(D)





66.3%
25%-30%a

a. The range is provided to avoid disclosing proprietary information of individual companies.
(D) = Data have been withheld to avoid disclosing proprietary information of individual companies.
1.1.2.4.1 Cl Commercial Applications

       The supply structure of the commercial Cl marine diesel engines market
resembles the supply structure of the recreational Cl market, with DEMs and PMMs
supplying 76 percent of the engines to the market (Figure 1-4). As opposed to the
recreational Cl market, dressers supply a larger portion of the commercial Cl market
(19 percent), with FEMs supplying 5 percent.
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Draft Regulatory Impact Analysis
Figure 1-4 Commercial Cl Marine Diesel Engine Market Supply by Manufacturer Type (2002)
                  M   x^T^x  *

                  (                          )
                   FEM X^^^^^^^^^X
                   5%   ^^^^^^^^^
                                Dresser
                                  19%
      Commercial Cl marine diesel engine market shares are listed by the type of
manufacturer in Table 1-12. DEMs Caterpillar and Deere and engine marinizer
Kohler have approximately equal market shares of 15 percent each. They are
followed by U.S.-based marinizer Westerbeke with an 11 percent market share. Even
though engine dressers are not covered by this rule, it is worth noting that the vast
majority of the engines supplied in  the commercial Cl market by these companies are
auxiliary engines.

  Table 1-12 Top Three Commercial Cl Marine Diesel Engine Manufacturers and Marinizers
                                (2002)
Cl
Engine Manufacturers
Caterpillar
Deere & Company
Cummins
Top 3 Firms' Production
Engine Marinizers
Kohler
Westerbeke
Valley Power Systems, Inc.
Top 3 Firms' Production
Total Dressers
Total Cl Market
2002 Production




6,452




5,690
1,383
15,826
Market Share




40.8%




36.0%
8.7%

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                                          Chapter 1: Industry Characterization
1.1.2.4.2 Commercial C2 Applications

       The commercial C2 marine diesel market is not supplied by dresser
companies; most of the supply comes from marinizers, which supply approximately
half of its volume.  U.S.-based companies are dominant in the commercial C2 marine
diesel engine market.  Among engine manufacturers, Caterpillar, and among
marinizers, General Motors and Stewart and Stevenson, together compose 78.4
percent of the market. Caterpillar is followed by Japanese manufacturer Yanmar and
German MAN B&W with  11 and 6 percent,  respectively (Table 1-13).
  Table 1-13 Top Three Commercial C2 Marine Diesel Engine Manufacturers and Marinizers
                                    (2002)
C2
Engine Manufacturers
Caterpillar
Greenbriar Equity LLC
Yanmar
Top 3 Firms' Production
Engine Marinizers
Stewart and Stevenson
Total Dressers
Total C2 Market
2002 Production

87
73
31
191

(D)
—
277
Market Share




69.0%

(D)
0.0%

(D) = Data have been withheld to avoid disclosing proprietary information of individual companies.

1.1.2.4.3 Pricing Behavior of Marine Diesel Engine Markets

       Discussions about market competitiveness usually focus on two types of
pricing behavior: perfect competition (price-taking behavior) and imperfect
competition (lack of price-taking behavior).  Under the former scenario, buyers and
sellers take (and thus are "price takers") the market price set in a competitive
equilibrium: the market price equals the value consumers place on the marginal
product, as well as the marginal cost to producers.  Under this scenario, firms have
some ability to influence the market price of the output they produce.  For example, a
firm might produce a commodity with unique qualities that differentiate its product
from its competitors' product. The value consumers place on the marginal product,
the market price, is greater than the cost to producers.  Thus,  the social welfare is
reduced under this scenario.

       As evident from the market share information presented in this report, marine
diesel engine markets are moderately (small  and commercial Cl) to highly
(recreational Cl and commercial C2) concentrated and thus have a potential  for
emergence of imperfect competition. Nevertheless, our analysis suggests mitigating
factors will limit prices from rising above the marginal cost; therefore, the assumption
of perfect competition is justified.
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Draft Regulatory Impact Analysis
       First, the threat of entry encourages price-taking behavior. Industries with
high profits provide incentives to new firms to enter the market and lower the market
price to their competitive levels.  In all of the marine diesel markets, domestic and
foreign candidates can enter any of these markets without incurring significant costs.

       Second, the data on capacity utilization rates published by the Federal Reserve
(for machinery, NAICS  333) suggest  that excess capacity exists in the broad category
that also includes converted internal combustion engines industry (NAICS
333618B106). February 2006 data present an industry utilization rate of 82.6 percent.
If these data do, in fact, indicate excess capacity in the marine diesel engine industry,
then the ability to raise prices is limited by excess idle capacity.

       Third, other theories place less value on market shares as a determinant of
pricing behavior and examine the role of potential competition instead.  For instance,
three conditions of perfectly contestable markets demonstrate how potential
competition may lead to perfect competition:8

   •  New firms have access to the same production technology, input prices,
       products, and demand information as existing firms

   •  All costs associated with entry can be fully recovered

   •  After learning about new firms' entry, existing firms  cannot adjust prices
       before these  new firms supply the market

       Although the extent to which these conditions apply to marine diesel engine
markets is not clear, the  theory suggests that market shares alone should not
necessarily be considered as an indicator of imperfect competition in the market.

1.1.2.5 Historical Market Data

1.1.2.5.1 Recreational Applications

       The historical market statistics are presented as a means to assess the future of
marine diesel engine production. Information on production trends is presented here.

       Historical production volumes for recreational Cl and small marine diesel
engine markets are presented in Table 1-14. The small marine diesel engine market
demonstrated continuous growth in production between 1998 and 2002, growing by
37 percent since 1998. The recreational Cl market experienced a slight peak in 2000
with 7 percent growth and then leveled off in 2002 at a slightly higher volume than it
was in 1998.
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                                         Chapter 1: Industry Characterization
  Table 1-14 Historical Market Trends for Small and Recreational Cl Marine Diesel Markets
                             Recreational C1
Small
2002
2001
2000
1999
1998
Percentage Change
13,952
13,754
14,408
13,836
13,446
3.8%
10,761
9,833
9,576
7,997
7,853
37.0%
1.1.2.5.2 Commercial Cl Applications

       The commercial Cl engine market demonstrated a strong steady growth in the
past 5 years. Starting at 10,508 engines produced and imported into the United States
in 1998, it grew by more than 50 percent and equaled 15,826 engines in 2002 (Table
1-15).

         Table 1-15 Historical Market Trends Commercial Cl Marine Diesel Market
Year
2002
2001
2000
1999
1998
Percent Change
Production
15,826
14,078
12,838
12,178
10,508
50.6%
1.1.2.5.3 Commercial C2 Applications

       The commercial C2 market has a relatively small volume of sales compared to
the recreational and commercial Cl markets. Nevertheless, the commercial C2
market experienced significant growth in the past 5 years.  In the period from 1998 to
2002, market volume more than doubled and equaled 277 engines in 2002 (Table 1-
16).

         Table 1-16 Historical Market Trends Commercial Cl Marine Diesel Market
Year
2002
2001
2000
1999
1998
Percentage Change
Production
277
231
200
138
134
106.7%
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Draft Regulatory Impact Analysis
1.1.3 Marine Vessel Manufacturers

       Marine vessels include a wide variety of ships and boats.  Several alternative
definitions exist to distinguish between ships and boats.  For this profile, ships are
defined as those marine vessels exceeding 400 feet in length. They are built to
purchasers' specifications in specialized "Main Shipyard Base" ship yards, and
typically powered by Category 3 diesel engines. Under this definition most of the
vessels powered by small, Cl or C2 diesel engines would be considered boats. In this
section, the terms "vessel" and "boat" will be used interchangeably. Vessels powered
by Cl and C2 engines vary widely; they may be made from fiberglass-reinforced
plastic (FRP or fiberglass), aluminum, wood, or steel. Some vessels are serially
produced using assembly line methods; others are individually built to meet
purchasers' specifications in boatyards or in the same yards that build ships. Small
boats may be powered by small spark-ignition (gasoline) engines.  Vessels covered
by this profile include a small share of recreational boats: inboard cruisers, especially
those over 40 feet in length. In addition the profile covers diesel-powered
commercial and governmental vessels such as tug/tow boats, fishing vessels,
passenger vessels, cargo vessels, offshore service vessels and crew boats, patrol
boats, and assorted other commercial vessels.

       The Economic Census includes two industry sectors, NAICS 336611 Ship
Building and Repairing and NAICS 336612 Boat Building,  that together cover the
marine vessel types addressed in this profile. Each NAICS includes some vessels not
included  in this profile. NAICS 336612 defines boats as  "watercraft not built in
shipyards and typically of the type suitable or intended for personal use."; thus,
NAICS 336612 includes essentially recreational vessels; within this NAICS, NAICS
3366123  covers inboard motor boats,  including those powered by diesel engines.
Thus, the diesel-powered recreational vessels covered by this profile represent only a
relatively small share of NAICS 336612. NAICS 336611 comprises establishments
primarily engaged in operating a shipyard, fixed facilities with drydocks and
fabrication equipment capable of building a "watercraft typically suitable or intended
for other  than personal or recreational use."9  Commercial and governmental vessels
powered  by small, Cl and C2 diesel engines are included in NAICS 336611, along
with larger ships that are powered by C3 engines and thus not covered by this profile.

1.1.3.1 Overview of Vessels

       This profile covers a wide variety of vessels, including recreational vessels
and smaller commercial, service, and industrial vessels, generally less than 400 feet in
length. Commercial vessels under 400 feet long dominate inland and  coastal waters
where shallow drafts restrict access by larger ships.  Depending on their mission, Cl-
and C2-powered vessels also may operate in the Great Lakes, coastwise, intercoastal,
noncontiguous, and/or transoceanic environments.  The principal commercial boat
types are tugboats, towboats, offshore supply boats, fishing  and fisheries vessels,
passenger boats, and industrial boats, such as cable- and  pipe-laying boats,
oceanographic boats, dredges, and drilling boats. Passenger boats include crewboats,
excursion boats, and smaller ferries.
                                     1-24

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                                          Chapter 1: Industry Characterization
       Most commercial vessels covered by this profile are U.S.-built, U.S.-owned
and U.S.-operated. Under provision of the Jones Act (Section 27, Merchant Marine
Act, 1920), vessels transporting merchandise between U.S. ports must be built in and
documented under the laws of the United States and owned and operated by persons
who are citizens of the United States. Because Cl and C2 diesel engines are
frequently used to power vessels that operate in inland waters or coastwise, they are
generally operating between U.S. ports.  Thus, many cargo vessels powered by Cl
and C2 diesel engines are required to be  U.S.-built, -owned, and -operated, unless a
waiver is granted by the Secretary of the Treasury.

       Generally excluded from this profile, because they are powered by C3
engines, are larger merchant and military vessels, typically exceeding 400 feet in
length, that engage in waterborne trade and/or passenger transport or military
operations.  Commercial and government-owned (e.g., military) ships operate in
Great Lakes, coastwise,  intercoastal, noncontiguous (between United States mainland
and its noncontiguous territories, such as Alaska, Hawaii, and Puerto Rico), and/or
transoceanic routes. The principal commercial ship types are dry cargo ships,
tankers, bulk carriers, and passenger ships.  Dry cargo ships include break bulk,
container, and roll-on/roll-off vessels. Passenger ships include cruise ships and the
largest ferries. Military  ships include aircraft carriers, battleships, and destroyers.
Also excluded from the profile are the smallest recreational, commercial, and
government vessels, which are powered  by gasoline outboard, stern-drive, or inboard
engines.  Figure 1-5 illustrates the size of the U.S. commercial fleet over time from
1980 to 2003 and the distribution between  larger and smaller vessels.  Compared with
smaller commercial vessels,  larger commercial vessels represent a small fraction of
the U.S. commercial fleet.

       Figure 1-5 includes vessels as small as 1,000 gross tons in the ship, rather than
boat population, and omits key categories of boats (smaller vessels), such as supply
boats and fishing boats.10  It is very difficult to develop useful criteria which will
allow the separation of vessels populations into those powered by the various engines
categories. Nonetheless, this analysis provides some insight as to the relative
proportion of vessel in the U.S. fleet powered by C1/C2 engines versus C3 engines.
                                      1-25

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Draft Regulatory Impact Analysis
                   Figure 1-5 U.S. Commercial Fleet (1960 to 2003)
                       1980
1990
1995
Year
2000
2003
                                          D Ships • Boats
1.1.3.2 Overview of Vessel Manufacturers

       This report classifies vessel manufacturing facilities ("yards"), according to
the types of vessels manufactured.  The Economic Census reports on two industry
segments that are related to vessel manufacture—shipbuilding and repairing (NAICS
336611) and boatbuilding (NAICS 336612). Shipbuilding facilities typically have
drydocks. NAICS 336612 encompasses facilities that build "watercraft suitable for
personal or recreational use," which corresponds closely to recreational boats, and
NAICS 336611 includes facilities that build larger commercial and government
vessels. Both NAICS codes include vessels not covered by this profile.

       NAICS 336611 includes generally one-of-a-kind vessels built in a shipyard
with drydock facilities, including vessels powered by Category 1 and 2 diesel
engines, as well as the larger Category 3 engines. Most vessels manufactured by this
NAICS code are for commercial or governmental applications  (e.g., Coast Guard,
military, Army Corps of Engineers, municipal harbor police).

       NAICS 336612 covers generally recreational vessels. These may be built
using repetitive methods, such as an assembly line process or individually; it includes
those powered by gasoline, alcohol, and diesel engines. Within NAICS 336612, only
larger (over 40 feet) inboard cruisers are predominantly powered by diesel engines.
This segment of NAICS 336612 (NAICS 3366123 Inboard Motorboats) includes only
82 establishments, less than 7 percent of the total in the NAICS code. Because most
of the smaller inboard motorboats are Si-powered, the number  of facilities
manufacturing diesel-powered recreational vessels is even smaller. The information
summarized in Table  1-17 shows information about establishments and companies in
NAICS 336611 and 336612, and indicates that there are a large number of small
                                     1-26

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                                          Chapter 1: Industry Characterization
establishments in both of these industry segments.11 Most companies in both NAICS
codes are single-establishment companies.

     Table 1-17 2002 Economic Census Data on Shipbuilding and Boatbuilding Industries

Number of establishments
Number of companies
Establishments with 100+
employees
Establishments with 500+
employees
NAICS 3366 11
(shipbuilding)
639
586
91
21
NAICS 336612
(boatbuilding)
1,123
1,063
134
16
       Within NAICS 336611, the U.S. Maritime Administration (MARAD)
classifies yards as either first-tier or second-tier according to building capacity.  In the
Report on Survey of U.S. Shipbuilding and Repair Facilities, MARAD (2003)
identifies 24 first-tier yards, which form the "major shipbuilding base" (MSB) in the
United States. The 24 MSB yards satisfy several requirements, including at least one
construction position capable of accommodating a vessel that is 400 feet in length or
over and an unobstructed waterway leading to open water (i.e., locks, bridges) and the
channel water must be a minimum of 12 feet deep. While MSB yards are the only
ones to manufacture large ships, many of them also produce smaller commercial
vessels. Second-tier yards do not meet these criteria and include many small- and
medium-sized yards that construct and repair boats.12

1.1.3.3 Recreational Vessels

       This section  describes the recreational boat manufacturing industry, with
special attention to the segment of the industry using diesel engines.

1.1.3.3.1 Types of Recreational Vessels

       U.S. boatbuilders construct a variety of recreational boats, including
ski/wakeboard boats, powerboats, racing boats,  sailboats, recreational fishing boats,
and yachts. Only a small segment of recreational boats are powered by diesel engines
and thus addressed by this profile. Diesel-powered types of vessels include inboard
cruisers and most of the larger yachts.

1.1.3.3.2 Supply of Recreational Vessels

       Boats for personal and recreational use can be manufactured from many
different materials, including fiberglass-reinforced plastic (FRP), aluminum,
rotationally molded  (rotomolded) polyethylene  or other thermoplastic materials, and
wood.  Only relatively large (over 40 foot) inboard cruisers commonly use  diesel
engines; diesel engines used in recreational vessels are almost exclusively Cl
engines, although C2 engines may be used on the largest yachts. Among recreational
boats, large inboard  cruisers are  less likely to be serially produced; because they are

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Draft Regulatory Impact Analysis
quite costly, they tend to be customized to buyers' specifications. Like smaller
serially produced boats, the most common hull material is FRP.

1.1.3.3.3 Production Process

       The most common material used in boat manufacturing is FRP. Boats made
from FRP are typically manufactured serially. Using FRP makes it very difficult to
incorporate purchaser preferences into a vessel's design because 1) many features are
designed into fiberglass molds, making customization time consuming and expensive
and 2)  vessels constructed from FRP are very sensitive to changes in their vertical or
horizontal centers of gravity, making it difficult to change a particular design. In
some cases, boat manufacturers produce the FRP hulls and decks used in constructing
their boats; in other cases the FRP hulls and decks of boats are manufactured by a
contractor for the boat manufacturer.

       The process typically used to manufacture these boats is known as open
molding. In this  process, separate molds are used for the boat hull, deck, and
miscellaneous small FRP parts such as fuel tanks, seats, storage lockers, and hatches.
The parts are built on or inside the molds using glass roving, cloth, or  mat that is
saturated with a thermosetting liquid resin such as unsaturated polyester or vinylester
resin.   The liquid resin is mixed with a catalyst before it is applied to the glass.  The
catalyzed resin hardens to form a rigid shape consisting of the plastic resin reinforced
with glass fibers.

       The FRP boat manufacturing process generally follows the following
production steps:

       •  Before each use, the molds are cleaned and polished and then treated with
          a mold release agent that prevents the  part from sticking to the mold

       •  The open mold is first spray coated with a pigmented polyester resin
          known as a gel coat that will become the outer surface of the finished part.
          The gel coat is mixed with a catalyst as it is applied so that it will harden

       •  After the gel coat has hardened, the inside of the gel coat is coated with a
          skin coat of polyester resin and short glass fibers and then rolled with a
          metal or plastic roller to compact the fibers and remove air bubbles.  The
          fibers are applied in the form of a chopped strand mat or chopped roving
          from  a chopper gun; the skin coat is about 90 mils (0.09 inches) thick and
          is intended to prevent distortion of the gel coat (known as "print through")
          from  the subsequent layers of fiberglass and resin

       •  After the skin  coat has hardened, additional glass reinforcement in the
          form  of chopped roving, chopped strand mat, woven roving, or woven
          cloth is applied to the inside of the mold and saturated with catalyzed
          polyester resin. The resin is usually applied with either spray equipment
          or by hand using a bucket and brush or paint-type roller.  The saturated
                                      1-28

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                                          Chapter 1: Industry Characterization
          fabric is then rolled with a metal or plastic roller to compact the fibers and
          remove air bubbles

       •  More layers of woven glass or glass mat and resin are applied until the
          part is the desired thickness; the part is then allowed to harden while still
          in the mold. As the part cures, it generates heat from the exothermic
          reactions that take place as the resin hardens; very thick parts may be built
          in stages to allow this heat to dissipate to prevent heat damage to the mold

       •  After the resin has cured, the part is removed from the mold and the edges
          are trimmed to the final dimensions

       •  The different FRP parts of the boat are assembled using small pieces of
          woven glass or glass mat and resin, adhesives, or mechanical fasteners

       •  After the assembly of the hull is complete, the electrical and mechanical
          systems and the  engine are installed along with carpeting, seat cushions,
          and other furnishings and the boat is prepared for shipment

       •  Some manufacturers paint the topsides of their boats to obtain a superior
          finish; the larger boats generally also require extensive interior woodwork
          and cabin furnishings to be installed

       As noted above, only the larger inboard cruisers are likely to have diesel
propulsion engines. Of all inboard cruisers, 56 percent are  diesel-powered. For boats
less than 40 feet in length, less than 35 percent are diesel-powered; for those  over 40
feet in length, 85 percent are diesel-powered. Table 1-18 provides estimates of
inboard cruiser retail sales by engine type and length of boat. In 2003, 5,191 diesel-
powered inboard cruisers were sold; of these, 3,032 were 41 feet or longer. Another
988 diesel-powered cruisers ranged from 36 to 40 feet in length. Only 454 were 30
feet long or less.13

 Table 1-18 Estimates of Inboard Cruiser Retail Unit Sales by Engine Type and Length of Boat

Boat Length
30' and under
31-35'
36-40'
41' and over
Total
1997
Gas
917
1,525
1,048
529
4,019
Diesel
178
309
492
1,302
2,281
1999
Gas
1,064
2,199
1,142
428
4,833
Diesel
435
673
804
2,655
4,567
2001
Gas
1,059
2,458
1,280
420
5,217
Diesel
495
953
991
3,144
5,583
2003
Gas
279
1,294
1,984
572
4,109
Diesel
454
717
988
3,032
5,191
       Table 1-19 summarizes the sales data from 1997 through 2003 for recreational
boats. In 2003, an estimated 9,200 inboard cruisers were sold; 97 percent of inboard
cruisers over 31 feet long were powered by twin engines.  Sales in the United States
are expected to continue to decrease as more and more of the larger recreational boats
are being built overseas (e.g., Taiwan).14
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Draft Regulatory Impact Analysis
Table 1-19 Estimates of Inboard Cruiser Retail Unit Sales by Single vs. Twin Engine and Length
                                    of Boat

Boat Length
30' and under
31-35'
36-40'
41' and over
Total
1997
Single
789
91
51
30
961
Twin
306
1,742
1,490
1,801
5,339
1999
Single
1,028
97
112
23
1,260
Twin
471
2,775
1,834
3,060
8,140
2001
Single
1,004
155
233
32
1,424
Twin
550
3,256
2,038
3,532
9,376
2003
Single
463
86
136
20
705
Twin
271
1,925
2,815
3,584
8,595
       While not all inboard cruisers are diesel-powered, the production costs for
inboard cruisers as a group are likely representative of the relative costs of various
inputs used in producing diesel-powered inboard cruisers. Production costs for
builders of inboard cruisers include the costs of materials, labor, and capital
equipment. Materials costs are more than double the cost of labor for these producers
and represent roughly half of the value of shipments of inboard cruisers (see Table
1-20). 5 Because diesel engines are generally more expensive than gasoline engines,
materials may represent an even larger share of diesel-powered inboard cruiser costs.

Table 1-20 Costs of Production for NAICS 3366123, Inboard Motorboats, Including Commercial
                     and Military, Except Sailboats and Lifeboats
Establishments
82
Number
13,412
Payroll
($1,000)
427,949
Number
10,457
Hours
(1,000)
20,773
Wages
($1,000)
299,815
Cost of
Materials
($1,000)
1,197,464
Capital
Expenditures
($1,000)
39,900
Value of
Shipments
($1,000)
2,384,478
1.1.3.3.4 Demand for Recreational Vessels

       Recreational boats are final consumer goods, and are generally considered
discretionary purchases. Demand for recreational boats is typically characterized by
elastic demand.

1.1.3.3.5 Industrial Organization for Recreational Vessel Manufacturers

       Recreational boat builders are located along all coasts and major waterways.
Table 1-21 provides sales and employment information of recreational diesel boat
builders.16'1  '18 Of the 36 companies for which data were identified, only 9 employ
more than 500 employees. Two large, multi-facility companies (Genmar and
Brunswick)  employ 21,000 and 6,000 employees respectively.  Companies with
fewer than 500 employees would be considered small businesses under the criteria of
the Small Business Administration for NAICS 336612.  Based on that definition, the
majority of firms producing recreational diesel boats would thus be considered small
entities.
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                                          Chapter 1: Industry Characterization
      Table 1-21 Employment Distribution of Companies that Build Recreational Boats
Employment Range
0-100
101-250
251-500
501-1,000
1,000+
Total number of firms
Number of Firms
11
9
7
4
5
36
Revenue Range ($Millions)
1.3-8.5
9.2-45.0
20.2- 101.7
63.2- 131.0
45.60-5,229

       Although there are a few large companies in the recreational diesel boat
building industry, there are many more small companies. The boatyards are located
on water bodies throughout the country, and many serve somewhat regional markets.
Because there are a relatively large number of suppliers, because there is increasing
competition from foreign suppliers, and because barriers to entry and exit are low, it
is reasonable  to characterize the markets for recreational diesel vessels as
competitive.  As described in section 1.1.2.4.3, the potential for competition and entry
(contestable markets) forces existing producers to behave in a competitive manner.

1.1.3.3.6 Markets and Trends in the Recreational Vessel Manufacturing Industry

       As summarized in Table 1-22, prices for inboard cruisers 41 feet and longer
have displayed no clear trend during the period 2001-2003.19 Prices in most
categories dipped in 2003, reaching prices below 2001 levels. This may result from
increased competition from foreign suppliers.

 Table 1-22 Estimated Average Retail Selling Price of Recreational Inboard Boats by Length of
                                     Boat
Boat Length
41' and over
41'-49'
50'-59'
60'-65'
66' and over
1997
$490,409
—
—
—
—
1998
$475,869
—
—
—
—
1999
$469,866
—
—
—
—
2000
$516,146
—
—
—
—
2001
—
$449,990
$963,197
$2,166,030
$3,627,189
2002
—
$419,873
$898,256
$2,280,029
$4,464,111
2003
—
$384,329
$842,578
$2,220,833
$2,816,731
       Information from NMMA indicates that the number of larger recreational
boats being built abroad, in places like Taiwan, has increased significantly in the last
few years. A recent NMMA report on recreational boat sales compiled U.S.
Department of Commerce import and export data, as reported in the U.S.
International Trade Commission database.  The 2003 data confirmed that the trade
imbalance continues to grow. Factors affecting this growth include the rising cost of
shipping, trade disputes between the U.S. and Europe, and the strength of the dollar,
which makes it difficult for U.S. boatbuilders to offer competitive pricing overseas.

       Table 1-23 shows that exports of vessels declined from 1997 to 2001, then
increased, posting a substantial increase between 2002 and 2003.20 Imports continue
to outpace exports, with the trade balance deficit roughly tripling between 1997 and
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Draft Regulatory Impact Analysis
2003. However, because of the substantial increase in exports, the deficit actually fell
between 2002 and 2003.

            Table 1-23 Value of Imported and Exported Vessels (in SMillions)

Boats export
Boats import
Trade balance
1997
$678.6
$835.0
-$156.40
1998
$674.8
$874.7
-$199.90
1999
$698.5
$984.2
-$285.70
2000
$662.0
$1,074.8
-$412.80
2001
$560.4
$1,113.1
-$552.70
2002
$600.5
$1,157.7
-$557.20
2003
$746.5
$1,207.2
-$460.70
1.1.3.4 Commercial Vessels

       This section builds on earlier work by EPA to characterize commercial vessels
and identify how many of each type are powered by Cl and C2 diesel engines. U.S.
boatbuilders construct a wide variety of commercial vessels. Most of these
boatbuilders are single-establishment companies and manufacture a limited number
of boat designs. A handful of yards (e.g., Halter Marine) also have the capacity to
build ships that would be powered by C3 engines.  Most commercial and government
boats are manufactured individually or customized to purchaser's specifications.

       U.S. boatyards build boats primarily used on inland and coastal waterways
between U.S. ports. Cargo vessels on these routes must satisfy Jones Act
requirements and, therefore, be built in the United States (U.S. Department of
Transportation, 1998).  As described above, the Jones Act (Section 27 of the
Merchant Marine Act of 1920)  requires that any vessel transporting merchandise
between U.S. ports be built in the U.S., owned and operated by U.S. citizens.  For this
reason, the U.S. commercial boatbuilding industry has a protected local market and
does not face the intense foreign competition that recreational boat builders or
shipbuilders building vessels for international trade do.  Clients include American
waterways operators (e.g., tugboats), offshore petroleum exploration and drilling
companies (e.g., liftboats, crewboats, supply boats), fisheries companies (e.g., fishing
and fish processing boats), industrial companies, (e.g., cable-laying boats), and
research organizations (e.g., oceanographic research vessels).

       The markets for commercial and governmental vessels can be modeled as if
they were competitive. While the Jones Act prohibits foreign manufacture of cargo
vessels trading between U.S. ports and the Passenger Services Act imposes a fee of
$200 per passenger on carriers transporting passengers between U.S. ports unless the
vessels are U.S.-built,  -owned, and -operated, most markets for commercial vessels
have relatively low barriers to entry and exit.  There are a significant number of firms
in each market segment, and they compete for both government and commercial
contracts.

       For the commercial boat market, we collected much of the background
                             r\ -i                                   *—*
information in a separate report.   Although the objective of that report was to
develop inputs for emissions inventory modeling, the report provides a general
characterization of commercial vessels, and estimates both Cl and C2 vessel counts
                                     1-32

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                                         Chapter 1: Industry Characterization
of some types. This report adopts the same commercial/governmental vessel
categories and definitions.

1.1.3.4.1 Tug and Towboats

       Towboats, also known as tugboats, include boats with rounded bows used for
pulling (towboats) and boats with square bows for pushing barges, known as
pushboats.  Towboats that pull or push barges are referred to as line-haul boats, and
are the largest category of towboats. Specialized towboats may also be used for
maneuvering ships in harbors, channel dredging, and construction activities.
Towboats vary widely in size and configuration, ranging from small harbor tugs less
than 30 feet in length to large ocean-going tugs over 100 feet.

       Data from WorkBoat Magazine's annual construction survey are shown in
Table 1-24.22 Participating in this survey is voluntary, and only 56 of more than  500
companies that build commercial boats and ships responded. The voluntary nature of
the survey may result in some selection bias such that the respondents are not fully
representative of the nonrespondents. This effect may be relatively stable over time,
however, so that trends in the data may be indicative of trends in the industry as a
whole.

       Table 1-24 shows that the number of towboats (including  towboats,
pushboats, tugs, and AHTS) in production increased from 39 in 2003 to 57 in 2004,
and 73 in 2005. The Category 2 Vessel Census23 estimated that 3,164 of 4,337
towboats in existing databases had Cl engines. Thus, it is likely that the majority of
the newbuilt towboats are also powered by Cl engines. According to the Vessel
Census, the majority of these  towboats operate in the Gulf Inland and Inland areas.

       Table 1-24 U.S. Commercial Boat Orders, 1993,1994,1997 and 2003,2004,2005

Vessel Type
Number of survey respondents
Casino/gaming
Passenger (dive, dinner,
excursion, ferries, sightseeing,
water taxi, charter)
Crew, crew/supply pilot,
personnel launch
Supply/service
Liftboat, utility
Pushboat, towboat, tug
Fire, rescue
Boom, spill response
Small craft (assorted), tender
Patrol (military, nonmilitary)
Other military
Others
Number of Boats Produced
1993
85
34
102
27a

26b
28

60
44d
99'

26
1994
83
27
95
41
5

60
5
33
124e
89

33
1997
84
6
68
44
81
34
88C
7
38
38
48
79
38
2003
40

44
17
37
5
39
2
4
17
74
27
110s
2004
46

31
31
25
7
57
12
10
7
69
6
149
2005
56

40
18
29
8
73
2
6
14
92
24
155
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Draft Regulatory Impact Analysis

Total number of boats
Number of Boats Produced
446 | 512h | 569
376
| 405 460
a      Supply boats were consolidated with crew/supply boats and pilot boats.
b      General workboats were consolidated with utility boats in the 1993 survey.
c      AHTSs were consolidated with pushboats, towboats, and tugs.
d      Research and survey boats were consolidated with tenders in the. 1993 survey and in the table
for 2004 and 2005.
e      Research, survey, and utility boats were consolidated with the assorted small craft and tenders
in the 1994 survey.
f      Fireboats were consolidated with the patrol boats in the 1993 survey.
g      The total number of "other" boats in included nonself-propelled vessels (2003-42 vessels,
2004-92 vessels, 2005-80 vessels).
h      The total number of boats in 1994 did not include the 111 RIBS, skiffs, or small utility, or the
26 support, minehunter, or landing craft reported.

         1.1.3.4.1.1  Supply of Tugs and Towboats

       The majority of towboats are manufactured individually according to  buyer
specifications.  Some of the smallest ones may be serially produced. Towboats are
strongly built and have relatively large engines for their dimensions. All but  the very
smallest tugs and towboats are made of steel.

       Shipyards and boatyards building commercial ships including towboats use a
variety of manufacturing processes, including assembly, metal finishing operations,
welding, abrasive blasting, painting, and the use of engines for crane operation and
boilers. The typical ship construction process begins with steel plate material. The
steel is formed into shapes, abrasively cleaned (blasted), and then coated with a
preconstruction primer for corrosion protection.  This is typically done indoors at the
bigger shipyards and most facilities have automated these steps.  Using the preformed
steel plates, small subassemblies are then constructed and again a primer coat is
applied.  Larger subassemblies are similarly put together and primed to protect the
steel substrate material. At some point in the construction, components are moved
outdoors to work areas adjacent to the drydock.  Final assembly and engine
installation are done at the drydock.

       Based on statistics for the shipbuilding NAICS code, NAICS 336611,
materials account for  more than 50 percent of the cost of production, and labor for
approximately 40 percent.  Energy costs, investment in capital equipment, rental
payments,  and business services all account for smaller shares of total value of
shipments.

         1.1.3.4.1.2  Demand for Tugs and Towboats

       Towboats are  purchased by towing companies that move cargo on barges on
coastal routes or on the nation's rivers. According to the American Waterways
Operators, the tugboat, towboat, and barge industry include more than 4000 operating
tugs/towboats and more than 27,000 barges. These vessels move more than 800
million tons of raw materials and finished goods each year, including more than 20
percent of the nation's coal, more than 60 percent of the nation's grain exports, and
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                                          Chapter 1: Industry Characterization
most of New England's home heating oil and gasoline.24 In addition to commodity
transportation, tugs are needed within harbors to maneuver ships to and from their
berths, and to assist with bunkering and lightering. The demand for towboats is thus
derived from the demand for commodity transportation services, which in turn is
derived from the demand for the commodities being transported.

1.1.3.4.2 Commercial Fishing Vessels

       Commercial fishing vessels are self-propelled vessels dedicated to procuring
fish for market. Commercial fishing boats may be distinguished by whether they tow
nets or are engaged in "hook and line" fishing, or are multipurpose vessels that
support a variety of fishing activities. Fishing vessels vary widely in size and
configuration. Smaller fishing vessels may be serially produced using fiberglass,
similar to recreational boats. Larger fishing vessels are generally built individually to
buyer's specifications.  The largest fishing vessels also serve as factory ships with the
capacity to sort, clean, gut, and freeze large quantities of fish.

       The Vessel Census, based on the Coast Guard's Merchant Vessels of the U. S.
(MVUS) database, estimates that there are more than 30,000 commercial fishing
vessels operating in the U.S., with the largest number being in Alaska, followed by
Washington and Texas.  Other states with large numbers of commercial fishing
vessels include California, Florida, Louisiana, and Maine.  Of the roughly 30,000
commercial fishing vessels identified, 8,130 are listed as definitely Cl and another
21,300 are characterized by the report's authors as probably Cl. If accurate, this
means that all but 700 or so commercial fishing vessels are powered by Cl engines,
and that the remaining 700 are powered by C2 engines. The C2 vessel census 5
suggests that the actual number of C2 powered fishing vessels may be less than half
this number. Less than 1 percent of commercial fishing vessels were identified as
gasoline-powered.

       Given that the vast majority of commercial fishing vessels are powered by Cl
engines, it seems reasonable to assume that the majority of these vessels are also
similar to recreational vessels in construction. Small commercial fishing vessels must
be able to travel rapidly to and from fishing grounds given that their operations have
them going to fishing grounds and returning to port each day. Thus, many of these
vessels have fiberglass hulls and are designed for planning operation, much like
recreational vessels.

         1.1.3.4.2.1  Supply of Commercial Fishing Vessels

       Smaller commercial fishing vessels are generally produced using fiberglass
with a production method similar to that used for recreational boats. Mid-size fishing
boats may be made of fiberglass, aluminum, or steel, and are likely produced
individually to buyers' specifications. The largest fishing boats, factory ships, are
produced individually at shipyards and a few exceed the 400 foot length that is
covered by this profile. Serial and individual production methods are described
above.
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Draft Regulatory Impact Analysis
         1.1.3.4.2.2  Demand for Commercial Fishing Vessels

       Commercial fishing boats are inputs into the production of fish for sale to
consumers, restaurants, retailers, and processors.  Reduced catch in many of the
nations' fisheries has resulted in lower returns for fishermen, and thus in a declining
number of commercial fisherman and declining demand for commercial fishing
vessels. This decline is projected to continue.   To the extent that governmental
efforts to replenish stocks and increase catch are successful, some increase in the
number of commercial fishermen and fishing boats may occur in the future.

1.1.3.4.3 Patrol Vessels

       Patrol boats such as Coast Guard vessels (government, Department of
Homeland Security), include small boats used by harbor police and other patrols and
larger vessels such as cutters. Small boats used by the Coast Guard include
approximately 1,400 boats ranging from 12 to 64 feet, which operate close to shore.
Coast Guard cutters are at least 65 feet in length, and range up to more than 400 feet
in length. The Vessel Census identified 158 of 235 cutters that were powered by C2
engines. The smaller boats operated by the Coast Guard were determined to be
powered by Cl engines. Fast pursuit boats may be powered by gasoline engines.
The majority of patrol boats not operated by the Coast Guard are relatively small and
thus most likely powered by Cl engines, or SI outboards for the smallest patrol boats.

         1.1.3.4.3.1  Supply of Patrol Boats

       Patrol boats are  generally manufactured from aluminum (two major
manufacturers of patrol boats, Seaark Marine and SAFE Boats, Inc., both
manufacture aluminum boats in large numbers). Other aluminum boatbuilders with
government work, including military as well as state and local agencies, include
Kvichak Marine, Northwind Marine, Rozema, All American Marine, ACB, Almar,
Munson and Workskiff. While their designs can be customized, these aluminum
boats are largely serially produced. Significant inputs include aluminum, engines,
and labor. Some small  patrol boats are inflatable, with reinforced rigid hulls made of
steel. Larger patrol boats such as Coast Guard cutters  are made of steel.

         1.1.3.4.3.2  Demand for Patrol Boats

       Government agencies, including the Coast Guard, the Military, the Army
Corps of Engineers, as well as harbor police and municipalities are the major
demanders  of patrol boats. The need to increase vigilance along our coasts and in our
harbors since the September 11 attacks has led to a tremendous increase in demand
for Coast Guard patrol boats, which is likely to continue to be strong for several more
years as the fleet is built up.27 The Workboat Construction Survey shows that
contracts have risen from 48 in  1997 to 92 in 2005.
                                     1-36

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                                          Chapter 1: Industry Characterization
1.1.3.4.4 Passenger Vessels

       Passenger vessels powered by Cl or C2 diesel engines include ferries,
excursion boats, and water taxis.  Ferries are self-propelled vessels that carry
passengers from one location to another, either with or without their automobiles.
Ferries may be owned by states or private companies, and generally operate over set
routes according to regular schedules. Water taxis are generally smaller than ferries
and operate on a for-hire basis. The Vessel Census studied ferries, and identified 106
that were powered by C2 engines and 508 powered by Cl engines.  Water taxis are
generally powered by SI engines, although some may be powered by Cl inboard
engines. Excursion boats are generally powered by Cl engines, although some of the
larger ones that approach small cruise ships in  size, are powered by C2 engines.

        1.1.3.4.4.1  Supply of Passenger Vessels

       Passenger vessels may be made of aluminum or steel.  For example, Derektor
Shipyards had orders to deliver three aluminum ferries ranging from a 92 foot high
speed catamaran ferry to a passenger/vehicle ferry that was 239 feet long.  Two other
companies had orders for large steel ferries, including two 310-foot Staten Island
Ferries. Larger ferries and other passenger vessels are likely powered by C2 engines,
while smaller ones  are likely Cl or even SI outboard or sterndrive for the smallest
and lightest ones.

        1.1.3.4.4.2  Demand for Passenger Vessels

       Ferries and water taxis are needed for transportation services, and are
generally used in urban areas.  Other types of passenger vessels, including excursion
boats, dinner boats, and floating casinos, are needed for recreational purposes.  Some
of these, such as whale watching boats, are very small; others such as floating casinos
and some excursion boats may be more than 100 feet in length.  Workboat's 2005
Construction Survey showed orders for 19 dinner, excursion, or sightseeing boats and
also for 19 ferries or water taxis.  Both types of passenger boats are likely to respond
to cyclical patterns in the economy, as both commuting and recreation increase when
the economy is strong.

1.1.3.4.5 Research Vessels

       Research vessels include vessels equipped with scientific monitoring
equipment used to track wildlife, map geological formations, monitor coastal water
quality, measure meteorological conditions, and conduct other scientific
investigations. They vary widely in size and complexity and may be made of
aluminum, fiberglass, or steel.  They may be powered by SI outboard engines,  Cl, or
C2 inboard engines, depending on their size. While they may be built on a standard
hull design, the  fittings are highly individualized based on their task, and may be
technically complex. Of 12 research vessels reported in the Workboat 2005
Construction Survey, most are made  of aluminum and are less than 80 feet in length.
Two are made of steel and are about  150 to 200 feet in length.  Of the purchasers
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Draft Regulatory Impact Analysis
listed, three of the vessels were ordered by the National Oceanic and Atmospheric
Administration (NOAA) and one by a university.  The instruments and other
scientific equipment are a special and potentially expensive cost element for these
vessels. Demand for the vessels is a function of demand for the research products
that they support.

1.1.3.4.6 Offshore Support Vessels

       Offshore support vessels include a variety of vessels used to construct,
operate, maintain, and service offshore oil platforms. Of the categories listed in Table
1-24, crew, crew/supply, personnel, supply/service and liftboat/utility vessels are all
vessel types that support the offshore oil industry. This is a heterogeneous category,
including a wide range of sizes, materials, and configurations.  Platform supply boats
and crew/supply boats tend to be over 150 feet in length and may be made of steel or
aluminum.  Lift boats tend to be about  150 feet in length and made of steel. OSVs
listed in Workboat's 2005 Construction Survey range from 145 feet to 280 feet and
are made of steel. At the other end of the spectrum are smaller aluminum  crew and
utility boats. Most offshore oil activity in the U.S. is in the Gulf of Mexico; thus,
most offshore support vessels operate there.

       Demand for offshore support vessels depends largely on the status  of the
offshore oil industry. Changes in that industry over the past 15 years have resulted in
reduced numbers of rigs, but some much farther from shore. Thus, while fewer
support vessels may be needed, they may be required to be larger and more
seaworthy.  The Gulf Coast hurricanes  of 2005 had a substantial impact on the
offshore oil industry and offshore support vessels. Many platforms and offshore
support vessels suffered damage due to the storms. Demand for offshore support
vessels increased drastically, and day rates more than doubled.  This will likely result
in an increase in construction of offshore support vessels in the next few years,
relative to recent years.

       Table 1-25 gives a summary of the types of boats currently under contract to
be built at U.S. boatyards based on information taken from the  Marine Log website
and Workboat's 2005 Construction Survey, using the commercial boat categories
described above.28

     Table 1-25 Boats Under Construction by Type and Client, December 2005 Contracts
Type of Boat
Tow/Tug
Fishing
Coast Guard
Ferry
Cargo
Research
Offshore Support
Great Lake/Others
Commercial Clients
31
0
0
19
75
1
31
3
Government Clients
7
1
92
2
0
2
0
1
Total
38
1
92
21
75
3
31
4
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                                          Chapter 1: Industry Characterization
Military
Total
0
140
64
169
64
329
1.1.3.5 Industry Organization

       This section examines the organization of the boat building industry,
including characterizing firms in the industry, and examining market structure.

1.1.3.5.1 Location and Number of Vessel Manufacturers

       There are several hundred yards that build many different types of boats
powered with small (<37 kW), Cl and C2 engines.  Boatbuilders are located along all
coasts and major inland waterways of the United States. Figure 1-6 shows the
geographic distribution of boatbuilders in the United States.  A majority of these
boatbuilders are located in the Gulf Coast, the Northeast, and the West Coast. The
number of boatbuilders in these three regions account for approximately 30 percent,
25 percent, and 26 percent of the boatbuilding industry, respectively. A majority of
boatbuilders are located in the Gulf Coast (128), the Northeast (107), and the West
Coast (110).  Collectively, these three regions represent 345 boatbuilders, or 80
percent of all companies in the 1998 Boatbuilder Database.

               Figure 1-6 Major Boatbuilding Regions of the United States
                                                      3%
                                                                 NorttMMl JS*
                                          1    Mississippi R|v*r 3% I
                  DthtrE'i
                               Gulf Ccasi 30%
                                                              Soutti AllarUk, 10%
1.1.3.5.2 Firm Characteristics

       Table 1-26 summarizes company financial data for companies that produce
commercial vessels powered by Cl and C2 engines.29'30'31 The available data capture
total company employment and sales figures including any subsidiaries and
operations, such as boat repair, that may not be related to boatbuilding; similarly,
because many companies may produce boats powered by both SI and Cl engines, or
                                      1-39

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Draft Regulatory Impact Analysis
may produce larger vessels powered by C3 engines, not all of the boatbuilding
employment and revenues are related to vessels powered by Cl and C2 engines.

  Table 1-26 Employment Distribution of Companies that Build Commercial and Government
                                    Boats
Employment Range
100 or fewer
101-250
251-500
501-1,000
1,001 or more
Total number of firms
Number of Firms
29
12
5
3
13
62
Revenue Range ($Millions)
0.15-7.0
12.0-50.0
11.0-30.9
42.0-73.0
82.0-29.9

       Almost all companies that produce commercial or governmental vessels
powered by Cl or C2 engines would be classified under NAICS 336611. Of an
estimated 589 firms in that NAICS code, company names, employment, and sales
data were obtained for only 62. Using the Small Business Administration's small
business criterion for NAICS 336611 (1,000 employees), 49 of the 62 (79 percent) of
the companies for which data were obtained would qualify as small entities.

1.1.3.5.3 Markets and Trends in Commercial Vessel Manufacturing

       Markets for commercial and governmental vessels can be modeled as
competitive. While products are differentiated rather than homogeneous, there are
many yards that produce similar types of vessels, and compete for both commercial
and governmental contracts.  Barriers to entry and exit are relatively low, at least
domestically. For commercial cargo vessels working between U.S. ports, foreign
competition is limited by the Jones Act. Similarly, passenger vessels plying
exclusively domestic routes  are constrained by the U.S. Passenger Services Act.
Nevertheless, because the technology and materials for boat building are widely
available, costs of entry into the market are fully recoverable, and barriers to entry
and exit are thus low, domestic commercial boat manufacturers face markets that are
contestable and therefore behave as if the markets were competitive.

       The U.S. boatbuilding industry is currently influenced by several key factors.
These factors suggest a continued increase in the number of commercial boats built in
the United States:

    •   Increasing demand for the T-class vessels. (The U.S. Coast Guard defines T-
       class boats as boats not designed to see the open  ocean, such as cruise boats,
       dinner and gambling boats, crew boats in the  Gulf of Mexico, and off-shore
       vessels)
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                                           Chapter 1: Industry Characterization
    •   Increasing demand for offshore supply vessels to repair and service offshore
       oil rigs, including repairing or replacing rigs and OSVs damaged or destroyed
       by Gulf Coast hurricanes in 2005

    •   Increasing demand for oil (e.g., drillships and semisubmersible rigs)

    •   Expansion in casino boats

    •   Decisions by leading boatbuilders to reopen facilities and expand their labor
       forces are strong indications that they  anticipate continued growth in the
       market for commercial and governmental vessels. An increase in demand for
       new boats will mean more business for the commercial U.S. boatbuilding
       industry, as foreign builders are ineligible to build for segments of this market.
       Some of the larger boatbuilders in the  United States also build boats for
       foreign owners/operators, particularly for foreign militaries. As noted in the
       table summarizing current shipyard/boatyard contracts, there are at least three
       yards doing work with foreign governments (e.g., Egypt and Oman)

       In summary, U.S. boatbuilders are  cautiously optimistic about the future
because almost every segment of the U.S.  flag fleet is  facing significant replacement
requirements.  The commercial boatbuilders are expected to continue to be a major
consumer of marine diesel engines.

1.2 Locomotive

       The regulations for locomotives and locomotive engines are expected to
directly impact three industries.  These industries are:  (1) locomotive and locomotive
engine original equipment manufacturers (OEMs);  (2) owners and operators of
locomotives (railroads); and (3) remanufacturers of locomotives and locomotive
engines including OEMs, railroads,  and independent remanufacturers. Locomotive
manufacturers are companies that make or import complete "freshly" manufactured
locomotives6.

       Remanufacturers are companies that certify kits for remanufactured
locomotives.0 A brief overview of these industries follows, along with descriptions
of the national economic impact of railroads and current regulations in effect for
railroads.
B Freshly manufactured locomotives are those which are powered by freshly manufactured engines,
and contain fewer than 25 percent previously used parts (weighted by the dollar value of the parts).
c Remanufactured locomotives are locomotives in which all of the power assemblies are replaced with
freshly manufactured (containing no previously used parts) or refurbished power assemblies.
Remanufacturing includes the following: replacing an engine, upgrading an engine, and converting an
engine to enable it to operate using a fuel other than it was originally manufactured to use.
                                      1-41

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Draft Regulatory Impact Analysis
1.2.1 Current Emission Regulations

       The Agency's 1998 Locomotive Rule (63 FR 18978; April 16, 1998) created a
comprehensive program that both the large Class I and small Class II and III railroads
were subject to, including emission standards, test procedures and a full compliance
program. The unique feature of this program was the regulation of the engine
remanufacturing process, including the remanufacture of locomotives originally
manufactured prior to the effective date of that rulemaking.  Regulation of the
remanufacturing process was critical because locomotives are generally
remanufactured four to eight times during their total service lives of approximately
40+ years.  Electric locomotives, historic steam-powered locomotives, and
locomotives freshly manufactured prior to 1973 were not covered by the 1998
regulations.

       Several requirements are currently applicable to Class I railroads.  First,
railroads purchasing a new locomotive must insure it meets the current standards and
has a valid certificate of conformity. Second, with regard to in-use testing, railroads
must reasonably supply locomotives to the locomotive engine manufacturers for
purposes of testing them under the manufacturer in-use testing program. In cases
where the railroads fail to meet this requirement EPA could, under section 114 of the
Act, require the railroads to perform the testing itself. Third, the railroads must also
comply with the in-use  testing requirements  of the post-useful life railroad in-use
testing program. Fourth, failure of a railroad to perform all proper maintenance on
certified locomotives, so they continue to meet the applicable emissions standards,
are subject to civil penalties for tampering. Railroads must also keep records of this
maintenance. Finally, when remanufacturing all 1973 and later locomotives,
railroads must remanufacture to new standards.  (Note: small railroads are generally
exempt from these provisions.)

       Small railroads have three requirements under the existing emission
regulations.  First, small railroads are subject to the prohibition against
remanufacturing their locomotives without a valid certificate of conformity.
However, the regulations exempted their existing noncompliant locomotives as well
as any noncompliant locomotives that they purchase from other railroads in the
future. The prohibition only applies to previously certified locomotives. For
example, if a Class I railroad had a 1990 locomotive that was remanufactured in 2005
to meet the Tier 0 standards, any small railroad that purchased that locomotive would
need to comply with the Tier 0 requirements for all subsequent remanufacturing.
Second, small railroads must properly maintain (with respect to emissions) all
certified locomotives, and they must keep records of this maintenance. Finally, if any
small railroad purchased a totally new locomotive, they would need to ensure that it
meets the current standards and has a valid certificate of conformity.

       Three separate sets of emission standards (Tiers) have been adopted, with
applicability of the standards dependent on the date a locomotive is manufactured.
The first set of standards (Tier 0) applies to locomotives and locomotive engines
originally manufactured from 1973 through 2001. The second set of standards (Tier
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                                         Chapter 1: Industry Characterization
1) applies to locomotives and locomotive engines originally manufactured from 2002
to 2004, and the final set of standards (Tier 2) applies to locomotives and locomotive
engines originally manufactured in 2005 or later.  All of these standards must be met
when a locomotive is "freshly manufactured" and at each subsequent remanufacture.
The emission standards set in 1998 for Class I and large Class II and II line-haul and
switch duty-cycles are  shown in Table 1-27.

          Table 1-27 Maximum Permissible NOX, CO, HC, and PM Rates by Tier

(g/bhp/hr)
NOX
CO
HC
PM
Tier 0 Line-
Haul Duty-
Cycle
9.5
5.0
1.00
0.60
TierO
Switch
Duty-
Cycle
14.0
8.0
2.10
0.72
Tier 1 Line-
Haul Duty-
Cycle
7.4
2.2
0.55
0.45
Tierl
Switch
Duty-
Cycle
11.0
2.5
1.20
0.54
Tier 2 Line-
Haul Duty-
Cycle
5.5
1.5
0.30
0.20
Tier 2
Switch
Duty-
Cycle
8.1
2.4
0.60
0.24
1.2.1.1 Certification

       Locomotive manufacturers must produce compliant locomotives, and they
must be certified.  In order for a locomotive to be certified, a company must certify
the engine together with the locomotive.  An engine manufacturer can certify, but it
must certify the complete locomotive.  Currently, engine manufacturers have only
certified locomotives they manufactured themselves. Class I and all Class II and III
railroads must purchase all new locomotives with a valid certificate of conformity,
and when remanufacturing a locomotive must have a valid certificate of conformity.
Small Class II and III railroads are, however,  provided an exemption for their existing
noncompliant locomotives as well as any noncompliant locomotives that they
purchase from other railroads in the future.

1.2.2  Supply: Locomotive Manufacturing and Remanufacturing

1.2.2.1 Locomotive Manufacturing

1.2.2.1.1 Types  of Locomotives

       Locomotives generally fall into three broad categories based on their intended
use: switcher, passenger, and line-haul locomotives. Switch locomotives, typically
2000 hp or less, are the least powerful locomotives, and are used in freight yards to
assemble and disassemble trains, or for short hauls of small trains.  Some larger road
switchers can be rated as high as 2300 hp.  Passenger locomotives are powered by
engines of approximately 3000 hp, with high-speed electric passenger locomotives
powered by BOOOhp or more.  Freight or line-haul locomotives are the most powerful
locomotives and are used to power freight train operations over long distances. Older
line-haul locomotives are typically powered by engines of approximately 2000-3000
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Draft Regulatory Impact Analysis
hp, while newer line-haul locomotives are powered by engines of approximately
3500-5000 hp.  In some cases, older line-haul locomotives (especially lower powered
ones) are used in switch applications. The industry has been producing higher
powered locomotives, with some new models having 4400hp.  The development of
line-haul locomotives with even higher horsepower ratings, such as 6000 hp or more
continues, but it is not clear if this will be the future of locomotive engines.

1.2.2.1.2 Type of Propulsion Systems

       Locomotives can be subdivided into three general groups on the basis of the
source of energy powering the locomotive: 1) "all-electric" 2) "engine-powered" 3)
"hybrid".  In the "all-electric" group, externally generated electrical energy is
supplied to the locomotive by means of an overhead contact system, these types of
locomotives have existed for over 125 years.  An example of this type of locomotive
is commonly seen on commuter trains. Power to operate the locomotive is not
generated by an onboard engine. Emission control requirements for all-electric
locomotives would be achieved at the point of electrical power generation, and thus
are not included in this rulemaking.

       In the "engine-powered" group of locomotives, fuel (usually diesel in the
U.S., although natural gas options are still being pursued) is carried on the
locomotive. The energy contained in the  fuel is converted to power by burning the
fuel in the locomotive engine. A small portion of the engine output power is
normally used directly to  drive an air compressor to provide brakes for the
locomotive and train.  However, the vast majority of the output power from the
engine is converted to electrical energy in an alternator or generator which is directly
connected to the engine. This electrical energy is transmitted to electric motors
(traction motors) connected directly to the drive wheels of the locomotive for
propulsion, as well as to motors which drive the cooling fans, pumps, etc., necessary
for operation of the engine and the locomotive.0 In the case of passenger
locomotives, electrical energy is also supplied to the train's coaches for heating, air
conditioning, lighting, etc. (i.e., "hotel power").  In some passenger trains, electrical
energy required for the operation of the passenger coaches is supplied by an auxiliary
engine mounted either on the locomotive or under the floor of passenger cars.

       The third category "hybrid"  is a combination of the "electric" and "engine-
powered"  groups, and was first developed and used in the 1920's, although at the
time it wasn't very successful.  Today's technology is considered "battery dominant"
and uses a small diesel engine and generator to charge a battery pack; the battery pack
will then supply energy on demand to the traction motors.32  The engine can be 250-
640hp (200-480kW) and will typically operate at a constant speed, which is
optimized for efficiency and will only run to keep the batteries at a certain charge
D Essentially all "engine powered" locomotives used in the U.S. employ a diesel engine and the
electrical drive system described. The term "diesel-electric" has therefore become the most common
terminology for these locomotives.
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                                          Chapter 1: Industry Characterization
level.33  This technology is currently only available for switcher locomotives,
although it is being developed for use in line-hauls.

1.2.2.1.3 Locomotive Design Features and Operation

         1.2.2.1.3.1  Sizing Constraints

       Similar to the variation in horsepower, locomotive size determines the work it
will perform. Switch locomotives tend to be about 40 to 55 feet long, while line-haul
locomotives are typically 60 to 76  feet long. Locomotive length is roughly correlated
with engine size, and thus the difference in length has become more significant as
locomotive engines have become larger and more powerful. Locomotive length is
also related to the number of axles that a locomotive has. In the past, the typical
locomotive had four axles (two trucks with two axles each). While there still are a
large number of four-axle locomotives in service, all newly manufactured line-haul
locomotives have six axles (two trucks with three axles each). There are two primary
advantages of having more axles on the locomotive. First,  additional axles allow
locomotives to be heavier, without increasing the load on each individual axle (and
thus the load on the rail).  Second,  six-axle locomotives typically have greater tractive
power at low speeds, which can be critical when  climbing steep grades.  The use of
six-axles on a locomotive does increase its overall length, and continues to lead to the
discontinuation of the practice of converting old line-haul locomotives into switch
locomotives, since these larger six-axle locomotives are typically too long to be
practical in most switch applications.

         1.2.2.1.3.2  Operation

       One unique feature of locomotives that makes them different than other,
currently regulated mobile sources is the way that power is transferred from the
engine to the wheels. Most mobile sources utilize mechanical means (i.e., a
transmission) to transfer energy from the engine to the wheels (or other point where
the power is applied).  Because there is a mechanical connection between the road,
vehicle engine and the wheels, the relationship between engine rotational speed and
vehicle speed is mechanically dictated by the gear ratios in the transmission and final
drive (e.g., the differential and rear axle).  This results in engine operation which is
very transient in nature, with respect to changes in both speed and load.  In contrast,
locomotive engines are typically connected to an electrical alternator or generator to
convert the mechanical energy to electricity.  As  noted above, this electricity is then
used to power traction motors which turn the wheels. The effect of this arrangement
is that a locomotive engine can be  operated at a desired power output and
corresponding  engine speed without being constrained by vehicle speed.  The range
of possible combinations of locomotive speed and engine power vary from a
locomotive speed approaching zero with the engine at rated power and speed, to the
locomotive at maximum speed and the engine at  idle speed producing no propulsion
power. This lack of a direct, mechanical  connection between the engine and the
wheels allows the engine to operate in an essentially steady-state mode, in a number
of discrete power settings, or notches, which are described below.


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Draft Regulatory Impact Analysis
       Dynamic braking is another unique feature of locomotives setting them apart
from other mobile sources. Dynamic braking is especially important given the
traction problems that locomotives must overcome. Locomotives generate an
enormous amount of power that can be applied to the wheels when they start to roll,
however, the use of steel wheels (which provide less rolling resistance) also make it
difficult to start moving a locomotive. The ridges on the sides of the wheels provide
traction during cornering to keep the wheels on the rails, and some locomotives are
equipped with an oil system that puts oil on the sides of the rails to reduce friction on
the sides of the wheels during turns and cornering. On straight sections of rail, some
locomotives have a built-in system that will put sand on the rails  and in order to
increase traction.

       In dynamic braking the traction motors act as generators, with the generated
power being dissipated as heat through an electric resistance grid, this  feature
decreases overall braking distance and wear on the wheels.  While the  engine is not
generating motive power (i.e., power to propel the locomotive, also known as tractive
power) in the  dynamic brake mode, it is generating power to operate resistance grid
cooling fans, and is essentially dissipated into the air as heat.  As such, the engine is
operating in a power mode that is different than the power notches or idle settings
discussed above. While most diesel-electric locomotives have a dynamic braking
mode, some do not (generally switch locomotives). The potential energy that could
be recovered during dynamic braking and utilized by the locomotive is one area
researchers are focusing on to increase locomotive efficiency.  GE has noted that "the
energy dissipated in braking a 207-ton locomotive during the course of one year is
enough to power 160 households for that year"34. It is, however, very difficult to
capture and store this energy,  the power generated from dynamic breaking is
instantaneous and high enough that it cannot be effectively used by the locomotive at
the time it is generated. If the energy could be stored in batteries, or a mechanical
device  such as a flywheel, tremendous fuel savings could be gained, and therefore
development of these types of systems continues

       Hotel power or "Head End Power" (HEP) is power used to operate lighting,
heating, ventilation and air conditioning, and all other electrical needs  of the crew and
passengers alike. This power can be provided by the  lead locomotive, or by an
additional engine, which is then distributed to the rest of the cars as needed. The
design  of locomotives for use in passenger train service (without additional engines
used to provide  HEP) provides for a locomotive to be operated in either of two
distinct modes.  In one mode, the locomotive engine  provides only propulsion power
for the  train. In this mode, the engine speed changes with changes in power output,
resulting in operation similar to freight locomotives.  In the second mode, the
locomotive engine supplies HEP to the passenger cars, in addition to providing
propulsion power for the train.  Hotel power provided to the passenger cars can
amount to as much as 800 kW (1070 hp). In contrast to operation in the non-hotel
power mode, the engine speed remains constant with changes occurring in power
output when operating in hotel power mode.  Thus, the two modes of operation utilize
different speed and load points to generate similar propulsion power. These
differences in speed and load points mean that locomotive engines will have different
                                     1-46

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                                          Chapter 1: Industry Characterization
emissions characteristics when operating in hotel power mode than when operating in
non-hotel power mode.

         1.2.2.1.3.3  Design Characteristics

       In 1909 Rudolph Diesel helped construct the first diesel locomotive, and in
1918 the first diesel-electric switch locomotives were put into service.  By the 1950's
diesel-electric had replaced steam powered locomotives because they required less
fuel, maintenance, and man-power.36  Locomotives use diesel engines because they
are much more efficient, reliable, and can generate tremendous power. The diesel
engine is the most efficient transportation power plant available today. Thermal
efficiency of locomotive diesel engines is 40% or higher, which results from high
power density (via high turbocharger boost), high turbocharger efficiencies, direct
fuel injection with electronic timing control, high compression ratio, and low thermal
and mechanical losses.  Many locomotive engines achieve the equivalent of one
million miles before overhaul.35  Durability is critical as a locomotive breakdown on
the tracks can bottleneck the  entire system; road failures are very costly to the
railroads because the importance of timeliness to their customers, and the difficulty in
getting replacement locomotives to the location of the failure. The trend toward
higher power locomotives is  naturally resulting in a trend of fewer locomotives per
train, thereby increasing the likelihood that a train would become immobilized by the
failure of a single locomotive.

       Another unique design feature of locomotives is the  design of the engine
cooling system and procedures used to control engine coolant temperature. Normal
practice in locomotive design has been to mount the radiator on the roof of the
locomotive and not to use a thermostat. Control of coolant temperature is achieved
by controlling the heat rejection  rate at the radiator.  The rate of heat rejection at the
radiator can be controlled by means such as turning fans on  and off or employing a
variable speed fan drive, or by controlling the amount of coolant flow to the radiator
(using non-thermostat controls).  A related point of difference between road vehicle
and locomotive engine cooling systems is that antifreeze is not generally used in
locomotives.  Locomotives use water, not antifreeze to cool their engines because
water is much more efficient at removing heat.  Using antifreeze would require a
cooling system approximately 20% larger than the current design (which holds
approximately 450 gallons of water).37 The size of a locomotive is limited by the
existing track and tunnel infrastructure which restricts the height, width and length of
a locomotive.  Locomotives usually run in consists (groups) which means that the one
following the lead locomotive will not have the same effective cooling as the one in
front since the air it encounters will be warmer.  The practice of following creates
additional cooling problems especially in tunnels which call for special design
considerations.

       The final unique design feature noted here is the manner in which new designs
and design changes are developed. The initial design of any new
models/modifications and production of prototype models are done in much the same
manner as is the case with other  mobile sources.  Locomotive manufacturers

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Draft Regulatory Impact Analysis
indicated that this process can be expected to require from 12 to 24 months for
significant changes such as those required to comply with the new Tier 0 standards.
Prototype locomotives are typically sold or leased to the railroads for extended field
reliability testing, normally of one to two years duration.  Only after this testing is
completed can the new design/design change be certified and placed into normal
production.

1.2.2.2 Line-Haul Manufacturing

1.2.2.2.1 Manufacturers

       Locomotives used in the United States are primarily produced by two
manufacturers: Electromotive Diesel (EMD) and General Electric Transportations
Systems (GETS). EMD manufactures its locomotives primarily in London, Ontario
and their engines in La Grange, Illinois.  The GETS locomotive manufacturing
facilities are located in Erie, Pennsylvania, while their engine manufacturing facilities
are located in Grove City, Pennsylvania. These manufacturers produce both the
locomotive chassis and propulsion  engines;  they also remanufacture engines.
MotivePower Industries has produced some mid-horsepower locomotives suited for
commuter or long-distance service  using engines manufactured by Caterpillar, Inc,.
MotivePower's Wabtec division also manufactures a switcher locomotive that runs on
liquefied natural gas.  The Cummins Engine Company, Inc. produces V12 and V16
diesel engines for use in locomotives.  The EPA has identified four locomotive diesel
manufacturers, one of which can be considered a small business according to SBA
guidelines.  There are also a few companies such as Steward and Stevenson or
Brookville Mining Equipment that  manufacture small switch locomotives (under 700
bhp) for use in mines or for companies who need to move a few cars around a local
yard.

       EMD was founded in 1922  and acquired by General Motors in 1930; EMD
was sold in 2005 by General Motors to the Greenbriar Equity Group and Berkshire
Partners, and is now called Electro-Motive Diesel, Inc. While they primarily
manufacture a 2-stroke diesel locomotive engine, they started manufacturing a 4-
stroke engine in 1997. They currently produce five national models ranging from
3000-6000hp, and have other international models as well as custom built
locomotives.38 EMD employs approximately 2,600 people and designs,
manufactures, market, sells and services freight and passenger diesel-electric
locomotives worldwide. GE was formed by Thomas Edison who developed his first
experimental electrical locomotive  in 1880,  they also built and put into the service the
world's first diesel-electric switcher locomotive in 1924 that remained in service until
1957. GE currently produces at least five national models, two international models,
passenger locomotives and is developing a hybrid locomotive.39 GE's Transportation
division employs approximately 8,000 people and also  engineers, manufactures,
markets and services their diesel locomotive products worldwide.
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                                         Chapter 1: Industry Characterization
1.2.2.2.2 Production

       Due to the long total life span of locomotives and their engines, annual
replacement rates of existing locomotives with freshly-manufactured units are very
low. EPA estimated a replacement rate for locomotives and locomotive engines
based on historical data supplied by AAR, Table illustrates the historical replacement
rates for locomotives in the Class I railroad industry. Sales of new locomotives have
averaged approximately 780 units per year over the last ten years. This replacement
rate indicates a fleet turnover time of about 30 years for Class I railroads. Fleet
turnover is the time required for the locomotive fleet to be entirely composed of
locomotives that were  not in service as of the base year. Class II an  III railroads
generally buy used locomotives from Class I railroads, although some are purchasing
new switchers and a few line-hauls.

                 Table 1-28 Class I New Locomotive Turnover Rates40
Year
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
Number of New
Locomotives Installed
928
761
743
889
709
640
710
745
587
1,121
Number of Remanufactured
Locomotives Installed
201
60
68
172
156
81
45
33
34
5
Total Number of
Locomotives in Service
18,812
19,269
19,684
20,261
20,256
20,028
19,745
20,506
20,774
22,015
Percent
Turnover of New
4.9%
3.9%
3.8%
4.4%
3.5%
3.2%
3.6%
3.6%
2.8%
5.1%
1.2.2.2.3 Cost

       The cost of AC-traction locomotives can be as high as $2.2 million, while DC
locomotives are usually less than 1.5$ million.  Figure 1-7 shows data from the
AAR's Railroad Ten-Year Trends 1995-2004 publication. Some of the variation from
year to year can be attributed to differences in features, but it appears the overall trend
is the price of AC locomotives seems to be coming down, while DC locomotives
remain about the same.
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Draft Regulatory Impact Analysis
Figure 1-7 Cost of New Locomotives1
                     Cost of Diesel-Electric Locomotives
            2500000
            2000000 -
            1500000 -
            1000000
                   1995  1996 1997  1998 1999 2000 2001 2002 2003 2004
                                       Year
                         -de-traction
                                               -ac-traction
1.2.2.3 Switcher Manufacturing

1.2.2.3.1 Manufacturers

       The majority of switchers in operation today are former line-haul locomotives
that have been assigned to a yard, and they are usually quite old. This trend will most
likely wane over time because of the size and power of most new locomotives, which
make them unsuitable for switching operations. While EMD does offer a traditional
new switch locomotive, other companies are offering switchers with alternative
power plants that are usually built off of an old switcher platform.

       Motive Power, headquartered in Wilmerding, PA offers a switching
locomotive fueled by liquefied natural gas, which they will build on a core supplied
by a railroad. Motive Power is a large company with nearly 5,000 employees; they
service other industries such as marine, transit  and power generation.  National
Railway Equipment Co. (NREC) based in Houma, Louisiana with facilities also in
Illinois manufactures a "gen-set" switcher locomotive (powered by multiple smaller
diesel engines) that is completely built by them from the ground up. They employ
approximately 150 employees. RailPower Technologies, is headquartered in
Brossard, Quebec but also has an American office in Erie, Pennsylvania; they employ
approximately 100 people. RailPower manufactures the Green Goat® hybrid yard
switcher and is developing a natural gas switcher locomotive as well, and they also
use an old switcher locomotive core to build their platform on.

1.2.2.3.2 Production

       Multi gen-set switchers are a falling back into favor; they were originally used
in the late 1920's in some applications. The existing fleet of retired line-haul switcher
locomotives turns over very slowly, and production of alternative technology
switchers is beginning to increase.  NREC is working with UP and is building sixty
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                                          Chapter 1: Industry Characterization
2,100hp triple-engin GS21B gensets equipped with four-cycle, six-cylinder 700hp
Cummins QSK-19 engines, these switchers are purported to reduce NOX and PM by
80% as compared to reduce fuel consumption by up to 40%.  Railpower has also been
asked by UP to build 80 triple-engine switchers on the GreenGoat platform and they
have noted that their system can reduce fuel consumption by up to 35% and NOX and
PM emissions by 80%, Norfolk Southern has ordered two of these from RailPower in
the form  of rebuild kits where their own maintenance staff will install this triple-
engine system during a switcher rebuild.41 New switchers can cost upwards of $1.5
million dollars, the GreenGoat hybrid switcher can cost as little as $700,000 if a
customer supplies a completely reconditioned GP-9 locomotive.42 The price of these
and other switchers depends on whether or not a core is supplied and what features it
will be built with.

1.2.2.3.3 Trends

      Trends: remote control locomotives have been used in Canada and the U.S.
for many years; however, Class I railroads have recently begun to implement this on a
wider scale according to the FRA. Although this is mainly a switch yard  function,
this type  of operation may be applied on line-hauls as well in the future.  This may
affect cab design and what necessary equipment is built into future switchers, for
example  if it is a remote control unit it wouldn't need cab comfort equipment such as
heaters or air  conditioners. Many new switchers have been retrofitted with idle
reduction devices to decrease fuel consumption and increase the railroads efficiency.

1.2.2.4 Remanufactured Locomotives

      Since  most locomotive engines are designed to be remanufactured a number
of times,  they generally have extremely durable engine blocks and internal parts.
Parts or systems that experience inherently high wear rates (irrespective of design and
materials used) are designed to be easily replaced so as to limit the time that the unit
is out of service for repair or remanufacture. The prime example  of parts that are
designed to be readily replaceable on locomotive engines are the power assemblies(
i.e., the pistons, piston rings, cylinder liners, fuel injectors and controls, fuel injection
pump(s)  and controls, and valves). Within the power assemblies, parts such as the
cylinder head in general do not experience high wear rates, and may be reused after
being inspected and requalified (determined to be within manufacturers
specifications). The power assemblies can be remanufactured to bring them back to
as-new condition or they can be upgraded to incorporate the latest design
configuration for that engine.  In addition to the power assemblies there are numerous
other parts or systems that may also be replaced   Engine remanufactures may be
performed either by the railroad that owns the locomotive or by the original
E Bottom end components, such as crankshafts and bearings, are often remanufactured only during
every other remanufacture event.  Remanufacture events that do not include these bottom end
components are sometimes referred to as "partial remanufactures"

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Draft Regulatory Impact Analysis
manufacturer of the locomotive. Remanufactures are also performed by companies
that specialize in performing this work.

       During its forty-plus year total life span, a locomotive engine could be
remanufactured as many as ten times (although this would not be considered the
norm). Locomotive engine remanufacturing events are thus routine, and are usually
part of the scheduled maintenance. It is standard practice for the Class I railroads
within the railroad industry to remanufacture a line-haul locomotive engine  every
four to eight years. Typically newer locomotives, which have very high usage rates,
are remanufactured every four years. Older locomotives usually are remanufactured
less frequently because they are used less within each year. Such remanufacturing is
necessary to insure the continued proper functioning of the engine. Remanufacturing
is performed to correct losses in power or fuel economy, and to prevent catastrophic
failures, which may cause a railroad line to be blocked by an immobile train.

       When a locomotive engine is remanufactured, it receives replacement parts
which are either freshly-manufactured or remanufactured to as-new condition (in
terms of their operation and durability) .F  This includes the emission-related parts
which, if not part of the basic engine design, are also generally designed to be
periodically replaced.  The replacement parts are also often updated designs, which
are designed to either restore or improve the original performance of the engine in
terms of durability, fuel economy and emissions. Because of a locomotive engine's
long life, a significant overall improvement in the original design of the parts, and
therefore of the engine, is possible over the total life of the unit. Since these
improvements in design usually occur in the power assemblies (i.e., the components
where fuel is burned and where emissions originate), remanufacturing of the engine
essentially also makes the locomotive or locomotive engine a new system in terms of
emission performance. A remanufactured locomotive would therefore be like-new in
terms of emissions generation and control.

       While Class I locomotives are remanufactured on a relatively frequent and
scheduled basis of 4 to 8 years, Class II and III locomotives may be remanufactured
on a longer schedule or may not be remanufactured at all. The typical service life of a
locomotive (40 years) is often exceeded by small railroads that continue to use older
locomotives.  It is important to note that there is no inherent limit on how many times
a locomotive can be remanufactured, or how long it can last. Rather, the service life
of a locomotive or locomotive engine is limited by economics.  For example, in cases,
where it is economical to cut out damaged sections  of a frame, and weld in new
metal, an old locomotive may be salvaged instead of being scrapped.
Remanufacturers can also replace other major components such as the trucks or
traction motors, to allow an  older locomotive to stay in service. However, at some
point, most railroads decide that the improved efficiency of newer technologies
F In some cases, some components are remanufactured by welding in new metal and remachining the
component to the original specifications.
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                                         Chapter 1: Industry Characterization
justifies the additional cost, and thus scrap the entire locomotive.  Nevertheless, many
smaller railroads, especially switching and terminal railroads, are still using
locomotives that were originally manufactured in the 1940s.

1.2.2.4.1 Remanufacturers

       While the original manufacturers provide much of the remanufacturing
services to their customers, there are several smaller entities that also provide
remanufacturing services for locomotive engines.  These businesses can be rebuilders
licensed by the OEMs, in addition to the OEMs themselves. Moreover, some  of the
Class I and II railroads remanufacture locomotive engines for their own units and on a
contract basis for other railroads.  EPA has been able to identify nine independent
locomotive remanufacturers, four of which are small business entities. Many of these
businesses are full service operations that remanufacture locomotive assemblies (such
as trucks or air brake systems), sell new and used parts, repair wrecked locomotives
or provide routine maintenance. A few apparently remanufacture locomotives
primarily for resale or lease, while others remanufacture engines for operating
railroads or industrial customers. A few also offer contract maintenance; this may be
tied to a locomotive lease, or may be offered separately to owners of locomotives.
The size  of these companies vary tremendously as some have as few as two
employees, while others can have up to 5,000 employees. The cost of
remanufacturing kits can vary depending on the model of locomotive and year of
manufacture, an estimated range is $15,000 - $30,000 per kit.

1.2.3 Demand: Railroads

       Railroads transport freight more efficiently than other modes of surface
transportation because they require less energy and emit fewer pollutants.43 The 2006
Transportation Energy Data Book shows that rail transportation used approximately
7.4% of all diesel fuel used in transportation and 2.1% of the total energy used by all
forms of transportation to move 22.1% of all freight ton-miles  (miles one ton of
freight is moved). It also shows that this is less than 1% of the total U.S. energy use,
but that locomotives currently emit slightly less than one million tons of NOX each
year, which is about 4% of total NOX emitted by all sources. It is important to
recognize, however, that the 2.1% of energy used by rail transportation (625.5 trillion
BTUs) is the total of all rail sectors including: line-haul, switcher, Amtrak, commuter
rail, and transit rail,  as shown in Figure 1-9. This means that the freight railroads use
approximately 1.86% of all energy consumed by every source  of transportation to
haul 22.1% of all ton-miles.
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Draft Regulatory Impact Analysis
                            Figure 1-8 Rail Energy Use

                      Rail Energy Use
                       (Total is 605 trillion BTU)
                                         n Line-haul
                                         • Switcher

                                         QAmtrak
                                         n Commuter rail
                                         D Transit
     Source: Linda Gains, "Reduction of Impacts from Locomotive Idling", Argonne National Laboratory, 2003
       There are many other unique characteristics of the railroad industry such as
track sharing, locomotive sharing, and fleet age. Unlike most other methods of
shipping, railroads are responsible to maintain their own infrastructure such as tracks,
and bridges, which is a very expansive network. The Class I railroads spent more
than $320 billion or approximately 44% of their operating revenue between 1980-
2003 to maintain and improve their infrastructure and equipment.44 As locomotives
grow larger and heavier, and as cars are designed to hold more weight, track is
required that can handle this increased load, and this is quite costly.  To date, of the
549 short line and regional railroads in existence, 333 have  track that cannot handle
these increased loads.45

1.2.3.1 Railroad Classification System (Class I, II and III)

       In the United States, freight railroads are subdivided into three classes based
on annual  revenue by the Federal government's Surface Transportation Board (STB)
(STB regulations for the classification of railroads are contained in 49 CFR Chapter
X). The STB regulations divide the railroads into three classes based on their annual
carrier operating revenue46. As of 2004, Class I railroads are those with annual
carrier operating revenues of at least $289.4 million, Class II railroads are those with
annual carrier operating revenues between $23.1-$289.3 million, Class III railroads
are those with annual carrier operating revenues of $23.1 or less. The AAR further
subdivides Class II and III railroads based on the miles of track over which they
operate and their revenue. These categories are then called Short Line and Regional
Railroads and usually belong to the American Short Line and Regional Railroad
Association  (ASLRRA).
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                                           Chapter 1: Industry Characterization
                      Figure 1-9 Freight Rail Industry Overview
                        95%
     Freight  Rail Industry Overview
           (% of Industry Totals in 2003)
(Source: Assoc. of American Railroads. Overview of U.S. Freight Railroads, Feb.2005)
                                                                      37%
                   Class I
                                    Regional
                                                     Local Linehaul
                                                1.70%
                                                ^

                                       Switching & Terminal
                     D Number of Railroads
            I Track Miles Operated   n Fuel Consumption
1.2.3.2 Class I Characteristics

       Current railroad networks (rail lines) are geographically widespread across the
United States, serving every major city in the country. Approximately one-sixth of
the freight hauled in the United States is hauled by train.4  There are few industries
or citizens in the country who are not ultimate consumers of services provided by
American railroad companies. According to statistics compiled by AAR, Class I rail
revenue accounted for 0.36 percent of Gross National Product in 2004.  Thus,
efficient train transportation is a vital factor in the strength of the U.S. economy.

       In order for Class I railroads to operate nationally, they need unhindered rail
access across all state boundaries.  If different states regulated locomotives
differently, a railroad could conceivably be forced to change locomotives at state
boundaries, and/or have state-specific locomotive fleets. Currently, facilities for such
changes do not exist, and even if switching areas were available at state boundaries, it
would be a costly and time consuming disruption of interstate commerce. A
disruption in the efficient interstate movement of trains throughout the U.S. could
have an impact on the health and well-being of not only the rail industry, but the
entire U.S. economy as well.

       The Class I railroads are the nationwide, long-distance, line-haul railroads
which carry the bulk of the railroad commerce. There are currently 7 Class I freight
railroads operating in the country, two of which are Canadian owned. Class I
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Draft Regulatory Impact Analysis
railroads operated approximately 22,400 locomotives in the U.S., over 97,662G miles
of track and accounted for approximately 90 percent of the ton-miles of freight hauled
by rail annually and consumed 4.1 billion gallons of diesel fuel in 2004.47'48  Of these,
the two largest Class I railroads, BNSF, and Union Pacific, accounted for the vast
majority (63%) of the Class I locomotives in service in the U.S as of the end of
2004.49 According to the 2004 AAR's' Analysis of Class I Railroads, Class  I
railroads paid on average $1.06 for a gallon of fuel in 2004 for a total  expenditure of
$4.2 billion which was 11% of their operating revenue. U.S. Class I railroads employ
approximately 177,000 people, the vast majority of whom are unionized, and as of
2004 receive an average  compensation of $65,500.49

       The Bureau of Transportation Statistics 2006 report shows that in terms of
ton-miles of freight, railroads haul 36.8% of total ton-miles, followed  by trucking
(29%), pipline (19.9%), river/canal/barge (13.9%), and air (0.3%), also shown in
Figure 1-10 .  Rail is a primary means of transport for many bulk commodities,
according to AAR, 65%  of all coal produced in the U.S., 33% of all grain harvested in
the U.S. and 75% of all new automobiles manufactured in the U.S. were transported
by rail.  Being a primary source/mode of transporting these items, the  railroad
industry normally sets the industry standard price ($/ton-mile). Rail transport is
typically more fuel efficient and less expensive than other land-based  sources of
transport. In terms of BTUs of energy expended per ton-mile of freight hauled,
Department of Energy statistics indicate that rail transport can be as much as three to
four times more efficient than truck transport. The AAR has asserted  that one
double-stack train can carry the equivalent of 280 truckloads of freight.50

Figure 1-10 U.S. Freight Transportation Share by Mode
                                           Air, 0.3%
                Pipeline, 19.9%   	
                                                                      Truck, 29.0%
        Water, 13.9%
                                               Railroad, 36.8%
G This is the road length of track or the aggregate length of track excluding sidings and parallel tracks,
actual track miles are 167,312.
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                                          Chapter 1: Industry Characterization
       Figure 1-12 and Table 1-29 show the long term growth trends for the amount
of freight carried by Class I railroads and the amount of fuel consumed in carrying
that freight.51 As can be seen from these data, the ton miles of freight carried have
almost tripled, while total fuel consumption has risen only 10-20%, showing an
approximate 250% improvement in freight hauling efficiency.1 The reason for this is
that locomotive manufacturers have made continual progress in improving the fuel
efficiency of their engines and the electrical efficiency of their alternators and motors,
and railroads have made significant improvements to their operational efficiency.
Fuel efficiency of the railroad industry overall has improved 16% over the last
decade.43 It is reasonable to project that the growth in the amount of freight hauled
will continue in the future.  It is less certain, however, whether fuel consumption will
increase significantly in the near future.

       Table 1-29 Annual Fuel Consumption and Revenue Freight For Class I Railroads
Annual Fuel Consumption and Revenue Freight
For Class I Railroads
Year
1960
1970
1980
1990
1995
2000
2001
2002
2003
2004
Revenue Freight
(Million Ton-Miles)
572,309
764,809
918,958
1,033,969
1,305,969
1,456,960
1,495,472
1,507,011
1,551,438
1,662,598
Fuel Consumption
(Million Gallons)
3,463
3,545
3,904
3,115
3,480
3,700
3,710
3,730
3,826
4,059
Ton-Miles of Freight
moved per gallon of
fuel
165
216
235
332
375
394
403
404
405
410
        Figure 1-11 Fuel Consumption and Revenue Ton-Miles for Class I Railroads
          =
          06
                2000
                1500 -
                1000 -
                 500 -
                     od '-•»
                     gs1
                     g s-
                     ™ o
                      1955 1960 1965 197O 1975 198O 1985 1 99O 1 995 2OOO 2OO4
                                      Ton-Miles
Fuel
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Draft Regulatory Impact Analysis
1.2.3.2.1 Class I Market Share

       Union Pacific (UP) operates over the most miles of track (32,616), has the
largest number of employees (49,511), the greatest operating revenue ($12,180
million), but is surpassed in revenue ton-milesH by BNSF (569 billion). UP owns
more miles of track than any other Class I  (27,123), and operates the most
locomotives (7,680), as show in Table 1-30.

                  Table 1-30 Class I Railroads - Number of Locomotives
8000 -,
7000 -
cnnn
Annn




Class 1 Railroads - Number of Locomotives
(2003 Data)
(Source: https://www .aar.org/AboutThelndustry/Railroad Profiles .asp)































| 	 1 | 	 1 , 	 , |
Union Pacific Burlington CSX Norfolk Candian Kansas City Canadian
Railroad Northern and Transportation Southern National Southern Pacific Railway
Company Santa Fe Combined Railway
Railway Railroad Company
Company Subsidiaries
1.2.3.2.2 Locomotive Fleet

       Purchasing practices have historically been for Class I railroads to buy
virtually all of the freshly-manufactured locomotives sold. As the Class I railroads
replace their equipment with freshly-manufactured units, the older units are either
sold by the Class I railroads to smaller railroads, are scrapped, or are purchased for
remanufacture and ultimate resale (or leasing) by companies specializing in this work.
The industry-wide replacement rate for locomotives would therefore actually be
lower than those indicated for the Class I railroads only. This would mean that the
time required for the total locomotive fleet to turn over would be longer.

       Additionally, independent of cyclic changes in the industry, future locomotive
replacement rates could actually  decrease.  Locomotive manufacturers are now
producing locomotives that have significantly more horsepower than older
H A revenue ton-mile is calculated by dividing freight revenue by total freight ton-miles, it is a measure
of the level of revenue received by a railroad for hauling weight over distance. (AAR Railroad Facts,
2006)
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                                         Chapter 1: Industry Characterization
locomotives.  Railroads have requested this change so that fewer locomotives are
needed to pull a train.  Placing more horsepower on a locomotive chassis increases
overall train fuel efficiency. For example, it would be more fuel-efficient to use two
6000 hp locomotives, rather than three 4000 hp locomotives, to pull the same weight
train, because the weight of an entire locomotive can be eliminated. Thus, whereas
three old locomotives may be scrapped, only two new locomotives may need to be
bought as replacements.

       On the other hand, the business outlook for the railroad industry has been
improving in the last few years. As railroads have become increasingly cost-
competitive, they are attracting more business. This in turn increases demand for
locomotive power to move the additional freight. Thus, while purchases of new
locomotives may increase in the next few years, these locomotives will likely
supplement, rather than replace, existing locomotives. Moreover, if freight demands
continue to increase, it may become cost-effective to operate locomotives for longer
periods than are estimated here.

1.2.3.2.3 Operation Profile

         1.2.3.2.3.1  Fuel consumption.52

       Class I railroads consumed 531 trillion BTUs in 2003.  Locomotives traveled
1,538 million unit-miles in 2004, and averaged 69,900 miles per locomotive in  2004.
The Surface Transportation Board reported that Class I railroads consumed 4.1  billion
gallons of diesel fuel in 2004, for an average mile traveled per gallon of 0.13.
Amtrak traveled 37 million train miles in 2004, and consumed 69.9 million gallons of
fuel. The 4.1  billion gallons of diesel fuel used by the Class I railroad's is 96%  of all
locomotive fuel used in the U.S. and 7.4% of all diesel fuel used for transportation in
the United States. Class I railroads spent $4.2 billion which is 11% of total operating
expenses on fuel in 2004.  The railroads are continually trying to reduce their fuel
consumption through efforts such as idle reduction, and other operational
improvements.  In a study done by the Department of Energy, the aerodynamic drag
of coal cars has been shown to account for 15% of total  round-trip fuel consumption
for a coal train, intermodal cars that are double stacked also carry an aerodynamic
fuel consumption penalty of about 30% loss due to drag. Experiments have
developed some fairings and foil that can reduce this drag loss on coal cars by up to
5% which would save 75 million gallons or 2% of total  Class I fuel consumption in
2002.

         1.2.3.2.3.2  Maintenance Practices

       Locomotive maintenance practices also present some unique features. As is
the case with other mobile sources, locomotive maintenance activities can  be broken
down into a number of subcategories. Routine servicing consists of providing the
fuel, oil, water, sand (which is applied to the rails for added traction), and other
expendables necessary for day-to-day operation.  Scheduled maintenance can be
classified as light (e.g., inspection and cleaning of fuel injectors) or heavy, which can
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Draft Regulatory Impact Analysis
range from repair or replacement of major engine components (such as power
assemblies) to a complete engine remanufacture.  Wherever possible, scheduled
maintenance, particularly the lighter maintenance, is timed to coincide with periodic
federally-required safety inspections, which normally occur at 92-day intervals.
Breakdown maintenance, which may be required to be done in the field, consists of
the actions necessary to get a locomotive back into service.  Because of the high cost
of a breakdown in terms of lost revenue that could result from a stalled train or
blocked track, every effort is made to minimize the need for this type of maintenance.
In general, railroads strive to maintain a high degree of reliability, which results in
more rigorous maintenance practices than would be expected for most other mobile
sources.  However, the competitive nature of the business also results in close
scrutiny of costs to achieve the most cost-effective approach to achieving the
necessary reliability.  This has resulted in a variety of approaches to providing
maintenance.

       Maintenance functions were initially the purview of the individual railroads.
Some major railroads with extensive facilities have turned to providing this service
for other railroads, and a few of the smaller railroads also have done the same, in
particular for other small railroads. However, the tendency in recent years has been
toward a diversification of maintenance providers; a number of independent
companies have come into existence to provide many of the necessary, often
specialized services involved (e.g., turbocharger repair or remanufacture).  The trend
toward outside maintenance has also been accelerated by the policies of some of the
larger railroads to divest themselves of not only maintenance activities, but ownership
of locomotives as well. The logical culmination of this trend is the "power by the
mile" concept, whereby a railroad can lease a locomotive with all the necessary
attendant services for an agreed-upon rate.

1.2.3.2.4 Leasing

       Locomotives are available for lease from OEMs, remanufacturers, and a small
number of specialized leasing companies formed for that purpose. Leasing practices
appear to be fairly standardized throughout the industry. Although lease contracts
can be tailored on an individual basis, most leases seem to incorporate standard
boilerplate language, terms and conditions. Under a typical lease, the lessee takes on
the responsibility for safety certification and maintenance (parts and scheduled
service) of the locomotive (including the engine), although these could be made a part
of the lease package if desired. The lease duration ranged between 30 days and 5
years, with the average being 3 years

       As can be seen from Figure 1-12 leasing has been a continuing trend among
Class I railroads, with almost two-thirds of the locomotives placed in service in 2004
being leased. Leasing among Class II and III railroads is not nearly as widespread.
                                     1-60

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                                          Chapter 1: Industry Characterization
  Figure 1-12 Source: AAR Railroad Ten-year Trends 1995-2004 : Number of Purchased and
                            Leased Class I Locomotives
         1200
         1000 -
          800 -
          600 —
          400 -
          200 -
               1995   1996  1997   1998   1999   2000   2001   2002   2003  2004
               52
1.2.3.2.5 Traffic

       Between 1993-2002 the value of goods being transported by all modes of
transportation increased by 43.6% to $8,397.2 billion, and the ton miles increased
over that period by 29.6% to 3,137.9 billion ton-miles. The railroads share of the
value market increased during that time by 25.7%, and the percent increase in their
ton-miles shipped over that time was 33.8%.  Ton-miles shipped using multiple
modes of transportation also increased over this period such as Truck and Rail
(20.8%) and rail and water (63.8%).

       Figure 1-13 shows that the overall Class I traffic volumes are still increasing,
and as the car miles and train miles converge, this means they are optimizing the
number of cars a locomotive can carry most likely by using fewer more  powerful
locomotives to haul more cars.48 The average length of a haul for Class I railroads
has generally increased every year, and has almost doubled since 1960 when 461
miles was the average haul as compared to 2004 where 862 miles is the  average haul
length, commuter rail has not really increased its average haul length over this same
time period.  Class I train-miles, (a train-mile is the movement of a train, which can
consist of multiple cars, the distance of one mile) were 535 million in 2004, Class I
car-miles (a car-mile measures the distance traveled by every car in a train) were
37,071 million miles in 2004.
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Draft Regulatory Impact Analysis
Figure 1-13 Class I Train Miles and Car Miles  Source: AAR Ten Year Trends 1995-2004
                                                                         550
                                                                       -- 500
                                                                       -- 450
                                                                       -- 400
                                                                       -- 350
                                                                         300
                        52
1.2.3.3 Hauling Statistics

       Class I railroads hauled 1,603,564 million ton-miles of freight in 2003, which
was 37% of all freight hauled in the US; they also carried 19.8 billion ton-miles of
crude oil and petroleum products, which was 2.2% of all those products, trucks
carried 3.8%, but the bulk is transported via pipeline (66.8%) or water carriers
(27.2%). As of 2002, railroads transported 72.1 billion ton miles of hazardous
materials, or 22.1% of all hazardous material being shipped an average of 695 miles
per shipment (BTS 2006). Railroads and trucks carry roughly equal hazmat ton-
mileage, but trucks have nearly 16 times more hazmat releases than railroads.56

       The 2006 FRA Freight Railroad Overview indicates that intermodal shipping
is the fastest growing segment of rail traffic, doublestack containers were introduced
in the 1980's and since then number of trailer and container loadings has risen from
3.4 million to 11.0 million in 2004. Figure 1-14 shows the near doubling of this
traffic in each of the past two  decades. The Staggers Act of 1980 also legalized
railroad-shipper contracts, and according the STB, at least 55% of all traffic moves
under contract, which allows railroads to increase efficiency by permitting better
planning.
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                                          Chapter 1: Industry Characterization
Figure 1-14 Class I Intermodal Traffic Source: AAR Railroad Facts 2006 Edition
                     Intermodal Traffic (AAR Railroad Facts 2006)
           12000000
           10000000 -
         5 8000000
         o
           6000000 -
           4000000 -
           2000000 -
                    1980
                            1985
                                    1990     1995

                                        year
                                                    2000
                                                             2004
1.2.3.4 Track Statistics

       As of 2004, Class I owned 97,662 miles of road Since 1980, capital
expenditures on roadway and structures has increased 88% from 2.6 billion in 1990 to
4.9 in 2004 as railroad tracks have been upgraded to 130 pound per yard weighted rail
to accommodate heavier loads being hauled per car. Class I railroads have increased
their traffic (ton-miles) by approximately 81%, while they have decreased the miles
of track they own by 41%. This has increased traffic density, and although double-
stacking containers has helped to reduce traffic to some degree, this is still a concern
due to the continual growth in ton-miles.

1.2.3.5 Class II & III Characteristics53

       In the 1970's, deregulation allowed the Class I railroads to stop serving many
smaller lines that were unprofitable to them.  This allowed many small independent
railroads to take over that portion of the line and run it more efficiently and
sometimes at a lower cost due to their enhanced flexibility as a small business, in
2004 there were 549 Class II and III railroads. In many cases, these smaller railroads
are also able to receive financial assistance from local governments or associations of
customers to help them upgrade their infrastructure (in many cases, the tracks are
quite old and are not rated for the loads that today's cars typically carry).

       In 2004, Short Lines originated or terminated one out of every four carloads
moved by the domestic rail industry, and operated over approximately 50,000 miles
of track, which is nearly 29% of all U.S. rail mileage. They had over  19,000
employees and served over 11,700 customers and facilities. Of the track they operate,
only 43% is capable of handling the heavier 286,000 axle weight cars. The total
revenue for the Class II and III railroads in 2004 was almost $3 billion, while they
spent nearly $433 million on capital expenditures, $397 million on maintenance of
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Draft Regulatory Impact Analysis
equipment, road and structures, and $221 million on fuel. More than half of the short
line and regional railroads connect to two or more other railroads, and over 80%
operate in one state only.

       Statistics compiled by the American Short Line and Regional Railroad
Association (ASLRRA)  2004 show that there are approximately 549 Class II and III
railroads (not including commuter and insular railroads).  A more detailed breakdown
of these can be found in  Table 1-31.  They consist primarily of regional and local
line-haul and switching railroads1, which operate in a much more confined
environment than do the Class I railroads.  Class II and III railroads operate
approximately 3,777 locomotives. In a recent survey taken by the ASLRRA,
locomotive fleet age data shows that over 92% of the locomotives owned by the Class
II and III railroads are over twenty years old, 5.4% are 10-19 years old, and 2% are
newer than 10 years old.  Class II and III railroads used 552 million gallons of fuel in
2004, which is about  13% of the amount of diesel fuel used by Class I locomotives in
2004. Employment has declined for all  railroads substantially since the 1990's, but all
railroads are predicting growth in hiring.

                    Table 1-31 Profile of Railroad Industry -200454
Type of Railroad
Number of Railroads
Number of Employees
Class I Freight Railroad
National Passenger Railroads
Regional Railroads
Local/Line-Haul Railroads
Switching and Terminal
Class I Subsidiaries
Commuter Railroads
Shipper-Owned Railroads
Government Owned
Railroads
1
1
31
314
204
102
18
68
28
157699
18,909
7422
5349
6429
3687
25,29655


       Some of the smaller railroads are owned and operated by Class I railroads,
many of which are operated as formal subsidiaries for financial purposes, but are run
as standalone entities. In 2004, there were 31 regional railroads, 314 local line-haul
railroads and 204 switching and terminal railroads, including subsidiaries (regional
and local railroads may also have subsidiaries).  A few of these are publicly held
railroads and some are shipper-owned. Insular in-plant railroads are not included in
this total.  ASLRRA estimated that there are probably about 1,000 insular railroads in
the U.S.  These railroads are not common carriers, but rather are dedicated to in-plant
use.  They typically operate a single switch locomotive  powered by an engine with
less than 1000 hp.  Such locomotives typically use a few thousand gallons of diesel
1 "Regional railroad" and "local railroad" are terms used by AAR that are similar, but not identical, to
"Class II" and "Class III", respectively.
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                                         Chapter 1: Industry Characterization
fuel each year, and thus are not a particularly significant source of emissions. Finally,
there are a handful of very small passenger railroads that are primarily operated for
tours. These tourist railroads are included within the Class II and III railroads.

1.2.3.6 Passenger Rail

1.2.3.6.1 Amtrak

       Amtrak was formed in 1971 by Congress through the Rail Passenger Service
Act of 1970 (P.L. 91-518, 84 Stat.1327) to relieve the railroads of the financial
burden of providing passenger railway service. In return for government permission
to leave the passenger rail business and avoid massive losses, many of the freight
railroads donated equipment to Amtrak as well as $200 million in startup capital.56
Amtrak is operated by the National Railroad Passenger Corporation of Washington,
B.C. The Secretary of Transportation has the authority to designate Amtrak's
destinations, which as of 2004 included 527 cities; other transit rail serves 2,909,
some of which may be shared with Amtrak (STB 2006).52 On average, 777,000
people each day depend on commuter rail services operated under contract by
Amtrak, or that use Amtrak-owned infrastructure, shared operations and dispatching;
an average of 69,000 people ride on up to 300 Amtrak trains each day. Amtrak relies
on receiving federal subsidies in order to  operate, although it continually working to
become independent and profitable.

       Although Amtrak's rates are not regulated, they do depend on the amount of
subsidies received from the Federal government; this is not unlike most other forms
of passenger rail in the U.S. Their only source of competition is  other modes of
transportation, and this also affects their rates.  Fuel costs can dramatically affect
rates and Amtrak's need for subsidies; between 2004 and 2005, Amtrak's fuel costs
increased 149%, and continue to increase substantially. Despite an increase in
passengers between 2004-2005 and improved fuel conservation methods that reduced
their fuel consumption by nearly 10%, their fuel cost increased by $43 million.57

       Amtrak is the sole large-scale provider of inter-city passenger transport. Their
fleet includes 436 locomotives, of which  360 are diesel locomotives that used a
reported 69.958 million of gallons of fuel in 2005, and 76 are electric locomotives.
The FRA provided Amtrak with funding to purchase Acela locomotives, which are
4,000 horsepower gas turbine locomotives.  These trains consume about the same
amount of fuel as a diesel locomotive  but produce about 1/1 Oth of the NOX

       They offer service to 46 states on  21,00059 miles of routes, only 745 miles of
which are actually owned by  Amtrak,  primarily in Michigan, and between Boston and
Washington DC.   Based on gross revenue, Amtrak is classified as a Class I railroad
by the STB. However, unlike the Class I freight railroads, Amtrak's current operating
expenses exceed its gross revenue.

       The average age of a passenger train from Amtrak is  quite young, in fact,
since 1980 it has remained under 14.5 years old. Amtrak was on-time 74% of the
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Draft Regulatory Impact Analysis
time in 2003, but the 65% of that delay was caused by a host railroad. A host railroad
is a freight or commuter railroad over which Amtrak operates on for all or part of a
trip, and delays can include signal delays, train interference, routing delays or power
outages. Amtrak must pay these host railroads for their use of this track and any other
resources, in 2005, those payments were for more than 25 million train miles (one
train-mile is a mile of track usage by each train) which totaled more than $92 million.

       The average  Amtrak/intercity fair was $55.15, the average revenue per
passenger-mile is $0.249 for Amtrak, and the average length of haul was 231 miles61
In 2006, Amtrak was able to obtain an additional subsidy in order to remain
operational in 2006, in the amount of $1.1 billion62, but the future of Amtrak may
change if the Passenger Rail Reform Act is  passed, this bill is currently in the House
Subcommittee on Railroads, and would split Amtrak up into three different entities,
two privately owned and one government corporation.

1.2.3.6.2 Commuter63

       There are also 21 independent commuter rail systems operating in 16 U.S.
cities, consuming 72 million gallons of diesel fuel annually, operating over 6,785
miles of track.  They employed approximately 25,000 employees in 2004. Many of
these commuter railroads rely  on Federal subsidies to improve their infrastructure, in
some cases they also rely on state and local government subsidies to support their
operations.

       The average  length of haul for commuter rail in 2004 was 23.5 miles, an
average of 414 million people  use commuter rail each year to result in over 9.7 billion
passenger-miles. The average  commuter rail fair in 2004 was $3.90, with an average
$0.154 revenue per passenger-mile. The commuter rail is also a young fleet and has
remained younger than  17 years old since 1985.

1.2.4 Existing Regulations

1.2.4.1 Safety

       Achieving and maintaining the safe  operation of commercial (common
carrier) railroads in the U.S. falls under the jurisdiction of the Federal Railroad
Administration (FRA), which  is a part of the Department of Transportation. The
FRA was created in  1966 to perform a number of disparate functions, including
rehabilitating Northeast Corridor rail passenger service, supporting research and
development for rail transportation, and promoting and enforcing safety regulations
throughout the railway system.

       FRA safety regulations apply to railroads on a nationwide basis. In 49 CFR
section 229 the regulations require safety inspections of each locomotive used in
commercial operations: daily,  every 92 days (i.e. the periodic inspection), annually,
and biennial. Each inspection increases in complexity. The inspections are usually
performed by the railroad which owns or leases the locomotive.  FRA personnel
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                                          Chapter 1: Industry Characterization
review the findings of these inspections and any corrective actions identified and
taken.  Since each locomotive is required to be out of revenue service for inspection
every 92 days, railroads commonly schedule their performance of preventive
maintenance at these times. It appears likely that each locomotive is out of service
for 12 to 24 hours during each FRA safety inspection and preventative maintenance
period.J To limit the time that locomotives are out of service for these safety
inspections and preventive maintenance, railroads maintain suitable facilities
distributed across the nation.  Thus, it appears that the railroads have had a long
history of compliance with federal regulations, and have developed strategies to live
within the regulations and to minimize any adverse business impacts that may have
resulted.

1.2.4.2 Federal

       In 1980 Congress passed the Staggers Act (USCA 49 § 10101) which laid out
the government's statutory objectives for the Railroad Industry which are to balance
the efficiency and viability of the industry with the need for: reasonable rates, fair
wages, public health and safety, and energy conservation.

       The railroads are governed by two separate Federal Agencies directly, both
under the Department of Transportation, a cabinet-level department. The Federal
Railroad Administration (FRA) regulates safety issues. The FRA sets safety
standards for rail equipment and operation, and also investigates accidents on rail
lines and at rail crossings. The FRA also plays a role in labor disputes to a small
degree, by monitoring the progress of negotiations, projecting the economic impact of
a strike and  assisting the Secretary in briefing  Congress if necessary. The STB is an
adjudicatory body that was formed in 1966 to  settle disputes and regulate the various
modes of surface transportation within the U.S.  Organizationally, the STB is part of
the Department of Transportation (DOT), the STB deals with railway rate and service
issues, railway restructuring and various other issues, including classification of
railroads. The Surface Transportation Board (STB) regulates economic issues such as
rates. The STB can also mandate access to locations in order to maintain competition
in areas where mergers reduced the number of available carriers

1.2.4.3 Rates

       Rail transportation accounts for 8.7% of all for-hire transportation services
that are a measured in the GDP, or 0.2% of the total U.S. GDP.  The average freight
revenue per ton-mile for Class I rail in 2004 was $0.0235,  and average operating
revenue of $40.5 billion.  Freight rates adjusted for inflation have  declined by an
average of 1.1% a year between 1990 and 2004 due in large  part to the passage of the
Staggers Act, as shown in Figure 1-15.64
J Values are an approximate estimate by FRA personnel.

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Draft Regulatory Impact Analysis
       If a shipper believes a rate is unreasonable (only if that shipper does not have
access to another railroad, and waterway or highway modes are not feasible), they can
complain to the STB, which has a stand-alone rate standard. This means that they
determine what a hypothetical new carrier to serve that shipper would need to charge
to cover all of its costs including capital and construction.  Complaints such as these
are typically made by bulk shippers, such as coal or chemicals, who cannot use other
modes of transportation such as highway or can't access other railroads.

Figure 1-15 Railroad Rate Trends Before and After Staggers Act of 198064
                     Railroad Rates After Inflation
                                          1972=100

                                             Year
            Sources: U.S. Dept. of Labor, Bureau of Labor Statistics, Producer Price Index of Line-
            Haul Operating Railroads; U.S. Dept. of Commerce, Bureau of Economic Analysis, Implicit
            Price Deflator for Gross Domestic Product

1.2.5 Foreign Railroads in US

       Locomotives that operate extensively within the U.S. are subject to the
existing provisions of 40 CFR Part 92.

1.2.5.1 Mexico

       In 2004, the BTS says there were a total of 675,305 US/Mexico railcar
crossings, that's an average of almost 1900 crossings a day, or one every minute. The
Mexican Railroads and 16,415 miles of track have been privately owned since a
Constitutional amendment was passed in 1995 (FRA "Border Issues"). They
primarily haul NAFTA generated goods, such as cars, automobile parts, and other
manufactured products.  Mexico has two railroads, Ferrocarril Mexicano, which has a
joint venture with UP and Transportacion Ferroviaria Mexicana (TFM) of which
Kansas City Southern has controlling interest.
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                                               Chapter 1: Industry Characterization
1.2.5.2 Canada

        In 2004, the BTS says there were 1,950,909 border crossings into Canada by
railcars.  Canada is also home to two Class I railroads that operate extensively in the
U.S., Grand Trunk Corporation which includes almost all of Canadian National's
(CN) U.S. operations, and Canadian Pacific Railway which operates its Soo Line
primarily in the U.S.
                                          References
2 Power Systems Research (PSR). 2004. OELink™. .
1 RTI International, "Industry Profile for Small, Category 1, and Category 2 Marine Diesel Engines
and Marine Vessels," Final Report, May 2006. Prepared for U.S Environmental Protection Agency,
Office of Transportation and Air Quality..

3 U.S. Environmental Protection Agency (EPA). 1995. EPA Office of Compliance Sector Notebook
Project: Profile of the Motor Vehicle Assembly Industry. EPA310-R-95-009. Washington, DC: U.S.
EPA.
4 U.S. Census Bureau. 2004. Economic Manufacturing Industry Series: 2002. EC02-31I-333618.
Washington, DC: U.S. Census Bureau. Tables 1, 5, and 7.
5 Wooldridge, David. 2003. "2003 Marine Shop Profile." Engine Builder (June): 23-40.
(http://www.babcox.com/editorial/ar/60323.pdf).  As obtained on May 10, 2006.
6 National Marine Manufacturers'  Association (NMMA). January 12, 2006. Facsimile from John
McKnight  (NMMA) to Dave Reeves (RTI).
7 Workboat.  January 2005. Workboat Construction Survey. Last obtained March 15, 2006.
(http://www.workboat.com/pdfs/WB_2004const_survey.pdf)
8 Viscusi, W.K., J.M. Vernon and J.E. Harrington. 1992. Economics of Regulation and Antitrust.
Lexington, MA: D.C. Heath and Co.
9 U.S. Census Bureau. 2004. Economic Manufacturing Industry Series: 2002. EC02-31L333618.
Washington, DC: U.S. EPA.
10 U.S. Department of Transportation. 1998 and 2006. National Transportation Statistics 1997 and
2005. Washington, DC: U.S Department of Transportation.
11 U.S. Bureau of the Census. 2002 Economic Census.
http://www.census.gov/prod/ec02/ec0231i336611.pdfand
http://www.census.gov/prod/ec02/ec0231i336612.pdf.
12 U.S. Maritim Administration (MARAD). 2003. Report on the survey of U.S. Shipbuilding and
Repair Facilities.  U.S. Department of Transportation, Maritime Administration.
13 National Marine Manufacturers  Association (NMMA). 2004. 2004 Recreational Boating Statistical
Abstract. Chicago, IL.
14 National Marine Manufacturers  Association (NMMA). 2004. 2004 Recreational Boating Statistical
Abstract. Chicago, IL.
15 U.S. Bureau of the Census. 2002 Economic Census.
http://www.census.gov/prod/ec02/ec0231i336612.pdf.
16 Hoover's Online. 2006. Online company database, .
17 Dun & Bradstreet. 2006a. D&B Million Dollar Directory. Bethlehem, Pennsylvania: Dun &
Bradstreet, Inc.
18 Dun & Bradstreet. 2006b. Small Business Database, .
19 National Marine Manufacturers  Association (NMMA). 2004. 2004 Recreational Boating Statistical
Abstract. Chicago, IL.
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Draft Regulatory Impact Analysis
20 National Marine Manufacturers Association (NMMA). 2004. 2004 Recreational Boating Statistical
Abstract. Chicago, IL.
21 Eastern Research Group, Inc. (ERG). "Category 2 Vessel Census, Activity, and Spacial Allocation
Assessment and Category 1 and Category 2 In-port/At-sea Splits," Final Report, Feb. 16, 2007.
Prepared for U.S Environmental Protection Agency, Office of Transportation and Air Quality.
22 WorkBoat. Annual Construction Survey. January/February 1992, January/February 1994,
January/February 1995, January 1998, and January 2004. Portland, ME: Workboat.
23 Eastern Research Group, Inc. (ERG). "Category 2 Vessel Census, Activity, and Spacial Allocation
Assessment and Category 1 and Category 2 In-port/At-sea Splits," Final Report, Feb. 16, 2007.
Prepared for U.S Environmental Protection Agency, Office of Transportation and Air Quality.
24 American Waterways Operators (AWO). 2006. Facts About the American Tugboat, Towboat, and
Barge Industry, http://www.americanwaterways.com/. Arlington, VA.
25 Eastern Research Group, Inc. (ERG). "Category 2 Vessel Census, Activity, and Spacial Allocation
Assessment and Category 1 and Category 2 In-port/At-sea Splits," Final Report, Feb. 16, 2007.
Prepared for U.S Environmental Protection Agency, Office of Transportation and Air Quality.
26 U.S. Department of Labor Statistics. 2006. Occupational Outlook Handbook.
http://www.bls.gov/oco/ocosl77.htm.
27 WorkBoat.com. February 2006. 2005 Construction Survey.

28 WorkBoat.com. February 2006. 2005 Construction Survey.

29 Hoover's Online. 2006. Online company database, .
30 Dun & Bradstreet. 2006a. D&B Million Dollar Directory. Bethlehem, Pennsylvania: Dun &
Bradstreet, Inc.
31 Dun & Bradstreet. 2006b. Small Business Database, .
32 Frank W. Donnelly, Raymond L. Cousineau, R. Nigel M. Horsley,  "Hybrid Technology for the Rail
Industry" ASME/IEEE Document RTD2004-66041, April 2004.
33 www.railpower.com/products_hl_howitworks.html
34 https://www.getransportation.com/general/locomotives/hybrid/hybrid_default.asp
35 "Railroad and Locomotive Technology Roadmap" Argonne National Laboratory, December 2002
36 en.wikipedia.org/wiki/Diesel_locomotive
37 Steven Fritz, "On Track Toward Cleaner Large Engines: New emissions reduction strategies focus
on locomotives and ferry boats" Southwest Research Technology Today, Spring 2004.
38 http://www.emdiesels.com/lms/en/company/history
39 www.getransportation.com/general/freight_rail/models
40 AAR Railroad Ten-Year Trends 1995-2004
41 William C. Vantuono, "New power plays to watch" Railway Age, August 2006.
42 http://www.railpower.com/dl/greensavesgreen.pdffsearch='price%20hybrid%20green%20goat'
43 "Railroad and Locomotive Technology Roadmap" Argonne National Laboratory, December 2002
44 nationalatlas.gov/articles/transportation/a_freightrr.html
45 American Short Line and Regional Railroad Association 2005 Facts and Figures.
46 STB Railroad Revenue Deflator Formula: Current Year's Revenues x (1991 Average Index/Current
Year's Average Index)
47 AAR Railroad Facts 2005
48 Transportation Energy Data Book, Edition 25, 2006
49 Based on 2005 Railroad Annual Reports filed with STB.
50  Quoted from May 15, 1997 testimony by Bruce Wilson representing AAR. Docket item f A-94-31-
IV-D-7.
51  "Railroad Facts", Association of American Railroads, 2006 edition.
52 National Transportation Statistics 2006, Bureau of Transportation
53 Short Line and Regional Railroad Facts and Figures, 2005 Edition
54 AAR "Class Railroad Ten-Year Trends" 1995-2004
55 apta.com
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                                                Chapter 1: Industry Characterization
56 http://nationalatlas.gov/articles/transportation/a_freightrr.html
57 www.amtrak.com
58 amtrak.com report
59 Amtrak Media Relations "National Fact Sheet" July, 2006
60 Railroad Facts 2005
61 Bureau of Transportation National Statistics 2006
62 Andrew Taylor,  "Amtrak Supporters Aim to Ease Budget Cuts" 06/14/06, Associated Press.
63  "2006 Transit Fact Book", American Public Transportation Association.
64 FRA "Freight Railroad Overview" www.fra.dot.gov
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                  Chapter 2: Air Quality and Resulting Health and Welfare Effects
CHAPTER 2: AIR QUALITY AND RESULTING HEALTH AND WELFARE
EFFECTS OF AIR POLLUTION FROM MOBILE SOURCES	2-2

      2.1 Particulate Matter	2-4

         2.1.1 Science of PM Formation	2-5

         2.1.2 Health Effects of PM Pollution	2-10

         2.1.3 Attainment and Maintenance of the PM2.5 NAAQS	2-12

         2.1.4 Source Apportionment Studies of PM2.5	2-16

         2.1.5 Risk of Future Violations	2-18

         2.1.6 Environmental Effects of PM Pollution	2-27

      2.2 Ozone	2-40

         2.2.1 Science of Ozone Formation	2-40

         2.2.2 Health Effects of Ozone	2-42

         2.2.3 Current 8-Hour Ozone Levels	2-43

         2.2.4 Projected 8-Hour Ozone Levels	2-45

         2.2.5 Environmental Effects of Ozone Pollution	2-53

      2.3 Air Toxics	2-55

         2.3.1 Diesel Exhaust PM	2-56

      2.4 Gaseous Air Toxics—benzene, 1,3-butadiene, formaldehyde,

      acetaldehyde, acrolein, POM, naphthalene	2-67
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Draft Regulatory Impact Analysis
CHAPTER 2:  Air Quality and Resulting Health and Welfare
                  Effects of Air Pollution from Mobile Sources

       Locomotive and marine diesel engines subject to today's proposal generate significant
emissions of particulate matter (PM) and nitrogen oxides (NOX) that contribute to
nonattainment of the National Ambient Air Quality Standards (NAAQS) for PM2.5 and
ozone. These engines also emit hazardous air pollutants or air toxics which are associated
with serious adverse health effects. Emissions from locomotive and marine diesel engines
also cause harm to public welfare and contribute to visibility impairment and other harmful
environmental impacts across the US. Therefore, EPA is proposing to adopt new standards
to control these emissions.

       The health and environmental effects  associated with these emissions are a classic
example of a negative externality (an activity that imposes uncompensated costs on others).
With a negative externality, an activity's social cost (the cost borne to society imposed as a
result of the activity taking place) exceeds its private cost (the cost to those directly engaged
in the activity).  In this case, as described in this chapter, emissions from locomotives and
marine diesel engines and vessels impose public health and environmental costs on society.
However, these added costs to society are not reflected in the costs of those using these
engines and equipment. The  market system itself cannot correct this externality because
firms in the market are rewarded for minimizing their production costs, including the costs of
pollution control.  In addition, firms that may take steps to use equipment that reduces air
pollution may find themselves at a competitive disadvantage compared to firms that do not.
To correct this market failure and reduce the negative externality from these emissions, it is
necessary to give producers the market signals for the social costs generated from the
emissions.  The standards EPA is proposing will accomplish this by mandating that
locomotives and marine diesel engines reduce their emissions to a technologically feasible
limit. In  other words, with this proposed rule the costs of the transportation services
produced by these engines and equipment will reflect social costs more efficiently.

       Today millions of Americans continue to live in areas with unhealthful air quality that
may endanger public health and welfare  (i.e., levels not requisite to protect the public health
with an adequate margin of safety).  With regard to PM2.5 nonattainment,  EPA recently
finalized  PM2.5 nonattainment designations (70 FR 943, Jan 5, 2005) and as of October 2006
there are  88 million people living in 39 areas  (which include all or part of 208 counties) that
either do  not meet the PM2.s NAAQS or contribute to violations in other counties.  These
numbers do not include the people living in areas where  there is a significant future risk of
failing to maintain or achieve the PM2.5 NAAQS.  Currently, ozone concentrations exceeding
the  level of the 8-hour ozone  NAAQS occur over wide geographic areas, including most  of
the  nation's major population centers. As of October 2006 there are approximately 157
million people living in 116 areas (461 full or partial counties) designated as not in
attainment with the 8-hour ozone NAAQS. These numbers do not include the people living
in areas where there is a future risk of failing  to maintain or achieve the 8-hour ozone
NAAQS.  Figure 2-1 illustrates the widespread nature of these problems highlighting
counties which are currently designated in nonattainment for the 8-hour ozone, PM2.5
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


NAAQS, or for both pollutants.  It also shows the location of mandatory class I federal areas
for visibility.

                Figure 2.1-1 Air Quality Problems are Widespread (October 2006)
 Legend

   | PM and Ozone NonAttainmerit
 |    | Ozone NonAttaintnent
      prn25 NonAttainment
   • Class I Areas
       Emissions from locomotive and marine diesel engines account for substantial portions
of today's ambient PM2.s and NOX levels [20 percent of total mobile source NOX emissions
and 25 percent of total mobile source diesel PM 2.s emissions].  Over time, the relative
contribution of these engines to air quality problems will increase unless EPA takes action to
reduce their pollution levels. By 2030 locomotive and marine diesel engines could constitute
more than 65 percent of mobile source diesel PM2.s emissions and 35 percent of mobile
source NOX emissions.

       Under today's proposed comprehensive standards annual NOX emissions would be
reduced by more than 765,000 tons and annual PM2.s  emissions by about 28,000 tons in
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Draft Regulatory Impact Analysis
2030. We estimate that the reduced PM2.s levels would produce nationwide air quality
improvements.  According to air quality modeling performed in conjunction with this
proposed rule, if finalized, all current PM2.5 nonattainment areas would experience a resulting
decrease in their 2020 and 2030 PM2.s design values (DV).  In addition, all 116 monitored
mandatory class I federal areas would also experience improved visibility.  For the current 39
PM2.s nonattainment areas (annual DVs greater than 15pg/m3) the average population
weighted modeled future-year annual PM2.5 DVs would on average decrease by 0.06 pg/m3
in 2020 and by 0.14 pg/m in 2030. The maximum decrease for future-year annual PM2.5
DVs in these nonattainment areas would be 0.35pg/m3 in 2020 and 0.90pg/m3 in 2030.
       This rule would also result in ozone benefits in 2030 for 114 of the current 116 ozone
nonattainment areas.  According to air quality modeling performed for this rulemaking, the
proposed locomotive and marine diesel engine emissions controls are expected to provide
nationwide improvements in ozone levels. On a population-weighted basis, the average
modeled future-year 8-hour ozone design values would decrease by 0.29 ppb in 2020 and
0.80 ppb in 2030.  Within projected ozone nonattainment areas, the average  decrease would
be somewhat higher:  -0.30 ppb in 2020 and - 0.88 ppb in 2030.A The maximum decrease for
future-year DVs over the U.S. would be -1.10 ppb in 2020 and -2.90 ppb in  2030

       While EPA has already adopted many emission control programs that are expected to
reduce both ambient ozone and PM levels, including the Clean Air Interstate Rule (CAIR)
(70 FR 25162, May 12, 2005), the Clean Air Nonroad Diesel rule (69 FR 38957, June 29,
2004), the additional  PM2.5  and NOX emissions reductions resulting from this locomotive and
marine diesel engine rule would be important to states' efforts in attaining and maintaining
the Ozone and PM2.5  NAAQS near term and in the decades to come.

2.1  Particulate Matter

       In this section we review the health and welfare effects of PM2.s. We also describe
air quality monitoring and modeling data that indicate many areas across the country
continue to be exposed to high levels of ambient PM2.s. Emissions of hydrocarbons (HCs)
and NOX from the engines subject to this proposed rule contribute to these PM
concentrations.  Information on air quality was gathered from a variety of sources, including
monitored PM concentrations, air quality modeling done for recent EPA rulemakings and
other state and local air quality information.
A This is in spite of the fact that NOx reductions can at certain times in some areas cause ozone levels to
increase.  Such "disbenefits" are predicted in our modeling, but these results make clear that the overall effect of
the proposed rule is positive. The two nonattainment areas that show slight increases in 2030 as a result of the
rule are Los Angeles / South Coast Air Basin (0.1 ppb) and Norfolk-Virginia Beach-Newport News (0.8 ppb)
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


2.1.1 Science of PM Formation

       Particulate matter (PM) represents a broad class of chemically and physically diverse
substances. It can be principally characterized as discrete particles that exist in the condensed
(liquid or solid) phase spanning several orders of magnitude in size. PM is further described
by breaking it down into size fractions. PMio refers to particles generally less than or equal
to 10 micrometers (pm).  PM2.s refers to fine particles, those particles generally less than or
equal to 2.5 pm in diameter. Inhalable (or "thoracic") coarse particles  refer to those particles
generally greater than 2.5 pm but less than or equal to 10 pm in diameter. Ultrafine PM
refers to particles less than 100 nanometers (0.1 pm). Larger particles  tend to be removed by
the respiratory clearance mechanisms, whereas smaller particles are deposited deeper in the
lungs.

       Particles span many sizes and shapes and consist of hundreds of different chemicals.
Particles are emitted directly from sources and are also formed through atmospheric chemical
reactions; the former are often referred to as "primary" particles, and the latter as
"secondary" particles. In addition, there are also physical, non-chemical reaction
mechanisms that contribute to secondary particles.  Particle pollution also varies by time of
year and location and is affected by several weather-related factors, such as temperature,
clouds, humidity, and wind.  A further layer of complexity comes from particles' ability to
shift between solid/liquid and gaseous phases, which is influenced by concentration and
meteorology, especially temperature.

       Particles are made up of different chemical components. The major chemical
components include carbonaceous materials (carbon soot and organic compounds), and
inorganic compounds including, sulfate and nitrate compounds that usually include
ammonium, and a mix of substances often apportioned to crustal materials such as soil and
ash (Figure 2-2). The different  components that make up particle pollution come from
specific sources and are often formed in the atmosphere. As mentioned above, particulate
matter includes both "primary" PM, which is directly emitted into the air, and "secondary"
PM. Primary PM consists of carbonaceous materials (soot and accompanying organics)—
emitted from cars, trucks, heavy equipment, forest fires, some industrial processes and
burning waste—and both combustion and process related fine metals and larger crustal
material from unpaved roads, stone crushing, construction sites, and metallurgical operations.
Secondary PM forms in the atmosphere from gases. Some of these reactions require sunlight
and/or water vapor. Secondary PM includes:

       Sulfates formed from sulfur dioxide emissions from power plants and industrial
facilities;

       Nitrates formed from nitrogen oxide emissions from cars, trucks, industrial facilities,
and power plants; and

       Organic carbon formed from reactive organic gas emissions from cars, trucks,
industrial facilities, forest fires, and biogenic sources such as trees.
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Draft Regulatory Impact Analysis
           Figure 2-2 National Average of Source Contribution to Fine Particle Levels
 Cars, trucks, industrial
 combustion and
 processes, heavy
 equipment,  wildfires,
 wood/waste burning,
     Cars, trucks,
     industrial combustion, and
     power generation
    Suspended soils, industrial
    metallurgical operations
Mobile power generation,
industrial combustion and
processes
       Source: The Paniculate Matter Report, USEPA 454-R-04-002, Fall 2004. Carbon reflects both organic
carbon and elemental carbon. Organic carbon accounts for emissions from a wide range of sources including
locomotive and marine diesel engines as well as automobiles, biogenic, gas-powered off-road vehicles, and
wildfires.  Elemental carbon is formed from both diesel and gasoline powered sources.
2.1.1.1  Composition of PM2.s in Selected Urban Areas

       Note that fine particles can be transported long distances by wind and weather and
can be found in the air thousands of miles from where they formed. The relative contribution
of various chemical components to PM2.5 varies by region of the country, as illustrated in
Figure 2-3. Data on  PM2.5 composition are available from the EPA Speciation Trends
Network and the IMPROVE Network, covering both urban and rural areas in numerous
regions of the U. S.

       These data show that carbonaceous PM2.5 makes up the major component for PM2.5
in both urban and rural areas in the Western U.S. Carbonaceous PM2.5 includes both
elemental and organic carbon. Nitrates formed from NOX  also play a major role in the
western U.S., especially in the California area where nitrates are responsible for about a
quarter of the ambient PM2.5 concentrations.  Sulfate plays a lesser role in these regions by
mass, but it remains important to visibility impairment discussed below.  For the Eastern and
mid U.S., these data  show that both sulfates and carbonaceous PM2.5 are major contributors
to ambient  PM2.5 in both urban and rural areas. In some eastern areas, carbonaceous PM2.5 is
responsible for up  to half of ambient PM2.5 concentrations. Sulfate is also a major
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                       Chapter 2: Air Quality and Resulting Health and Welfare Effects


contributor to ambient PM2.5 in the Eastern U.S. and in some areas sulfate makes greater
contribution than carbonaceous PM2.s.
              Figure 2-3 Average PM2.5 Composition in Urban areas by Region, 2003
                           WEST
                  EAST
                Northwest
                  (5
 Upper
Midwest
          Southern
          California
                         Southwest
   Industrial
   Midwest
    e
Southeast
 8
Northeast
 e
                               &  Sulfates
                               4  Nitrates
                               ^  Carbon
                               ^  Crystal

                               Circle size corresponds
                               to PM2 5 concentration.
2.1.1.2  Regional and Local Source Contributions to Formation of PM2.s

       Both local and regional sources contribute to particle pollution. Figure 2-4 shows
how much of the PM2.5 mass can be attributed to local versus regional sources for 13 selected
urban areas. The urban excess is estimated by subtracting the measured PM2.s species at a
regional monitor location B assumed to be representative of regional background) from those
measured at an urban location.

       As shown in Figure 2-4, we observe a large urban excess across the U.S. for most
PM2.s species but especially for total carbon mass. All of these locations have consistently
high urban excess for total carbon mass with Fresno, CA and Birmingham, AL having the
B Regional concentrations are derived from the rural IMPROVE monitoring network Interagency Monitoring of
Protected Visual Environments. See http://vista.cira.colostate.edu/improve.
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Draft Regulatory Impact Analysis
largest observed measures. Larger urban excess of nitrates is seen in the western U.S. with
Fresno, CA and Salt Lake City, UT significantly higher than all other areas across the nation.
These results indicate that local sources of these pollutants are indeed contributing to the
PM2.s air quality problem in these areas.

       Urban and nearby rural PM2.5 concentrations suggest substantial regional
contributions to fine particles in the East. The measured PM2.s concentration is not
necessarily the maximum for each urban area.  As expected for a predominately regional
pollutant, only a modest urban excess is observed for sulfates
        Figure 2-4. Estimated "Urban Excess" of 13 Urban Areas by PM2.5 Species Component
                                  Total Carbon Mass
                                  (TCM)fk=1.6J:
       Note:   Total Carbon Mass (TCM) is the sum of Organic Carbon (OC) and Elemental Carbon (EC).
In this graph, the light grey is OC and the dark grey is EC. See: Turpin, B. and H-J, Lim, 2001: Species
contributions to PM2.5 mass concentrations: Revisiting common assumptions for estimating organic mass,
Atmospheric Environment, 35, 602-610.
       In the East, regional pollution contributes more than half of total PM2.5
concentrations. Rural background PM2.5 concentrations are high in the East and are
somewhat uniform over large geographic areas. These regional concentrations come from
emission sources such as power plants, natural sources, and urban pollution and can be
transported hundreds of miles and reflect to some extent the denser clustering of urban areas
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                     Chapter 2: Air Quality and Resulting Health and Welfare Effects


in the East as compared to the West. The local and regional contributions for the major
chemical components that make up urban PM2.s are sulfates, carbon, and nitrates.

2.1.1.3 Composition of PM2.s in Locomotive and Marine Diesel Engines

       Locomotive and Marine Diesel engines contribute significantly to ambient PM2.s
levels, largely through emissions of carbonaceous PM2.5.  As discussed in the previous
section, carbonaceous PM2.s is a major portion of ambient PM2.5, especially in populous
urban areas.  For the medium speed diesel engine commonly used in locomotive and
Category 2 marine applications, the majority of the total carbon PM is organic carbon.
Locomotive and marine diesels also emit high levels of NOX which react in the atmosphere to
form secondary PM2.5 (namely ammonium nitrate). Locomotive and marine diesel engines
also emit S02 and HC which form secondary PM2.5 (namely sulfates and organic
carbonaceous PM2.5). Figure 2-5 shows the relative contribution of elemental and organic
carbon to PM emissions for six Tier 0, Tier 1, and Tier 2 locomotives (three locomotive
engines were 2-stroke while 3 locomotive engines were 4- stroke). This recent data, while
limited to six locomotives, suggest that locomotives, regardless of when it was built, tend to
emit a very high level of organic  carbon PM precisely the type of carbon that appears to be
responsible for a high percentage of the urban excess PM2.5 species across the US.
     Figure 2-5: PM emissions for 6 locomotives tested using 3000 ppm sulfur nonroad diesel fuel.
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                                          2-9

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Draft Regulatory Impact Analysis
       The proposed locomotive and marine engine standards would reduce emissions of
carbonaceous PM. NOX emissions, a prerequisite for formation of secondary nitrate aerosols,
would also be reduced. The proposed standards would also reduce VOC emissions. The
emission inventories are discussed in detail in Chapter 3 for primary PM2.s emissions from
these sources.  This proposed rule would also reduce secondary PM produced from these
engines emissions.

       As discussed in Sections 2.2 diesel PM also contains small quantities of numerous
mutagenic and carcinogenic compounds associated with the particles (and also organic
gases).  In addition, while toxic trace metals emitted by locomotive and marine diesel engines
represent a very small portion of the  national emissions of metals  (less than one percent) and
a small portion of diesel PM (generally much less than one percent of diesel PM), we note
that several trace  metals of potential  toxicological significance and persistence in the
environment are emitted by diesel engines. These trace metals include chromium,
manganese, mercury and nickel. In addition, small amounts of dioxins have been measured
in highway engine diesel exhaust, some of which may partition  into the particulate phase;
dioxins  are a major health concern but diesel engines are a minor contributor to overall
dioxin emissions.  Diesel engines also emit polycyclic organic matter (POM), including
polycyclic aromatic hydrocarbons  (PAH),  which can be present in both gas and particle
phases of diesel exhaust.  Many PAH compounds are classified by EPA as probable human
carcinogens.

2.1.2 Health Effects of PM Pollution

       As stated in the EPA Particulate Matter Air Quality Criteria Document (PM AQCD),
available scientific findings "demonstrate well that human health outcomes are associated
with ambient PM."C We are relying  on the data and conclusions in the PM AQCD and PM
staff paper, which reflects EPA's analysis  of policy-relevant science from the PM AQCD,
regarding the health effects associated with particulate matter.1'2 We also present additional
recent studies published after the cut-off date for the PM AQCD.03 Taken together this
information supports the conclusion that PM-related emissions such as those controlled in
this action are associated with adverse health effects. Information on PM-related mortality
and morbidity is presented first, followed by information on near-roadway exposure studies,
marine ports  and rail yard exposure studies.
c Personal exposure includes contributions from many different types of particles, from many sources, and in
many different environments. Total personal exposure to PM includes both ambient and nonambient
components; and both components may contribute to adverse health effects.
D These additional studies are included in the 2006 Provisional Assessment of Recent Studies on Health Effects
of Particulate Matter Exposure. The provisional assessment did not and could not (given a very short
timeframe) undergo the extensive critical review by EPA, CAS AC, and the public, as did the PM AQCD. The
provisional assessment found that the "new" studies expand the scientific information and provide important
insights on the relationship between PM exposure and health effects of PM. The provisional assessment also
found that "new" studies generally strengthen the evidence  that acute and chronic exposure to fine particles and
acute exposure to thoracic coarse particles are associated with health effects.
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                     Chapter 2: Air Quality and Resulting Health and Welfare Effects


2.1.2.1  Short-term Exposure Mortality and Morbidity Studies

       As discussed in the PM AQCD, short-term exposure to PM2.s is associated with
mortality from cardiopulmonary diseases (PM AQCD, p. 8-305), hospitalization and
emergency department visits for cardiopulmonary diseases (PM AQCD, p. 9-93), increased
respiratory symptoms (PM AQCD, p. 9-46), decreased lung function (PM AQCD Table 8-
34) and physiological changes or biomarkers for cardiac changes (PM  AQCD, Section
8.3.1.3.4). In addition, the PM AQCD describes a limited body of new evidence from
epidemiologic studies for potential relationships between short term exposure to PM and
health endpoints such as low birth weight, preterm birth, and neonatal  and infant mortality.
(PM AQCD, Section 8.3.4).

       Among the studies of effects from short-term exposure to PM2.5, several studies
specifically address the contribution of mobile sources to short-term PM2.5 effects on daily
mortality. These studies indicate that there are statistically significant  associations between
mortality and PM related to mobile source emissions (PM AQCD, p.8-85). The analyses
incorporate source apportionment tools into daily mortality studies and are briefly mentioned
here. Analyses incorporating source  apportionment by factor analysis with daily time-series
studies of daily death indicated a relationship between mobile source PM2.5 and mortality.4'5
Another recent study in 14 U.S. cities examined the effect of PMio exposures on daily
hospital admissions for cardiovascular disease. They found that the  effect of PMio was
significantly greater in areas with a larger proportion of PMio coming from motor vehicles,
indicating that PMio from these sources may have a greater effect on the toxicity of ambient
PMio when compared with other sources.6 These studies provide evidence that PM-related
emissions, specifically from mobile sources, are associated with adverse health effects.

       In terms of morbidity, short-term studies have shown associations between  ambient
PM2.s and cardiovascular and respiratory hospital admissions (PM AQCD, p. 9-93),
decreased lung function (PM AQCD Table 8-34), and physiological cardiac changes (PM
AQCD, Section 8.3.1.3.4).

2.1.2.2 Long-term Exposure Mortality and Morbidity Studies

       Long-term exposure to elevated ambient PM2.5 is associated with mortality  from
cardiopulmonary diseases and lung cancer (PM AQCD, p. 8-307), and effects on the
respiratory system such as decreased lung function or the development of chronic respiratory
disease (PM AQCD, pp. 8-313,  8-314). Of specific importance to this proposal, the PM
AQCD also notes that the PM components of gasoline and diesel engine exhaust represent
one class of hypothesized likely important contributors to the observed ambient PM-related
increases in lung cancer incidence and mortality  (PM AQCD, p. 8-318).

       The PM AQCD and PM Staff Paper emphasize the results of two long-term studies,
the Six Cities and American Cancer  Society (ACS) prospective cohort studies, based on
several factors - the inclusion of measured PM data, the fact that the study populations were
similar to the general population, and the fact that these studies have undergone extensive
reanalysis (PM AQCD, p. 8-306, Staff Paper, p.3-18).7'8'9  These studies indicate that there
are significant associations for all-cause, cardiopulmonary, and lung cancer mortality with
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Draft Regulatory Impact Analysis
long-term exposure to PM2.5. One analysis of a subset of the ACS cohort data, which was
published after the PM AQCD was finalized but in time for the 2006 Provisional
Assessment, found a larger association than had previously been reported between long-term
PM2.s exposure and mortality in the Los Angeles area using a new exposure estimation
method that accounted for variations in concentration within the city.10

       As discussed in the PM AQCD, the morbidity studies that combine the features of
cross-sectional and cohort studies provide the best evidence for chronic exposure effects.
Long-term studies evaluating the effect of ambient PM on children's development have
shown  some evidence indicating effects of PM2.5 and/or PMio on reduced lung function
growth (PM AQCD, Section 8.3.3.2.3). In another recent publication included in the 2006
Provisional Assessment, investigators in southern California reported the results of a cross-
sectional study of outdoor PM2.5 and measures of atherosclerosis in the Los Angeles basin.11
The study found significant associations between ambient residential PM2.5 and carotid
intima-media thickness (CIMT), an indicator of subclinical atherosclerosis, an underlying
factor in cardiovascular disease.

2.1.2.3 Roadway-Related Exposure and Health Studies

       A recent body of studies reinforces the findings of these PM morbidity and mortality
effects  by looking at traffic-related exposures, PM measured along roadways, or time spent
in traffic and adverse health effects.  While many of these studies did not measure PM
specifically, they include potential exhaust exposures which include mobile source PM
because they employ indices such as roadway proximity or traffic volumes. One study with
specific relevance to PM2.s health effects is a study that was done in North Carolina looking
at concentrations of PM2.5 inside police cars and corresponding physiological changes in the
police personnel driving the cars. The authors report significant elevations in markers of
cardiac risk associated with concentrations of PM2.5 inside police cars on North Carolina
              19
state highways.   A number of studies of traffic-related pollution have shown associations
between fine particles and adverse respiratory outcomes in children who live near major
roadways.13'14'15

2.1.2.4  Marine Ports and Rail Yard Studies

       Recently, new studies from the State of California provides evidence that PM2.5
emissions within marine ports  and rail yards contribute significantly to elevated ambient
concentrations near these sources16 and that a substantial number of people experience
exposure to fresh locomotive and marine diesel engine emissions, raising potential health
concerns.  Additional information on near roadway, marine port, and rail yard emissions and
potential health effects can be found in Section 2.3.1.4 of this  draft RIA.

2.1.3 Attainment and Maintenance of the PM2.5 NAAQS

       EPA has recently amended the NAAQS for PM2.5 (71 FR 61144, October 17, 2006).
The final rule, signed on September 21, 2006 and published on October 17, 2006, addressed
revisions to the primary and secondary NAAQS for PM to provide increased protection of
public  health and welfare, respectively. The primary PM2.5 NAAQS include a short-term
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


(24-hour) and a long-term (annual) standard. The level of the 24-hour PM2.5 NAAQS has
been revised from 65^ig/m3to 35 ^ig/m3 to provide increased protection against health effects
associated with short-term exposures to fine particles. The current form  of the 24-hour PM2.5
standard was retained (e.g., based on the 98th percentile concentration averaged over three
years). The level of the annual PM2.5 NAAQS was retained at 15^g/m3,  continuing
protection against health effects associated with long-term exposures. The current form of
the annual PM2.5 standard was retained as an annual arithmetic mean averaged over three
years, however, the following two aspects of the spatial averaging criteria were narrowed: (1)
the annual mean concentration at each site shall be within 10 percent of  the spatially
averaged annual mean, and (2) the daily values for each monitoring site  pair shall yield a
correlation coefficient of at least 0.9 for each calendar quarter.

       With regard to the secondary PM2.5 standards, EPA has revised these standards to be
identical in all respects to the revised primary standards. Specifically, EPA has revised the
current 24-hour PM2.s secondary standard by making it identical to the revised 24-hour PM2.s
primary standard and retained the annual PM2.5 secondary standard. This suite of secondary
PM2.5 standards is intended to provide protection against PM-related public welfare effects,
including visibility impairment, effects on vegetation and ecosystems, and material damage
and soiling.

       The proposed emission reductions from this rule would assist PM2.5 nonattainment
areas in reaching the standard by each area's respective attainment date  and assist PM2.5
maintenance areas in maintaining the PM2.s standards in the future. The emission reductions
will also help continue to lower ambient PM levels and resulting health  impacts into the
future. In this section we present  information on current and future PM2.5 levels.

2.1.3.1 Current PM2.5 Air Quality

       A nonattainment area is defined in the Clean Air Act (CAA) as an area that is
violating an ambient standard or is contributing to a nearby area that is violating the standard.
In 2005, EPA designated 39 nonattainment areas for the 1997 PM2.5 NAAQS based on air
quality design values  (using 2001-2003 or 2002-2004 measurements) and a number of other
factors.E(70 FR 943, January 5, 2005; 70 FR 19844, April 14, 2005).  These  areas are
comprised of 208 full or partial counties with a total population exceeding 88 million.  The
1997 PM2.5 nonattainment counties, areas and populations, as of October 2006, are listed in
Appendix 2A to this RIA. The 1997  PM2.5 NAAQS was recently revised and the 2006 PM2.5
NAAQS became effective on December 18, 2006.  Nonattainment areas will be designated
with respect  to the 2006 PM2.5 NAAQS in early 2010.

       As can be seen in Figure 2-1 ambient PM2.5 levels exceeding the 1997 PM2.5 NAAQS
are widespread throughout the country. States with PM2.5 nonattainment areas will be
required to take action to bring those areas into compliance in the future. Most PM2.5
nonattainment areas will be required to attain the 1997 PM2.5 NAAQS in the 2010 to 2015
 '' The full details involved in calculating a PM2.5 design value are given in Appendix N of 40 CFR Part 50.
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Draft Regulatory Impact Analysis
time frame and then be required to maintain the 1997 PM2.5 NAAQS thereafter.F The
attainment dates associated with the potential nonattainment areas based on the 2006 PM2.s
NAAQS would likely be in the 2015 to 2020 timeframe. The emission standards being
proposed in this action would become effective between 2008 and 2017. The expected PM2.5
and PM2.s precursor inventory reductions from the standards being proposed in this action
will be needed by states to attain or maintain the PM2.s NAAQS.

       Table 2-1 provides an estimate  of the counties violating the 2006 PM2.5 NAAQS
based on  2003-05 air quality data. The areas designated as nonattainment for the 2006
PM2.5 NAAQS will be based on three years of air quality data from later years. Also, the
county numbers in the summary table include only the counties with monitors violating the
2006 PM2.5 NAAQS. The monitored  county violations may be an underestimate of the
number of counties and populations that will eventually be included  in areas with multiple
counties designated nonattainment. Currently more than 106 million people live in counties
where monitors show violation of the 2006 standards.
      Table 2-1  Counties violating the 2006 PM2.5 NAAQS based on 2003-2005 Air Quality Data
Fine Particle Standards:
Current Nonattainment Areas and Other Violated Counties

1997 PM2.5 Standards: 39 areas currently designated
2006 PM2.5 Standards: Counties with violating
monitors
Total
Number of Counties
208
49
257
Population
88,394,000
18,198,676
106,592,676
2.1.3.2 Current and Projected Composition of Urban PM2.s for Selected Areas

       Based on CMAQ modeling for the new PM NAAQS standard, a local perspective of
PM2.5 levels and composition was developed by EPA to elaborate further on the nature of the
PM2.5 air quality problem after implementation of the CAIR/CAMR/CAVR rules, the
national mobile rules for light and heavy-duty vehicles and nonroad mobile sources, and
current state programs that were on the books as of early 2005.17 As an illustrative example,
the PM NAAQS RIA developed a localized analysis of current ambient and future-year
speciation for two cities, one in the East (Detroit) and one in the West (Salt Lake City).18

       Figure 2-6 shows projected PM2.5 component species concentrations (i.e., sulfate,
nitrate, elemental carbon, organic aerosols, crustal,  and uncontrollable PM2.5) for current
ambient data (5 year weighted average, 1999-2003) and a 2020 regulatory base case with the
F The EPA finalized PM2.5 attainment and nonattainment areas in April 2005. The EPA finalized the PM
Implementation rule in Nov. 5, 2005, 70 FR 65984).
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                       Chapter 2: Air Quality and Resulting Health and Welfare Effects


addition of the controls mentioned in the previous paragraph. Note that organic aerosols
include directly emitted organic carbon and organic carbon particles formed in the
atmosphere from anthropogenic sources and biogenic sources. Uncontrollable PM2.5 is based
upon a 0.5 pg/m3 PM2.s blank mass correction used in the Speciated Modeled Attainment
Test (SMAT) approach, in which a number of adjustments and additions were made to the
measured species data to provide for consistency with the chemical components retained on
the FRM Teflon filter.19 The analysis provided here specifically looks at one area in the East
(Detroit), and one in the West (Salt Lake City).
 Figure 2-6. Base Case and Projected PM2.5 Component Species Concentrations in Detroit and Salt Lake
                                           City
                    Ambient and Projected 2020 Base Annual Average PM2.5 Species
                            Concentration in Detroit and Salt Lake City
         E 10
            ~-=	=-=-
                     D Nitrate
                     • Elemental Carbon
                     D Organic Aersols
                     DSulfate
                     • Soil
                     D Uncontrollable
               Ambient
                Detroit
 Ambient
Salt Lake City
       Note: The ambient and projected 2020 base case annual design values above are averages taken across
multiple urban area monitors. Thus, while the average 2020 Detroit base case design value reflected above is
lower than the projected base case design values at certain Detroit monitors.
       Notably, organic aerosols constitute a large fraction of the overall remaining PM2.5
mass in Detroit and Salt Lake City. Sulfate is a considerable part of the total PM2.5 mass in
both cities and is the largest contributor to PM2.5 mass in Detroit. Nitrate is a relatively small
source of PM2.s for Detroit but nitrate is the second largest contributor to the remaining PM2.s
problem in Salt Lake City; the exception is that on higher days, nitrate represents the largest
contributor in Salt Lake City. The relatively large contribution of sulfate to PM2.5 mass in
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Draft Regulatory Impact Analysis
Detroit is characteristic of the urban air pollution mixture in the East, while the nitrate
contribution to PM2.s mass in Salt Lake City is characteristic of that found in the West.

2.1.4 Source Apportionment Studies of PM2.s

       Determining sources of fine particulate matter is complicated in part because the
concentrations of various components are influenced by both primary emissions and
secondary atmospheric reactions. As described earlier, when attempting to characterize the
sources affecting PM2.5 concentrations, it is important to note that both regional and local
sources impact ambient levels. In the eastern US, regional fine particles are often dominated
by secondary particles including sulfates, organics (primary and secondary) and nitrates.
These are particles which form through atmospheric reactions of emitted sulfur dioxide,
oxides of nitrogen and ammonia, and are transported over long distances. Conversely, local
contributions to fine particles are likely dominated by directly emitted particulate matter from
sources such as gasoline and diesel mobile sources, including locomotive and marine diesel
engines20, industrial facilities (e.g., iron and steel manufacturing, coke ovens, or pulp mills),
and residential wood and waste burning.

       Development of effective and efficient emission control strategies to lower PM2.5
ambient concentrations can be aided by determining the relationship between the various
types of emissions sources and elevated levels of PM2.5 at ambient monitoring sites. Source
apportionment analyses such as receptor modeling are useful in this regard by both
qualifying and quantifying potential fine particulate regional and local source impacts on a
receptor's ambient concentrations. The goal is to apportion the mass concentrations into
components attributable to the most significant sources. Receptor modeling techniques are
observation-based models which utilize measured ambient concentrations of PM2.5  species to
quantify the contribution that regional and local sources have at a given receptor which, in
this case, is an ambient monitoring location.21 These techniques are very useful in
characterizing fine particulate source contributions to ambient PM2.5 levels; however, there
are inherent limitations including but not limited to the adequacy (e.g., vintage and
representativeness) of existing source profiles in identifying source groups or specific
sources, availability and completeness of ambient datasets to fully inform these techniques,
and current scientific understanding and measured data to relate tracer elements to specific
sources, production processes, or activities. Additionally, commingling of similar species
from different sources in one "factor" can make it difficult to relate the  "factor" to a
particular source.

       A literature compilation summarizing source apportionment studies was conducted as
part of a research and preparation program for the CAIR (EPA,  2005) rule, which was
focused on PM2.5 transport.22 Literature selected in this compilation represented key source
apportionment research, focusing primarily on recent individual source  apportionment
studies in the eastern U.S. The sources identified are grouped into seven categories:
secondary sulfates, mobile, secondary nitrates, biomass burning, industrial, crustal and salt,
and other/not identified. Some of these studies are based on older ambient databases and
more recent ambient data have shown improvement and reduced levels  of ambient PM2.5
concentrations across the U.S., especially in the East, which affects the  quantitative
conclusions  one may draw from these studies. Notably, the relative fraction of sulfates has
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


continued to decrease with the implementation of the acid rain program and removal of sulfur
from motor vehicle fuels.  More routine monitoring for specific tracer compounds that are
unique to individual sources can lead to better separation of blended "factors" such as
secondary commingled sulfates and organic aerosols which are more attributed to emissions
from vehicles and vegetation. Western studies have focused on sources impacting both high
population areas such as Seattle, Denver, the San Joaquin Valley, Los Angeles, San
Francisco as well as national parks_23'24'25'26'27'28'29'30'31'32  More routine monitoring for
specific tracer compounds that are unique to individual sources can lead to better separation
of blended "factors" such as secondary commingled sulfates and organic aerosols which are
more attributed to emissions from vehicles and vegetation.

       As mentioned previously, the sources of PM2.5 can be categorized as either direct
emissions or contributing to secondary formation. The results of the studies showed that
approximately 20 to 60% of the fine particle mass comes from secondarily formed nitrates
and sulfates depending on the area of the country, with nitrates predominantly affecting the
West, sulfates in the East and a mixture of the two in the Industrial Midwest.

       The precursors of these particles are generally gaseous pollutants such as sulfur
dioxide or oxides of nitrogen, which react with ammonia in the atmosphere to form
ammonium salts.  Dominant sources of S02 include power generation facilities, which, are
also sources of NOX along with mobile sources including locomotive and marine diesel
engines. The result of recent and future reductions in precursor emissions from electrical
generation utilities and mobile sources, however, will lead to a reduction in precursor
contributions which would aid in limiting the production of secondary sulfates and nitrates.
Also, reductions in gasoline and diesel fuel sulfur will reduce mobile source SOz emissions.

       In addition, secondary organic carbon aerosols (SOA) also make a large contribution
to the overall total PM2.s concentration in both the Eastern and Western United States. For
many of the receptor modeling studies, the majority of organic carbon is attributed to mobile
source emissions (including both gasoline and diesel). While vehicles emit organic carbon
particulate,  the various organic gases also emitted by these sources react in the atmosphere to
form SOA which shows a correlation to the other secondarily formed aerosols due to
common atmospheric reactions.  As section 2.1.1.3 of this RIA discusses, based on current
data, locomotives and larger marine diesel engines which have similar engine
characterizations emit a relatively large amount of organic PM. Other common sources of
the organic gases which form SOA include vegetation, vehicles, and industrial VOC and
SVOC emissions.  However, due to some limits on data and a lack of specific molecular
markers, current receptor modeling techniques have some difficulty attributing mass to SOA.
Therefore, currently available source apportionment studies may be attributing an unknown
amount of SOA in ambient PM to direct emissions of mobile sources; concurrently, some
secondary organic aerosol found in ambient samples may, as mentioned above, be coming
from mobile sources and not be fully reflected in these assessments. Research is underway to
improve estimates of the contribution of SOA to total fine particulate mass.

       While gaseous precursors of PM2.s are important contributors, urban primary sources
still influence peak local concentrations that exceed the NAAQS,  even if their overall
contributions are smaller. The mixture of industrial source contributions to mass vary across
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Draft Regulatory Impact Analysis
the nation and include emissions from heavy manufacturing such as metal processing (e.g.,
steel production, coke ovens, foundries), petroleum refining, and cement manufacturing,
among others. Other sources of primary PM2.5 are more seasonal in nature. One such source
is biomass burning, which usually contributes more during the winter months when
households burn wood for heat, but also contributes episodically during summer as a result of
forest fires. Other seasonal sources of primary PM include soil, sea salt and road salting
operations that occur in winter months. The extent of these primary source contributions to
local PM2.s problems varies across the U.S. and can even vary within an urban area. The key
for individual areas is to understand the nature of the problem  (i.e., determining the
relationship between various types of emissions sources and elevated levels of PM2.s at
ambient monitoring) in order to develop effective and efficient emission control strategies to
reduce PM2.s ambient concentrations through local control program scenarios

2.1.5 Risk of Future Violations

       States with PM2.5 nonattainment areas will be required to take action to bring those
areas into compliance in the future. Based on the final rule designating and classifying 1997
PM2.5 nonattainment areas, most of these areas will be required to attain the 1997 PM2.5
NAAQS in the 2009 to 2014 time frame and then be required to maintain the PM2.5 NAAQS
thereafter.

       As mentioned in Section 2.1.3, the 1997 PM2.5 NAAQS was recently revised (71 FR
61144, October 17, 2006) and the 2006 NAAQS, effective on December 18, 2006,  revised
the level of the 24-hour PM2.5 standard to 35 pg/m3 from the old standards of 65 pg/m3 and
retained the level of the annual PM2.5 standard at 15 pg/m3.33 The nonattainment areas will be
designated with respect to the 2006 PM NAAQS in early 2010. The attainment dates
associated with the potential new PM2.5 nonattainment areas would likely be in the 2015 to
2020 timeframe. The emission standards being proposed in this action will become effective
between 2008 and 2017 and it is anticipated that the expected PM2.5 inventory reductions
from the standards being proposed will be useful to states seeking to attain or maintain both
the 1997 PM2.5 NAAQS as well as the 2006 PM standards.

       Even with the implementation of all current state and federal regulations, including
the CAIR Rule, the NOX SIP call, nonroad and on-road diesel rules and the Tier 2 rule, there
are projected to be U.S. counties violating the PM2.5 NAAQS well into the future.  EPA
modeling conducted as part of the final PM NAAQS rule projects that in 2015, with all
current controls in effect, up to 52 counties, with a population of 53 million people, may not
attain some combination  of the annual standard of 15 pg/m3 and the daily standard of 35
pg/m3, and that even in 2020 up to 48 counties with a population of 54 million people may
still not be able to attain either the annual, daily, or both the annual and daily PM2.5
standards.34 This does not account for additional areas that have air quality measurements
within 10 percent of the 2006 PM2.s standard. These areas, although not violating the
standards, would also benefit from the emissions reductions being proposed, ensuring long
term maintenance of the PM NAAQS. For example, in 2015, an additional 27 million people
are projected to live  in 54 counties that have air quality measurements within 10 percent of
the 2006 PM NAAQS. In 2020, 25 million people, in 50 counties, will continue to have air
quality measurements within 10 percent of the revised standards. The expected PM2.5
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                     Chapter 2: Air Quality and Resulting Health and Welfare Effects


reductions from this proposed in this action will be needed by states to both attain and
maintain the PM2.5 NAAQS.35

       States and state organizations have told EPA that they will need the reductions
proposed in this proposed rule in order to be able to attain or maintain the 1997 PM2.5
standards as well as necessary to attain the 2006  PM2.5 NAAQS.36

       In conjunction with this rulemaking, we performed a series of PM2.s air quality
modeling simulations for the continental U.S. The model simulations were performed for
five emissions scenarios:

       (1) 2001/2002 baseline projection,

       (2) 2020 baseline projection,

       (3) 2020 projection  with locomotive/marine diesel engine controls,

       (4) 2030 baseline projection, and

       (5) 2030 projection  with locomotive/marine diesel engine controls.

       Further discussion of this modeling, including evaluations of model performance
relative to predicted future  air quality, occur in section 2.1.5.2 of this RIA and also in the AQ
Modeling TSD.

       The model outputs from the2001/2002, 2020 and 2030 baselines, combined with
current air quality data, were used to identify areas expected to exceed the PM2.5 NAAQS in
2020 and 2030. These areas became candidates for being determined to be residual
excedence areas which would require additional  emission reductions to attain and maintain
the PM2.5 NAAQS. The impacts of the locomotive/marine diesel engine controls were
determined by comparing the model results in the future year control runs against the
baseline simulations of the  same year.  This modeling supports the conclusion that there are a
substantial number of counties across the US projected to experience PM2.5 concentrations at
or above the PM2.5 NAAQS in 2020 and 2030. Emission reductions from locomotive and
marine diesel engines will be helpful for these counties in attaining and maintaining the
PM2.5 NAAQS.

2.1.5.1 Air Quality Modeling Results for PM2.5

       According to air quality modeling performed for this rulemaking, the proposed
locomotive and marine diesel engine standards are expected to provide nationwide
improvements in PM2.5 levels.  On a population-weighted basis, the  average modeled future-
year annual PM2.5 design value for all counties is expected to decrease by 0.06 pg/m3 in 2020
and 0.13 pg/m3 in 2030.  In counties predicted to have annual design values greater than 15
pg/m3  the average decrease would be somewhat higher: 0.16 pg/m3 in 2020 and 0.36 pg/m3
in 2030. In addition, those counties that are within 10 percent of the annual PM2.5 design
value would see their average DV decrease by 0.06 pg/m3 in 2020 and 0.23 pg/m3 in 2030.
The maximum decrease for future-year annual PM2.5 design values in 2020 would be
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Draft Regulatory Impact Analysis
0.35pg/m3 and 0.90pg/m3 in 2030.  Note that for the current 39 PM2.s nonattainment areas
the average population weighted modeled future-year annual PM2.s design values would on
average decrease by 0.06pg/m3 in 2020 and by 0.14 pg/m3 in 2030.

       The geographic impact of the proposed locomotive and marine diesel engine controls
in 2030 on annual PM2.s design values (DV) in counties across the US, can be seen in Figure
2-7.  A complete set of maps illustrating the geographic impact of various alternatives
explored as part of this rulemaking are available in Air Quality Modeling TSD for this
rulemaking.
Figure 2-7 Impact of Proposed Locomotive/Marine controls on annual PM2.5 Design Values (DV) in 2030
   Legend

   ^| -0.90 to -0.50
      |-0.49 to-0.25
   Q^ -0.24 to-0.10
   Q^ -0.09 to-0.05
     B -0.04 to no change
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


       Figure 2-7 illustrates that the greatest emission reductions in 2030 are projected to
occur in Southern California where three counties would experience reductions in their PM2.s
design values of -0.50 to -0.90 pg/m3. The next level of emission reductions would occur
among 13 counties geographically dispersed along the Gulf Coast, near St. Louis, and again
Southern California. An additional 325 counties spread across the US would see a decrease
in PM2.5 DV ranging from -0.05 to -0.24 pg/m3.

       Table 2-2 lists the counties with 2020 and  2030 projected annual PM2.5 design values
that violate the annual standard or are within 10 percent of it.  Counties are marked with a
"V" in the table if their projected design values are greater than or equal to 15.05 pg/m3.
Counties are marked with an "X" in the table if their projected design values are greater than
or equal to 13.55 pg/m3, but less than 15.05 pg/m3.  These are counties that are not projected
to violate the standard, but to be close to it, so the  proposed rule will help assure that these
counties continue to meet the standard.  The current design values of these counties are also
listed.  Recall that we project future design values only for counties that have current design
values, so this list is limited to those counties with ambient monitoring data sufficient to
calculate current 3-year design values.
 Table 2-2 Counties with 2020 and 2030 Projected Annual PM2.5Design Values in Violation or within 10
               percent of the Annual PM2.5 Standard. In the Base and Control cases.
State
AL
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
County
Jefferson
Fresno
Imperial
Kern
Kings
Los Angeles
Merced
Orange
Riverside
San Bernardino
San Diego
San Joaquin
1999-2003
Average Design
Value (pg/m3)
19.05
21.85
15.22
22.74
18.52
24.21
16.73
20.39
28.82
25.27
16.44
15.46
2020
Base
V
V
X
V
V
V
V
V
V
V
X
V
Control
V
V
X
V
V
V
V
V
V
V
X
V
2030
Base
V
V
X
V
V
V
V
V
V
V
V
V
Control
V
V
X
V
V
V
V
V
V
V
X
V
2000 Population
662,046
799,406
142,360
661,644
129,460
9,519,334
210,553
2,846,288
1,545,386
1,709,433
2,813,831
563,597
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CA
CA
GA
GA
GA
GA
IL
IL
IL
KY
Ml
MT
NY
OH
OH
OH
OH
PA
PA
TX
WV
WV
Stanislaus
Tulare
Bibb
Clayton
Floyd
Fulton
Cook
Madison
St. Clair
Jefferson
Wayne
Lincoln
New York
Cuyahoga
Hamilton
Jefferson
Scioto
Allegheny
Philadelphia
Harris
Cabell
Kanawha
17.87
23.06
16.42
17.51
16.67
19.51
18.00
17.40
16.87
17.07
19.62
16.24
16.67
19.25
18.55
18.36
19.53
21.17
16.39
14.13
17.22
17.75
V
V
X
X
X
V
V
V
X
X
V
X
X
V
X
X
V
V



X
V
V
X
X
X
V
V
X
X

V
X
X
V
X
X
V
V



X
V
V
X
X
X
V
V
V
X
X
V
X
X
V
X
X
V
V
X
X
X
X
V
V
X
X
X
V
V
V
X
X
V
X
X
V
X
X
V
V
X
X

X
446,996
368,020
153,887
236,516
90,565
816,005
5,376,739
258,940
256,081
693,603
2,061,161
18,837
1,537,194
1,393,977
845,302
73,894
79,195
1,281,665
1,517,549
3,400,577
96,784
200,072
2.1.5.2 PM Air Quality Modeling and Methods

2.1.5.2.1 Air Quality Modeling Overview

       A national scale air quality modeling analysis was performed to estimate future year
annual and daily PM2.s concentrations and visibility. These projections were used as inputs
to the calculation of expected benefits from the locomotive and marine emissions controls
considered in this assessment. The 2001-based CMAQ modeling platform was used as the
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


tool for the air quality modeling of future baseline emissions and control scenarios. In
addition to the CMAQ model, the modeling platform includes the emissions, meteorology,
and initial and boundary condition data which are inputs to this model. The CMAQ model is
a three-dimensional grid-based  Eulerian air quality model designed to estimate the formation
and fate of oxidant precursors, primary and secondary particulate matter concentrations and
deposition over regional and urban spatial scales (e.g., over the contiguous U.S.).37 38 39
Consideration of the different processes that affect primary (directly emitted) and secondary
(formed by atmospheric processes) PM at the regional scale in different locations is
fundamental to understanding and assessing the effects of pollution control measures that
affect PM, ozone and deposition of pollutants to the surface.

       The CMAQ model was  peer-reviewed in 2003 for EPA as reported in "Peer Review
of CMAQ Model".40  The latest version of CMAQ (Version 4.5) was employed for this
modeling analysis. This version reflects updates in a number of areas to improve the
underlying science and address comments from the peer-review including (1) use of a state-
of-the-science inorganic nitrate partitioning module (ISORROPIA) and updated gaseous,
heterogeneous chemistry in the calculation of nitrate formation, (2) a state-of-the-science
secondary organic aerosol (SOA)  module that includes a more comprehensive gas-particle
partitioning algorithm from both anthropogenic and biogenic SOA, (3) an in-cloud sulfate
chemistry module that accounts for the nonlinear sensitivity of sulfate formation to varying
pH, and (4) an updated CB-IV gas-phase  chemistry mechanism and aqueous chemistry
mechanism that provide a comprehensive simulation of aerosol precursor oxidants.41

2.1.5.2.2 Model Domain and Configuration

       As shown in Figure 2-8 the CMAQ modeling domain encompasses all of the lower 48
States and portions of Canada and Mexico (Figure 2.1-6). The domain extends from  126
degrees to 66 degrees west longitude and from  24 degrees north latitude to 52 degrees north
latitude. The horizontal grid cells  are approximately 36 km by 36 km. The modeling domain
contains 14 vertical layers with the top of the modeling domain at about 16,200 meters, or
100 mb.

             Figure 2-8. Map of the CMAQ modeling domain.
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Draft Regulatory Impact Analysis
2.1.5.2.3 Model Inputs

       The key inputs to the CMAQ model include emissions from anthropogenic and
biogenic sources, meteorological data, and initial and boundary conditions. The CMAQ
meteorological input files were derived from a simulation of the Pennsylvania State
University / National Center for Atmospheric Research Mesoscale Model42 for the entire year
of 2001. This model, commonly referred to as MM5, is a limited-area, nonhydrostatic,
terrain-following system that solves for the full set of physical and thermodynamic equations
which govern atmospheric motions. For this analysis, version 3.6.1 of MM5 was used.  The
horizontal domain consisted of a single 36 x 36 km grid with 165 by 129 cells, selected to
maximize the coverage of the ETA model analysis region and completely cover the CMAQ
modeling domain with some buffer to avoid boundary effects.  The meteorological outputs
from MM5  were processed to create model-ready inputs for CMAQ using the Meteorology-
Chemistry Interface Processor (MCIP) version 3.1 to derive the specific inputs to CMAQ:
horizontal wind components (i.e., speed and direction), temperature, moisture, vertical
diffusion rates, and rainfall rates for each grid cell in each vertical layer.43

       The lateral boundary and initial species concentrations are provided by a three-
dimensional global atmospheric chemistry model, the GEOS-CHEM model.44 The global
GEOS-CHEM model simulates atmospheric chemical and physical processes driven by
assimilated meteorological observations from the NASA's Goddard Earth Observing System
(GEOS). This model was run for 2001 with a grid resolution of 2 degree x 2.5 degree
(latitude-longitude) and 20 vertical layers. The predictions were used to provide one-way
dynamic boundary conditions at three-hour intervals and an initial concentration field for the
CMAQ simulations.

       A complete description of the development and processing of model-ready
meteorological inputs and initial and boundary condition inputs used for this analysis are
discussed in the CAIR TSD.45  In addition, the development of the gridded, hourly model-
ready emissions inputs used for the 2001 base year and each of the future year base cases and
control scenarios are summarized above in Chapter 2.

2.1.5.2.4 CMAQ Evaluation

       An operational model performance evaluation for PM2.5 and its related speciated
components (e.g., sulfate, nitrate,  elemental carbon, organic carbon, etc.) was conducted
using the 2001 data in order to estimate the ability of the CMAQ modeling system to
replicate base year concentrations. In summary, model performance statistics were
calculated for observed/predicted pairs of daily/monthly/seasonal/annual concentrations.
Statistics were generated for the following geographic groupings: domain wide, Eastern vs.
Western (divided along the 100th meridian), and each Regional Planning Organization
(RPO)  region.46 The "acceptability" of model performance was judged by comparing our
results  to those found in recent regional PM2.5 model applications for other, non-EPA
studies47. Overall, the performance for this application is within the range or better than
these other  applications.  A detailed summary of the  2001 CMAQ model performance
evaluation is available within the PM NAAQS RIA, Appendix 0.
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2.1.5.2.5 Model Simulation Scenarios

       As part of our analysis the CMAQ modeling system was used to calculate daily and
annual PM2.5 concentrations and visibility estimates for each of the following eleven
emissions scenarios:

       2001 base year

       2020 base line projection 2020 with projection of impact of primary
locomotive/marine control case, low control option, high control option, and a locomotive
only control case

       2030 base line projection

       2030 with projection of impact of primary locomotive/marine control case, low
control option, high control option, and a locomotive-only control case

       We use the predictions from the model in a relative sense by combining the 2001
base-year predictions with predictions from each future-year scenario and speciated ambient
air quality observations to determine PM2.s concentrations and visibility for each of the 2020
and 2030 scenarios.  After completing this process, we then calculated daily and seasonal PM
air quality metrics as inputs to the health and welfare impact functions of the benefits
analysis. The following sections provide a more detailed discussion of our air quality
projection method and a summary of the results.

2.1.5.2.6 Projection Methodology for Annual Average Design Values

       The procedures used to project the annual design values are generally consistent with
the projection techniques used in the Clean Air Interstate Rule (CAIR).  The projected annual
design values were calculated using the Speciated Modeled Attainment Test (SMAT)
approach. The SMAT uses an FRM mass construction methodology that results in reduced
nitrates (relative to the amount measured by routine speciation networks), higher mass
associated with sulfates (reflecting water included in FRM measurements), and a measure of
organic carbonaceous mass that is derived from the difference between measured PM2.s and
its non-carbon components.  This characterization of PM2.5 mass also reflects crustal material
and other minor constituents. The resulting characterization provides a complete mass
balance. It does not have  any unknown mass that is sometimes presented as the difference
between measured PM2.5 mass and the characterized chemical components derived from
routine speciation measurements. However, the assumption that all mass difference is
organic carbon has not been validated in many  areas of the US. The SMAT methodology
uses the following PM2.5 species components:  sulfates, nitrates, ammonium, organic carbon
mass, elemental carbon, crustal, water, and blank mass (a fixed value of 0.5 pg/m3).

       More complete details of the SMAT procedures used in the CAIR analysis can be
found in the report "Procedures for Estimating  Future PM2.5 Values for the CAIR Final Rule
by Application of the (Revised) Speciated Modeled Attainment Test (SMAT)".48 For this
latest analysis, several datasets and techniques were updated. The changes and updates
include:
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Draft Regulatory Impact Analysis
       1) Revised database of PM2 5 speciation data which includes data from 2002 and
       2003.

       2) Revised interpolations of PM2.5 species data using updated techniques.

       3) An updated equation to calculate particle bound water.

       4) Revised treatment of ambient ammonium data.

       Documentation of these updates and changes can be found in "Procedures for
Estimating Future PM2.5 Values for the PM NAAQS Final Rule by Application of the
Speciated Modeled Attainment Test (SMAT)"  (EPA,  2006).49 Below are the steps we
followed for projecting future PM2.5 concentrations. These steps were performed to estimate
future case concentrations at each FRM monitoring site. The starting point for these
projections is a 5 year weighted average design value for each site. The weighted average is
calculated as the average of the 1999-2001, 2000-2002, and 2001-2003 design values at each
monitoring site.  By averaging 1999-2001, 2000-2002, and 2001-2003, the value from 2001
is weighted three times, whereas, values for 2000 and 2002 are each weighted twice, and
1999 and 2003 are each weighted once. This approach has the desired benefits of (1)
weighting the PM2.s values towards the middle year of the five-year period (2001), which is
the Base Year for our emissions projections,  and (2) smoothing out the effects of year-to-year
variability in emissions and meteorology that occurs over the full five-year period. This
approach provides a robust estimate of current air quality for use as a basis for future year
projections.

       Step  1: Calculate  quarterly mean ambient concentrations for  each of the major
components  of PM2.s (i.e., sulfate, nitrate, ammonium, elemental carbon, organic carbon,
water, and crustal material) using the component species concentrations estimated for each
FRM site.

       The component species concentrations were estimated using an average of 2002 and
2003 ambient data from speciation monitors. The speciation data was interpolated to provide
estimates for all FRM sites across the country.  The interpolated component concentration
information was used to calculate species fractions  at each FRM site. The estimated
fractional composition of each species (by quarter) was then multiplied by the 5 year
weighted average 1999-2003 FRM quarterly mean concentrations at each site (e.g., 20
percent sulfate multiplied by  15.0 pg/m3 of PM2.5 equals 3 pg/m3 sulfate).  The end result is a
quarterly concentration for each of the PM2.5 species at each FRM site.

       Step  2: Calculate  quarterly average Relative Reduction Factors (RRFs) for sulfate,
nitrate, elemental carbon,  organic carbon, and crustal  material.  The species-specific RRFs
for the location of each FRM are the ratio of the 2015 (or 2020) future year cases to the  2001
Base Year quarterly average model predicted species  concentrations. The species-specific
quarterly RRFs are then multiplied by the corresponding 1999-2003 quarterly species
concentration from Step 1. The result is the future case quarterly average concentration for
each of these species for each future year model run.
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


       Step 3:  Calculate future case quarterly average concentrations for ammonium and
particle-bound water. The future case concentrations for ammonium are calculated using the
future case sulfate and nitrate concentrations determined from Step 2 along with the degree
of neutralization of sulfate (held constant from the base year). Concentrations of particle-
bound water are calculated using an empirical equation derived from the AIM model using
the concentrations of sulfate, nitrate, and ammonium as inputs.

       Step 4:  Calculate the mean of the four quarterly average future case concentrations to
estimate future  annual average concentration for each component species. The annual
average concentrations of the components are added together to obtain the future annual
average concentration for PM2.s.

       Step 5:  For counties with only one monitoring site, the projected value at that site is
the future case value for that county. For counties with more than one monitor, the highest
future year value in the county is selected as the concentration for that county.

2.1.6 Environmental Effects of PM Pollution

       In this section we discuss public welfare effects of PM and its precursors including
visibility impairment, atmospheric deposition, and materials damage and soiling.

2.1.6.1  Visibility Impairment

       Visibility can be defined as the degree to which the atmosphere is transparent to
visible light.50 Visibility impairment manifests  in two principal ways: as local visibility
impairment and as regional haze.51 Local visibility impairment may take the form of a
localized plume, a band or layer of discoloration appearing well above the  terrain as a result
from complex local meteorological conditions.  Alternatively, local visibility impairment
may manifest as an urban haze, sometimes referred to as a "brown cloud."  This urban haze
is largely caused by emissions from multiple sources in the urban areas and is not typically
attributable to only one nearby source or to long-range transport. The second type of
visibility impairment, regional haze, usually results from multiple pollution sources spread
over a large geographic region. Regional haze can impair visibility over large regions and
across states.

       Visibility is important because it has direct significance to people's enjoyment of
daily activities in all parts of the country.  Individuals value good visibility for the well-being
it provides them directly, where they live and work, and in places where they enjoy
recreational opportunities. Visibility is also highly valued in significant natural areas such as
national parks and wilderness areas, and special emphasis is given to protecting visibility in
these areas. For more information on visibility see the PM AQCD as well  as the 2005 PM
Staff Paper.52'53

           Fine particles are the major cause of reduced visibility in parts of the United
States. To address the welfare effects of PM on visibility, EPA set secondary PM2.s
standards which would work in conjunction with the establishment of a regional haze
program.  The secondary (welfare-based) PM2.s NAAQS was established as equal to the suite
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Draft Regulatory Impact Analysis
of primary (health-based) NAAQS. Furthermore, Section 169 of the Act provides additional
authority to remedy existing visibility impairment and prevent future visibility impairment in
the  156 national parks, forests and wilderness areas labeled as mandatory class I federal areas
(62 FR 38680-81, July 18, 1997). These areas are defined in Section 162 of the Act as those
national parks exceeding 6,000 acres, wilderness areas and memorial parks exceeding 5,000
acres, and all international parks which were in existence on August 7, 1977. In July 1999
the  regional haze rule (64 FR 35714) was put in place to protect the visibility in mandatory
class I federal areas. A list of the mandatory class I federal areas is included in Appendix
2D. Visibility can be said to be impaired in both PM2.5 nonattainment areas and mandatory
class I federal areas.

          Control of locomotive and marine diesel engine emissions will improve visibility
across the nation.  The PM and NOX emissions from locomotive and marine diesel engines
subject to this proposed rule either directly emit PM2.5 or contribute to formation of
secondary PM-precursors and contribute to these visibility effects.  This is evident in the
PM2.5 visibility modeling completed for this rulemaking.  In this section we present current
information and projected estimates about both visibility impairment related to ambient
PM2.5 levels across the country and visibility impairment in mandatory class I federal areas.
We conclude that visibility will continue to be impaired in the future and the projected
emission reductions from this proposed action will help improve visibility conditions across
the  country and in mandatory class I federal areas. More detailed discussions on visibility
are  contained in the EPA PM AQCD and the revised PM NAAQS rule RIA.54'55

2.1.6.1.1 Current Visibility Impairment

       The need for reductions in the levels of PM2.5 is widespread. Currently, high ambient
PM2.s levels are measured throughout the country. Fine particles may remain suspended for
days or weeks and travel hundreds to thousands of kilometers, and  thus fine particles emitted
or created in one county may contribute to ambient concentrations  in a neighboring region.56

       As mentioned above the secondary PM2.5 standards were set as equal to the suite of
primary PM2.5 standards. Recently designated PM2.5 nonattainment areas indicate that almost
90 million people live in 208 counties that are in nonattainment for the 1997 PM2.5 NAAQS,
(see Appendix 2A for the complete list of current nonattainment areas). Thus, at least these
populations (plus others who travel to these areas) would likely be  experiencing visibility
impairment.

       As discussed in the Staff Paper (EPA 2004, section 6.2), in  mandatory class I federal
areas, visibility levels on the 20 percent haziest days in the West are about equal to levels on
the  20 percent best days in the East. Despite improvement through the 1990's, visibility in
the  rural East remains significantly impaired, with an  average visual range of approximately
20 km on the 20 percent haziest days (compared to the naturally occurring visual range in the
eastern US of about 150 ±45km). In the rural West, the average visual range showed little
change over this period, with an average visual range  of approximately 100km on the 20
percent haziest days (compared to the naturally occurring visual range in the western US of
about 230 ±40km).
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


       In urban areas, visibility levels show far less difference between eastern and western
regions.  For example, the average visual ranges on the 20 percent haziest days in eastern
and western urban areas are approximately 20 km and 27 km, respectively (Schmidt et al.,
2005). Even more similarity is seen in considering 4-hour (12 to 4 pm.) average PM2.s
concentrations for which the average visual ranges on the 20 percent haziest days in eastern
and western urban areas are approximately 26 km and 31 km, respectively (Schmidt et al.,
2005).

2.1.6.1.2 Current Visibility Impairment at Mandatory Class I Federal Areas

       Detailed information about current and historical visibility conditions in mandatory
class I federal areas is summarized in the EPA Report to Congress and the 2002 EPA Trends
Report.57'58 The conclusions draw upon the Interagency Monitoring of Protected Visual
Environments  (IMPROVE) network data. One of the objectives of the IMPROVE
monitoring network program is to provide regional haze monitoring representing all
mandatory class I federal areas where practical. The National Park Service report also
describes the state of national park visibility conditions and discusses the need for
improvement'59

       The regional haze rule requires states to establish goals for each affected mandatory
class I federal area that  1) improves visibility on the haziest days (20% most impaired days),
2) ensures no degradation occurs on the cleanest days (20% least impaired days), and  3)
achieves natural background visibility levels by 2064. Although there have been general
trends toward improved visibility, progress is still needed on the haziest days. Specifically,
as discussed in the 2002 EPA Trends Report, without the effects of pollution a natural visual
range in the United States is approximately 75 to 150 km in the East and 200 to 300 km in
the West. In 2001, the mean visual range for the worst days was 29 km in the East and 98
km in the West.60 Table 2-3  below provides the current visibility deciviews for each of the
116 monitored federal class 1  areas along with the natural background values for each area.

       The level of visibility impairment in an area is based on the light-extinction
coefficient and a unitless visibility index, called a "deciview", which is used in the valuation
of visibility. The deciview metric provides a scale for perceived visual changes over the
entire range of conditions, from clear to hazy. Under many scenic conditions, the average
person can generally  perceive a change of one deciview. The higher the deciview value, the
worse the visibility. Thus, an improvement in visibility is a decrease in deciview value.

2.1.6.1.3 Future Visibility Impairment

       Additional emission reductions will be needed from a broad set of sources, including
those proposed in this action, as part of the overall strategy to achieve the  visibility goals of
the Act and the regional haze program.

       Modeling conducted for this proposed rule was used to project visibility conditions in
116 of the mandatory class I federal areas across the US in 2020 and 2030 as a result of the
proposed locomotive and marine diesel standards. The results indicate that improvements in
visibility would occur in all 116 mandatory class I federal areas, although all these areas
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Draft Regulatory Impact Analysis
would continue to have annual average deciview levels above background in both 2020 and
2030. Table 2-3 below indicates the current monitored deciview values, the natural
background levels each area is attempting to reach, and also the projected deciview values in
2020 and 2030 with and without the proposed standards. In 2030, the greatest visibility
improvement due to this proposed rule would occur at Agua Tibia (-0.24 deciview) located in
San Diego County, California followed by San Georgonio (-0.22 deciview) in San Bernadino
County, California.

Table 2-3 Current and Future projected Visibility Conditions With and Without Proposed Locomotive
and Marine Diesel Rule in Mandatory Class I Federal Areas (Annual Average Deciview)
Annual Results
Site name
Acadia
Agua Tibia
Anaconda - Pintler
Arches
Badlands
Bandelier
Big Bend
Black Canyon of the
Gunnison
Desolation
Bob Marshall
Boundary Waters Canoe
Area
Bryce Canyon
Bridger
Brigantine
Cabinet Mountains
Caney Creek
Canyonlands
Caribou
Carlsbad Caverns
Chassahowitzka
Chiricahua NM
Chiricahua W
Craters of the Moon
Dome Land
Dolly Sods
Eagles Nest
Emigrant
Everglades
state
ME
CA
MT
UT
SD
NM
TX
CO
CA
MT
MN
UT
WY
NJ
MT
AR
UT
CA
NM
FL
AZ
AZ
ID
CA
WV
CO
CA
FL
DeciViews"
1998-2002
Baseline
Visibility
(deciviews)
22.7
23.2
18.0
12.3
12.0
17.3
13.2
18.4
11.6
14.2
20.0
11.5
27.6
12.0
13.8
25.9
12.0
25.9
14.8
17.6
25.7
13.9
13.9
14.7
12.9
27.6
20.3
19.6
2020base
case
without
controls
12.84
16.03
7.53
8.19
11.42
8.63
12.16
6.84
7.63
9.25
12.06
7.53
6.98
18.49
8.55
17.52
8.06
7.64
11.74
18.54
8.60
8.60
8.74
11.89
16.79
6.26
9.50
14.33
2020 base
case with
proposed
controls
12.83
15.94
7.52
8.18
11.39
8.62
12.15
6.83
7.61
9.24
12.04
7.51
6.97
18.46
8.53
17.47
8.06
7.62
11.73
18.52
8.59
8.59
8.72
11.87
16.77
6.25
9.49
14.32
2030 base
case
without
controls
12.88
15.98
7.53
8.22
11.38
8.66
12.17
6.83
7.59
9.24
12.10
7.53
6.97
18.61
8.57
17.52
8.09
7.60
11.74
18.62
8.59
8.59
8.71
11.73
16.84
6.26
9.41
14.40
2030 base
case with
proposed
controls
12.87
15.74
7.51
8.19
11.32
8.63
12.15
6.81
7.55
9.21
12.04
7.51
6.95
18.55
8.52
17.43
8.08
7.55
11.71
18.58
8.57
8.57
8.66
11.66
16.80
6.24
9.37
14.38
Natural
Background
(deciviews)
11.5
7.2
7.9
7.3
7.0
7.3
7.0
6.9
7.1
7.4
11.2
7.1
11.3
7.0
7.4
11.3
7.0
11.4
7.3
7.0
11.5
6.9
6.9
7.1
7.1
11.3
7.1
7.3
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Chapter 2: Air Quality and Resulting Health and Welfare Effects
Fitzpatrick
Flat Tops
Galiuro
Gates of the Mountains
Gila
Glacier
Glacier Peak
Grand Teton
Great Gulf
Great Sand Dunes
Great Smoky Mountains
Guadalupe Mountains
Hells Canyon
Isle Royale
Jarbidge
James River Face
Joshua Tree
Joyce Kilmer - Slickrock
Kalmiopsis
Kings Canyon
Lava Beds
La Garita
Lassen Volcanic
Linville Gorge
Lostwood
Lye Brook
Mammoth Cave
Marble Mountain
Maroon Bells -
Snowmass
Mazatzal
Medicine Lake
Mesa Verde
Mingo
Mission Mountains
Mount Hood
Mokelumne
Moosehorn
Mount Rainier
Mount Jefferson
Mount Washington
Mount Zirkel
North Cascades
Okefenokee
Otter Creek
Pasayten
Petrified Forest
WY
CO
AZ
MT
NM
MT
WA
WY
NH
CO
TN
TX
OR
MI
NV
VA
CA
NC
OR
CA
CA
CO
CA
NC
ND
VT
KY
CA
CO
AZ
MT
CO
MO
MT
OR
CA
ME
WA
OR
OR
CO
WA
GA
WV
WA
AZ
11.3
17.6
20.3
11.5
11.3
13.9
11.2
13.5
19.5
14.0
12.1
23.2
13.1
29.5
17.6
18.1
21.1
28.5
12.6
19.5
29.5
14.8
23.5
11.6
14.8
16.6
27.9
19.6
23.9
30.2
17.1
11.3
13.1
17.7
12.8
27.5
14.2
12.9
21.4
14.0
15.7
18.9
15.7
11.7
14.0
26.4
6.98
6.32
8.58
6.43
8.20
12.38
7.61
7.55
12.87
8.52
18.16
11.76
10.66
12.48
7.11
17.89
12.35
18.16
9.02
16.46
8.21
7.19
7.68
16.84
13.24
12.71
19.95
9.13
6.15
9.38
12.38
8.16
19.15
8.91
7.55
7.69
13.23
10.31
8.21
8.31
7.70
7.76
17.83
16.74
7.67
8.54
6.97
6.31
8.57
6.42
8.19
12.32
7.59
7.54
12.87
8.51
18.12
11.74
10.63
12.46
7.10
17.84
12.30
18.12
9.01
16.44
8.18
7.18
7.66
16.80
13.22
12.70
19.91
9.11
6.14
9.37
12.35
8.15
19.09
8.90
7.53
7.68
13.23
10.28
8.20
8.29
7.69
7.75
17.80
16.71
7.65
8.50
6.97
6.33
8.58
6.43
8.20
12.40
7.67
7.53
12.90
8.51
18.19
11.76
10.64
12.50
7.11
17.93
12.34
18.19
9.02
16.36
8.18
7.19
7.64
16.87
13.19
12.75
19.97
9.09
6.16
9.43
12.34
8.18
19.15
8.89
7.63
7.63
13.26
10.37
8.25
8.36
7.72
7.81
17.87
16.77
7.67
8.55
6.95
6.31
8.55
6.40
8.18
12.29
7.63
7.51
12.89
8.50
18.11
11.72
10.56
12.45
7.08
17.83
12.20
18.11
8.99
16.30
8.12
7.18
7.59
16.80
13.15
12.73
19.87
9.04
6.14
9.40
12.28
8.16
19.02
8.87
7.56
7.60
13.25
10.30
8.20
8.32
7.70
7.79
17.80
16.73
7.62
8.48
7.1
7.1
11.2
7.1
7.1
6.9
7.2
7.0
7.6
7.8
7.1
11.3
7.1
11.4
7.0
7.3
11.2
11.2
7.1
7.1
11.5
7.7
7.1
7.1
7.3
7.5
11.4
7.3
11.3
11.5
7.7
7.1
6.9
7.3
7.1
11.3
7.4
7.1
11.4
7.8
7.8
7.9
7.9
7.1
7.8
11.5
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Draft Regulatory Impact Analysis
Pine Mountain
Presidential Range - Dry
Rawah
Red Rock Lakes
Redwood
Cape Romain
Rocky Mountain
Roosevelt Campobello
Salt Creek
San Gorgonio
San Jacinto
San Pedro Parks
Sawtooth
Scapegoat
Selway - Bitterroot
Seney
Sequoia
Shenandoah
Sierra Ancha
Sipsey
Alpine Lakes
South Warner
Eagle Cap
Strawberry Mountain
Swanquarter
Sycamore Canyon
Teton
Theodore Roosevelt
Three Sisters
Superstition
Thousand Lakes
UL Bend
Upper Buffalo
Voyageurs
Weminuche
West Elk
Wind Cave
Wolf Island
Yellowstone
Yolla Bolly - Middle Eel
Yosemite
Zion
AZ
NH
CO
WY
CA
SC
CO
ME
NM
CA
CA
NM
ID
MT
MT
MI
CA
VA
AZ
AL
WA
CA
OR
OR
NC
AZ
WY
ND
OR
AZ
CA
MT
AR
MN
CO
CO
SD
GA
WY
CA
CA
UT
27.6
14.7
13.5
13.1
23.2
11.7
12.1
16.5
14.1
21.4
17.7
21.5
21.5
11.4
13.6
14.2
12.3
23.8
23.5
27.6
13.4
28.7
16.6
19.6
14.7
24.6
16.1
12.1
17.6
14.8
15.7
14.7
25.5
18.4
11.6
11.3
16.0
26.4
12.1
17.1
17.6
13.5
9.30
12.61
7.55
7.53
9.49
17.14
8.36
13.35
12.12
13.72
13.33
7.20
8.49
9.09
7.53
13.22
15.96
16.26
9.50
19.15
10.92
8.31
11.25
11.35
16.39
10.71
7.71
11.96
8.31
9.89
7.68
9.16
16.89
11.25
6.90
6.18
9.56
18.14
7.69
9.31
9.30
8.92
9.29
12.61
7.54
7.52
9.46
17.10
8.34
13.34
12.09
13.63
13.22
7.19
8.48
9.07
7.51
13.20
15.93
16.23
9.49
19.10
10.88
8.29
11.21
11.33
16.37
10.66
7.70
11.89
8.29
9.87
7.66
9.15
16.85
11.23
6.89
6.17
9.52
18.11
7.67
9.30
9.28
8.89
9.29
12.66
7.55
7.51
9.46
17.28
8.37
13.37
12.07
13.65
13.12
7.20
8.48
9.08
7.54
13.27
15.73
16.27
9.50
19.16
11.03
8.27
11.24
11.34
16.43
10.72
7.70
11.91
8.36
9.86
7.64
9.13
16.88
11.25
6.89
6.19
9.55
18.18
7.67
9.28
9.21
8.95
9.26
12.66
7.53
7.49
9.38
17.17
8.33
13.37
12.02
13.43
12.85
7.18
8.46
9.06
7.48
13.21
15.66
16.20
9.47
19.06
10.92
8.23
11.14
11.28
16.39
10.64
7.68
11.79
8.32
9.84
7.59
9.10
16.79
11.21
6.88
6.17
9.47
18.13
7.65
9.23
9.17
8.90
11.3
7.8
7.0
6.9
11.3
7.1
7.1
7.8
7.1
11.4
7.0
7.1
7.1
7.0
7.2
7.3
7.3
11.4
7.1
11.3
6.9
11.4
7.3
7.5
6.9
11.2
7.0
7.1
7.3
7.3
7.9
7.2
11.3
11.1
7.1
7.1
7.2
11.4
7.1
7.4
7.1
7.0
a) The level of visibility impairment in an area is based on the light-extinction coefficient and a unitless
visibility index, called a "deciview", which is used in the valuation of visibility. The deciview metric provides
a scale for perceived visual changes over the entire range of conditions, from clear to hazy. Under many scenic
conditions, the average person can generally perceive a change of one deciview. The higher the deciview
value, the worse the visibility. Thus, an improvement in visibility is a decrease in deciview value.
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2.1.6.1.4  Visibility Modeling Methodology

       The modeling platform described in Section 2.1.5 above was also used to project
changes in visibility.  The estimate of visibility benefits was based on the projected
improvement in annual average visibility at mandatory class I federal areas.  There are 156
Federally mandated Class I areas which, under the Regional Haze Rule, are required to
achieve natural background visibility levels by 2064. These mandatory class I federal areas
are mostly national parks, national monuments, and wilderness areas.  There are currently
110 Interagency Monitoring of Protected Visual Environments (IMPROVE) monitoring sites
(representing all 156 mandatory class I federal areas) collecting ambient PM2.s data  at
mandatory class I federal areas, but only 81 of these sites have complete data for 2001. For
this analysis, we quantified visibility improvement at the 116 mandatory class I federal areas
which have complete IMPROVE ambient data for 2001 or are  represented by IMPROVE
monitors with complete data.G

       Visibility impairment is quantified in extinction units.  Visibility degradation is
directly proportional to decreases in light transmittal in the atmosphere. Scattering and
absorption by both gases and particles decrease light transmittance. To quantify changes  in
visibility, our analysis computes a light-extinction coefficient (bext) and visual range. The
light extinction coefficient is based on the work of Sisler (1996), which shows the total
fraction of light that is decreased per unit distance.  This coefficient accounts for the
scattering and absorption of light by both particles and  gases and accounts for the higher
extinction efficiency of fine particles compared to coarse particles. Fine particles with
significant light-extinction efficiencies include sulfates, nitrates, organic carbon, elemental
carbon, and soil (Sisler, 1996).

       Visual range is a measure of visibility that is inversely related to the extinction
coefficient. Visual range can be defined as the maximum distance at which one can identify
a black object against the horizon sky. Visual range (in units of kilometers) can be calculated
from bext using the formula: Visual Range (km) = 3912/bext  (bext units are inverse
megameters [Mm4])

       The future year visibility impairment was  calculated  using a methodology which
applies modeling results in a relative sense similar to the Speciated Modeled Attainment Test
(SMAT).

       In calculating visibility impairment, the extinction coefficient is made up of
individual component species (sulfate, nitrate, organics, etc). The predicted change in
visibility is calculated as the percent change in the extinction coefficient for each of the PM
species (on a daily average basis).  The individual daily species extinction coefficients are
summed to get a daily total extinction value.  The daily extinction coefficients are converted
G There are 81 IMPROVE sites with complete data for 2001. Many of these sites collect data that is
"representative" of other nearby unmonitored mandatory class I federal areas. There are a total of 116
mandatory class I federal areas that are represented by the 81 sites. The matching of sites to monitors is taken
from "Guidance for Tracking Progress Under the Regional Haze Rule".
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Draft Regulatory Impact Analysis
to visual range and then averaged across all days.  In this way, we can calculate annual
average extinction and visual range at each IMPROVE site. Subtracting the annual average
control case visual range from the base case visual range gives a projected improvement in
visual range (in km) at each mandatory class I federal area. This serves as the visibility input
for the benefits analysis (See Chapter 6).

       For visibility calculations, we are continuing to use the IMPROVE program species
definitions and visibility formulas which are recommended in the draft modeling guidance.
Each IMPROVE site has measurements of PM2.s species and therefore we do not need to
estimate the species fractions in the same way that we did for FRM sites (using interpolation
techniques and other assumptions concerning volatilization of species).

2.1.6.2  Other PM Related Welfare Effects

       Particulate matter contributes to adverse effects on vegetation and ecosystems, and to
soiling and materials damage. These welfare effects result predominately from exposure to
excess amounts of specific chemical species, regardless of their source or predominant form
(particle, gas or liquid).  Reflecting this fact, the PM AQCD concludes that regardless of size
fractions, particles containing nitrates and sulfates have the greatest potential for widespread
environmental significance, while effects are also related to other chemical constituents
found in ambient PM, such as trace metals and organics.  (The Staff Paper notes that some of
these other components  are regulated under separate statutory authorities, e.g.,  section 112 of
the CAA.)  The following characterizations of the nature of these welfare effects are based on
the information contained in the PM AQCD and Staff Paper.

2.1.6.2.1 Effects on Vegetation and Ecosystems

       Potentially adverse PM-related effects on vegetation and ecosystems are principally
associated with particulate nitrate and sulfate deposition.  In characterizing such effects,  it is
important to recognize that nitrogen and sulfur are necessary and beneficial nutrients for
most organisms that make up ecosystems, with optimal  amounts of these nutrients varying
across organisms, populations, communities, ecosystems and time scales.  Therefore, it is
impossible to generalize to all species in all circumstances as to the amount at which inputs
of these nutrients or acidifying compounds become stressors. The Staff Paper recognizes the
public welfare benefits from the use of nitrogen (N) and sulfur (S) nutrients in fertilizers in
managed agricultural and commercial forest settings.

2.1.6.2.1.1  Vegetation Effects

       At current ambient levels, risks to vegetation from short-term exposures to dry
deposited particulate nitrate or sulfate are low.  However, when found in acid or acidifying
deposition, such particles do have the potential to cause direct leaf injury.  Specifically, the
responses of forest trees to acid precipitation (rain, snow) include accelerated weathering of
leaf cuticular surfaces, increased permeability of leaf surfaces to toxic materials, water, and
disease agents; increased leaching of nutrients from foliage; and altered reproductive
processes—all which serve to weaken trees so that they are more susceptible to other stresses
(e.g., extreme weather, pests, pathogens). Acid deposition with levels of acidity associated
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


with the leaf effects described above are currently found in some locations in the eastern US
(EPA 2003). Even higher concentrations of acidity can be present in occult depositions (e.g.,
fog, mist or clouds)  which more frequently impacts higher elevations. Thus, the risks of leaf
injury occurring from acid deposition in some areas of the eastern U.S.  is high.  However,
based on currently available information, the contribution of particulate sulfates and nitrates
to the total acidity found at  these locations is not clear.

2.1.6.2.1.2  Ecosystem Effects

       The nitrogen and sulfur containing components of PM have been associated with a
broad spectrum of ecosystems impacts that result from either the nutrients or acidifying
characteristics of the deposited compounds.

       Reactive nitrogen is the form of nitrogen that is available to support the growth of
plants and microorganisms. Since the mid-1960's reactive nitrogen creation through natural
processes has been overtaken by reactive nitrogen creation as a result of human processes,
and is now accumulating in the environment on the local, regional and global scale. Some
reactive nitrogen emission are transformed into ambient PM and deposited onto sensitive
ecosystems. Some of the most significant detrimental effects associated with excess reactive
nitrogen deposition  are those associated with a syndrome known as "nitrogen saturations.:
These effects include; (1) Decreased productivity, increased mortality, and/or shifts in plant
community composition, often leading to decreased biodiversity in many natural habitats
wherever atmospheric reactive nitrogen deposition increases significantly and critical
thresholds are exceeded; (2) leaching of excess nitrate and associated base cations from soils
into streams, lakes, and rivers, and mobilization of soil aluminum; and  (3) alternation of
ecosystem processes such as nutrient and energy cycles through changes in the functioning
and species composition of beneficial soil organisms (Galloway and Cowling, 2002). Thus,
through its effects on habitat suitability, genetic diversity, community dynamics and
composition, nutrient status, energy and nutrient cycling, and frequency and intensity of
natural disturbance regimes (fire), exceed reactive nitrogen deposition is have profound and
adverse impact on essential ecological attributes associated with terrestrial ecosystems.   In
the US numerous  forests now show severe symptoms of nitrogen saturation.  For other
forested locations, ongoing  expansion in nearby urban areas will increase the potential for
nitrogen saturation unless there are improved emissions controls.

       Excess nutrient inputs into aquatic ecosystems (i.e. streams, rivers, lakes, estuaries or
oceans) either form  direct atmospheric deposition, surface runoff, or leaching from nitrogen
saturated soils into ground or surface waters can contribute to conditions of severe water
oxygen depletion; eutrophication and algae blooms; altered fish distributions, catches, and
physiological states; loss of biodiversity; habitat degradation; and increases in the incidence
of disease.

       In the U.S., forests that are now showing severe symptoms of nitrogen saturation
include: the northern hardwoods and mixed conifer forests in the Adirondack and Catskill
Mountains of  New  York; the red spruce forests at Whitetop Mountain, Virginia, and Great
Smoky Mountains National Park, North Carolina; mixed hardwood watersheds at Fernow
Experimental Forest in West Virginia; American beech forests in Great Smoky Mountains
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National Park, Tennessee; mixed conifer forests and chaparral watersheds in southern
California and the southwestern Sierra Nevada in Central California; the alpine
tundra/subalpine conifer forests of the Colorado Front Range; and red alder forests in the
Cascade Mountains in Washington.

2.1.6.2.1.2.1 Eutrophication, Nitrification, and Fertilization

       In recent decades, human activities have greatly accelerated nutrient impacts, such as
nitrogen deposition in both aquatic and terrestrial systems. Nitrogen deposition in aquatic
systems can cause excessive growth of algae and lead to degraded water quality and
associated impairment of fresh water and estuarine resources for human uses.   Nitrogen
deposition on terrestrial systems can cause fertilization and lead to ecosystem stress and
species shift.

       Eutrophication is the accelerated  production of organic matter, particularly algae, in a
water body. This increased growth can cause numerous adverse ecological effects and
economic impacts, including nuisance algal blooms, dieback of underwater plants due to
reduced light penetration, and toxic plankton blooms.  Algal and plankton blooms can also
reduce the level of dissolved oxygen, which can adversely affect fish and shellfish
populations.

       Deposition of nitrogen contributes to elevated nitrogen levels in waterbodies.  The
NOX reductions from today's promulgated standards will help reduce the airborne nitrogen
deposition that contributes to eutrophication of watersheds, particularly in aquatic systems
where atmospheric deposition of nitrogen represents a significant portion of total  nitrogen
loadings.

       Severe and persistent eutrophication often directly impacts human activities.  For
example, losses in the nation's fishery resources may be directly caused by fish kills
associated with low dissolved oxygen and toxic blooms. Declines in tourism occur when low
dissolved oxygen causes noxious smells  and floating mats of algal blooms create  unfavorable
aesthetic conditions. Risks to human health increase when the toxins from algal blooms
accumulate in  edible fish and shellfish, and when toxins become airborne, causing respiratory
problems due to inhalation. According to the NOAA report, more than half of the nation's
estuaries have  moderate to high expressions of at least one of these symptoms - an indication
that eutrophication is well developed in more than half of U.S. estuaries.625

       In its Third Report to Congress on the Great Waters, EPA reported that atmospheric
deposition contributes from 2 to 38 percent of the nitrogen load to certain coastal  waters.63
A review of peer reviewed literature in 1995 on the subject of air deposition suggests a
typical contribution of 20 percent or higher.64  Human-caused nitrogen loading to the Long
Island Sound from the atmosphere was estimated at 14  percent by a collaboration of federal
and state air and water agencies in 1997.65  The National Exposure Research Laboratory,
U.S. EPA, estimated based on prior studies that 20 to 35 percent of the nitrogen loading to
the Chesapeake Bay is attributable to atmospheric deposition.66 The mobile source portion of
atmospheric NOX contribution to the Chesapeake Bay was modeled at about 30 percent of
total air deposition.10
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


       In U.S. terrestrial systems, the nutrient whose supply most often sets the limit of
possible plant based productivity at a given site is nitrogen. By increasing available nitrogen,
overall ecosystem productivity may be expected to increase for a time, and then decline as
nitrogen saturation is reached.  However, because not all vegetation, organisms, or
ecosystems react in the same manner to increased nitrogen fertilization, those plants or
organisms that are predisposed to capitalize on any increases in nitrogen availability gain an
advantage over those that are not as responsive to added nutrients, leading to a change in
plant community composition and diversity. Changes to plant community composition and
structure within an ecosystem are of concern because plants in large part determine the food
supply and habitat types available for use by other organisms. Further, in terrestrial systems,
plants serve as the integrators between above-ground and below-ground environments and
influence nutrient, energy and water cycles.  Because of these linkages, chronic excess
nutrient nitrogen additions can lead to complex, dramatic, and severe ecosystem level
responses such as changes in habitat suitability, genetic diversity, community dynamics and
composition,  nutrient status, energy and nutrient cycling, and frequency and intensity of
natural disturbance regimes such as fire.

       These types of effects have been observed both experimentally and in the field. For
example, experimental additions of nitrogen to a Minnesota grassland dominated by native
warm-season grasses produced a shift to low-diversity mixtures dominated by coolseason
grasses over a 12 year period at all but the lowest rate of nitrogen addition.   Similarly, the
coastal sage scrub (CSS) community in California has been declining in land area and in
drought deciduous  shrub density over the past 60 years, and is being replaced in many areas
by the more nitrogen responsive Mediterranean annual grasses.  Some 25  plant species are
already extinct in California, most of them annual and perennial forbs that occurred in sites
now experiencing conversion to annual grassland. As CSS converts more  extensively to
annual grassland dominated by invasive species, loss of additional rare species may be
inevitable. Though invasive species are often identified as the main threat to rare species, it is
more likely that invasive species combine with other factors, such as excess N deposition, to
promote increased productivity of invasive species and resulting species shifts.

       Deposition  of nitrogen from the engines covered in this proposal contributes to
elevated nitrogen levels in bodies of water and on land. The NOX reductions proposed in this
action will reduce the airborne nitrogen deposition that contributes to eutrophication of
watersheds and nitrogen saturation on land.

2.1.6.2.1.2.2  Atmospheric Deposition

       Wet and dry deposition of ambient particulate matter delivers a complex mixture of
metals (e.g., mercury, zinc, lead, nickel, aluminum, and cadmium), organic compounds (e.g.,
POM, dioxins, and furans) and inorganic compounds (e.g., nitrate, sulfate) to terrestrial and
aquatic ecosystems. The chemical form of the compounds deposited is impacted by a variety
of factors including ambient conditions (e.g., temperature, humidity, oxidant levels) and the
sources of the material. Chemical and physical transformations of the particulate compounds
occur in the atmosphere as well as the media onto which they deposit. These transformations
in turn influence the fate, bioavailability and potential toxicity of these compounds.
Atmospheric  deposition has been identified as a key component of the environmental and
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Draft Regulatory Impact Analysis
human health hazard posed by several pollutants including mercury, dioxin and PCBs.68

       Adverse impacts on water quality can occur when atmospheric contaminants deposit
to the water surface or when material deposited on the land enters a water body through
runoff. Potential impacts of atmospheric deposition to water bodies include those related to
both nutrient and toxic inputs. Adverse effects to human health and welfare can occur from
the addition of excess particulate nitrate nutrient enrichment which contribute to toxic algae
blooms and zones of depleted oxygen that can lead to fish kills, frequently in coastal waters.
Particles contaminated with heavy metals or other toxins may lead to the ingestion of
contaminated fish, ingestion of contaminated water, damage to the marine ecology, and
limited recreational uses. Several studies have been conducted in U.S. coastal waters and in
the Great Lakes Region in which the role of ambient PM deposition and runoff is
investigated.69'70'71'71'73

       Adverse impacts on soil chemistry and plant life have been observed for areas heavily
impacted by atmospheric deposition of nutrients, metals and acid species, resulting in species
shifts, loss of biodiversity, forest decline and damage to forest productivity. Potential
impacts also include adverse effects to human health through ingestion of contaminated
vegetation or  livestock (as in the case for dioxin deposition), reduction in crop yield, and
limited use of land due to contamination.

       In the  following subsections, atmospheric deposition of heavy metals and particulate
organic material is discussed.

2.1.6.2.1.2.2.1 Heavy Metals

       Heavy metals, including cadmium, copper, lead, chromium, mercury, nickel and zinc,
have the greatest potential for influencing forest growth (PM AQCD, p. 4-87) .74
Investigation  of trace metals near roadways and industrial facilities indicate that a substantial
burden of heavy metals can accumulate on vegetative surfaces. Copper, zinc, and nickel
have been documented to cause direct toxicity to vegetation under field conditions (PM
AQCD, p. 4-75).  Little research has been conducted on the effects associated with mixtures
of contaminants found in ambient PM. While metals typically  exhibit low solubility, limiting
their bioavailability and direct toxicity, chemical transformations of metal compounds occur
in the environment, particularly in the presence of acidic or other oxidizing species. These
chemical changes influence the mobility and toxicity of metals in the environment. Once
taken up into  plant tissue, a metal compound can undergo chemical changes, accumulate and
be passed along to herbivores or can re-enter the soil and further cycle in the environment.

       Although there has been no direct evidence of a physiological association between
tree injury and heavy metal exposures, heavy metals have been implicated because of
similarities between metal deposition patterns and forest decline (PM AQCD, p. 4-76) .75
Contamination of plant leaves by heavy metals can lead to elevated soil levels.  Trace metals
absorbed into the plant frequently bind to the leaf tissue, and then are lost when the leaf drops
(PM AQCD, p. 4-75).  As the fallen leaves decompose, the heavy metals are transferred into
the soil.76'77
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       The environmental sources and cycling of mercury are currently of particular concern
due to the bioaccumulation and biomagnification of this metal in aquatic ecosystems and the
potent toxic nature of mercury in the forms in which is it ingested by people and other
animals. Mercury is unusual compared with other metals in that it largely partitions into the
gas phase (in elemental form), and therefore has a longer residence time in the atmosphere
than a metal found predominantly in the particle phase. This property enables mercury to
travel far from the primary source before being deposited and accumulating in the aquatic
ecosystem.  The major source of mercury in the Great Lakes is from atmospheric deposition,
accounting  for approximately eighty percent of the mercury in Lake Michigan.78'79 Over fifty
percent of the mercury in the Chesapeake Bay has been attributed to atmospheric
deposition.80 Overall, the National Science and Technology Council (NSTC, 1999) identifies
atmospheric deposition as the primary source of mercury to aquatic systems.  Forty-four
states have  issued health advisories for the consumption offish contaminated by mercury;
however, most of these advisories are issued in areas without a mercury point source.

       Elevated levels of zinc and lead have been identified in streambed sediments, and
these elevated levels have been correlated with population density and motor vehicle use.81'82
Zinc and nickel have also been identified in urban water and soils. In addition, platinum,
palladium, and rhodium, metals found in the catalysts  of modern motor vehicles, have been
measured at elevated levels along roadsides.83 Plant uptake of platinum has been observed at
these locations.

2.1.6.2.1.2.2.2 Poly cyclic Organic Matter

       Polycyclic organic matter (POM) is a byproduct of incomplete combustion and
consists of organic compounds with more than one benzene ring and a boiling point greater
than or equal to 100 degrees centigrade.84 Polycyclic aromatic hydrocarbons (PAHs) are a
class of POM that contain compounds which are known or suspected carcinogens.

       Major sources of PAHs include mobile sources.  PAHs in the environment may be
present as a gas or adsorbed onto airborne particulate matter. Since the majority of PAHs are
adsorbed onto particles less than 1.0 pm in diameter, long range transport is possible.
However, studies have shown that PAH compounds adsorbed onto diesel exhaust particulate
and exposed to ozone have half lives of 0.5 to 1.0 hours.85

       Since PAHs are insoluble, the compounds generally are particle reactive and
accumulate in sediments. Atmospheric deposition of particles is believed to be the major
source  of PAHs to the sediments of Lake Michigan.86'   Analyses of PAH deposition to
Chesapeake and Galveston Bay indicate that dry deposition and gas exchange from the
atmosphere to the surface water predominate.88'89 Sediment concentrations of PAHs are high
enough in some segments of Tampa Bay to pose an environmental health threat. EPA funded
a study to better characterize the sources and loading rates for PAHs into Tampa Bay.90
PAHs that enter a water body through gas exchange likely partition into organic rich particles
and be  biologically recycled, while dry deposition of aerosols containing PAHs tends to be
more resistant to  biological recycling   Thus, dry deposition is likely the main pathway for
PAH concentrations in sediments while gas/water exchange at the  surface may lead to PAH
distribution into the food web, leading to increased health risk concerns.
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Draft Regulatory Impact Analysis
       Trends in PAH deposition levels are difficult to discern because of highly variable
ambient air concentrations, lack of consistency in monitoring methods, and the significant
influence of local sources on deposition levels.92  Van Metre et al. (2000)  noted PAH
concentrations in urban reservoir sediments have increased by 200-300%  over the last forty
years and correlates with increases in automobile  use.93

       Cousins et al. (1999) estimates that greater than ninety percent of semi-volatile
organic compound (SVOC) emissions in the United Kingdom deposit on soil.94  An analysis
of polycyclic aromatic hydrocarbon (PAH) concentrations near a Czechoslovakian roadway
indicated that concentrations were thirty times greater.

2.1.6.2.1.2.2.3 Materials Damage and Soiling

       The deposition of airborne particles can also reduce the aesthetic appeal of buildings
and culturally important articles through soiling, and can contribute directly (or in
conjunction with other pollutants) to structural damage by means of corrosion or erosion.95
Particles affect materials principally by promoting and accelerating the corrosion of metals,
by degrading paints, and by deteriorating building materials such as concrete and limestone.
Particles contribute to these effects because of their electrolytic, hygroscopic, and acidic
properties, and their ability to sorb corrosive gases (principally sulfur dioxide). The rate of
metal corrosion depends on a number of factors, including the deposition  rate and nature of
the pollutant; the influence of the metal protective corrosion film; the amount of moisture
present; variability in the electrochemical reactions; the presence and concentration of other
surface electrolytes; and the orientation of the metal surface.

2.2 Ozone

       In this section we review the health and welfare effects of ozone.  We also describe
the air  quality monitoring and modeling data which indicate that people in many areas across
the country continue to be  exposed to high levels  of ambient ozone and will continue to be
into the future.  Emissions of nitrogen oxides (NOX) and volatile organic compounds (VOCs)
from locomotive and marine diesel engines subject to  this proposed  rule have been shown to
contribute to these  ozone concentrations. Information on air quality was gathered from a
variety of sources,  including monitored ozone concentrations, air quality modeling forecasts
conducted for this rulemaking, and other state and local air quality information.

       The proposed emission reductions from this rule would assist 8-hour ozone
nonattainment and  maintenance areas in reaching  the standard by each area's respective
attainment date, and maintaining the  8-hour ozone standard in the future. The emission
reductions will also help continue to lower ambient ozone levels and resulting health impacts.

2.2.1  Science of  Ozone Formation

       Ground-level ozone pollution  is formed by the reaction of VOCs and nitrogen oxides
(NOX)  in the atmosphere in the presence of heat and sunlight. These pollutants, often
referred to as ozone precursors, are emitted by many types of pollution sources such as
highway and nonroad vehicles, power plants, chemical plants, refineries, makers of consumer
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                     Chapter 2: Air Quality and Resulting Health and Welfare Effects


and commercial products, and smaller area sources.

       The science of ozone formation, transport, and accumulation is complex.96  Ground-
level ozone is produced and destroyed in a cyclical set of chemical reactions, many of which
are sensitive to temperature and sunlight.  When ambient temperatures and sunlight levels
remain high for several days and the air is relatively stagnant, ozone and its precursors can
build up and result in more ozone than typically would occur on a single high-temperature
day.  Ozone also can be transported into an area from pollution sources found hundreds of
miles upwind, resulting in elevated ozone levels even in areas with low VOC or NOX
emissions.

       The highest levels of ozone are produced when both VOC and NOX emissions are
present in significant quantities on clear summer days. Relatively small amounts of NOX
enable  ozone to form rapidly when VOC levels are relatively high, but ozone production is
quickly limited by removal of the NOX.  Under these conditions NOX reductions are highly
effective in reducing ozone while VOC reductions have little effect. Such conditions are
called "N0x-limited". Because the contribution of VOC emissions from biogenic (natural)
sources to local ambient ozone concentrations can be significant, even some areas where
man-made VOC emissions are relatively low can be NOX -limited.

       When NOX levels are relatively high and VOC levels relatively low, NOX forms
inorganic nitrates (i.e., particles)  but relatively little ozone. Such conditions are called
"VOC-limited." Under these conditions, VOC reductions are effective in reducing ozone,
but NOX reductions can actually increase local ozone under certain circumstances.  Even in
VOC-limited urban areas, NOX reductions are not expected to increase ozone levels if the
NOX reductions are sufficiently large.

       Rural areas are usually N0x-limited, due to the relatively large amounts of biogenic
VOC emissions in many rural areas. Urban areas can be either VOC- or NOX -limited, or a
mixture of both, in which ozone levels exhibit moderate sensitivity to changes in either
pollutant.

       Ozone concentrations in an area also can be lowered by the reaction of nitric oxide
with ozone, forming nitrogen dioxide (NOz);  as the air moves downwind and the cycle
continues, the NOz forms additional ozone. The importance of this reaction depends, in part,
on the relative concentrations of NOX, VOC, and ozone, all of which change with time and
location.

       The current ozone National Ambient Air Quality Standards (NAAQS) has an  8-hour
averaging time.H The 8-hour ozone NAAQS, established by EPA in 1997, is based on well-
documented science demonstrating that  more people were experiencing adverse health
effects  at lower levels of exertion, over longer periods, and at lower ozone concentrations
than addressed by the previous one-hour ozone NAAQS. The  current ozone NAAQS
H EPA's review of the ozone NAAQS is underway and a proposal is scheduled for May 2007 with a final rule
scheduled for February 2008.
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addresses ozone exposures of concern for the general population and populations most at
risk, including children active outdoors, outdoor workers, and individuals with pre-existing
respiratory disease, such as asthma.  The 8-hour ozone NAAQS is met at an ambient air
quality monitoring site when the average of the annual fourth-highest daily maximum  8-hour
average ozone concentration over three years is less than or equal to 0.084 ppm.

2.2.2 Health Effects of Ozone

       Exposure to ambient ozone contributes to a wide range of adverse health effects1.
These health effects are well documented and are critically assessed in the EPA ozone air
quality criteria document (ozone AQCD) and EPA staff paper.97'98 We are relying on the
data and conclusions in the ozone AQCD and staff paper, regarding the health effects
associated with ozone exposure.

       Ozone-related health effects include lung function decrements, respiratory symptoms,
aggravation of asthma, increased hospital and emergency room visits, increased asthma
medication usage, inflammation of the lungs and a variety of other respiratory effects and
cardiovascular effects. People who are more susceptible to effects associated with exposure
to ozone include children, asthmatics and the elderly. There is also suggestive evidence that
certain people may have greater genetic susceptibility. Those with greater  exposures to
ozone, for instance du to time spent outdoors (e.g. outdoor workers), are also of concern.

       Based on a large number of scientific studies, EPA has identified several key health
effects associated with exposure to levels of ozone found today in many areas of the country.
Short-term (1 to 3 hours)  and prolonged exposures (6 to 8 hours) to higher ambient ozone
concentrations have been linked to lung function decrements, respiratory symptoms,
increased hospital admissions and emergency room visits for respiratory problems.99'100'101'
102,103,104  Repeaj-ec[ exposure to ozone can increase susceptibility to respiratory infection and
lung inflammation and can aggravate preexisting respiratory diseases, such as asthma.105'106'
107, TOS, 109 Repeatec[ exposure to sufficient concentrations of ozone can also cause
inflammation of the lung, impairment of lung defense mechanisms, and possibly irreversible
changes in lung structure, which over time could lead to premature aging of the lungs and/or
chronic respiratory illnesses, such as  emphysema and chronic bronchitis.110'm'112'l  3

       Children and adults who are outdoors and active during the summer months, such as
construction workers and other outdoor workers, are among those most at  risk of elevated
ozone exposures.114  Children and outdoor workers tend to have higher ozone exposure
because they typically are active outside, working, playing and exercising, during times of
day and seasons (e.g. the summer) when ozone levels are highest.115  For example, summer
camp studies in the Eastern United States and Southeastern Canada have reported significant
reductions in lung function in children who are active outdoors.116'117'118'   '120'121'   '123
1 Human exposure to ozone varies over time due to changes in ambient ozone concentration and because people
move between locations which have notable different ozone concentrations. Also, the amount of ozone
delivered to the lung is not only influenced by the ambient concentration but also by the individuals breathing
route and rate.
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


Further, children are more at risk of experiencing health effects from ozone exposure than
adults because their respiratory systems are still developing.  These individuals (as well as
people with respiratory illnesses such as asthma, especially asthmatic children) can
experience reduced lung function and increased respiratory symptoms, such as chest pain and
cough, when exposed to relatively low ozone levels during prolonged periods of moderate
exertion.124' 125>i26'm

       EPA typically quantifies ozone-related health impacts in its regulatory impact
analyses (RIAs) when possible.  In the analysis of past air quality regulations, ozone-related
benefits have included morbidity endpoints and welfare effects such as damage to
commercial crops. EPA has not recently included a separate and additive mortality effect for
ozone, independent of the effect associated with fine particulate matter. For a number of
reasons, including 1) advice from the Science Advisory Board (SAB) Health and Ecological
Effects Subcommittee (HEES) that EPA consider the plausibility and viability of including
an estimate of premature mortality associated with short-term ozone exposure in its benefits
analyses and 2) conclusions regarding the scientific support for such relationships in EPA's
2006 Air Quality Criteria for Ozone and Related Photochemical Oxidants (the CD), EPA is
in the process of determining how to appropriately characterize ozone-related mortality
benefits within the context of benefits analyses for air quality regulations.  As part of this
process, we are seeking advice from the National Academy of Sciences (NAS) regarding
how the ozone-mortality literature should be used to quantify the reduction in premature
mortality due to diminished exposure to ozone, the amount of life expectancy to be added
and the monetary value of this increased life expectancy in the context of health benefits
analyses associated with regulatory assessments.

       Since the NAS effort is not expected to conclude until 2008, the agency is currently
deliberating how best to characterize ozone-related mortality benefits in its rulemaking
analyses in the interim.  For the analysis of the proposed locomotive and marine standards,
we do not quantify an ozone mortality benefit. So that we do not provide an incomplete
picture of all of the benefits associated with reductions in emissions of ozone precursors, we
have chosen not to include an estimate of total ozone benefits in the proposed RIA. By
omitting ozone benefits in this proposal, we acknowledge that this analysis underestimates
the benefits associated with the proposed standards. For more information regarding the
quantified benefits included in this analysis, please refer to Chapter 6.

2.2.3 Current 8-Hour Ozone Levels

       The proposed locomotive and marine engine emission reductions will assist 8-hour
ozone nonattainment areas in reaching the standard by each area's respective attainment date
and assist in maintaining the 8-hour ozone standard in the future.  In this section and the next
section we present information on current and model-projected future 8-hour ozone levels.

       A nonattainment area is defined in the CAA as an area that is violating a NAAQS or
is contributing to a nearby area that is violating the NAAQS. EPA designated nonattainment
areas for the 8-hour ozone NAAQS in June 2004. The final rule on Air Quality Designations
and Classifications for the 8-hour Ozone NAAQS (69 FR 23858, April 30, 2004) lays out the
                                           2-43

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Draft Regulatory Impact Analysis
factors that EPA considered in making the 8-hour ozone nonattainment designations,
including 2001-2003 measured data, air quality in adjacent areas, and other factors:1

       As of October 2006 there are approximately 157 million people living in 116 areas
designated as not in attainment with the 8-hour ozone NAAQS. There are 461 full or partial
counties that make up the 8-hour ozone nonattainment areas. These numbers do not include
the people living in areas where there is a future risk of failing to maintain or achieve the 8-
hour ozone NAAQS. Figure 2-1 illustrates the widespread nature of these current problems.
Shown in this figure are counties designated as nonattainment for the 8-hour ozone NAAQS,
PM2.5 nonattainment counties, and mandatory class I federal areas.  The current 8-hour ozone
nonattainment areas, nonattainment counties, and populations are listed in Appendix 2C to
this draft RIA.

       Counties designated as 8-hour ozone nonattainment were classified, on the basis of
their one-hour ozone design value,  as Subpart 1 or Subpart 2 (69 FR 23951, April 30, 2004).
Areas classified as Subpart 2 were then further classified, on the basis of their 8-hour ozone
design value, as marginal, moderate, serious, severe or extreme.  The maximum attainment
date assigned to an ozone nonattainment area is based on the area's classification.

       States with 8-hour ozone nonattainment areas will be required to take action to bring
those areas into  compliance in the future. Based  on the final rule designating and classifying
8-hour ozone nonattainment areas (69 FR 23951, April 30, 2004), most 8-hour ozone
nonattainment areas will be required to attain the 8-hour ozone NAAQS in the 2007 to 2013
time frame and then be  required to maintain the 8-hour ozone NAAQS thereafter.K We
expect many of the 8-hour ozone nonattainment areas will need to adopt additional emission
reduction programs. The expected  NOX and VOC reductions from the standards proposed in
this action would be useful to states as they seek  to either attain or maintain the 8-hour ozone
NAAQS.

       Further insight into the need for reductions from this rule can be gained by evaluating
counties at various levels above the level of the 8-hour ozone NAAQS. As shown in Table
2-4 below, of the 158 million people living in counties with 2001-2003 design value
J An ozone design value is the concentration that determines whether a monitoring site meets the NAAQS for
ozone. Because of the way they are defined, design values are determined based on three consecutive-year
monitoring periods.  For example, an 8-hour design value is the fourth highest daily maximum 8-hour average
ozone concentration measured over a three-year period at a given monitor. The full details of these
determinations (including accounting for missing values and other complexities) are given in Appendices H and
I of 40 CFR Part 50. Due to the precision with which the standards are expressed (0.08 parts per million (ppm)
for the 8-hour), a violation of the 8-hour standard is defined as a design value greater than or equal to 0.085
ppm or 85 parts per billion (ppb). For a county, the design value is the highest design value from among all the
monitors with valid design values within that county.  If a county does not contain an ozone monitor, it does not
have a design value. However, readers should note that ozone design values generally represent air quality
across a broad area and that absence of a design value does not imply that the county is in compliance with the
ozone NAAQS. Therefore, our analysis may underestimate the number of counties with design values above
the level of NAAQS.
K The Los Angeles South Coast Air Basin 8-hour ozone nonattainment area will have to attain before June 15,
2021.
                                            2-44

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                     Chapter 2: Air Quality and Resulting Health and Welfare Effects


measurements above the 8-hour ozone NAAQS, almost 90 million live in counties with
2001-2003 8-hour ozone design values above 95 ppb.
     Table 2-4 Population Living in Counties with 2001-2003 8-hour Ozone Design Values Shown
2001-2003 8-hour Ozone Design
Value (ppb)
>95
>90 <=95
>85 <= 90
Number of Counties Within The
Concentration Range
25
47
54
2000 Population Living in
Counties Within The
Concentration Range (Millions,
2000 Census Data)
89.7
40.0
29.6
       EPA's review of the ozone NAAQS is currently underway and a proposal is
scheduled for June 2007 with a final rule scheduled for March 2008. If the ozone NAAQS is
revised then new nonattainment areas could be designated. While EPA is not relying on it
for purposes of justifying this proposal, the emission reductions from this proposed
rulemaking would also be helpful to states if there is an ozone NAAQS revision.

2.2.4 Projected 8-Hour Ozone Levels

       EPA has already adopted many emission control programs that are expected to reduce
ambient ozone levels. These control programs include the Clean Air Interstate Rule  (70 FR
25162, May 12,  2005), the Clean Air Nonroad Diesel rule (69 FR 38957, June 29, 2004), and
the Heavy Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control
Requirements (66 FR 5002, Jan.  18, 2001). As a result of these programs, the number of
areas that fail to meet the 8-hour ozone NAAQS in the future is expected to decrease.

       The base case air quality modeling completed for this proposed rule predicts that
without additional local, regional or national controls there will continue to be a need for
reductions in 8-hour ozone  concentrations in some areas in the future. The determination
that an area is at risk of exceeding the 8-hour ozone standard in the future was made  for all
areas with current design values greater than or equal to 85 ppb (or within a 10 percent
margin) and with modeling evidence that concentrations at and above this level will persist
into the future. Those interested in greater detail should review the air quality modeling
TSD.

       With reductions from programs already in place (but excluding the emission
reductions from this rule), the number  of counties with projected 8-hour ozone design values
at or above  85 ppb in 2020 is expected to be 31 counties where 35 million people are
projected to live. In addition, in 2020, 89 counties where 60 million people are projected to
live, will be within 10 percent of violating the 8-hour ozone NAAQS. Table 2- 5 below
provides the full list of counties in 2020 projected to have design values at or above 85 ppb
as well as the 89 counties within 10 percent of violating the NAAQS in 2020. By 2030 27
                                          2-45

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Draft Regulatory Impact Analysis
current ozone nonattainment counties would still remain impacting 37 million people. Even
in 2030, 75 million people, living in 108 counties would continue to be within 10 percent of
the current 8-hour ozone standard.

       Clearly the almost 300,000 tons of annual NOX  reductions in 2020 and the more than
7650,000 NOX tons reduced in 2030 would be very important to these areas as they struggle
to attain the 8-hour ozone standard or continue to maintain the standards. Table 2-5 below
shows the current 8-hour ozone nonattainment areas which are projected to be in
nonattainment in 2020 and 2030 as well as those current nonattainment areas, which will be
in attainment but within 10 percent of not meeting the standard. The table also presents
ozone design values and populations in 2020  and 2030.
Table 2-5 Counties with 2020 and 2030 projected Annual 8-hour Ozone Design Values in Violation or within
               10 percent of the Annual Ozone Standard in the Base and Control Cases.
State

AZ
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CO
CO
CT
CT
CT
County

Maricopa
Amador
Calaveras
El Dorado
Fresno
Imperial
Kern
Kings
Los Angeles
Madera
Mariposa
Merced
Nevada
Orange
Placer
Riverside
Sacramento
San Bernardino
San Diego
Stanislaus
Tehama
Tulare
Tuolumne
Ventura
Douglas
Jefferson
Fair field
Hartford
Middlesex
2001-2003
Average
Ozone DV
(ppb)

85.0
88.0
92.3
105.7
111.3
87.0
112.0
97.3
110.0
90.7
88.3
101.3
97.7
82.7
100.3
108.7
99.7
129.3
94.0
94.0
84.3
105.3
91.5
97.7
82.5
83.7
98.7
89.3
98.0
2020
base
X
X
X
X
V
V
X
V
V
V
X
V
V
X
X
V
V
X
V
X
X
X
V
V
V
X
X
V
X
control
X
X
X
X
V
V
X
V
V
V
X
V
V
X
X
V
V
X
V
X
X
X
V
X
V
X
X
V
X
2030
base
X
X
X
X
V
V
X
V
X
V
X
X
V
X
X
X
V
X
V
X


V
X
V
X
X
V
X
control
X
X

X
X
V
X
V
X
V
X
X
V
X

X
V
X
V
X


V
X
V
X
X
V
X
2020 population

4,609,780
52,471
58,261
236,310
1,066,878
161,555
876,131
173,390
10,376,013
173,940
22,272
277,863
131,831
3,900,599
451,620
2,252,510
1,640,590
2,424,764
3,863,460
607,766
64,298
477,296
70,570
1,023,136
303,846
655,782
962,824
942,284
177,500
                                           2-46

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Chapter 2: Air Quality and Resulting Health and Welfare Effects
CT
CT
CT
DC
DE
DE
DE
GA
GA
IL
IN
IN
IN
IN
IN
KY
LA
LA
MD
MD
MD
MD
MD
MD
MD
MA
MA
MI
MI
MI
MI
MI
MO
MO
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
NY
New Haven
New London
Tolland
Washington
Kent
New Castle
Sussex
De Kalb
Fulton
Cook
Hamilton
Lake
Marion
Porter
Shelby
Campbell
East Baton Rou
Iberville
Anne Arundel
Baltimore
Cecil
Harford
Kent
Montgomery
Prince Georges
Barnstable
Bristol
Allegan
Macomb
Muskegon
Oakland
Wayne
St Louis
St Louis City
Bergen
Camden
Cumberland
Gloucester
Hudson
Hunterdon
Mercer
Middlesex
Monmouth
Morris
Ocean
Erie
Jefferson
Niagara
Putnam
Richmond
Suffolk
Westchester
99.0
90.7
93.0
94.3
91.3
95.3
93.3
95.3
99.0
87.7
93.3
90.7
90.0
89.0
93.5
91.7
87.3
86.7
101.0
93.0
102.7
103.7
99.0
88.7
95.0
94.7
92.7
92.0
91.0
92.0
87.0
88.0
89.3
87.0
92.5
102.3
96.7
100.3
88.0
97.3
102.3
100.7
95.7
97.7
109.0
96.0
91.7
91.0
91.3
96.0
98.5
92.0
V
V
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
V
V
X
X
X
X
X
X
X
X
X
X
X
X
X
V
X
V
X
X
V
V
V
X
V
X
X
X
X
X
V
V
V
X
X
X

X
X
X
X
X
X
V


X
X
X

X
X
V
V
X
X
X
X
X
X
X
X
X
X
X
X
X
V
X
V
X
X
V
V
X
X
V
X
X
X
X
X
V
V
V
X
X
X
X
X
X
X
X
X
X
X



X
X
X
V
X
V
V
X
X
X
X
X

X
X
X
X
X
X
X
V
X
V
X
X
V
V
V
X
V
X
X
X
X
X
V
V
V
X
X
X

X


X
X

X






X
X
V
V
X
X
X
X
X

X
X
X
X
X

X
V
X
V
X
X
V
V
X
X
V
X

X
X
X
V
898,415
280,729
152,653
554,330
153,635
584,627
202,387
801,817
929,278
5,669,479
279,537
509,293
935,610
188,604
50,387
95,622
522,399
33,130
596,924
855,464
109,425
317,847
21,407
1,060,716
944,987
283,735
605,591
141,851
894,095
183,444
1,443,380
1,908,196
1,057,171
303,712
944,507
547,817
161,512
304,105
694,357
160,989
392,236
934,654
741,640
548,694
644,323
959,145
119,264
220,989
124,395
561,360
1,598,742
1,027,798
                    2-47

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Draft Regulatory Impact Analysis
OH
OH
OH
PA
PA
PA
PA
PA
PA
PA
PA
PA
PA
RI
RI
RI
TX
TX
TX
TX
TX
TX
TX
TX
VA
VA
VA
VA
VA
VA
VA
WI
WI
WI
WI
WI
WI
WI
WI
Ashtabula
Geauga
Lake
Allegheny
Beaver
Bucks
Chester
Delaware
Lancaster
Lehigh
Montgomery
Northampton
Philadelphia
Kent
Providence
Washington
Brazoria
Dallas
Denton
Galveston
Gregg
Harris
Jefferson
Tarrant
Alexandria Cit
Arlington
Charles City
Fairfax
Hampton City
Hanover
Suffolk City
Door
Kenosha
Kewaunee
Manitowoc
Milwaukee
Ozaukee
Racine
Sheboygan
94.0
98.3
92.7
93.0
90.7
103.0
96.5
93.7
94.0
93.3
96.3
93.0
97.5
95.3
90.3
93.3
91.0
91.0
99.0
92.0
88.3
105.0
90.5
98.3
90.0
95.7
89.3
96.3
88.7
94.0
87.3
92.7
98.7
90.0
90.0
91.3
95.3
91.7
98.0
X
X
X
X
X
X
V
X
X
X
X
X
X
V
X
X
X
X
X
X
X
X
V
X
X
X
V
X
X
X
X
X
X
V
X
X
X
X
X
X
X
X
X
X
X
V
X
X
X
X
X
X
V
X
X
X
X
X
X
X
X
V
X
X
X
V
X
X
X
X
X
X
V
X
X
X
X
X
X
X
X
X
X
X
V
X
X
X
X
X
X
V
X
X
X
X
X
X
X
X
V
X
X
X
V
X
X
X
X

X
V
X
X
X
X
X
X
X
X
X
X
X
V
X
X


X

V
X
X
X
X
X

X
X
V
X
X
X
V

X
X
X
X

V

X
X
X
X
108,355
114,438
250,353
1,242,587
186,566
711,275
528,797
548,283
568,258
351,875
805,003
301,041
1,394,176
183,833
648,008
156,286
322,385
2,828,339
715,168
318,966
132,922
4,588,812
272,075
2,137,957
132,893
208,368
8,086
1,281,265
161,913
109,984
72,313
34,106
184,825
21,040
85,187
927,845
110,294
212,351
128,777
2.2.4.1  Ozone Modeling Results with proposed controls

       This section summarizes the results of our modeling of ozone air quality impacts in
the future due to the reductions in locomotive and marine diesel emissions proposed in this
action. Specifically, we compare baseline scenarios to scenarios with the proposed controls.
Our modeling indicates that the reductions from this proposed rule will contribute to
reducing ambient ozone concentrations and potential exposures in future years.
                                          2-48

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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


       According to air quality modeling performed for this rulemaking, the proposed
locomotive and marine diesel engines standards are expected to provide nationwide
improvements in ozone levels for the vast majority of areas. Specifically, this proposed rule
would result in ozone benefits for all but two U.S. ozone nonattainment areas in both their
2020 and 2030 ozone design values. There are two areas with small (i.e., less than 1 ppb)
increases in their annual 8- hour ozone design values due to the NOX disbenefits which
occurs in some VOC-limited ozone nonattainment areas. Briefly NOX reductions can at
certain times and in some areas cause ozone levels to increase slightly. Section 2.2.4.1.1
provides additional detail about NOX disbenefits.

       Despite of the localized areas that experience  small increases, the overall effect of this
proposed rule is positive with 454 (of 473) counties experiencing at least a 0.1 ppb decrease
in both their 2020 and 2030 ozone design values.  On a population-weighted basis, the
average modeled future-year 8-hour ozone design values would decrease by 0.29 ppb in 2020
and 0.80 ppb in 2030.  Within projected ozone nonattainment areas in 2030, the average
decrease would be somewhat higher: -0.30 ppb in 2020 and - 0.88 ppb in 2030 while the
maximum decrease for future-year design values would be -1.10 ppb in 2020 and -2.90 ppb
in 2030.

       Table 2-6 shows the average change in future year eight-hour ozone design values.
Average changes are shown 1) for all counties with 2020 baseline design values, 2) for
counties with baseline design values that exceeded the standard in 2001-2003 ("violating"
counties), and 3) for counties that did not exceed the standard, but were within 10 percent of
it in 2001-2003.  This last category  is intended to reflect counties that meet the standard, but
will likely benefit from help in maintaining that status in the face of growth. The average
and population-weighted average over all counties demonstrates a broad improvement in
ozone air quality. The average across violating counties shows that the proposed rule will
help bring these counties into attainment. Since some of the VOC and NOX emission
reductions expected from this proposed rule will go into effect during the period when areas
will need to attain the 8-hour ozone NAAQS, the projected reductions in emissions are
expected to assist States and local agencies in their effort to attain and maintain  the 8-hour
ozone standard. The average over counties within ten percent of the standard shows that the
proposed rule will also help those counties to maintain the standard. All of these metrics
show a decrease in 2020 and a larger decrease in 2030, indicating in four different ways the
overall improvement in ozone air quality.
            Table 2-6 Average change in projected future year 8-hour ozone design value
Averagea
All
All, population-weighted
Violating counties0
Violating counties0,
population-weighted
Number of US
Counties
473
473
277
277
Change in 2020
design valueb (ppb)
0.32
0.29
0.33
0.29
Change in 2030
design valueb (ppb)
0.86
0.80
0.88
0.87
                                           2-49

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Draft Regulatory Impact Analysis
Counties within 10
percent of the standardd
Counties within 10
percent of the standardd,
population-weighted
146
146
0.35
0.32
0.94
1.02
       a) averages are over counties with 2020 modeled design values
       b) assuming the nominal modeled control scenario
       c) counties whose 2001 baseline design values exceeded the 8-hour ozone standard (>= 85 ppb)
       d) counties whose 2001 baseline values were less than but within 10 percent of the 8-hour ozone standard.

       The impact of the proposed reductions has also been analyzed with respect to those
areas that have the highest projected design values.  We project that there will be 27 US
counties with design values at or above 85 ppb in 2030.  After implementation of this
proposed action, we project that 3 of these 27 counties will attain the standard. Further, 17 of
the 27 counties will be at least 10 percent closer to a design value of less than 85 ppb, and on
average all 27 counties will be 29 percent closer to a design value of less than 85 ppb.

       The geographic impact of these emissions reductions in 2030 on annual ozone design
values in counties across the US, can be seen in Figure 2-9.
Figure 2-9 Impact of Proposed Locomotive/Marine controls on annual Ozone Design Values (DV) in 2030
                                                                               2030bn_p
                                             2-50

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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects
       Figure 2.9 shows those US counties in 2030 which are projected to experience a
change in their ozone design values as a result of this proposed rule.  The most significant
decreases, equal or greater than -2.0 ppb, would occur in 7 counties across the US including:
Grant (-2.1 ppb) and Lafayette (-2.0 ppb) Counties in Louisiana; Montgomery (-2.0 ppb),
Galveston (-2.0ppb), and Jefferson (-2.0 ppb) Counties in Texas; Warren County (-2.9 ppb)
in Mississippi; and Santa Barbara County (-2.7 ppb) in California. One hundred eighty-seven
(187) counties would see annual ozone design value reductions from -1.0 to -1.9 ppb while
an estimated 217 additional  counties would see annual design value reductions from -0.5 to -
0.9 ppb.  Note that 5 counties including: Suffolk  (+1.5 ppb)  and Hampton (+ 0.8 ppb)
Counties in Virginia; Cook County (+ 0.7 ppb) in Illinois; Lake County (+ 0.2 ppb) in
Indiana; and San Bernardino County (+ 0.1 ppb) in California are projected to experience
increased ozone design values because of the NOx disbenefit that occurs under certain
conditions.

       It should be noted that the emission control scenarios used in the air quality and
benefits modeling are slightly different than the emission control program being proposed.
The differences reflect further refinements of the regulatory program since we performed the
air quality modeling for this rule. Chapter 3 of this RIA describes the changes in the inputs
and resulting emission inventories between the preliminary assumptions used for the air
quality modeling and the final proposed regulatory scenario.  These refinements to the
proposed program would not significantly change  the results summarized  here or our
conclusions drawn from this analysis.

2.2.4.1.1 Potentially Counterproductive Impacts on Ozone Concentrations from NOx
         Emissions Reductions

   While the proposed rule would reduce ozone levels generally and provide significant
national ozone-related health benefits, this is not always the case at the local level. Due to
the complex photochemistry of ozone production,  NOX emissions lead to both the formation
and destruction of ozone, depending on the relative quantities of NOX, VOC,  and ozone
catalysts such as the OH and H02 radicals. In areas dominated by fresh emissions of NOX,
ozone catalysts are removed via the production of nitric acid which slows  the ozone
formation rate. Because NOX is generally depleted more rapidly than VOC, this effect is
usually short-lived and the emitted NOx can lead to ozone formation later and further
downwind. The terms "NOX disbenefits" or "ozone disbenefits" refer to the ozone increases
that can result from NOx emissions reductions in these localized areas. According to the
NARSTO Ozone Assessment, these disbenefits are generally limited to small regions within
specific urban cores and are surrounded by larger regions in which NOX control is beneficial.
128

   In the context of ozone disbenefits, some have postulated that present-day weekend
conditions serve as a demonstration of the effects of future NOX reduction strategies because
NOX emissions decrease more than VOC emissions on weekends, due to a disproportionate
decrease in the activity of heavy-duty diesel trucks and other  diesel equipment. Recent
research indicates that ambient ozone levels are higher in some metropolitan  areas on
                                          2-51

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Draft Regulatory Impact Analysis
weekends than weekdays.129' 13°  There are other hypotheses for the cause of the "weekend
effect." 131 For instance, the role of ozone and ozone precursor carryover from previous days
is difficult to evaluate because of limited ambient data, especially aloft. The role of the
changed timing of emissions is difficult to evaluate because of limited ambient and emissions
inventory information.  It is also important to note that in many areas with "weekend effects"
(e.g., Los Angeles and San Francisco) significant ozone reductions have been observed over
the past 20 years for all days of the week, during a period in which both NOX and VOC
emissions have been greatly reduced.

   EPA maintains that the best available approach for determining the value of a particular
emissions reduction strategy is the net air quality change projected to result from the rule,
evaluated on a nationwide basis and for all pollutants that are health and/or welfare concerns.
The primary tool for assessing the net impacts of this rule are the air quality simulation
models. Model scenarios of 2020 and 2030 with and without the proposed controls are
compared to determine the expected changes in future pollutant levels resulting from the
proposed rule. There are several factors related to the air quality modeling and inputs which
should be considered regarding the disbenefit issue. First, our future year modeling
conducted does not contain any local governmental actions beyond the controls proposed in
this rule.   It is possible that significant local controls of VOC and/or NOX could modify the
conclusions regarding ozone changes in some areas. Second, recent work by CARB has
indicated that model limitations and uncertainties may lead to overestimates of ozone
disbenefits attributed to NOX emission reductions. While EPA maintains that the air quality
simulations conducted for the rule represent state-of-the-science analyses, any changes to the
underlying chemical mechanisms, grid resolution, and emissions/meteorological inputs could
result in revised conclusions regarding the strength and frequency  of ozone disbenefits.

   A wide variety of ozone metrics were considered in the assessment of the proposed
emissions reductions. Three of the most important assessments are:  1) the effect of the
proposed rule on projected future-year ozone design values, 2) the effect of the proposed rule
in assisting local areas in attainment and maintenance  of the NAAQS, and 3) an economic
assessment of the rule benefits based on existing health studies.

   Based only on the reductions from today's rule, our modeling predicts that in 2020 and
2030 periodic ozone disbenefit would occur in up to five counties: Suffolk and Hampton
Counties in Virginia, Cook County in Illinois, Lake County in Indiana, and San Bernardino
County in California. Despite these localized increases, the net ozone impact of the rule
nationally is positive for the majority of the analysis metrics as described in section 2.2.4.1
above.

   Historically, NOX reductions have been very successful at reducing regional/national
ozone levels. Consistent with that fact, the photochemical modeling completed for this rule
indicates that the emissions reductions proposed today will significantly assist in the
attainment and maintenance of the ozone NAAQS at the national level.  Furthermore, NOX
reductions also result in reductions in PM and its associated health and welfare effects. This
rule is one aspect of overall emissions reductions that States, local governments, and Tribes
need to reach their clean air goals. It is expected that future local and national controls that
decrease  VOC, CO, and regional ozone will mitigate any localized disbenefit.  EPA will
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


continue to rely on local attainment measures to ensure that the NAAQS are not violated in
the future.  Many organizations with an interest in improved air quality support the rule
because they believe the resulting NOX reductions would reduce both ozone and PM 132.
EPA believes that a balanced air quality management approach that includes NOX emissions
reductions from nonroad engines is needed as part of the Nation's progress toward clean air.

   Another category of potential effects that may change in response to ozone reduction
strategies results from the shielding provided by ozone against the harmful effects of
ultraviolet radiation (UV-B) derived from the sun. The great majority of this shielding
results from naturally occurring ozone in the stratosphere, but the 10 percent of total
"column"ozone present in the troposphere also contributes.133  A variable portion of this
tropospheric fraction of UV-B shielding is derived from ground level ozone related to
anthropogenic air pollution. Therefore, strategies that reduce ground level ozone could, in
some small measure, increase exposure to UV-B from the sun.

   While it is possible to provide quantitative estimates of benefits associated with globally
based strategies to restore the far larger and more spatially uniform stratospheric ozone layer,
the changes in UV-B exposures associated with ground level ozone reduction strategies are
much more complicated and uncertain. Comparatively smaller changes in ground-level
ozone (compared to the total ozone in the troposphere) and UV-B are not likely to
measurably change long-term risks of adverse effects.
2.2.4.2 Ozone Air Quality Modeling Methodology

       To model the ozone air quality benefits of this rule we also used the CMAQ model.
CMAQ simulates the numerous physical and chemical processes involved in the formation,
transport, and destruction of ozone. This model is commonly used in developing attainment
demonstration State Implementation Plans as well as for estimating the ozone reductions
expected to occur from a reduction in emitted pollutants. The model was applied for two
separate domains: a) a 36 km continental U.S. domain as described in Section 2.1.5, and b) a
smaller easter U.S. grid with a grid resolution of 12 km.

       For ozone modeling results over the western U.S. the 36 km modeling results were
used, but only for those periods within the months from May to October. Over the eastern
U.S. we utilized two periods of episodic modeling to generate the projections:  June 15-30,
2001 and July 15-August 10, 2001. Model configurations for the finer-scale episodic
modeling was identical to that described in Section 2.1.5.2 except for the use of finer-scale
MM5 meteorological inputs and that the boundary conditions were taken from the
appropriate 36 km continental U.S. simulations.

2.2.5 Environmental Effects  of Ozone Pollution

       There are a number of public welfare effects associated with the presence of ozone in
the ambient air.134 In this section we discuss the impact of ozone on plants, including trees,
agronomic crops and urban ornamentals.
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2.2.5.1 Impacts on Vegetation

        The Air Quality Criteria Document for Ozone and related Photochemical Oxidants
notes that "ozone affects vegetation throughout the United States, impairing crops, native
vegetation, and ecosystems more than any other air pollutant.  Like carbon dioxide (C02) and
other gaseous substances, ozone enters plant tissues primarily through apertures  (stomata)  in
leaves in a process called "uptake".135 Once sufficient levels of ozone, a highly reactive
substance, (or its reaction products) reaches the interior of plant cells, it can inhibit or
damage essential cellular components and functions, including enzyme activities, lipids, and
cellular membranes, disrupting the plant's osmotic (i.e., water) balance and energy utilization
patterns.136'137 This damage is commonly manifested as visible foliar injury such as chlorotic
or necrotic spots, increased leaf senescence (accelerated leaf aging) and/or reduced
photosynthesis.  All these effects reduce a plant's capacity to form carbohydrates, which are
the primary form of energy used by plants    With fewer resources available, the plant
reallocates existing resources away from root growth and storage, above ground  growth or
yield, and reproductive processes, toward leaf repair and maintenance.  Studies have shown
that plants stressed in these ways may exhibit a general loss of vigor, which can lead to
secondary impacts that modify plants' responses to other environmental factors.  Specifically,
plants may become more sensitive to other air pollutants, more susceptible to disease, insect
attack, harsh weather (e.g.,  drought, frost) and other environmental stresses.  Furthermore,
there is evidence that ozone can interfere with the formation of mycorrhiza, essential
symbiotic fungi associated with the roots of most terrestrial plants, by reducing the amount of
carbon available for transfer from the host to the symbiont.1 9'140

       Ozone can produce  both acute and chronic injury in sensitive species depending on
the concentration level and the duration of the exposure. Ozone effects also tend to
accumulate over the growing  season of the plant, so that even lower concentrations
experienced for a longer duration have the potential to create chronic stress on sensitive
vegetation. Not all plants, however, are equally sensitive to ozone. Much of the variation in
sensitivity between individual plants or whole species is related to the plant's ability to
regulate the extent of gas exchange via leaf stomata (e.g., avoidance of 03 uptake through
closure of stomata).14 i142'143  Other resistance mechanisms may involve the intercellular
production of detoxifying substances.  Several biochemical substances capable of detoxifying
ozone have been reported to occur in plants including the antioxidants ascorbate  and
glutathione.  After injuries have occurred, plants may be capable of repairing the damage to a
limited extent.144

       Because of the differing sensitivities among plants to ozone, ozone pollution can also
exert a selective pressure that leads to changes in plant community composition.  Given the
range of plant sensitivities and the fact that numerous other environmental factors modify
plant uptake and response to ozone, it is not possible to identify threshold values above
which ozone is  consistently toxic for all plants. The next few  paragraphs present additional
information on  ozone damage to trees, ecosystems, agronomic crops and urban ornamentals.

       Ozone also has been conclusively shown to cause discernible injury to  forest
trees.145'146 In terms of forest productivity and ecosystem diversity, ozone may be the
pollutant with the greatest potential for regional-scale forest impacts. Studies have
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


demonstrated repeatedly that ozone concentrations commonly observed in polluted areas can
have substantial impacts on plant function.147'148

       Because plants are at the center of the food web in many ecosystems, changes to the
plant community can affect associated organisms and ecosystems (including the suitability of
habitats that support threatened or endangered species and below ground organisms living in
the root zone). Ozone impacts at the community and ecosystem level vary widely depending
upon numerous factors, including concentration and temporal variation of tropospheric
ozone, species composition, soil properties and climatic factors.149 In most instances,
responses to chronic or recurrent exposure in forested ecosystems are subtle and not
observable for many years.  These injuries can cause stand-level forest decline in sensitive
ecosystems.150'151'1 2  It is not yet possible to predict ecosystem responses to ozone with much
certainty; however, considerable knowledge of potential ecosystem responses has been
acquired through long-term observations in highly damaged forests in the United States.

       Laboratory and field experiments have also shown reductions in yields for agronomic
crops exposed to ozone, including vegetables (e.g., lettuce) and field crops (e.g., cotton and
wheat). The most extensive field experiments, conducted under the National Crop Loss
Assessment Network (NCLAN) examined 15 species and numerous cultivars.  The NCLAN
results show that "several economically important crop species are sensitive to ozone levels
typical of those found in the Unites States."153 In addition, economic studies have shown
reduced economic benefits as a result of predicted reductions in crop yields associated with
observed ozone levels.154'155'156

       Urban ornamentals represent an  additional vegetation category likely to experience
some  degree of negative effects associated with exposure to ambient ozone levels.  It is
estimated that more than $20 billion (1990 dollars) are spent annually on landscaping using
ornamentals, both by private property owners/tenants and by governmental units responsible
for public areas.157 This is therefore a potentially costly environmental effect.  However, in
the absence of adequate exposure-response functions and economic damage functions for the
potential range of effects relevant to these types of vegetation, no direct quantitative analysis
has been conducted.

2.3 Air Toxics

       People experience elevated risk of cancer and other noncancer health effects from
exposure to air toxics. Mobile sources are responsible for a significant portion of this risk.
According to the National Air Toxic Assessment (NATA) for 1999, mobile sources were
responsible for 44 percent of outdoor toxic emissions and almost 50 percent of the cancer
risk.  Benzene is the largest contributor to cancer risk of all 133 pollutants quantitatively
assessed in the 1999 NATA. Mobile sources were responsible for 68 percent of benzene
emissions in 1999. In response, EPA has proposed a series of mobile source and fuel
controls that address this serious problem.  Although the 1999 NATA did not quantify
 U.S. EPA (2006). Control of Hazardous Air Pollutants From Mobile Sources. 71 FR 15804; March 29, 2006.
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Draft Regulatory Impact Analysis
cancer risks associated with exposure to this diesel exhaust, EPA has concluded that diesel
exhaust ranks with the other air toxic substances that the national-scale assessment suggests
pose the greatest relative risk.

        At the same time, nearly the entire U.S. population was exposed to an average level
of air toxics that has the potential for adverse respiratory health effects (noncancer).  This
will continue to be the case in 2030, even though toxics levels will be lower. Mobile sources
were responsible for 74 percent of the noncancer (respiratory) risk from outdoor air toxics in
1999. The majority of this risk was from acrolein, and formaldehyde also contributed to the
risk of respiratory health effects. Mobile sources will continue to be responsible for the
majority of noncancer risk from outdoor air toxics in 2030. Although not included in
NATA's estimates of noncancer risk, PM from gasoline and diesel mobile sources contribute
significantly to the health effects associated with ambient PM.

       It should be noted that the NATA modeling framework has a number of limitations
which prevent its use as the sole basis for setting regulatory standards. These limitations and
uncertainties are discussed on the 1999 NATA website.158  Even so, this modeling
framework is very useful in identifying air toxic pollutants and sources of greatest concern,
setting regulatory priorities, and informing the decision making process.

       The following section provides an overview of air toxics which are associated with
nonroad engines including locomotive and marine diesel engines and provides a discussion
of the health risks associated with each air toxic.

2.3.1 Diesel Exhaust PM

       Locomotive and marine diesel engine PM2.5 emissions include diesel exhaust (DE), a
complex mixture comprised of carbon dioxide, oxygen, nitrogen, water vapor,  carbon
monoxide, nitrogen compounds, sulfur compounds and numerous low-molecular-weight
hydrocarbons.  A number of these gaseous hydrocarbon components are individually known
to be toxic including aldehydes, benzene and 1,3-butadiene. The diesel particulate matter
(DPM) present in diesel exhaust consists of fine particles (< 2.5pm), including a subgroup
with a large number of ultrafine particles (< 0.1 pm).  These particles have large surface area
which makes them an excellent medium for adsorbing organics as well as their small size
makes them highly respirable and able to reach the deep lung. Many of the organic
compounds present on the particles and  in the gases are individually known to  have
mutagenic and carcinogenic properties.  Diesel exhaust varies significantly in chemical
composition and particle sizes between different engine types (heavy-duty, light-duty),
engine operating conditions (idle, accelerate, decelerate), and fuel formulations (high/low
sulfur fuel).152  Also, there are emission differences between on-road and nonroad engines
because the nonroad engines are generally of older technology. This is especially true for
locomotive and marine diesel engines.

       After emission from the tailpipe, diesel exhaust undergoes dilution as well as
chemical and physical changes in the atmosphere. The lifetime for some of the compounds
present in diesel exhaust ranges from hours to days.  Although the 1999 National-Scale Air
Toxics Assessment (NATA)  did not quantify cancer risks associated with exposure to this
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


pollutant, EPA has concluded that diesel exhaust ranks with the other air toxic substances
that the national-scale assessment suggests pose the greatest relative risk. Following is a
discussion of the health risks associated with diesel exhaust.

       A number of health studies have been conducted regarding diesel exhaust including
epidemiologic studies of lung cancer in groups of workers, and animal studies focusing on
non-cancer effects specific to diesel exhaust. Diesel exhaust PM (including the associated
organic compounds which are generally high molecular weight hydrocarbon types but not the
more volatile gaseous hydrocarbon compounds) is generally used as a surrogate measure for
diesel exhaust.

2.3.1.1 Potential Cancer Effects of Diesel Exhaust

       In addition to its contribution to ambient PM inventories, diesel exhaust is of specific
concern because it has been judged to pose a lung cancer hazard for humans as well as a
hazard from noncancer respiratory effects such as pulmonary inflammation.

       EPA's 2002 final "Health Assessment Document for Diesel Engine Exhaust" (the
EPA Diesel HAD classified diesel exhaust as likely to be carcinogenic to humans by
inhalation at environmental exposures, in accordance with the revised draft 1996/1999 EPA
cancer guidelines.160'161   In accordance with earlier EPA guidelines, diesel exhaust would be
similarly classified as a probable human carcinogen (Group Bl).162-163 A number of other
agencies (National Institute for Occupational Safety and Health, the International Agency for
Research on Cancer, the World Health Organization,  California EPA, and the US
Department of Health and Human Services)  have made similar classifications.164' 165>166>167>168
The Health Effects Institute has also made numerous  studies and report on the potential
carcinogenicity of diesel exhaust.169'170' m Numerous animal and bioassay/genotoxic tests
have been done on diesel exhaust.172'173 Also, case-control and cohort studies have been
conducted on railroad engine exposures174'175'176 in addition to studies on truck workers.177'
178,179, iso Also, there are numerous other epidemiologic studies including some studying mine
workers and fire fighters.181'182

       More specifically, the EPA Diesel HAD states that the conclusions of the document
apply to diesel exhaust in use today including both  onroad and nonroad engines.  The EPA
Diesel HAD acknowledges that the studies were  done on engines with older technologies
generally for onroad and that "there have been changes in the physical and chemical
composition of some DE [diesel exhaust] emissions (onroad vehicle emissions) overtime,
though there is no definitive information to show that the emission changes portend
significant toxicological changes." In any case, the diesel technology used for locomotive
and marine diesel engines typically lags that used for nonroad engines which have been
subject to PM standards since 1998, thus it is reasonable to assume that the hazards identified
from older technologies may be largely applicable to  locomotive and marine engines.

       For the Diesel HAD, EPA reviewed 22 epidemiologic studies on the subject of the
carcinogenicity of workers exposed to diesel exhaust in various occupations, finding
increased lung cancer risk, although not always statistically significant, in 8 out of 10 cohort
studies and 10 out of 12 case-control studies within several industries, including railroad
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workers. Relative risk for lung cancer associated with exposure ranged from 1.2 to 1.5,
although a few studies show relative risks as high as 2.6.  Additionally, the Diesel HAD also
relied on two independent meta-analyses, which examined 23 and 30 occupational studies
respectively, which found statistically significant increases in smoking-adjusted relative lung
cancer risk associated with diesel exhaust, of 1.33 to 1.47. These meta-analyses demonstrate
the effect of pooling many studies and in this case show the positive relationship between
diesel exhaust exposure and lung cancer across a variety of diesel exhaust-exposed
occupations. 183
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


showed that for certain occupations the exposures are similar to environmental exposures
while, for others, they differ by a factor of about 200 or more.

       The first step in this process is to note that the occupational relative risk of 1.4, or a
40 percent from increased risk compared to the typical 5 percent lung cancer risk in the U.S.
population, translates to an increased risk of 2 percent (or 102) for these diesel exhaust
exposed workers.  The Diesel HAD derived a typical nationwide average environmental
exposure level of 0.8 pg/m3 for diesel PM from  on-highway sources for 1996.  This estimate
was based on national exposure modeling; the derivation of this exposure is discussed in
detail in the EPA Diesel HAD.  Diesel PM is a surrogate for diesel exhaust and, as mentioned
above,  has been classified as  a carcinogen by some agencies.

       The possible environmental risk range was estimated by taking the relative risks in
the occupational setting, EPA selected 1.4 and converting this to absolute risk of 2% and then
ratioing this risk by differences in the occupational versus environmental exposures of
interest. A number of calculations are needed to accomplish this, and these can be seen in
the EPA Diesel HAD. The outcome was that environmental risks from diesel exhaust using
higher  estimates of occupational exposure could range from a low of 104 to 105 or be as
high as 103 if lower estimates of occupational exposure were used.  Note that the
environmental exposure of interest (0.8 pg/m3) remains constant in this analysis, while the
occupational exposure is a variable. The range of possible environmental risk is a reflection
of the range of occupational exposures that could be associated with the relative and related
absolute risk levels observed in the occupational studies.

       While these risk estimates are  exploratory  and not intended to provide a definitive
characterization of cancer risk, they are useful in gauging the possible range of risk based on
reasonable judgment.  It is important to note that the possible risks could also be higher or
lower and a zero risk cannot be ruled out.  Some individuals in the population may have a
high tolerance to exposure from diesel exhaust and low  cancer susceptibility. Also, one
cannot rule out the possibility of a threshold of exposure below which there is no cancer risk,
although no evidence is available on this point.  As discussed in the Diesel HAD, there is a
relatively small difference between some occupational studies where increased lung cancer
risk is reported and concentrations sometimes seen in ambient settings.

       EPA recently assessed air toxic emissions  and their associated risk (the National-
Scale Air Toxics Assessment or NATA for 1996 and 1999), and we concluded that diesel
exhaust ranks with substances that the national-scale assessment suggests pose the greatest
relative risk.189'190 This national assessment estimates average population inhalation
exposures to diesel PM for nonroad as well as on-highway sources.  These are the sum of
ambient levels in various locations weighted by the amount of time people spend in each of
the locations.  The EPA Diesel HAD states that use of the 1996 NATA exposure estimates
instead of the 0.8 |^g/m3 estimate results in a similar risk perspective.

       In summary, even though EPA does not  have a specific carcinogenic potency with
which to accurately estimate  the carcinogenic impact of diesel exhaust, the likely hazard to
humans together with the potential for significant  environmental risks leads us to conclude
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Draft Regulatory Impact Analysis
that diesel exhaust emissions from locomotive and marine engines present public health
issues of concern to this proposal.

2.3.1.2 Other Health Effects of Diesel Exhaust

       Noncancer health effects of acute and chronic exposure to diesel exhaust emissions
are also of concern to the Agency. The Diesel HAD established an inhalation Reference
Concentration (RfC)  specifically based on animal studies of diesel exhaust. An RfC is
defined by EPA as "an estimate of a continuous inhalation exposure to the human population,
including sensitive subgroups, with uncertainty spanning perhaps an order of magnitude,
which is likely to be without appreciable risks of deleterious noncancer effects during a
lifetime." EPA derived the RfC from consideration of four well-conducted chronic rat
inhalation studies showing adverse pulmonary effects.191,192,193)194 The diesel RfC is based
on a "no observable  adverse effect" level of  144 pg/m3 that is further reduced by applying
uncertainty factors of 3 for interspecies extrapolation and 10 for human variations in
sensitivity.  The resulting RfC derived in the Diesel HAD is 5 pg/m3 for diesel exhaust as
measured by diesel PM. This RfC does not consider allergenic effects such as those
associated with asthma or immunologic effects. There is growing evidence that diesel
exhaust can exacerbate these effects, but the exposure-response data is presently lacking to
derive an RfC. The EPA Diesel HAD states, "With DPM [diesel particulate matter] being a
ubiquitous component of ambient PM, there is an uncertainty about the adequacy of the
existing DE [diesel exhaust] noncancer database to identify all of the pertinent DE-caused
noncancer health hazards"  (p. 9-19).

       While there have been relatively few human studies associated specifically with the
noncancer impact of diesel PM alone, diesel PM is frequently part of the ambient particles
studied in numerous epidemiologic studies.  Conclusions that health effects associated with
ambient PM in general is relevant to diesel PM is supported by studies that specifically
associate observable human noncancer health effects with exposure to diesel PM. As
described in the Diesel HAD, these studies include some of the same health effects reported
for ambient PM, such as respiratory symptoms (cough, labored breathing, chest tightness,
wheezing), and chronic respiratory disease (cough, phlegm, chronic bronchitis and
suggestive evidence for decreases in pulmonary function).  Symptoms of immunological
effects such as wheezing and increased allergenicity are also seen. Studies in rodents,
especially rats, show the potential for human inflammatory effects in the lung and
consequential lung tissue damage from chronic diesel exhaust inhalation exposure. The
Diesel HAD notes that acute or short-term exposure to diesel exhaust can cause acute
irritation (e.g., eye, throat, bronchial), neurophysiological symptoms (e.g., lightheadedness,
nausea), and respiratory symptoms (cough, phlegm). There is also evidence for an
immunologic effect such as the exacerbation of allergenic responses to known allergens and
asthma-like symptoms.195'196'197 The Diesel HAD lists numerous other studies as well.  Also,
as discussed in more  detail previously, in addition to its contribution to ambient PM
inventories, diesel PM is of special concern because it has been associated with an increased
risk of lung cancer.

       Diesel exhaust has been shown to cause serious noncancer effects in occupational
exposure studies.  One recent study 198  of a small group of railroad workers and electricians
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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


found that exposure to diesel exhaust resulted in neurobehavioral impairments in one or more
areas including reaction time, balance, blink reflex latency, verbal recall, and color vision
confusion indices.  Pulmonary function tests also showed that 10 of the 16 workers had
airway obstruction and another group of 10 of 16 workers had chronic bronchitis, chest pain,
tightness, and hyperactive airways.  Finally, a variety of studies have been published
subsequent to the completion of the Diesel HAD.  One such study, published in 2006199
found that railroad engineers and conductors with diesel exhaust exposure from operating
trains had an increased incidence of chronic obstructive pulmonary disease (COPD)
mortality. The odds of COPD mortality increased with years on the job so that those who
had worked more than 16 years as an engineer or conductor after 1959 had an increased risk
of 1.61 (95% confidence interval, 1.12 - 2.30).  EPA is assessing the significance of this
study within the context of the broader literature.

       The Diesel HAD also briefly summarizes health effects  associated with ambient PM
and discusses the EPA's annual NAAQS of 15 pg/m3. There is a much more extensive body
of human data showing a wide spectrum of adverse health effects associated with exposure to
ambient PM, of which diesel exhaust is an important component. The PM2.s NAAQS is
designed to provide protection from the non-cancer and premature  mortality effects of PM2.s
as a whole, of which diesel PM is a constituent.

       Also, as mentioned earlier in the health effects discussion for  PM2.5, there are a
number of other health effects associated with PM in general, and mobile source exhaust
including diesels in particular, that provide  additional evidence  for the need for significant
emission reductions from locomotive and marine diesel sources.

       As indicated earlier, a number of recent studies have associated living near roadways
with adverse health effects.  Two of the studies cited earlier will be mentioned again here as
examples of the type of work that has been  done. A Dutch study (discussed earlier by G.
Hoek and others) of a population of people  55-69 years old found that there was an elevated
risk of heart and lung related mortality among populations living near high traffic roads.  In a
review discussed earlier of studies  (by R. Delfino) of the respiratory health of people living
near roadways, another publication indicated that the risk of asthma and related respiratory
disease appeared elevated in people living near heavy traffic. These studies offer evidence
that people exposed most directly to emissions from mobile sources including those from
diesels face an elevated risk of illness or death.

       All of these health effects plus the designation of diesel  exhaust as a likely human
carcinogen provide ample health justification  for control.

2.3.1.3 Diesel Exhaust PM Ambient Levels

       Because diesel PM is part of overall ambient PM  and cannot be easily distinguished
from overall PM, we do not have direct measurements of diesel PM in the ambient air.
Diesel PM concentrations are estimated instead  using one of three approaches: 1) ambient air
quality modeling based on diesel PM emission inventories; 2) using elemental carbon
concentrations in monitored data as surrogates; or 3) using the chemical mass balance (CMB)
model in conjunction with ambient PM measurements. (Also, in addition to CMB,
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Draft Regulatory Impact Analysis
UNMIX/PMF have also been used). Estimates using these three approaches are described
below. In addition, estimates developed using the first two approaches above are subjected
to a statistical comparison to evaluate overall reasonableness of estimated concentrations
from ambient air quality modeling. It is important to note that, while there are
inconsistencies in some of these studies on the relative importance of gasoline and diesel PM,
the studies which are discussed in the Diesel HAD all show that diesel PM is a significant
contributor to overall ambient PM. Some of the studies differentiate nonroad from on-
highway diesel PM.

2.3.1.3.1 Toxics Modeling and Methods

       In addition to the general ambient PM modeling conducted for this proposal, diesel
PM concentrations for 1999 were recently estimated as part of the second National-Scale Air
Toxics Assessment (NATA; EPA, 2006). Ambient  impacts of mobile source emissions were
predicted using the Assessment System for Population Exposure Nationwide (ASPEN)
dispersion model.

       From the  NATA 1999 modeling, overall medium  annual national ambient diesel PM
levels of .91 |^g/m3 were calculated with a medium of 1.06 in urban counties and 0.43 in rural
counties.  Table 2-8 below summarizes the distribution of medium ambient concentrations to
diesel PM at the national scale. Over half, 62 percent, of the diesel PM and diesel exhaust
organic gases can be attributed to nonroad diesels. A map of county median ambient
concentrations is provided in Figure 2-8. While the high median concentrations are
clustered in the Northeast, Great Lake States California, and the Gulf Coast States, areas of
high median concentrations are distributed throughout the U.S.
   Table 2-8 Distribution of Median Ambient Concentrations of Diesel PM at the National Scale in the
                                1999 NATA Assessment.

5th Percentile
25th Percentile
Medium
75th Percentile
95th Percentile
Onroad Contribution to Mean
Nonroad Contribution to Mean
Nationwid
e (nR/m3)
0.21
0.54
0.91
1.41
2.91
0.43
0.78
Urban
(nR/m3)
0.22
.70
1.06
1.56
3.21
0.49
0.90
Rural
(nR/m3)
0.08
0.28
0.43
0.62
.96
0.20
0.28
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                     Chapter 2: Air Quality and Resulting Health and Welfare Effects
Figure 2-10 Estimated County Median Ambient Concentration of Diesel Particulate Matter
     1990  Estimated  County  Median Ambient Concentrations
        Diesel  participate  matter  -  United States  Counties
  Distribution  of U.S. Ambient Concentrations
        HlghsBtlnlAS.
               95
               90
   Percentile   75
               so
               25
a.4-i
1.12
                       a.aaa 24-
       County Median Ambient Pollutant Concentration
       ( micrograms / cubic meter)

                                       Source:  US, EPA/QAQPS
                       1999 NATA National-Scale Aj'r Toxics Assessment
2.3.1.4 Diesel Exhaust PM Exposures

       Exposure of people to diesel exhaust depends on their various activities, the time
spent in those activities, the locations where these activities occur, and the levels of diesel
exhaust pollutants in those locations. The major difference between ambient levels of diesel
particulate and exposure levels for diesel particulate is that exposure accounts for a person
moving from location to location, proximity to the emission source, and whether the
exposure occurs in an enclosed environment.
                                         2-63

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Draft Regulatory Impact Analysis
2.3.1.4.1 Occupational Exposures

       Occupational exposures to diesel exhaust from mobile sources, including locomotive
engines and marine diesel engines, can be several orders of magnitude greater than typical
exposures in the non-occupationally exposed population.

       Over the years, diesel particulate exposures have been measured for a number of
occupational groups resulting in a wide range of exposures from 2 to 1,280 pg/m3 for a
variety of occupations.  Studies have shown that miners and railroad workers typically have
higher diesel exposure levels than other occupational groups studied, including firefighters,
truck dock workers, and truck drivers (both short and long haul) .20° A 1988 study201
estimated that U.S. railroad workers received an estimated occupational
exposure/concentration of between 39-191 pg/m3 which resulted in an equivalent
environmental exposure of 8-40 pg/m3. As discussed in the Diesel HAD, the National
Institute of Occupational Safety and Health (NIOSH) has estimated a total of 1,400,000
workers are occupationally exposed to diesel exhaust from on-road and nonroad vehicles
including locomotive and marine diesel engines.

          2.3.1.4.1.1  Elevated Concentrations and Ambient Exposures in Mobile Source-
                  Impacted Areas

       While occupational studies indicate that those in closest proximity to diesel exhaust
experience the greatest health effects, recent studies are showing that human populations
living near large diesel emission sources such as major roadways,202  rail yards and marine
ports 203 are also likely to experience greater diesel exhaust exposure  levels than the overall
population putting them at greater health risks.

       Regions immediately downwind of rail yards and marine ports may experience
elevated ambient concentrations of directly-emitted PM2.5 from diesel engines. Due to the
unique nature of rail yards and marine ports, emissions from a large number of diesel engines
are concentrated in a small area.  Furthermore, emissions occur at or near ground level,
allowing emissions of diesel engines to reach nearby receptors without fully mixing with
background air.

       A recent study conducted by the California Air Resources Board (CARB) examined
the air quality impacts of railroad operations at the J.R. Davis Rail Yard, the largest rail
facility in the western United States.204 The yard occupies 950 acres along a one-quarter
mile wide and four mile long section of land in Roseville, CA. The study developed an
emissions inventory for the facility for the year 2000 and modeled ambient concentrations of
diesel PM using a well-accepted dispersion model  (ISCST3).  The study found substantially
elevated concentrations in an area 5,000 meters from the facility, with higher concentrations
closer to the rail yard.  Using local meteorological data, annual average contributions from
the rail yard to ambient diesel PM concentrations under prevailing wind conditions were
1.74, 1.18, 0.80, and 0.25 pg/m3 at receptors located 200, 500, 1000, and 5000 meters from
the yard, respectively. Several tens of thousands of people live within the area experiencing
substantial increases in annual average ambient PM2.5 as a result of emissions from the yard.
                                           2-64

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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


       Another study from CARB evaluated air quality impacts of diesel engine emissions
within the Ports of Long Beach and Los Angeles in California, one of the largest ports in the
U.S.205 Like the earlier rail yard study, the port study employed the ISCST3 dispersion
model. Also using local meteorological data, annual average concentrations were
substantially elevated over an area exceeding 200,000 acres.  Because they are located near
heavily-populated areas, the modeling indicated that over 700,000 people lived in areas with
at least 0.3 pg/m3 of port-related diesel PM in ambient air, about 360,000 people lived in
areas with at least 0.6 pg/m3 of diesel PM, and about 50,000 people lived in areas with at
least 1.5 pg/m3 of ambient diesel PM directly from the port.  Figure 2-11 provides an aerial
shot of the Port of Long beach and Los Angeles in California.

                Figure 2-11 Aerial Shot - Port of LA and Long Beach, California
       While these studies focus on two large marine port and one large rail yard facility,
these studies do highlight the substantial contribution these facilities make to elevated
ambient concentrations in large, densely populated areas.

       We have recently initiated a study to better understand the populations that are living
near rail yards and marine ports.  As part of the study, a computer geographic information
system (CIS) is being used to identify the locations and property boundaries of a sampling of
these facilities nationally, and to determine the size and demographic characteristics of the
population living near these facilities. We anticipate that the results of this study will be
complete in early 2007 and we intend to add this report to the public docket in advance of the
final rulemaking.   Figure 2.-12 to 2.-14 provides a sampling of aerial photos of the rail yards
and marine ports that are part of this study.
                                           2-65

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Draft Regulatory Impact Analysis
                 Figure 2-12 2006 aerial photo Port of Cleveland, Cleveland Ohio
             Figure 2-13 2006 aerial photo Argentine Rail Yard, Kansas City, Missouri
                                             2-66

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                     Chapter 2: Air Quality and Resulting Health and Welfare Effects
            Figure 2-14. 2006 aerial photo DeButts Rail Yard, Chattanooga, Tennessee
2.4 Gaseous Air Toxics—benzene, 1,3-butadiene, formaldehyde,
    acetaldehyde, acrolein, POM, naphthalene

       Locomotive and marine diesel engine emissions contribute to ambient levels of other
air toxics known or suspected as human or animal carcinogens, or that have non-cancer
health effects. These other compounds include benzene, 1,3-butadiene, formaldehyde,
acetaldehyde, acrolein, polycyclic organic matter (POM), and naphthalene.  All of these
compounds, except acetaldehyde, were identified as national or regional risk drivers in the
1999 National-Scale Air Toxics Assessment (NATA) and have significant inventory
contributions from mobile sources. Table 2-9 provides the mobile source contributions
associated with these compounds. The reductions in locomotive and marine diesel engine
emissions proposed in this rulemaking would help reduce exposure to these harmful
substances.

               Table 2-9 Mobile Source Contribution to 1999 NATA Risk Drivers
1999 NATA Risk Drivers
Benzene
1,2-Butadiene
Formaldehyde
Acrolein
Percent Contribution from
ALL Mobile Sources
68%
58%
47%
25%
Percent Contribution for
Non-road Mobile Sources
19%
17%
20%
11%
                                         2-67

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Draft Regulatory Impact Analysis
Polycyclic organic matter
(POM)*
Naphthalene
Diesel PM and Diesel
exhaust organic gases
6%
27%
100%
3%
6%
62%
  *This POM inventory includes the 15 POM compounds:  benzo[b]fluoranthene, benz[a]anthracene, indeno(l,2,3-
  c,d)pyrene,benzo[k]fluoranthene, chrysene, benzo[a]pyrene, dibenz(a,h)anthracene,anthracene, pyrene,
  benzo(g,h,i)perylene, lluoranthene, acenaphthylene, phenanthrene, fluorine, and acenaphthene.
       Air toxics can cause a variety of cancer and noncancer health effects. A number of the
mobile source air toxic pollutants described in this section are known or likely to pose a
cancer hazard in humans. Many of these compounds also cause adverse noncancer health
effects resulting from chronic,    subchronic,   or acute208 inhalation exposures. These
include neurological, cardiovascular, liver, kidney, and respiratory effects as well as effects
on the immune and reproductive systems.

       Benzene:  The EPA's IRIS database lists benzene as a known human carcinogen
(causing leukemia) by all routes of exposure, and that exposure is associated with additional
health effects, including genetic changes in both humans and  animals and increased
proliferation of bone marrow cells in mice'209'210'211  EPA states in its IRIS database that data
indicate a causal relationship between benzene exposure and acute lymphocytic leukemia and
suggests a relationship between benzene exposure and chronic non-lymphocytic leukemia
and chronic lymphocytic leukemia.  A number of adverse noncancer health effects including
blood disorders, such as preleukemia and aplastic anemia, have also been associated with
long-term exposure to benzene.212'213 The most sensitive noncancer effect observed in
humans, based on current data, is the depression of the absolute lymphocyte count in
blood.214,215 In addition, recent work, including studies sponsored by the Health Effects
Institute (HEI), provides evidence that biochemical responses are occurring at lower levels
of benzene exposure than previously known.216'217'218'     EPA's IRIS program has not yet
evaluated these new data

       1,3-Butadiene:  EPA has characterized 1,3-butadiene as carcinogenic to humans by
inhalation.220'221  The specific mechanisms of 1,3-butadiene-induced carcinogenesis are
unknown.  However, it is virtually certain that the carcinogenic effects are mediated by
genotoxic metabolites of 1,3-butadiene.  Animal data suggest that females may be more
sensitive than males for cancer effects; while there are insufficient data in humans from
which to draw conclusions about sensitive subpopulations. 1,3-Butadiene also causes a
variety of reproductive and developmental effects in mice; no human data on these effects are
available. The most sensitive effect was ovarian atrophy observed in a lifetime bioassay of
female mice.222

       Formaldehyde:  Since 1987,  EPA has classified formaldehyde as a probable human
carcinogen based on  evidence in humans and in rats, mice, hamsters, and monkeys.223 EPA's
current IRIS summary provides an upper bound cancer unit risk estimate of 1.3x105 per
                                           2-68

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                      Chapter 2: Air Quality and Resulting Health and Welfare Effects


pg/m3. In other words, there is an estimated risk of about thirteen excess leukemia cases in
one million people exposed to 1 pg/m3 of formaldehyde over a lifetime. EPA is currently
reviewing recently published epidemiological data. For instance, research conducted by the
National Cancer Institute (NCI) found an increased risk of nasopharyngeal cancer and
lymphohematopoietic malignancies such as leukemia among workers exposed to
formaldehyde.  4'225 NCI is currently performing an update of these studies.  A recent
National Institute of Occupational Safety and Health (NIOSH) study of garment workers also
found increased risk of death due to leukemia among workers exposed to formaldehyde.226
Extended follow-up of a cohort of British chemical workers did not find evidence of an
increase in nasopharyngeal or lymphohematopoeitic cancers, but a continuing statistically
significant excess in lung cancers was reported.227

       Based on the developments of the last decade, in 2004, the working group of the
International Agency for Research  on Cancer (IARC) concluded that formaldehyde is
carcinogenic to humans (Group 1), on the basis of sufficient evidence in humans and
sufficient evidence in experimental animals—a higher classification than previous IARC
evaluations. The Agency is currently conducting a reassessment of the human hazard and
dose-response associated with formaldehyde.

       In the past 15 years there has been substantial research on the inhalation dosimetry for
formaldehyde in rodents and primates by the CUT Centers for Health Research (formerly the
Chemical Industry Institute of Toxicology), with a focus on use of rodent data for refinement
of the quantitative cancer dose-response assessment.228'229'230' CIIT's risk assessment of
formaldehyde incorporated mechanistic and dosimetric information on formaldehyde. The
risk assessment analyzed carcinogenic risk from inhaled formaldehyde using approaches that
are consistent with EPA's draft guidelines for carcinogenic risk assessment.  In 2001,
Environment Canada relied on this cancer dose-response assessment in their assessment of
formaldehyde.231  In 2004, EPA also relied on this cancer unit risk estimate during the
development of the plywood and composite wood products national emissions standards for
hazardous air pollutants (NESHAPs).   In these rules, EPA  concluded that the CUT work
represented the best available application of the available mechanistic and dosimetric science
on the dose-response for portal of entry cancers due to formaldehyde exposures.  EPA is
reviewing the recent work cited above from the NCI and NIOSH, as well as the analysis by
the CUT Centers for Health Research and other studies, as part of a reassessment of the
human hazard and dose-response associated with formaldehyde.

       Formaldehyde exposure also causes a range of noncancer health effects, including
irritation of the eyes (tearing of the eyes and increased blinking) and mucous membranes.

       Acetaldehyde:  Acetaldehyde is classified in EPA's IRIS database as a probable
human carcinogen, based on nasal tumors in rats, and is considered toxic by the inhalation,
oral, and intravenous routes.233 The primary acute effect of exposure to acetaldehyde vapors
is irritation of the eyes, skin, and respiratory tract.234 The agency is currently conducting a
reassessment of the health hazards  from inhalation exposure to acetaldehyde.

       Acrolein: Acrolein is intensely irritating to humans when inhaled, with acute
exposure resulting in upper respiratory tract irritation and congestion. EPA determined in
                                          2-69

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Draft Regulatory Impact Analysis
2003 using the 1999 draft cacner guidelines that the human carcinogenic potential of acrolein
could not be determined because the available data were inadequate. No information was
available on the carcinogenic effects of acrolein in humans and the animal data provided
inadequate evidence of carcinogenicity.235

       Polycyclic Organic Matter (POM): POM is generally defined as a large class of
organic compounds which have multiple benzene rings and a boiling point greater than 100
degrees Celsius.  Many of the compounds included in the class of compounds known as
POM are classified by EPA as probable human carcinogens based on animal data.  One of
these compounds, naphthalene, is discussed separately below.

       Recent studies have found that maternal exposures to PAHs, in a population of
pregnant women were associated with several adverse birth outcomes, including low birth
weight and reduced length at birth as well as impaired cognitive development at age three.236'
237 EPA has not yet evaluated these recent studies.

       Naphthalene:  Naphthalene is found in small quantities in gasoline and diesel fuels
but is primarily a product of combustion.  Naphthalene emissions have been measured in
larger quantities in both gasoline and diesel exhaust and evaporative emissions from mobile
sources. EPA recently released an external review draft of a reassessment of the inhalation
carcinogenicity of naphthalene based on a number of recent animal carcinogenicity
studies. 38 The draft reassessment recently completed external peer review. 39 California
EPA has released a new risk assessment for naphthalene, and the IARC has reevaluated
naphthalene and re-classified it as Group  2B: possibly carcinogenic to humans.240
Naphthalene also causes a number of chronic non-cancer effects in animals, including
abnormal cell changes and growth in respiratory and nasal tissues.241

       In addition to reducing substantial amounts of NOX and PM2.s emissions from
locomotive and marine diesel engines the standards being proposed today would also reduce
air toxics emitted from these  engines thereby helping  to mitigate some of the adverse health
effects associated with operation of these  engines.
                                          2-70

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       Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
                       Appendix 2A PM2.5 Nonattainment

Table 2A PM2.5 Nonattainment Areas and Populations (Data is current throughOctober 2006 and
                   Population Numbers are from 2000 Census Data
County
Area Name
County
NAWhole/Part
Design Value
(Pg/m3_
Pop (2000)
ALABAMA
Jackson Co
Jefferson Co
Shelby Co
Walker Co
Chattanooga, AL-TN-GA
Birmingham, AL
Birmingham, AL
Birmingham, AL
Part
Whole
Whole
Part
16.1
17.3
17.3
17.3
1,578
662,047
143,293
2,272
CALIFORNIA
Fresno Co
Kern Co
Kings Co
Los Angeles Co
Madera Co
Merced Co
Orange Co
Riverside Co
San Bernardino Co
San Joaquin Co
Stanislaus Co
Tulare Co
San Joaquin Valley, CA
San Joaquin Valley, CA
San Joaquin Valley, CA
Los Angeles-South Coast Air
Basin, CA
San Joaquin Valley, CA
San Joaquin Valley, CA
Los Angeles-South Coast Air
Basin, CA
Los Angeles-South Coast Air
Basin, CA
Los Angeles-South Coast Air
Basin, CA
San Joaquin Valley, CA
San Joaquin Valley, CA
San Joaquin Valley, CA
Whole
Part
Whole
Part
Whole
Whole
Whole
Part
Part
Whole
Whole
Whole
21.8
21.8
21.8
27.8
21.8
21.8
27.8
27.8
27.8
21.8
21.8
21.8
799,407
550,220
129,461
9,222,280
123,109
210,554
2,846,289
1,194,859
1,330,159
563,598
446,997
368,021
CONNECTICUT
Fairfield Co
New Haven Co
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
Whole
Whole
17.7
17.7
882,567
824,008
DELAWARE
New Castle Co
Philadelphia-Wilmington, PA-
NJ-DE
Whole
16.2
500,265
DISTRICT OF COLUMBIA
Entire District
Washington, DC-MD-VA
Whole
15.8
572,059
GEORGIA
Barrow Co
Bartow Co
Bibb Co
Carroll Co
Catoosa Co
Cherokee Co
Atlanta, GA
Atlanta, GA
Macon, GA
Atlanta, GA
Chattanooga, AL-TN-GA
Atlanta, GA
Whole
Whole
Whole
Whole
Whole
Whole
18
18
15.2
18
16.1
18
46,144
76,019
153,887
87,268
53,282
141,903
                               A2-1

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Draft Regulatory Impact Analysis
County
Clayton Co
Cobb Co
Coweta Co
De Kalb Co
Douglas Co
Fayette Co
Floyd Co
Forsyth Co
Fulton Co
Gwinnett Co
Hall Co
Heard Co
Henry Co
Monroe Co
Newton Co
Paulding Co
Putnam Co
Rockdale Co
Spalding Co
Walker Co
Walton Co
Area Name
Atlanta, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Rome, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Macon, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Atlanta, GA
Chattanooga, AL-TN-GA
Atlanta, GA
County
NAWhole/Part
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Part
Whole
Part
Whole
Whole
Part
Whole
Whole
Whole
Whole
Design Value
(Pg/m3_
18
18
18
18
18
18
15.6
18
18
18
18
18
18
15.2
18
18
18
18
18
16.1
18
Pop (2000)
236,517
607,751
89,215
665,865
92,174
91,263
90,565
98,407
816,006
588,448
139,277
170
119,341
950
62,001
81,678
3,088
70,111
58,417
61,053
60,687
ILLINOIS
Cook Co
DuPage Co
Grundy Co
Kane Co
Kendall Co
Lake Co
Madison Co
Me Henry Co
Monroe Co
Randolph Co
St Clair Co
Will Co
Chicago-Gary-Lake County,
IL-IN
Chicago-Gary-Lake County,
IL-IN
Chicago-Gary-Lake County,
IL-IN
Chicago-Gary-Lake County,
IL-IN
Chicago-Gary-Lake County,
IL-IN
Chicago-Gary-Lake County,
IL-IN
St. Louis, MO-IL
Chicago-Gary-Lake County,
IL-IN
St. Louis, MO-IL
St. Louis, MO-IL
St. Louis, MO-IL
Chicago-Gary-Lake County,
IL-IN
Whole
Whole
Part
Whole
Part
Whole
Whole
Whole
Whole
Part
Whole
Whole
17.7
17.7
17.7
17.7
17.7
17.7
17.5
17.7
17.5
17.5
17.5
17.7
5,376,741
904,161
6,309
404,119
28,417
644,356
258,941
260,077
27,619
3,627
256,082
502,266
INDIANA
                                 A2-2

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Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
County
Clark Co
Dearborn Co
Dubois Co
Floyd Co
Gibson Co
Hamilton Co
Hendricks Co
Jefferson Co
Johnson Co
Lake Co
Marion Co
Morgan Co
Pike Co
Porter Co
Spencer Co
Vanderburgh Co
Warrick Co
Area Name
Louisville, KY-IN
Cincinnati-Hamilton, OH-KY-
IN
Evansville, IN
Louisville, KY-IN
Evansville, IN
Indianapolis, IN
Indianapolis, IN
Louisville, KY-IN
Indianapolis, IN
Chicago-Gary-Lake County,
IL-IN
Indianapolis, IN
Indianapolis, IN
Evansville, IN
Chicago-Gary-Lake County,
IL-IN
Evansville, IN
Evansville, IN
Evansville, IN
County
NAWhole/Part
Whole
Part
Whole
Whole
Part
Whole
Whole
Part
Whole
Whole
Whole
Whole
Part
Whole
Part
Whole
Whole
Design Value
(Pg/m3_
16.9
17.8
16.2
16.9
16.2
16.7
16.7
16.9
16.7
17.7
16.7
16.7
16.2
17.7
16.2
16.2
16.2
Pop (2000)
96,472
10,434
39,674
70,823
3,698
182,740
104,093
16,770
115,209
484,564
860,454
66,689
4,633
146,798
5,092
171,922
52,383
KENTUCKY
Boone Co
Boyd Co
Bullitt Co
Campbell Co
Jefferson Co
Kenton Co
Lawrence Co
Cincinnati-Hamilton, OH-KY-
IN
Huntington- Ashland, WV-KY-
OH
Louisville, KY-IN
Cincinnati-Hamilton, OH-KY-
IN
Louisville, KY-IN
Cincinnati-Hamilton, OH-KY-
IN
Huntington- Ashland, WV-KY-
OH
Whole
Whole
Whole
Whole
Whole
Whole
Part
17.8
17.2
16.9
17.8
16.9
17.8
17.2
85,991
49,752
61,236
88,616
693,604
151,464
1,050
MARYLAND
Anne Arundel Co
Baltimore (City)
Baltimore Co
Carroll Co
Charles Co
Frederick Co
Harford Co
Howard Co
Montgomery Co
Baltimore, MD
Baltimore, MD
Baltimore, MD
Baltimore, MD
Washington, DC-MD-VA
Washington, DC-MD-VA
Baltimore, MD
Baltimore, MD
Washington, DC-MD-VA
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
16.6
16.6
16.6
16.6
15.8
15.8
16.6
16.6
15.8
489,656
651,154
754,292
150,897
120,546
195,277
218,590
247,842
873,341
                        A2-3

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Draft Regulatory Impact Analysis
County
Prince George's Co
Washington Co
Area Name
Washington, DC-MD-VA
Martinsburg, WV-Hagerstown,
MD
County
NAWhole/Part
Whole
Whole
Design Value
(Pg/m3_
15.8
16.3
Pop (2000)
801,515
131,923
MICHIGAN
Livingston Co
Macomb Co
Monroe Co
Oakland Co
St Clair Co
Washtenaw Co
Wayne Co
Detroit-Ann Arbor, MI
Detroit-Ann Arbor, MI
Detroit-Ann Arbor, MI
Detroit-Ann Arbor, MI
Detroit-Ann Arbor, MI
Detroit-Ann Arbor, MI
Detroit-Ann Arbor, MI
Whole
Whole
Whole
Whole
Whole
Whole
Whole
19.5
19.5
19.5
19.5
19.5
19.5
19.5
156,951
788,149
145,945
1,194,156
164,235
322,895
2,061,162
MISSOURI
Franklin Co
Jefferson Co
St Charles Co
St Louis
St Louis Co
St. Louis, MO-IL
St. Louis, MO-IL
St. Louis, MO-IL
St. Louis, MO-IL
St. Louis, MO-IL
Whole
Whole
Whole
Whole
Whole
17.5
17.5
17.5
17.5
17.5
93,807
198,099
283,883
348,189
1,016,315
MONTANA
Lincoln Co
Libby, MT
Part
16.2
2,626
NEW JERSEY
Bergen Co
Burlington Co
Camden Co
Essex Co
Gloucester Co
Hudson Co
Mercer Co
Middlesex Co
Monmouth Co
Morris Co
Passaic Co
Somerset Co
Union Co
New York-N. New Jersey-
Long Island, NY-NJ-CT
Philadelphia-Wilmington, PA-
NJ-DE
Philadelphia-Wilmington, PA-
NJ-DE
New York-N. New Jersey-
Long Island, NY-NJ-CT
Philadelphia-Wilmington, PA-
NJ-DE
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
17.7
16.2
16.2
17.7
16.2
17.7
17.7
17.7
17.7
17.7
17.7
17.7
17.7
884,118
423,394
508,932
793,633
254,673
608,975
350,761
750,162
615,301
470,212
489,049
297,490
522,541
                                 A2-4

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Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
County

Area Name
Long Island, NY-NJ-CT
County
NAWhole/Part

Design Value
(Pg/m3_

Pop (2000)

New York
Bronx Co
Kings Co
Nassau Co
New York Co
Orange Co
Queens Co
Richmond Co
Rockland Co
Suffolk Co
Westchester Co
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
New York-N. New Jersey-
Long Island, NY-NJ-CT
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
17.7
17.7
17.7
17.7
17.7
17.7
17.7
17.7
17.7
17.7
1,332,650
2,465,326
1,334,544
1,537,195
341,367
2,229,379
443,728
286,753
1,419,369
923,459
NORTH CAROLINA
Catawba Co
Davidson Co
Guilford Co
Hickory, NC
Greensboro-Winston Salem-
High Point, NC
Greensboro-Winston Salem-
High Point, NC
Whole
Whole
Whole
15.5
15.8
15.8
141,685
147,246
421,048
OHIO
Adams Co
Ashtabula Co
Belmont Co
Butler Co
Clark Co
Clermont Co
Coshocton Co
Cuyahoga Co
Delaware Co
Fairfield Co
Franklin Co
Gallia Co
Greene Co
Hamilton Co
Huntington- Ashland, WV-KY-
OH
Cleveland-Akron-Lorain, OH
Wheeling, WV-OH
Cincinnati-Hamilton, OH-KY-
IN
Dayton-Springfield, OH
Cincinnati-Hamilton, OH-KY-
IN
Columbus, OH
Cleveland-Akron-Lorain, OH
Columbus, OH
Columbus, OH
Columbus, OH
Huntington- Ashland, WV-KY-
OH
Dayton-Springfield, OH
Cincinnati-Hamilton, OH-KY-
Part
Part
Whole
Whole
Whole
Whole
Part
Whole
Whole
Whole
Whole
Part
Whole
Whole
17.2
18.3
15.7
17.8
15.2
17.8
16.7
18.3
16.7
16.7
16.7
17.2
15.2
17.8
2,374
23,239
70,226
332,807
144,742
177,977
1,286
1,393,978
109,989
122,759
1,068,978
3,625
147,886
845,303
                        A2-5

-------
Draft Regulatory Impact Analysis
County

Jefferson Co
Lake Co
Lawrence Co
Licking Co
Lorain Co
Medina Co
Montgomery Co
Portage Co
Scioto Co
Stark Co
Summit Co
Warren Co
Washington Co
Area Name
IN
Steubenville-Weirton, OH-WV
Cleveland-Akron-Lorain, OH
Huntington- Ashland, WV-KY-
OH
Columbus, OH
Cleveland-Akron-Lorain, OH
Cleveland-Akron-Lorain, OH
Dayton-Springfield, OH
Cleveland-Akron-Lorain, OH
Huntington- Ashland, WV-KY-
OH
Canton-Massillon, OH
Cleveland-Akron-Lorain, OH
Cincinnati-Hamilton, OH-KY-
IN
Parkersburg-Marietta, WV-OH
County
NAWhole/Part

Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Design Value
(Pg/m3_

17.8
18.3
17.2
16.7
18.3
18.3
15.2
18.3
17.2
17.3
18.3
17.8
16
Pop (2000)

73,894
227,511
62,319
145,491
284,664
151,095
559,062
152,061
79,195
378,098
542,899
158,383
63,251
PENNSYLVANIA
Allegheny Co
Allegheny Co
Armstrong Co
Beaver Co
Berks Co
Bucks Co
Butler Co
Cambria Co
Chester Co
Cumberland Co
Dauphin Co
Delaware Co
Greene Co
Indiana Co
Lancaster Co
Lawrence Co
Lebanon Co
Montgomery Co
Philadelphia Co
Liberty-Clairton, PA
Pittsburgh-Beaver Valley, PA
Pittsburgh-Beaver Valley, PA
Pittsburgh-Beaver Valley, PA
Reading, PA
Philadelphia-Wilmington, PA-
NJ-DE
Pittsburgh-Beaver Valley, PA
Johnstown, PA
Philadelphia-Wilmington, PA-
NJ-DE
Harrisburg-Lebanon-Carlisle,
PA
Harrisburg-Lebanon-Carlisle,
PA
Philadelphia-Wilmington, PA-
NJ-DE
Pittsburgh-Beaver Valley, PA
Johnstown, PA
Lancaster, PA
Pittsburgh-Beaver Valley, PA
Harrisburg-Lebanon-Carlisle,
PA
Philadelphia-Wilmington, PA-
NJ-DE
Philadelphia-Wilmington, PA-
Part
Part
Part
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Part
Part
Whole
Part
Whole
Whole
Whole
21.2
16.9
16.9
16.9
16.4
16.2
16.9
15.8
16.2
15.7
15.7
16.2
16.9
15.8
17
16.9
15.7
16.2
16.2
21,600
1,260,066
3,691
181,412
373,638
597,635
174,083
152,598
433,501
213,674
251,798
550,864
1,714
11,833
470,658
1,198
120,327
750,097
1,517,550
                                 A2-6

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Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
County

Washington Co
Westmoreland Co
York Co
Area Name
NJ-DE
Pittsburgh-Beaver Valley, PA
Pittsburgh-Beaver Valley, PA
York, PA
County
NAWhole/Part

Whole
Whole
Whole
Design Value
(Pg/m3_

16.9
16.9
17
Pop (2000)

202,897
369,993
381,751
TENNESSEE
Anderson Co
Blount Co
Hamilton Co
Knox Co
Loudon Co
Roane Co
Knoxville, TN
Knoxville, TN
Chattanooga, AL-TN-GA
Knoxville, TN
Knoxville, TN
Knoxville, TN
Whole
Whole
Whole
Whole
Whole
Part
16.4
16.4
16.1
16.4
16.4
16.4
71,330
105,823
307,896
382,032
39,086
737
VIRGINIA
Alexandria
Arlington Co
Fairfax
Fairfax Co
Falls Church
Loudoun Co
Manassas
Manassas Park
Prince William Co
Washington, DC-MD-VA
Washington, DC-MD-VA
Washington, DC-MD-VA
Washington, DC-MD-VA
Washington, DC-MD-VA
Washington, DC-MD-VA
Washington, DC-MD-VA
Washington, DC-MD-VA
Washington, DC-MD-VA
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
Whole
15.8
15.8
15.8
15.8
15.8
15.8
15.8
15.8
15.8
128,283
189,453
21,498
969,749
10,377
169,599
35,135
10,290
280,813
WEST VIRGINIA
Berkeley Co
Brooke Co
Cabell Co
Hancock Co
Kanawha Co
Marshall Co
Mason Co
Ohio Co
Pleasants Co
Putnam Co
Wayne Co
Wood Co
TOTAL
Martinsburg, WV-Hagerstown,
MD
Steubenville-Weirton, OH-WV
Huntington- Ashland, WV-KY-
OH
Steubenville-Weirton, OH-WV
Charleston, WV
Wheeling, WV-OH
Huntington- Ashland, WV-KY-
OH
Wheeling, WV-OH
Parkersburg-Marietta, WV-OH
Charleston, WV
Huntington- Ashland, WV-KY-
OH
Parkersburg-Marietta, WV-OH
208 Counties
Whole
Whole
Whole
Whole
Whole
Whole
Part
Whole
Part
Whole
Whole
Whole

16.3
17.8
17.2
17.8
17.1
15.7
17.2
15.7
16
17.1
17.2
16

75,905
25,447
96,784
32,667
200,073
35,519
2,774
47,427
1,675
51,589
42,903
87,986
88,394,361
                        A2-7

-------
Draft Regulatory Impact Analysis
                    Appendix 2B:   Current 8-Hour Ozone Nonattainment Areas

 Table 2B 8-Hour Ozone Nonattainment Areas and Populations (Data is current through October 2006
                    and Population Numbers are from 2000 Census Data)
8-hour Ozone Nonattainment

Albany-Schenectady-Troy
Area
Albany-Schenectady-Troy
Area
Albany-Schenectady-Troy
Area
Albany-Schenectady-Troy
Area
Albany-Schenectady-Troy
Area
Albany-Schenectady-Troy
Area
Allegan County Area
Allentown-Bethlehem-Easton
Area
Allentown-Bethlehem-Easton
Area
Allentown-Bethlehem-Easton
Area
Altoona Area
Amador and Calaveras
Counties (Central Mountain
Counties) Area
Amador and Calaveras
Counties (Central Mountain
Counties) Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
Atlanta Area
State
NY
NY
NY
NY
NY
NY
NY
MI
PA
PA
PA
PA
CA
CA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
Classification3'11
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1

Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
County Name
Albany Co
Greene Co
Montgomery Co
Rensselaer Co
Saratoga Co
Schenectady Co
Schoharie Co
Allegan Co
Carbon Co
Lehigh Co
Northampton Co
Blair Co
Amador Co
Calaveras Co
Barrow Co
Bartow Co
Carroll Co
Cherokee Co
Clayton Co
Cobb Co
Coweta Co
De Kalb Co
Douglas Co
Fayette Co
Forsyth Co
Fulton Co
Gwinnett Co
Hall Co
Henry Co
Newton Co
Paulding Co
Whole
/Part
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
2000 Cty Pop
294,565
48,195
49,708
152,538
200,635
146,555
31,582
105,665
58,802
312,090
267,066
129,144
35,100
40,554
46,144
76,019
87,268
141,903
236,517
607,751
89,215
665,865
92,174
91,263
98,407
816,006
588,448
139,277
119,341
62,001
81,678
                                   A2-8

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Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
8-hour Ozone Nonattainment
Atlanta Area
Atlanta Area
Atlanta Area
Baltimore Area
Baltimore Area
Baltimore Area
Baltimore Area
Baltimore Area
Baltimore Area
Baton Rouge Area
Baton Rouge Area
Baton Rouge Area
Baton Rouge Area
Baton Rouge Area
Beaumont-Port Arthur Area
Beaumont-Port Arthur Area
Beaumont-Port Arthur Area
Benton Harbor Area
Benzie County Area
Berkeley and Jefferson
Counties Area
Berkeley and Jefferson
Counties Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Lawrence-Worcester
(E. Mass) Area
Boston-Manchester-
Portsmouth (SE) Area
Boston-Manchester-
Portsmouth (SE) Area
Boston-Manchester-
Portsmouth (SE) Area
State
GA
GA
GA
MD
MD
MD
MD
MD
MD
LA
LA
LA
LA
LA
TX
TX
TX
MI
MI
WV
WV
MA
MA
MA
MA
MA
MA
MA
MA
MA
MA
NH
NH
NH
Classification3'1"
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 1
Subpart 1
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
County Name
Rockdale Co
Spalding Co
Walton Co
Anne Arundel Co
Baltimore (City)
Baltimore Co
Carroll Co
Harford Co
Howard Co
Ascension Par
East Baton Rouge Par
Iberville Par
Livingston Par
West Baton Rouge Par
Hardin Co
Jefferson Co
Orange Co
Berrien Co
Benzie Co
Berkeley Co
Jefferson Co
Barnstable Co
Bristol Co
Dukes Co
Essex Co
Middlesex Co
Nantucket Co
Norfolk Co
Plymouth Co
Suffolk Co
Worcester Co
Hillsborough Co
Merrimack Co
Rockingham Co
Whole
/Part
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
p
p
p
2000 Cty Pop
70,111
58,417
60,687
489,656
651,154
754,292
150,897
218,590
247,842
76,627
412,852
33,320
91,814
21,601
48,073
252,051
84,966
162,453
15,998
75,905
42,190
222,230
534,678
14,987
723,419
1,465,396
9,520
650,308
472,822
689,807
750,963
336,518
11,721
266,340
                        A2-9

-------
Draft Regulatory Impact Analysis
8-hour Ozone Nonattainment
Boston-Manchester-
Portsmouth (SE) Area
Buffalo-Niagara Falls Area
Buffalo-Niagara Falls Area
Canton-Massillon Area
Cass County Area
Charlotte-Gastonia-Rock Hill
Area
Charlotte-Gastonia-Rock Hill
Area
Charlotte-Gastonia-Rock Hill
Area
Charlotte-Gastonia-Rock Hill
Area
Charlotte-Gastonia-Rock Hill
Area
Charlotte-Gastonia-Rock Hill
Area
Charlotte-Gastonia-Rock Hill
Area
Charlotte-Gastonia-Rock Hill
Area
Chattanooga Area
Chattanooga Area
Chattanooga Area
Chicago-Gary-Lake County
Area
Chicago-Gary-Lake County
Area
Chicago-Gary-Lake County
Area
Chicago-Gary-Lake County
Area
Chicago-Gary-Lake County
Area
Chicago-Gary-Lake County
Area
Chicago-Gary-Lake County
Area
Chicago-Gary-Lake County
Area
Chicago-Gary-Lake County
Area
Chicago-Gary-Lake County
Area
Chico Area
Cincinnati-Hamilton Area
Cincinnati-Hamilton Area
Cincinnati-Hamilton Area
Cincinnati-Hamilton Area
State
NH
NY
NY
OH
MI
NC
NC
NC
NC
NC
NC
NC
sc
GA
TN
TN
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
CA
IN
KY
KY
KY
Classification3'1"
Subpart 2/Moderate
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Marginal
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
County Name
Strafford Co
Erie Co
Niagara Co
Stark Co
Cass Co
Cabarrus Co
Gaston Co
Iredell Co
Lincoln Co
Mecklenburg Co
Rowan Co
Union Co
York Co
Catoosa Co
Hamilton Co
Meigs Co
Cook Co
Du Page Co
Grundy Co
Kane Co
Kendall Co
Lake Co
Me Henry Co
Will Co
Lake Co
Porter Co
Butte Co
Dearborn Co
Boone Co
Campbell Co
Kenton Co
Whole
/Part
P
W
W
W
W
W
W
P
W
W
W
W
P
W
W
W
W
W
P
W
P
W
W
W
W
W
W
P
W
W
W
2000 Cty Pop
82,134
950,265
219,846
378,098
51,104
131,063
190,365
39,885
63,780
695,454
130,340
123,677
102,000
53,282
307,896
11,086
5,376,741
904,161
6,309
404,119
28,417
644,356
260,077
502,266
484,564
146,798
203,171
10,434
85,991
88,616
151,464
                                 A2-10

-------
Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
8-hour Ozone Nonattainment
Cincinnati-Hamilton Area
Cincinnati-Hamilton Area
Cincinnati-Hamilton Area
Cincinnati-Hamilton Area
Cincinnati-Hamilton Area
Clearfield and Indiana
Counties Area
Clearfield and Indiana
Counties Area
Cleveland-Akron-Lorain Area
Cleveland-Akron-Lorain Area
Cleveland-Akron-Lorain Area
Cleveland-Akron-Lorain Area
Cleveland-Akron-Lorain Area
Cleveland-Akron-Lorain Area
Cleveland-Akron-Lorain Area
Cleveland-Akron-Lorain Area
Columbia Area
Columbia Area
Columbus Area
Columbus Area
Columbus Area
Columbus Area
Columbus Area
Columbus Area
Dallas-Fort Worth Area
Dallas-Fort Worth Area
Dallas-Fort Worth Area
Dallas-Fort Worth Area
Dallas-Fort Worth Area
Dallas-Fort Worth Area
Dallas-Fort Worth Area
Dallas-Fort Worth Area
Dallas-Fort Worth Area
Dayton-Springfield Area
Dayton-Springfield Area
Dayton-Springfield Area
Dayton-Springfield Area
Denver-Boulder-Greeley-Ft.
Collins-Love. Area
Denver-Boulder-Greeley-Ft.
Collins-Love. Area
Denver-Boulder-Greeley-Ft.
Collins-Love. Area
Denver-Boulder-Greeley-Ft.
Collins-Love. Area
Denver-Boulder-Greeley-Ft.
State
OH
OH
OH
OH
OH
PA
PA
OH
OH
OH
OH
OH
OH
OH
OH
SC
SC
OH
OH
OH
OH
OH
OH
TX
TX
TX
TX
TX
TX
TX
TX
TX
OH
OH
OH
OH
CO
CO
CO
CO
CO
Classification3'1"
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
County Name
Butler Co
Clermont Co
Clinton Co
Hamilton Co
Warren Co
Clearfield Co
Indiana Co
Ashtabula Co
Cuyahoga Co
Geauga Co
Lake Co
Lorain Co
Medina Co
Portage Co
Summit Co
Lexington Co
Richland Co
Delaware Co
Fairfield Co
Franklin Co
Knox Co
Licking Co
Madison Co
Collin Co
Dallas Co
Denton Co
Ellis Co
Johnson Co
Kaufman Co
Parker Co
Rockwall Co
Tarrant Co
Clark Co
Greene Co
Miami Co
Montgomery Co
Adams Co
Arapahoe Co
Boulder Co
Broomfield Co
Denver Co
Whole
/Part
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
p
p
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
2000 Cty Pop
332,807
177,977
40,543
845,303
158,383
83,382
89,605
102,728
1,393,978
90,895
227,511
284,664
151,095
152,061
542,899
181,265
313,253
109,989
122,759
1,068,978
54,500
145,491
40,213
491,675
2,218,899
432,976
111,360
126,811
71,313
88,495
43,080
1,446,219
144,742
147,886
98,868
559,062
348,618
487,967
269,814
38,272
554,636
                        A2-11

-------
Draft Regulatory Impact Analysis
8-hour Ozone Nonattainment
Collins-Love. Area
Denver-Boulder-Greeley-Ft.
Collins-Love. Area
Denver-Boulder-Greeley-Ft.
Collins-Love. Area
Denver-Boulder-Greeley-Ft.
Collins-Love. Area
Denver-Boulder-Greeley-Ft.
Collins-Love. Area
Detroit- Ann Arbor Area
Detroit-Ann Arbor Area
Detroit-Ann Arbor Area
Detroit-Ann Arbor Area
Detroit-Ann Arbor Area
Detroit-Ann Arbor Area
Detroit-Ann Arbor Area
Detroit-Ann Arbor Area
Door County Area
Erie Area
Essex County (Whiteface
Mtn.) Area
Fayetteville Area
Flint Area
Flint Area
Fort Wayne Area
Franklin County Area
Frederick County Area
Frederick County Area
Grand Rapids Area
Grand Rapids Area
Greater Connecticut Area
Greater Connecticut Area
Greater Connecticut Area
Greater Connecticut Area
Greater Connecticut Area
Greene County Area
Greensboro-Winston-Salem-
High Point Area
Greensboro-Winston-Salem-
High Point Area
Greensboro-Winston-Salem-
High Point Area
Greensboro-Winston-Salem-
High Point Area
Greensboro-Winston-Salem-
High Point Area
Greensboro-Winston-Salem-
High Point Area
State

CO
CO
CO
CO
MI
MI
MI
MI
MI
MI
MI
MI
WI
PA
NY
NC
MI
MI
IN
PA
VA
VA
MI
MI
CT
CT
CT
CT
CT
PA
NC
NC
NC
NC
NC
NC
Classification3'1"

Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 1
Subpart 1
Subpart 1
Subpart 1 - EAC
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1
Subpart 1
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1
Subpart 2/Marginal - EAC
Subpart 2/Marginal - EAC
Subpart 2/Marginal - EAC
Subpart 2/Marginal - EAC
Subpart 2/Marginal - EAC
Subpart 2/Marginal - EAC
County Name

Douglas Co
Jefferson Co
Larimer Co
Weld Co
Lenawee Co
Livingston Co
Macomb Co
Monroe Co
Oakland Co
St Clair Co
Washtenaw Co
Wayne Co
Door Co
Erie Co
Essex Co
Cumberland Co
Genesee Co
Lapeer Co
Allen Co
Franklin Co
Frederick Co
Winchester
Kent Co
Ottawa Co
Hartford Co
Litchfield Co
New London Co
Tolland Co
Windham Co
Greene Co
Alamance Co
Caswell Co
Davidson Co
Davie Co
Forsyth Co
Guilford Co
Whole
/Part

W
W
P
P
W
W
W
W
W
W
W
W
W
W
P
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
2000 Cty Pop

175,766
525,507
239,000
172,000
98,890
156,951
788,149
145,945
1,194,156
164,235
322,895
2,061,162
27,961
280,843
1,000
302,963
436,141
87,904
331,849
129,313
59,209
23,585
574,335
238,314
857,183
182,193
259,088
136,364
109,091
40,672
130,800
23,501
147,246
34,835
306,067
421,048
                                 A2-12

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Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
8-hour Ozone Nonattainment
Greensboro-Winston-Salem-
High Point Area
Greensboro-Winston-Salem-
High Point Area
Greenville-Spartanburg-
Anderson Area
Greenville-Spartanburg-
Anderson Area
Greenville-Spartanburg-
Anderson Area
Hancock, Knox, Lincoln and
Waldo Counties (Central
Maine Coast) Area
Hancock, Knox, Lincoln and
Waldo Counties (Central
Maine Coast) Area
Hancock, Knox, Lincoln and
Waldo Counties (Central
Maine Coast) Area
Hancock, Knox, Lincoln and
Waldo Counties (Central
Maine Coast) Area
Harrisburg-Lebanon-Carlisle
Area
Harrisburg-Lebanon-Carlisle
Area
Harrisburg-Lebanon-Carlisle
Area
Harrisburg-Lebanon-Carlisle
Area
Haywood and Swain Counties
(Great Smoky NP) Area
Haywood and Swain Counties
(Great Smoky NP) Area
Hickory-Morganton-Lenoir
Area
Hickory-Morganton-Lenoir
Area
Hickory-Morganton-Lenoir
Area
Hickory-Morganton-Lenoir
Area
Houston-Galveston-Brazoria
Area
Houston-Galveston-Brazoria
Area
Houston-Galveston-Brazoria
Area
Houston-Galveston-Brazoria
Area
Houston-Galveston-Brazoria
Area
State
NC
NC
sc
sc
sc
ME
ME
ME
ME
PA
PA
PA
PA
NC
NC
NC
NC
NC
NC
TX
TX
TX
TX
TX
Classification3'1"
Subpart 2/Marginal - EAC
Subpart 2/Marginal - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
County Name
Randolph Co
Rockingham Co
Anderson Co
Greenville Co
Spartanburg Co
Hancock Co
Knox Co
Lincoln Co
Waldo Co
Cumberland Co
Dauphin Co
Lebanon Co
Perry Co
Haywood Co
Swain Co
Alexander Co
Burke Co
Caldwell Co
Catawba Co
Brazoria Co
Chambers Co
Fort Bend Co
Galveston Co
Harris Co
Whole
/Part
W
W
W
W
W
p
p
p
p
W
W
W
W
p
p
W
p
p
W
W
W
W
W
W
2000 Cty Pop
130,454
91,928
165,740
379,616
253,791
29,805
33,563
28,504
604
213,674
251,798
120,327
43,602
28
260
33,603
69,970
64,254
141,685
241,767
26,031
354,452
250,158
3,400,578
                        A2-13

-------
Draft Regulatory Impact Analysis
8-hour Ozone Nonattainment
Houston-Galveston-Brazoria
Area
Houston-Galveston-Brazoria
Area
Houston-Galveston-Brazoria
Area
Huntington-Ashland Area
Huron County Area
Imperial County Area
Indianapolis Area
Indianapolis Area
Indianapolis Area
Indianapolis Area
Indianapolis Area
Indianapolis Area
Indianapolis Area
Indianapolis Area
Indianapolis Area
Jamestown Area
Jefferson County Area
Johnson City-Kingsport-
Bristol Area
Johnson City-Kingsport-
Bristol Area
Johnstown Area
Kalamazoo-Battle Creek Area
Kalamazoo-Battle Creek Area
Kalamazoo-Battle Creek Area
Kent and Queen Anne's
Counties Area
Kent and Queen Anne's
Counties Area
Kern County (Eastern Kern)
Area
Kewaunee County Area
Knoxville Area
Knoxville Area
Knoxville Area
Knoxville Area
Knoxville Area
Knoxville Area
Knoxville Area
La Porte County Area
Lancaster Area
Lansing-East Lansing Area
Lansing-East Lansing Area
Lansing-East Lansing Area
State
TX
TX
TX
KY
MI
CA
IN
IN
IN
IN
IN
IN
IN
IN
IN
NY
NY
TN
TN
PA
MI
MI
MI
MD
MD
CA
WI
TN
TN
TN
TN
TN
TN
TN
IN
PA
MI
MI
MI
Classification3'1"
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1
Subpart 1
Subpart 2/Marginal
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Moderate
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 1
Subpart 1
Subpart 1
County Name
Liberty Co
Montgomery Co
Waller Co
Boyd Co
Huron Co
Imperial Co
Boone Co
Hamilton Co
Hancock Co
Hendricks Co
Johnson Co
Madison Co
Marion Co
Morgan Co
Shelby Co
Chautauqua Co
Jefferson Co
Hawkins Co
Sullivan Co
Cambria Co
Calhoun Co
Kalamazoo Co
Van Buren Co
Kent Co
Queen Annes Co
Kern Co
Kewaunee Co
Anderson Co
Blount Co
Cocke Co
Jefferson Co
Knox Co
Loudon Co
Sevier Co
La Porte Co
Lancaster Co
Clinton Co
Eaton Co
Ingham Co
Whole
/Part
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
p
W
W
W
p
W
W
W
W
W
W
W
W
W
2000 Cty Pop
70,154
293,768
32,663
49,752
36,079
142,361
46,107
182,740
55,391
104,093
115,209
133,358
860,454
66,689
43,445
139,750
111,738
53,563
153,048
152,598
137,985
238,603
76,263
19,197
40,563
99,251
20,187
71,330
105,823
20
44,294
382,032
39,086
71,170
110,106
470,658
64,753
103,655
279,320
                                 A2-14

-------
Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
8-hour Ozone Nonattainment
Las Vegas Area
Lima Area
Los Angeles and San
Bernardino Counties (W
Mojave Desert) Area
Los Angeles and San
Bernardino Counties (W
Mojave Desert) Area
Los Angeles-South Coast Air
Basin Area
Los Angeles-South Coast Air
Basin Area
Los Angeles-South Coast Air
Basin Area
Los Angeles-South Coast Air
Basin Area
Louisville Area
Louisville Area
Louisville Area
Louisville Area
Louisville Area
Macon Area
Macon Area
Manitowoc County Area
Mariposa and Tuolumne
Counties (Southern Mountain
Counties) Area
Mariposa and Tuolumne
Counties (Southern Mountain
Counties) Area
Mason County Area
Memphis Area
Memphis Area
Milwaukee-Racine Area
Milwaukee-Racine Area
Milwaukee-Racine Area
Milwaukee-Racine Area
Milwaukee-Racine Area
Milwaukee-Racine Area
Murray County
(Chattahoochee Nat Forest)
Area
Muskegon Area
Nashville Area
Nashville Area
Nashville Area
Nashville Area
Nashville Area
State
NV
OH
CA
CA
CA
CA
CA
CA
IN
IN
KY
KY
KY
GA
GA
WI
CA
CA
MI
AR
TN
WI
WI
WI
WI
WI
WI
GA
MI
TN
TN
TN
TN
TN
Classification3'1"
Subpart 1
Subpart 1
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Severe 17
Subpart 2/Severe 17
Subpart 2/Severe 17
Subpart 2/Severe 17
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1
Subpart 2/Marginal
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
County Name
Clark Co
Allen Co
Los Angeles Co
San Bernardino Co
Los Angeles Co
Orange Co
Riverside Co
San Bernardino Co
Clark Co
Floyd Co
Bullitt Co
Jefferson Co
Oldham Co
Bibb Co
Monroe Co
Manitowoc Co
Mariposa Co
Tuolumne Co
Mason Co
Crittenden Co
Shelby Co
Kenosha Co
Milwaukee Co
Ozaukee Co
Racine Co
Washington Co
Waukesha Co
Murray Co
Muskegon Co
Davidson Co
Rutherford Co
Sumner Co
Williamson Co
Wilson Co
Whole
/Part
P
W
P
P
P
W
P
P
W
W
W
W
W
W
P
W
W
W
W
W
W
W
W
W
W
W
W
P
W
W
W
W
W
W
2000 Cty Pop
1,348,864
108,473
297,058
359,350
9,222,280
2,846,289
1,194,859
1,330,159
96,472
70,823
61,236
693,604
46,178
153,887
50
82,887
17,130
54,501
28,274
50,866
897,472
149,577
940,164
82,317
188,831
117,493
360,767
1,000
170,200
569,891
182,023
130,449
126,638
88,809
                        A2-15

-------
Draft Regulatory Impact Analysis
8-hour Ozone Nonattainment
Nevada County (Western
part) Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
New York-N. New Jersey-
Long Island Area
Norfolk-Virginia Beach-
Newport News (Hampton
State
CA
CT
CT
CT
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
NY
NY
NY
VA
Classification3'1"
Subpart 1
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Marginal
County Name
Nevada Co
Fairfield Co
Middlesex Co
New Haven Co
Bergen Co
Essex Co
Hudson Co
Hunterdon Co
Middlesex Co
Monmouth Co
Morris Co
Passaic Co
Somerset Co
Sussex Co
Union Co
Warren Co
Bronx Co
Kings Co
Nassau Co
New York Co
Queens Co
Richmond Co
Rockland Co
Suffolk Co
Westchester Co
Chesapeake
Whole
/Part
P
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
2000 Cty Pop
77,735
882,567
155,071
824,008
884,118
793,633
608,975
121,989
750,162
615,301
470,212
489,049
297,490
144,166
522,541
102,437
1,332,650
2,465,326
1,334,544
1,537,195
2,229,379
443,728
286,753
1,419,369
923,459
199,184
                                 A2-16

-------
Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
8-hour Ozone Nonattainment
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Norfolk-Virginia Beach-
Newport News (Hampton
Roads) Area
Parkersburg-Marietta Area
Parkersburg-Marietta Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
State

VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
VA
OH
WV
DE
DE
DE
MD
NJ
NJ
Classification3'1"

Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 1
Subpart 1
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
County Name

Gloucester Co
Hampton
Isle Of Wight Co
James City Co
Newport News
Norfolk
Poquoson
Portsmouth
Suffolk
Virginia Beach
Williamsburg
York Co
Washington Co
Wood Co
Kent Co
New Castle Co
Sussex Co
Cecil Co
Atlantic Co
Burlington Co
Whole
/Part

W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
2000 Cty Pop

34,780
146,437
29,728
48,102
180,150
234,403
11,566
100,565
63,677
425,257
11,998
56,297
63,251
87,986
126,697
500,265
156,638
85,951
252,552
423,394
                        A2-17

-------
Draft Regulatory Impact Analysis
8-hour Ozone Nonattainment
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Philadelphia-Wilmington-
Atlantic City Area
Phoenix-Mesa Area
Phoenix-Mesa Area
Pittsburgh-Beaver Valley
Area
Pittsburgh-Beaver Valley
Area
Pittsburgh-Beaver Valley
Area
Pittsburgh-Beaver Valley
Area
Pittsburgh-Beaver Valley
Area
Pittsburgh-Beaver Valley
Area
Pittsburgh-Beaver Valley
Area
Portland Area
Portland Area
Portland Area
Portland Area
Poughkeepsie Area
Poughkeepsie Area
Poughkeepsie Area
Providence (all of RI) Area
Providence (all of RI) Area
Providence (all of RI) Area
State
NJ
NJ
NJ
NJ
NJ
NJ
NJ
PA
PA
PA
PA
PA
AZ
AZ
PA
PA
PA
PA
PA
PA
PA
ME
ME
ME
ME
NY
NY
NY
RI
RI
RI
Classification3'1"
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
County Name
Camden Co
Cape May Co
Cumberland Co
Gloucester Co
Mercer Co
Ocean Co
Salem Co
Bucks Co
Chester Co
Delaware Co
Montgomery Co
Philadelphia Co
Maricopa Co
Final Co
Allegheny Co
Armstrong Co
Beaver Co
Butler Co
Fayette Co
Washington Co
Westmoreland Co
Androscoggin Co
Cumberland Co
Sagadahoc Co
York Co
Dutchess Co
Orange Co
Putnam Co
Bristol Co
Kent Co
Newport Co
Whole
/Part
W
W
W
W
W
W
W
W
W
W
W
W
p
p
W
W
W
W
W
W
W
p
p
W
p
W
W
W
W
W
W
2000 Cty Pop
508,932
102,326
146,438
254,673
350,761
510,916
64,285
597,635
433,501
550,864
750,097
1,517,550
3,054,504
31,541
1,281,666
72,392
181,412
174,083
148,644
202,897
369,993
3,390
252,907
35,214
164,997
280,150
341,367
95,745
50,648
167,090
85,433
                                 A2-18

-------
Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
8-hour Ozone Nonattainment
Providence (all of RI) Area
Providence (all of RI) Area
Raleigh-Durham-Chapel Hill
Area
Raleigh-Durham-Chapel Hill
Area
Raleigh-Durham-Chapel Hill
Area
Raleigh-Durham-Chapel Hill
Area
Raleigh-Durham-Chapel Hill
Area
Raleigh-Durham-Chapel Hill
Area
Raleigh-Durham-Chapel Hill
Area
Raleigh-Durham-Chapel Hill
Area
Reading Area
Richmond-Petersburg Area
Richmond-Petersburg Area
Richmond-Petersburg Area
Richmond-Petersburg Area
Richmond-Petersburg Area
Richmond-Petersburg Area
Richmond-Petersburg Area
Richmond-Petersburg Area
Richmond-Petersburg Area
Riverside County (Coachella
Valley) Area
Roanoke Area
Roanoke Area
Roanoke Area
Roanoke Area
Rochester Area
Rochester Area
Rochester Area
Rochester Area
Rochester Area
Rochester Area
Rocky Mount Area
Rocky Mount Area
Sacramento Metro Area
Sacramento Metro Area
Sacramento Metro Area
Sacramento Metro Area
Sacramento Metro Area
Sacramento Metro Area
State
RI
RI
NC
NC
NC
NC
NC
NC
NC
NC
PA
VA
VA
VA
VA
VA
VA
VA
VA
VA
CA
VA
VA
VA
VA
NY
NY
NY
NY
NY
NY
NC
NC
CA
CA
CA
CA
CA
CA
Classification3'1"
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Serious
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
County Name
Providence Co
Washington Co
Chatham Co
Durham Co
Franklin Co
Granville Co
Johnston Co
Orange Co
Person Co
Wake Co
Berks Co
Charles City Co
Chesterfield Co
Colonial Heights
Hanover Co
Henrico Co
Hopewell
Petersburg
Prince George Co
Richmond
Riverside Co
Botetourt Co
Roanoke
Roanoke Co
Salem
Genesee Co
Livingston Co
Monroe Co
Ontario Co
Orleans Co
Wayne Co
Edgecombe Co
Nash Co
El Dorado Co
Placer Co
Sacramento Co
Solano Co
Sutter Co
Yolo Co
Whole
/Part
W
W
P
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
P
W
W
W
W
W
W
W
W
W
W
W
W
P
P
W
P
P
W
2000 Cty Pop
621,602
123,546
21,320
223,314
47,260
48,498
121,965
118,227
35,623
627,846
373,638
6,926
259,903
16,897
86,320
262,300
22,354
33,740
33,047
197,790
324,750
30,496
94,911
85,778
24,747
60,370
64,328
735,343
100,224
44,171
93,765
55,606
87,420
124,164
239,978
1,223,499
197,034
25,013
168,660
                        A2-19

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Draft Regulatory Impact Analysis
8-hour Ozone Nonattainment
San Antonio Area
San Antonio Area
San Antonio Area
San Diego Area
San Francisco Bay Area
San Francisco Bay Area
San Francisco Bay Area
San Francisco Bay Area
San Francisco Bay Area
San Francisco Bay Area
San Francisco Bay Area
San Francisco Bay Area
San Francisco Bay Area
San Joaquin Valley Area
San Joaquin Valley Area
San Joaquin Valley Area
San Joaquin Valley Area
San Joaquin Valley Area
San Joaquin Valley Area
San Joaquin Valley Area
San Joaquin Valley Area
Scranton-Wilkes-Barre Area
Scranton-Wilkes-Barre Area
Scranton-Wilkes-Barre Area
Scranton-Wilkes-Barre Area
Sheboygan Area
South Bend-Elkhart Area
South Bend-Elkhart Area
Springfield (W. Mass) Area
Springfield (W. Mass) Area
Springfield (W. Mass) Area
Springfield (W. Mass) Area
St. Louis Area
St. Louis Area
St. Louis Area
St. Louis Area
St. Louis Area
St. Louis Area
St. Louis Area
St. Louis Area
St. Louis Area
State College Area
Steubenville-Weirton Area
Steubenville-Weirton Area
Steubenville-Weirton Area
State
TX
TX
TX
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
CA
PA
PA
PA
PA
WI
IN
IN
MA
MA
MA
MA
IL
IL
IL
IL
MO
MO
MO
MO
MO
PA
OH
WV
WV
Classification3'1"
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1 - EAC
Subpart 1
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Marginal
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
Subpart 2/Serious
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Moderate
Subpart 1
Subpart 1
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1
Subpart 1
Subpart 1
Subpart 1
County Name
Bexar Co
Comal Co
Guadalupe Co
San Diego Co
Alameda Co
Contra Costa Co
Marin Co
Napa Co
San Francisco Co
San Mateo Co
Santa Clara Co
Solano Co
Sonoma Co
Fresno Co
Kern Co
Kings Co
Madera Co
Merced Co
San Joaquin Co
Stanislaus Co
Tulare Co
Lackawanna Co
Luzerne Co
Monroe Co
Wyoming Co
Sheboygan Co
Elkhart Co
St Joseph Co
Berkshire Co
Franklin Co
Hampden Co
Hampshire Co
Jersey Co
Madison Co
Monroe Co
St Clair Co
Franklin Co
Jefferson Co
St Charles Co
St Louis
St Louis Co
Centre Co
Jefferson Co
Brooke Co
Hancock Co
Whole
/Part
W
W
W
p
W
W
W
W
W
W
W
p
p
W
p
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
2000 Cty Pop
1,392,931
78,021
89,023
2,813,431
1,443,741
948,816
247,289
124,279
776,733
707,161
1,682,585
197,508
413,716
799,407
550,220
129,461
123,109
210,554
563,598
446,997
368,021
213,295
319,250
138,687
28,080
112,646
182,791
265,559
134,953
71,535
456,228
152,251
21,668
258,941
27,619
256,082
93,807
198,099
283,883
348,189
1,016,315
135,758
73,894
25,447
32,667
                                 A2-20

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Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
8-hour Ozone Nonattainment
Sutter County (part) (Sutter
Buttes) Area
Tioga County Area
Toledo Area
Toledo Area
Ventura County (part) Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington Area
Washington County
(Hagerstown) Area
Wheeling Area
Wheeling Area
Wheeling Area
York Area
York Area
Youngstown-Warren-Sharon
Area
Youngstown-Warren-Sharon
Area
Youngstown-Warren-Sharon
Area
Youngstown-Warren-Sharon
Area
State
CA
PA
OH
OH
CA
DC
MD
MD
MD
MD
MD
VA
VA
VA
VA
VA
VA
VA
VA
VA
MD
OH
WV
WV
PA
PA
OH
OH
OH
PA
Classification3'1"
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 2/Moderate
Subpart 1 - EAC
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
Subpart 1
County Name
Sutter Co
Tioga Co
Lucas Co
Wood Co
Ventura Co
Entire District
Calvert Co
Charles Co
Frederick Co
Montgomery Co
Prince George's Co
Alexandria
Arlington Co
Fairfax
Fairfax Co
Falls Church
Loudoun Co
Manassas
Manassas Park
Prince William Co
Washington Co
Belmont Co
Marshall Co
Ohio Co
Adams Co
York Co
Columbiana Co
Mahoning Co
Trumbull Co
Mercer Co
Whole
/Part
P
W
W
W
P
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
W
2000 Cty Pop
1
41,373
455,054
121,065
753,197
572,059
74,563
120,546
195,277
873,341
801,515
128,283
189,453
21,498
969,749
10,377
169,599
35,135
10,290
280,813
131,923
70,226
35,519
47,427
91,292
381,751
112,075
257,555
225,116
120,293
                        A2-21

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Draft Regulatory Impact Analysis
       References
^.S. EPA (2004) Air Quality Criteria for Particulate Matter (Oct 2004), Volume I Document
No. EPA600/P-99/002aF and Volume II Document No. EPA600/P-99/002bF.

2U.S. EPA (2005) Review of the National Ambient Air Quality Standard for Particulate
Matter: Policy Assessment of Scientific and Technical Information, OAQPS Staff Paper.
EPA-452/R-05-005.

3 U.S. EPA 2006. Provisional Assessment of Recent Studies on Health Effects of Particulate
Matter Exposure.  EPA/600/R-06/063.

4 Laden F; Neas LM; Dockery DW; et al. 2000. "Association of fine particulate matter from
different sources with daily mortality in six U.S. cities." Environ Health Perspectives
108(10):941-947.

5 Schwartz J; Laden F; Zanobetti A.  2002. "The concentration-response relation between
PM(2.5) and daily deaths." Environ Health Perspect 110(10): 1025-1029.

6 Janssen NA; Schwartz J; Zanobetti A.;  et al.  2002. "Air conditioning and source-specific
particles as modifiers of the effect of PM10 on hospital admissions for heart and lung
disease."  Environ Health Perspect 110(l):43-49.

7 Dockery, DW; Pope, CA, III; Xu, X; et al.  1993. "An association between air pollution and
mortality in six U.S. cities." N Engl J Med 329:1753-1759.

8 Pope, CA, III; Burnett, RT; Thun, MJ; Calle, EE; et al. 2002. "Lung cancer,
cardiopulmonary mortality, and long-term exposure to fine particulate air pollution."  J Am
MedAssoc287: 1132-1141.

9Krewski, D; Burnett, RT; Goldberg, M S; et al. 2000. "Reanalysis  of the Harvard Six Cities
study and the American Cancer Society study  of particulate air pollution and mortality. A
special report of the Institute's Particle Epidemiology Reanalysis Project." Cambridge, MA:
Health Effects Institute.

10 Jerrett, M; Burnett, RT; Ma, R; et al. 2005. "Spatial Analysis of Air Pollution and
Mortality in Los Angeles." Epidemiology. 16(6):727-736.

11 Kiinzli, N.; Jerrett, M.; Mack, W.J.; et al.(2004) Ambient air pollution and atherosclerosis
in Los Angeles. Environ Health Perspect doi:10.1289/ehp.7523 [Available at
http://dx.doi.org/].
                                   A2-22

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          Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
12Riediker, M.; Cascio, W.E.; Griggs, T.R.; et al. 2004. "Particulate matter exposure in cars
is associated with cardiovascular effects in healthy young men." Am J Respir Crit Care Med
169:934-940.

13 Van Vliet, P.; Knape, M.; de Hartog, J.; Janssen, N.; Harssema, H.; Brunekreef, B. (1997).
Motor vehicle exhaust and chronic respiratory symptoms in children living near freeways.
Env. Research 74: 122-132.

14 Brunekreef, B., Janssen, N.A.H.; de Hartog, J.; Harssema, H.; Knape, M.; van Vliet, P.
(1997).  Air pollution from truck traffic and lung function in children living near roadways.
Epidemiology 8:298-303.

15 Kim, J.J.; Smorodinsky, S.; Lipsett, M.; Singer, B.C.; Hodgson, A.T.; Ostro, B (2004).
Traffic-related air pollution near busy roads: The East Bay children's respiratory health
study. Am. J. Respir. Crit. Care Med. 170: 520-526.

16 State of California Air Resources Board.  Roseville Rail Yard Study. Stationary Source
Division, October 14, 2004. This document is available electronically at:
http://www.arb.ca.gov/diesel/documents/rrstudy.htm and State of California Air Resources
Board. Diesel Particulate Matter Exposure Assessment Study for the Ports of Los Angeles
and Long Beach, April 2006. This document is available electronically at:
ftp://ftp.arb.ca.gov/carbis/msprog/offroad/marinevess/documents/portstudy0406.pdf

17 Multi-pollutant legislation modeling. (Multi-pollutant analyses and technical support
documents, http://www.epa.gov/airmarkets/mp/.)

18 U.S. Environmental Protection Agency (2006), Regulatory Impact Analysis for the Review
of the Particulate Matter National Ambient Air Quality Standards, [Docket No. EPA -HQ-
OAR-2006-0834].  October 6, 2006.  Available Electronically at:
http:www.epa.gov.ttn/ecas/ria.html.

19 Procedures for  Estimating Future PM2.5 Values for the CAIR Final Rule by Applications
of the Speciated Modeling Attainment Test (SMAT), Updated November 8, 2004  (EPA
Docket*: OAR-2003-0053-1907).

20 Note that while we believe that the mobile source sector is a substantial contributor to total
PM2.5 mass;  our current mobile source inventory is likely underestimated and information
on control measures is incomplete.

21 Currently, two  established receptor models are widely used for source apportionment
studies: the Chemical Mass Balance (CMB) model and Positive Matrix Factorization (PMF).
The CMB receptor model relies on measured source profiles as well as ambient species
measurements to  produce a source contribution estimate at the receptor location, while the
                                   A2-23

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Draft Regulatory Impact Analysis
PMF technique decomposes the ambient measurement data matrix into source profiles and
contributions by utilizing the underlying relationship (i.e., correlations) between the
individually measured species.

22 Second Draft Technical Report (Revision 1), Compilation of Existing Studies on Source
Apportionment for PM2.5, August 22, 2003 (Contract No. 68-D-02-061; Work Assignment
1-05). http://www.epa.gov/oar/oaqps/pm25/docs/compsareports.pdf

23 Chow, J. C.; Fairley, D.; Watson, J. G.; de Mandel, R.; Fujita, E. M.; Lowenthal, D. H.; Lu,
Z.; Frazier, C. A.; Long, G.; Cordova, J. J. Environ. Eng. 1995, 21, 378-387.

24Magliano, K. L.; Hughes, V. M.; Chinkin, L. R.; Coe, D. L.; Haste, T. L.; Kumar, N.;
Lurmann, F. W. Atmos. Environ. 1999, 33 (29), 4757-4773.

25Schauer, J. J.; Cass, G. R. Environ. Sci. Technol. 2000, 34  (9), 1821-1832.

26Chow, J. C.; Watson, J. G.; Lowenthal, D. H.; Countess, R. J. Atmos. Environ. 1996, 30
(9), 1489-1499.

27 South Coast Air Quality Management District. 1997 air quality maintenance plan:
Appendix V, Modeling and attainment demonstrations. Prepared by South Coast Air Quality
Management District: Diamond Bar, CA, 1996.

28 Chow, J. C.; Watson, J. G.; Green, M. C.; Lowenthal, D. H.; Bates, B. A.; Oslund, W.;
Torres, G. Atmos. Environ. 2000, 34 (11), 1833-1843.

29 Chow, J. C.; Watson, J. G.; Green, M. C.; Lowenthal, D. H.; DuBois, D. W.; Kohl, S. D.;
Egami, R. T.; Gillies, J. A.; Rogers, C. F.; Frazier, C. A.; Gates, W. JAWMA 1999, 49 (6),
641-654.

30 Watson, J. G.; Fujita, E. M.; Chow, J. C.; Zielinska, B.; Richards, L. W.; Neff, W. D.;
Dietrich, D. Northern Front Range Air Quality Study. Final report. Prepared for Colorado
State University, Fort Collins, CO, by Desert Research Institute: Reno, NV, 1998.

31 Malm, W. C.; Gebhart, K. A. JAWMA 1997, 47 (3), 250-268.

32Eatough, D. J.; Farber, R. J.; Watson, J. G. JAWMA 2000, 50 (5), 759-774.

33 U.S. EPA (2006) National Ambient Air Quality Standards for Particulate Matter; Final
Rule.  October 17, 2006; Vol.71, No. 200; pp. 61144-61232.

34 Final RIA PM NAAQS, Chapter 2: Defining the PM2.5 Air Quality Problem. October 17,
2006.
                                  A2-24

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          Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
35 Final RIA PM NAAQS, Chapter 2: Defining the PM2.5 Air Quality Problem. October 17,
2006.

36 For example, see letter dated September 23, 2006 from Northeast States for Coordinated
Air Use Management to Administrator Stephen L. Johnson;  September 7, 2006 letter from
Executive Officer of the California Air Resources Board to Acting Assistant Administrator
William L. Wehrum; August 9, 2006 letter from State and Territorial Air Pollution Program
Administrators and Association of Local Air Pollution Control Officials (and other
organizations) to Administrator Stephen L. Johnson; January 20, 2006 letter from Executive
Director, Puget Sound Clean Air Agency to Administrator Stephen L. Johnson; June 30,
2005 letter from Western Regional Air Partnership to Administrator Stephen L. Johnson.

37 U.S. Environmental Protection Agency, Byun,  D.W., and Ching, J.K.S., Eds, 1999.
Science algorithms of EPA Models-3 Community Multiscale Air Quality (CMAQ modeling
system, EPA/600/R-99/030, Office of Research and Development).

38 Byun, D.W., and Schere, K.L., 2006. Review of the Governing Equations, Computational
Algorithms, and Other Components of the Models-3 Community Multiscale Air Quality
(CMAQ) Modeling System, J. Applied Mechanics Reviews, 59 (2), 51-77.

39 Dennis, R.L., Byun, D.W., Novak, J.H., Galluppi, K.J., Coats, C.J., and Vouk, M.A., 1996.
The next generation of integrated air quality modeling: EPA's Models-3, Atmospheric
Environment, 30, 1925-1938.

40 Amar, P., Bornstein, R., Feldman, H., Jeffries,  H., Steyn, D., Yamartino, R., Zhang, Y.,
2004. Final Report Summary:  December 2003 Peer Review of the CMAQ Model, p. 7.

41 Please see the Community Modeling and Analysis System (CMAS) Center website for
complete details on CMAQ version 4.5:  http://www.cmascenter.org/

42 Grell, G., J. Dudhia, and D. Stauffer, 1994: A Description  of the Fifth-Generation Penn
State/NCAR Mesoscale Model (MM5), NCAR/TN-398+STR., 138 pp, National Center for
Atmospheric Research, Boulder CO.

43 U.S. Environmental Protection Agency, Byun,  D.W., and Ching, J.K.S., Eds, 1999.
Science algorithms of EPA Models-3 Community Multiscale Air Quality (CMAQ modeling
system, EPA/600/R-99/030, Office of Research and Development). Please also see:
http://www.cmascenter.org/

44 Yantosca, B., 2004. GEOS-CHEMv7-01-02 User's Guide, Atmospheric Chemistry
Modeling Group, Harvard University, Cambridge, MA, October 15, 2004.
                                  A2-25

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Draft Regulatory Impact Analysis
45 U.S. Environmental Protection Agency, March 2005.  Technical Support Document for the
Clean Air Interstate Rule: Air Quality Modeling, Office of Air Quality Planning and
Standard, Research Triangle Park, NC.  (Docket No. OAR-2005-0053-2151).

46 Regional Planning Organization regions include:  Mid-Atlantic/Northeast Visibility Union
(MANE-VU), Midwest Regional Planning Organization - Lake Michigan Air Directors
Consortium (MWRPO-LADCO), Visibility Improvement State and Tribal Association of the
Southeast (VISTAS), Central States Regional Air Partnership (CENRAP), and Western
Regional Air Partnership (WRAP).

47 These other modeling studies represent a wide range of modeling analyses which cover
various models, model configurations, domains, years and/or episodes, chemical
mechanisms, and aerosol modules.

48 U.S. EPA, (2004), "Procedures for Estimating Future  PM2.5 Values for the CAIR Final
Rule by Application of the (Revised) Speciated Modeled Attainment Test (SMAT)- Updated
11/8/04".

49 U.S. EPA, (2006), "Procedures for Estimating Future  PM2.5 Values for the PM NAAQS
by Application of the Speciated Modeled Attainment Test (SMAT)".

50 National Research Council, 1993. Protecting Visibility in National Parks and Wilderness
Areas.  National Academy of Sciences Committee on Haze in National Parks and Wilderness
Areas.  National Academy Press, Washington, DC. This book can be viewed on the National
Academy Press Website at http://www.nap.edu/books/0309048443/html/ and is available in
Docket EPA-HQ-OAR-2004-0008.

51 See discussion in U.S. EPA , National Ambient Air Quality Standards for Particulate
Matter; Proposed Rule; January 17, 2006, Vol71  p 2676. This information is available
electronically at http://epa.gov/fedrgstr/EPA-AIR/2006/January/Day-17/al 77.pdf

52 U.S. EPA (2004) Air Quality Criteria for Particulate Matter (Oct 2004), Volume I
Document No. EPA600/P-99/002aF and Volume II Document No. EPA600/P-99/002bF.
This document is available in Docket EPA-HQ-OAR-2004-0008.

53 U.S. EPA (2005) Review of the National Ambient Air Quality Standard for Particulate
Matter: Policy Assessment of Scientific and Technical Information, OAQPS Staff Paper.
EPA-452/R-05-005. This document is available in Docket EPA-HQ-OAR-2004-0008.

54 U.S. EPA (2004) Air Quality Criteria for Particulate Matter. Document Nos. EPA/600/P-
99/002aF and EPA/600/P-99/002bF.  This document is available in Docket OAR-2004-0008,
Document Nos.  OAR-2004-0008-0042 and 0043. [Available online at
http://cfpub.epa.gov/ncea/cfm/partmatt.cfm].
                                  A2-26

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          Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
55  CANDruleRIA.

56 U.S. EPA. 2005. Review of the National Ambient Air Quality Standard for Particulate
Matter: Policy Assessment of Scientific and Technical Information, OAQPS Staff Paper.
EPA-452/R-05-005.

57 U.S. EPA. 1993. Effects of the 1990 Clean Air Act Amendments on Visibility in Class I
Areas: An EPA Report to Congress.  EPA452-R-93-014.

58 U.S. EPA (2002) Latest Findings on National Air Quality - 2002 Status and Trends.  EPA
454/K-03-001.

59 National Park Service.  Air Quality in the National Parks, Second edition. NFS, Air
Resources Division.  D 2266. September 2002.

60 U.S. EPA (2002) Latest Findings on National Air Quality - 2002 Status and Trends.  EPA
454/K-03-001.

61 Deposition of Air Pollutants to the Great Waters, Third Report to Congress, June 2000,
EPA-453/R-00-005.  This document can be found in Docket No. OAR-2002-0030,
Document No. OAR-2002-0030-0025. It is also available at
www.epa.gov/oar/oaqps/gr8water/3rdrpt/obtain.html.

62Bricker, Suzanne B., et al., National Estuarine Eutrophication Assessment, Effects of
Nutrient Enrichment in the Nation's Estuaries,  National Ocean Service, National Oceanic
and Atmospheric Administration, September, 1999.

63 Deposition of Air Pollutants to the Great Waters, Third Report to Congress, June, 2000.

64 Valigura, Richard, et al., Airsheds  and Watersheds II: A Shared Resources Workshop, Air
Subcommittee of the Chesapeake Bay Program, March, 1997.

65 The Impact of Atmospheric Nitrogen Deposition on Long Island Sound, The Long Island
Sound Study, September, 1997.

66 Dennis, Robin L., Using the Regional Acid Deposition Model to Determine the Nitrogen
Deposition Airshed of the Chesapeake Bay Watershed, SETAC Technical Publications
Series, 1997.

67 Wedin, D.A. and D. Tilman. 1996. Influence of nitrogen loading and species composition
on the carbon balance of grasslands.  Science 274:1720-1723.

68 U.S. EPA (2000) Deposition of Air Pollutants to the Great Waters: Third Report to
Congress. Office of Air Quality  Planning and Standards. EPA-453/R-00-0005.
                                  A2-27

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Draft Regulatory Impact Analysis
69 U.S. EPA (2004) National Coastal Condition Report II. Office of Research and
Development/ Office of Water. EPA-620/R-03/002.

70 Gao, Y., E.D. Nelson, M.P. Field, et al.  2002.  "Characterization of atmospheric trace
elements on PM2.5 particulate matter over the New York-New Jersey harbor estuary."
Atmos. Environ. 36:  1077-1086.

71 Kim, G., N. Hussain, J.R. Scudlark, and T.M. Church.  2000.  "Factors influencing the
atmospheric depositional fluxes of stable Pb, 210Pb, and 7Be into Chesapeake Bay." J.
Atmos. Chem.  36: 65-79.

72 Lu, R., R.P. Turco, K. Stolzenbach, et al. 2003.  "Dry deposition of airborne trace metals
on the Los Angeles Basin and adjacent coastal waters." J. Geophys. Res. 108(D2, 4074):
AAC 11-1 to 11-24.

73 Marvin, C.H., M.N. Charlton, EJ. Reiner, et al. 2002. "Surficial sediment contamination
in Lakes Erie and Ontario: A comparative analysis." J. Great Lakes Res. 28(3):  437-450.

74 Smith, W.H. 1991. "Air pollution and Forest Damage." Chemical Engineering News,
69(45): 30-43.

75 Gawel, J.E.; Ahner, B.A.; Friedland, A.J.; and Morel, F.M.M. 1996. "Role for  heavy
metals in forest decline indicated by phytochelatin measurements." Nature, 381:  64-65.

76 Cotrufo, M.F.; DeSanto, A.V.;  Alfani, A.; et al. 1995. "Effects of urban heavy  metal
pollution on organic  matter decomposition in  Quercus ilix L. woods." Environmental
Pollution, 89: 81-87.

77Niklinska, M.; Laskowski, R.; Maryanski, M. 1998.  "Effect of heavy metals and storage
time on two types  of forest litter:  basal respiration rate and exchangeable metals."
Ecotoxicological Environmental Safety, 41: 8-18.

78Mason, R.P. and Sullivan, K.A. 1997. "Mercury in Lake Michigan." Environmental
Science  & Technology,  31: 942-947.  (from Delta Report "Atmospheric deposition of toxics
to the Great Lakes").

79Landis, M.S. and Keeler,  G.J. 2002. "Atmospheric mercury deposition to Lake Michigan
during the Lake Michigan Mass Balance Study."  Environmental Science & Technology, 21:
4518-24.

80 U.S. EPA. 2000. EPA453/R-00-005, "Deposition of Air Pollutants to the Great Waters:
Third Report to Congress,"  Office of Air Quality Planning and Standards, Research Triangle
Park, North Carolina.
                                   A2-28

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          Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
81 Callender, E. and Rice, K.C. 2000. "The Urban Environmental Gradient: Anthropogenic
Influences on the Spatial and Temporal Distributions of Lead and Zinc in Sediments."
Environmental Science & Technology, 34: 232-238.

82 Rice, K.C. 1999. "Trace Element Concentrations in Streambed Sediment Across the
Conterminous United States." Environmental Science & Technology, 33: 2499-2504.

83 Ely, JC; Neal, CR; Kulpa, CF; et al. 2001. "Implications of Platinum-Group Element
Accumulation along U.S. Roads from Catalytic-Converter Attrition." Environ. Sci. Technol.
35: 3816-3822.

84 U.S. EPA. 1998. EPA454/R-98-014, "Locating and Estimating Air Emissions from
Sources of Polycyclic Organic Matter," Office of Air Quality Planning and Standards,
Research Triangle Park, North Carolina.

85 U.S. EPA. 1998. EPA454/R-98-014, "Locating and Estimating Air Emissions from
Sources of Polycyclic Organic Matter," Office of Air Quality Planning and Standards,
Research Triangle Park, North Carolina.

86Simcik, M.F.; Eisenreich, S.J.; Golden, K.A.; et al. 1996. "Atmospheric Loading of
Polycyclic Aromatic Hydrocarbons to Lake Michigan as Recorded in the Sediments."
Environmental Science and Technology, 30: 3039-3046.

87Simcik, M.F.; Eisenreich, S.J.; and Lioy, P.J. 1999. "Source apportionment and source/sink
relationship of PAHs in the coastal atmosphere of Chicago and Lake Michigan."
Atmospheric Environment, 33:  5071-5079.

88Arzayus, K.M.; Dickhut, R.M.; and Canuel, E.A. 2001.  "Fate of Atmospherically
Deposited Polycyclic Aromatic Hydrocarbons (PAHs) in Chesapeake Bay." Environmental
Science & Technology, 35, 2178-2183.

89 Park, J.S.; Wade, T.L.; and Sweet, S. 2001. "Atmospheric distribution of polycyclic
aromatic hydrocarbons and deposition to Galveston Bay, Texas, USA." Atmospheric
Environment,  35: 3241-3249.

90 Poor, N.; Tremblay, R.; Kay, H.; et al. 2002.  "Atmospheric concentrations and dry
deposition rates of polycyclic aromatic hydrocarbons (PAHs) for Tampa Bay, Florida, USA."
Atmospheric Environment 38: 6005-6015.

91 Arzayus, K.M.; Dickhut, R.M.; and Canuel, E.A. 2001.  "Fate of Atmospherically
Deposited Polycyclic Aromatic Hydrocarbons (PAHs) in Chesapeake Bay." Environmental
Science & Technology, 35, 2178-2183.
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92 U.S. EPA. 2000. EPA453/R-00-005, "Deposition of Air Pollutants to the Great Waters:
Third Report to Congress," Office of Air Quality Planning and Standards, Research Triangle
Park, North Carolina.

93 Van Metre, P.C.; Mahler, B.J.; and Furlong, E.T. 2000. "Urban Sprawl Leaves its PAH
Signature." Environmental Science & Technology, 34: 4064-4070.

94 Cousins, I.T.; Beck, A.J.; and Jones, K.C. 1999. "A review of the processes involved in the
exchange of semi-volatile organic compounds across the air-soil interface." The Science of
the Total Environment, 228: 5-24.

95 U.S. EPA (2005) Review of the National Ambient Air Quality Standard for Particulate
Matter: Policy Assessment of Scientific and Technical Information, OAQPS Staff Paper.
EPA-452/R-05-005.

96 U.S. EPA. 1996. Air Quality Criteria for Ozone and Related Photochemical Oxidants,
EPA600-P-93-004aF.

97 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.

98 U.S. EPA, Review of the National Ambient Air Quality Standards for Ozone:  Policy
Assessment of Scientific and Technical Information, OAQPS Staff Paper, Washington, DC,
EPA-452/R-07-003, January 2007.

"'Bates, D.V.; Baker-Anderson, M.; Sizto, R. (1990) Asthma attack periodicity: a study of
hospital emergency visits in Vancouver. Environ. Res. 51: 51-70.

100Thurston, G.D.; Ito, K.; Kinney, P.L.; Lippmann, M. (1992)  A multi-year study of air
pollution and respiratory hospital admissions in three New York State metropolitan areas:
results for 1988 and 1989 summers. J. Exposure Anal. Environ.  Epidemiol. 2:429-450.

101Thurston, G.D.; Ito, K.; Hayes, C.G.; Bates, D.V.; Lippmann, M. (1994) Respiratory
hospital admissions and summertime haze air pollution in Toronto, Ontario: consideration of
the role of acid aerosols.  Environ. Res. 65: 271-290.

102 Lipfert, F.W.;  Hammerstrom, T. (1992) Temporal patterns in air pollution and hospital
admissions. Environ. Res. 59: 374-399.

103'Burnett, R.T.;  Dales, R.E.; Raizenne, M.E.; Krewski, D.; Summers, P.W.; Roberts, G.R.;
Raad-Young, M.; Dann,T.; Brook, J. (1994) Effects of low ambient levels of ozone and
sulfates on the frequency of respiratory admissions to Ontario hospitals. Environ. Res. 65:
172-194'
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          Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
104 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.

105 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.

106'Devlin, R. B.; McDonnell, W. F.; Mann, R.; Becker, S.; House, D. E.; Schreinemachers,
D.; Koren, H. S. (1991) Exposure of humans to ambient levels of ozone for 6.6 hours causes
cellullar and biochemical changes in the lung. Am. J. Respir. Cell Mol. Biol. 4: 72-81.

107'Koren, H. S.; Devlin, R. B.; Becker, S.; Perez, R.; McDonnell, W. F. (1991) Time-
dependent changes of markers associated with inflammation in the lungs of humans exposed
to ambient levels of ozone. Toxicol. Pathol. 19: 406-411.

108'Koren, H. S.; Devlin, R. B.; Graham, D. E.; Mann, R.; McGee, M. P.; Horstman, D. H.;
Kozumbo, W. J.; Becker, S.; House, D. E.; McDonnell, W. F.; Bromberg, P. A. (1989a)
Ozone-induced inflammation in the lower airways of human subjects. Am. Rev. Respir. Dis.
139:407-415.

109'Schelegle, E.S.; Siefkin, A.D.; McDonald, RJ. (1991)  Time course of ozone-induced
neutrophilia in normal humans.  Am. Rev. Respir. Dis. 143:1353-1358.


110 U.S. EPA (1996). Air Quality Criteria for Ozone and Related Photochemical Oxidants,
EPA600-P-93-004aF; (See page 7-171).


11LHodgkin, J.E.; Abbey, D.E.; Euler, G.L.; Magie,  A.R.  (1984) COPD prevalence in
nonsmokers in high and low photochemical air pollution areas. Chest 86: 830-838.

112'Euler, G.L.; Abbey, D.E.; Hodgkin, J.E.; Magie,  A.R.  (1988)  Chronic obstructive
pulmonary disease symptom effects of long-term cumulative exposure to ambient levels of
total oxidants and nitrogen dioxide in California Seventh-day Adventist residents.  Arch.
Environ. Health 43: 279-285.

113'Abbey, D.E.; Petersen, F.; Mills, P.K.; Beeson, W.L. (1993) Long-term ambient
concentrations of total suspended particulates, ozone, and sulfur dioxide and respiratory
symptoms in a nonsmoking population. Arch. Environ. Health 48: 33-46.

114' U.S. EPA, Review of the National Ambient Air Quality Standards for Ozone:  Policy
Assessment of Scientific and Technical Information, OAQPS Staff Paper, Washington, DC,
EPA-452/R-07-003, January 2007.

115 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
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Draft Regulatory Impact Analysis
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.

116 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.

117'Avol, E. L.; Trim, S. C.; Little, D. E.; Spier, C. E.; Smith, M. N.; Peng, R.-C.; Linn, W.
S.; Hackney, J. D.;  Gross, K. B.; D'Arcy, J. B.; Gibbons, D.; Higgins, I. T. T. (1990) Ozone
exposure and lung function in children attending a southern California summer camp.
Presented at: 83rd annual meeting and exhibition of the Air & Waste Management
Association; June; Pittsburgh, PA. Pittsburgh,  PA: Air & Waste Management Association;
paper no. 90-150.3.

118' Higgins, I. T. T.; D'Arcy, J. B.; Gibbons, D. I.; Avol, E. L.; Gross, K. B. (1990) Effect of
exposures to ambient ozone on ventilatory lung function in children. Am. Rev. Respir. Dis.
141: 1136-1146.

119'Raizenne, M. E.; Burnett, R. T.; Stern, B.; Franklin, C. A.; Spengler, J. D. (1989) Acute
lung function responses to ambient acid aerosol exposures in children. Environ. Health
Perspect. 79: 179-185.

1211 Raizenne, M.; Stern, B.; Burnett, R.; Spengler, J. (1987) Acute respiratory function and
transported air pollutants:  observational studies. Presented at:  80th annual meeting of the Air
Pollution Control Association; June; New York, NY. Pittsburgh, PA: Air Pollution Control
Association; paper no. 87-32.6.

121 Spektor, D. M.;  Lippmann, M. (1991) Health effects of ambient ozone on healthy children
at a summer  camp.  In: Berglund, R. L.; Lawson, D. R.; McKee, D. J., eds. Tropospheric
ozone and the environment: papers from an international conference; March 1990; Los
Angeles, CA. Pittsburgh, PA: Air & Waste Management Association; pp. 83-89.  (A&WMA
transaction series no.  TR-19).

122'Spektor, D. M.;  Thurston, G. D.; Mao, J.; He, D.; Hayes, C.; Lippmann, M. (1991)
Effects of single- and multiday ozone exposures on respiratory function in active normal
children. Environ. Res. 55: 107-122.

123'Spektor, D. M.; Lippman, M.; Lioy, P. J.; Thurston, G. D.; Citak, K.; James, D. J.; Bock,
N.; Speizer, F. E.; Hayes, C. (1988a) Effects of ambient ozone on respiratory function in
active, normal children. Am. Rev. Respir. Dis. 137:  313-320.

124 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.

125 Hazucha, M. J.;  Folinsbee, L. J.; Seal, E., Jr. (1992) Effects of steady-state and variable
ozone concentration profiles on pulmonary function. Am. Rev. Respir. Dis. 146: 1487-1493.
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126 Horstman, D.H.; Ball, B.A.; Folinsbee, L.J.; Brown, J.; Gerrity, T. (1995) Comparison of
pulmonary responses of asthmatic and nonasthmatic subjects performing light exercise while
exposed to a low level of ozone. Toxicol. Ind. Health.

127 Horstman, D.H.; Folinsbee, L.J.; Ives, P.J.; Abdul-Salaam, S.; McDonnell, W.F. (1990)
Ozone concentration and pulmonary response relationships for 6.6-hour exposures with five
hours of moderate exercise to 0.08, 0.10, and 0.12 ppm. Am. Rev. Respir. Dis. 142: 1158-
1163.

128NARSTO Synthesis Team (2000).  An Assessment of Tropospheric Ozone Pollution: A
North American Perspective.

129Fujita, E.M., W.R. Stockwell, D.E. Campbell, R.E. Keislar, and D.R. Lawson (2003).
Evolution of the Magnitude and Spatial Extent of the Weekend Ozone Effect in California's
South Coast Air Basin from 1981 to 2000, Submitted to the J. Air & Waste Manage. Assoc.

130Marr, L.C. and R.A. Harley (2002).  Modeling the Effect of Weekday-Weekend
Differences in Motor Vehicle Emissions on Photochemical Air Pollution in Central
California, Environ. Sci. Technol., 36, 4099-4106.

131 Larsen, L.C. (2003). The Ozone  Weekend Effect in California:  Evidence Supporting NOx
Emissions Reductions,  Submitted to the J. Air & Waste Manage. Assoc.

132 For example, see letters in the Air Docket for this rule from American Lung Association,
Clean Air Trust, California Environmental Protection Agency, New York State Department
of Environmental Conservation, Texas Commission on Environmental Quality (TCEQ,
formerly Texas Natural Resources Conservation Commission), State and Territorial Air
Pollution Program Administrators and the Association of Local Air Pollution Control
Officials (STAPPA/ALAPCO), Natural Resources Defense Council, Sierra Club, and Union
of Concerned Scientists.).

133 (NAS, 1991).

134 U.S. EPA. 1999. The Benefits and Costs of the  Clean Air Act, 1990-2010.  Prepared for
U.S. Congress by U.S.  EPA, Office  of Air and Radiation, Office of Policy Analysis and
Review, Washington, DC, November; EPA report no. EPA410-R-99-001.

135 Winner, W.E., and CJ. Atkinson. 1986. "Absorption of air pollution by plants, and
consequences for growth." Trends in Ecology and Evolution 1:15-18.

136 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF,
2006.This document is  available in Docket EPA-HQ-OAR-2005-0036.
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137Tingey, D.T., and Taylor, G.E. 1982. "Variation in plant response to ozone: a conceptual
model of physiological events."  In: Effects of Gaseous Air Pollution in Agriculture and
Horticulture (Unsworth, M.H., Omrod, D.P., eds.) London, UK: Butterworth Scientific,
pp.113-138.

138 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF,
2006.This document is available in Docket EPA-HQ-OAR-2005-0036.

139 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.
This document is available in Docket EPA-HQ-OAR-2005-0036.

140 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.
This document is available in Docket EPA-HQ-OAR-2005-0036.

141 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.
This document is available in Docket EPA-HQ-OAR-2005-0036.

142 Ollinger, S.V., J.D. Aber and P.B. Reich. 1997. "Simulating ozone effects on forest
productivity: interactions between leaf canopy and stand level processes." Ecological
Applications 7:1237-1251.

143 Winner, W.E., 1994. "Mechanistic analysis of plant responses to air pollution."
Ecological Applications, 4(4):651-661.

144 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.
This document is available in Docket EPA-HQ-OAR-2005-0036.

145 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.
This document is available in Docket EPA-HQ-OAR-2005-0036.

146 Fox, S., and R. A. Mickler, eds. 1996.  Impact of Air Pollutants on Southern Pine Forests.
Springer-Verlag,  NY, Ecol. Studies, Vol.  118, 513 pp.

147 De Steiguer, J., J. Pye, C. Love. 1990.  "Air Pollution Damage to U.S. Forests." Journal of
Forestry, Vol 88 (8) pp. 17-22.

148 Pye, J.M. 1988. "Impact of ozone on the growth and yield of trees: A review." Journal of
Environmental Quality 17 pp.347-360.
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149 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.
This document is available in Docket EPA-HQ-OAR-2005-0036.

150 U.S. EPA. Air Quality Criteria for Ozone and Related Photochemical Oxidants (Final).
U.S. Environmental Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006.
This document is available in Docket EPA-HQ-OAR-2005-0036.

151 McBride, J.R., P.R. Miller, and R.D. Laven. 1985. "Effects of oxidant air pollutants on
forest succession in the mixed conifer forest type of southern California." In: Air Pollutants
Effects On Forest Ecosystems, Symposium Proceedings, St. P, 1985, p. 157-167.

152 Miller, P.R., O.C. Taylor, R.G. Wilhour. 1982. Oxidant air pollution effects on a western
coniferous forest ecosystem. Corvallis, OR: U.S. Environmental Protection Agency,
Environmental Research Laboratory (EPA600-D-82-276).

153 This document is available in Docket EPA-HQ-OAR-2005-0036.153 U.S. EPA. Air
Quality Criteria for Ozone and Related Photochemical Oxidants (Final). U.S. Environmental
Protection Agency, Washington, DC, EPA/600/R-05/004aF-cF, 2006. This document is
available in Docket EPA-HQ-OAR-2005-0036.

154 Kopp, R. J.; Vaughn, W. J.; Hazilla, M.; Carson, R. 1985. "Implications of environmental
policy for U.S. agriculture: the case of ambient ozone standards." J. Environ. Manage.
20:321-331.

155 Adams, R. M.; Hamilton, S. A.; McCarl, B. A.  1986.  "The benefits of pollution control:
the case of ozone and U.S. agriculture."  Am.J. Agric. Econ. 34:3-19.

156 Adams, R. M.; Glyer, J. D.; Johnson, S. L.; McCarl, B. A. 1989. "A reassessment of the
economic effects of ozone on U.S. agriculture." JAPCA 39:960-968.

157 Abt Associates, Inc. 1995. Urban ornamental plants: sensitivity to ozone and potential
economic losses. U.S. EPA, Office of Air Quality Planning and Standards, Research
Triangle Park.  Under contract to RADIAN Corporation, contract no. 68-D3-0033, WA no. 6.
pp. 9-10.
158 U.S. EPA (2006) National-Scale Air Toxics Assessment for 1999.
http://www.epa.gov/ttn/atw/natal999.

159 U.S. EPA (2002) Health Assessment Document for Diesel Engine Exhaust. EPA/600/8-
90/057F Office of Research and Development, Washington DC.  Ppl-1 1-2. This document
is available electronically at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=29060.
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160 U.S. EPA (2002) Health Assessment Document for Diesel Engine Exhaust. EPA/600/8-
90/057F Office of Research and Development, Washington DC.  This document is available
electronically at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=29060.

161 U.S. EPA.  (1999).  Guidelines for Carcinogen Risk Assessment. Review Draft.  NCEA-F-
0644, July. Risk Assessment Forum, Washington, DC.
http://www.epa.gov/ncea/raf/cancer.htm.

162 U.S. EPA.  (1986) .Guidelines for carcinogen risk assessment. Federal Register
51(185):33992-34003.

163 National Institute for Occupational Safety and Health (NIOSH). (1988).  Carcinogenic
effects of  exposure to diesel exhaust. NIOSH Current Intelligence Bulletin 50. DHHS
(NIOSH) Publication No. 88-116. Atlanta, GA: Centers for Disease Control.

164 International Agency for Research on Cancer - IARC. (1997). Monographs  on the
evaluation of carcinogenic risks to humans.  Vol. 68. Silica, some silicates, coal dust and
para-aramid fibrils. Lyon, France: IARC, pp. 362-375.

165 National Institute for Occupational Safety and Health (NIOSH). (1988).  Carcinogenic
effects of  exposure to diesel exhaust.. NIOSH Current Intelligence Bulletin 50. DHHS
(NIOSH) Publication No. 88-116. Atlanta, GA: Centers for Disease Control.

166 World Health Organization International Program on Chemical Safety (1996).
Environmental Health Criteria 171. Diesel fuel and exhaust emissions. Geneva: World
Health Organization, pp. 172-176.

167 California Environmental Protection Agency. (Cal EPA, OEHHA) (1998). Health risk
assessment for diesel exhaust.  Public and Scientific Review Draft.

168 National Toxicology Program (NTP). (2000). 9th report on carcinogens. Public Health
Service, U.S. Department of Health and Human Services, Research Triangle Park,  NC.
Available from: http://ntp-server.niehs.nih.gov.

169 Health Effects Institute (HEI).  (1995). Diesel exhaust: a critical analysis of emissions,
exposure, and health effects. Cambridge,  MA.

170 Health Effects Institute (HEI) (1999). Diesel emissions and lung cancer: epidemiology
and quantitative risk  assessment. A special report of the Institute's Diesel Epidemiology
Expert Panel. Cambridge,  MA.

171 Health  Effects Institute (HEI). (2002). Research directions to improve estimates of
human exposure and risk assessment. A special report of the Institute's Diesel Epidemiology
Working Group, Cambridge, MA.
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172Ishinishi, N., Kuwabara, N., Takaki, Y., etal. (1988). Long-term inhalation experiments
on diesel exhaust. In: Diesel exhaust and health risks. Results of the HERP studies. Ibaraki,
Japan: Research Committee for HERP Studies; pp. 11-84.

173Lewtas, J. (1983). Evaluation of the mutagenicity and carcinogenicity of motor vehicle
emissions in short-term bioassays.  Environ Health Perspect 47:141-152.

174Garshick, E., Schenker, M., Munoz, A, etal. (1987). A case-control study of lung
cancer and diesel exhaust exposure in railroad workers. Am Rev Respir Dis 135:1242-1248.

175Garshick, E., Schenker, M., Munoz, A, etal. (1988). A retrospective cohort study of
lung cancer and diesel  exhaust exposure in railroad workers. Am Rev Respir Dis 137:820-
825.

176 Woskie, SR; Smith, TJ; Hammond, SK; et al. (1988). Estimation of the diesel exhaust
exposures of railroad workers. I. Current exposures.  Am J Ind Med 13:381-394.

177 Steenland, K., Silverman,  D, Hornung, R.  (1990). Case-control study of lung cancer and
truck driving in the Teamsters Union. Am J Public Health 80:670-674.

178 Steenland, K., Deddens, J., Stayner, L. (1998). Diesel exhaust and lung cancer in the
trucking industry: exposure-response analyses and risk assessment. Am J Ind Med 34:220-
228.

179 Steenland, K., Deddens, J., Stayner, L. (1998). Diesel exhaust and lung cancer in the
trucking industry: exposure-response analyses and risk assessment. Am J Ind Med 34:220-
228.

180Zaebst, DD; Clapp,  DE; Blake, LM; et  al. (1991). Quantitative determination of trucking
industry workers' exposures to diesel exhaust particles. Am Ind Hyg Assoc J 52:529-541.

181 Saverin, R.  (1999). German potash miners: cancer mortality. Health Effects Institute
Number 7.  March 7-9, Stone Mountain, GA, pp.  220-229.

182 Saverin, R.  (1999). German potash miners: cancer mortality. Health Effects Institute
Number 7.  March 7-9, Stone Mountain, GA, pp.  220-229.

183 U.S. EPA (2002) Health Assessment Document for Diesel Engine Exhaust.  EPA/6008-
90/057F  Office of Research and Development, Washington DC. 9-11.

184 Bhatia, R., Lopipero, P., Smith, A. (1998) Diesel exposure and lung cancer.
Epidemiology 9(1):84-91.
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185 Lipsett, M: Campleman, S; (1999) Occupational exposure to diesel exhaust and lung
cancer:  a meta-analysis. Am J Public Health 80(7): 1009-1017.

186 Garshcik, E; Schenker, MB; Munoz,A; et al. (1988) A retrospective cohort study of lung
cancer and diesel exhaust exposure in railroad workers. Am Rev Respir Dis 137; 820-825.

187Swanson, GM; Lin, CS; Burn, PB. (1993) Diversity in the association between occupation
and lung cancer among black and white men. Cancer Epidemiol Biomarkers Prev 2:313-320.

188 Woskie, SR; Smith, TJ; Hammond, SK; et al. (1988a) Estimation of the diesel exhaust
exposures of railroad workers: I. Current exposures. Am J Ind Med 13:381-394; II National
and historical exposures. Am J Ind Med 13:395-404.

189 U.S. EPA (2002), National-Scale Air Toxics Assessment for 1996. This material is
available electronically at http://www.epa.gov/ttn/atw/nata/.

190 U.S. EPA (2006), National-Scale Air Toxics Assessment for 1999. This material is
available electronically at http://www.epa.gov/ttn/atw/natal999/.

191 Ishinishi, N; Kuwabara, N; Takaki, Y; et al. (1988) Long-term inhalation experiments on
diesel exhaust. In: Diesel exhaust and health risks. Results  of the HERP studies. Ibaraki,
Japan: Research Committee for HERP Studies; pp.11-84.

192Heinrich, U; Fuhst,  R; Rittinghausen, S; et al. (1995) Chronic inhalation exposure of
Wistar rats and two different strains of mice to diesel engine exhaust, carbon black, and
titanium dioxide. Inhal Toxicol 7:553-556.

193Mauderly, JL; Jones, RK; Griffith, WC; et al. (1987) Diesel exhaust is a pulmonary
carcinogen in rats exposed chronically by inhalation. Fundam Appl Toxicol 9:208-221.

194 Nikula, KJ; Snipes,  MB; Barr, EB; et al.  (1995) Comparative pulmonary toxicities and
carcinogenicities of chronically inhaled diesel exhaust and  carbon black  in F344 rats.
Fundam Appl Toxicol  25:80-94.

195 Reger, R; Hancock, J; Hankinson, J; et al. (1982) Coal miners exposed to diesel exhaust
emissions. Ann OccupHyg 26:799-815.

196 Attfield, MD. (1978) The effect of exposure to silica and diesel  exhaust in underground
metal and nonmetal miners.  In: Industrial hygiene for mining and tunneling: proceedings of a
topical symposium; November; Denver, CO. Kelley, WD,  ed. Cincinnati, OH: The American
Conference of Governmental Industrial Hygienists, Inc.

197 Wade, JF, III; Newman, LS. (1993) Diesel asthma: reactive airways disease following
overexposure to locomotive exhaust. J Occup Med 35:149-154.
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          Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
198Kilburn (2000) See HAD Chapter 5-7.

199 Hart, JE, Laden F; Schenker, M.B.; and Garshick, E. Chronic Obstructive Pulmonary
Disease Mortality in Diesel-Exposed Railroad Workers; Environmental Health Perspective
July 2006: 1013-1016.

200 Diesel HAD Page 2-110, 8-12; Woskie, SR; Smith, TJ; Hammond, SK: et al. (1988a)
Estimation of the DE exposures of railroad workers: II.  National and historical exposures.
Am JIndMed 12:381-394.

201 Woskie, SR; Smith, TJ; Hammond, SK: et al. (1988a) Estimation of the DE exposures of
railroad workers: II. National and historical exposures.  Am J Ind Med 12:381-394.

202Kinnee,EJ.; Touman, J.S.; Mason, R.; ThurmanJ.; Beidler, A.; Bailey, C.; Cook, R.
(2004) Allocation of onroad mobile emissions to road segments for air toxics modeling in an
urban area. Transport. Res. Part D 9: 139-150.

203 State of California Air Resources Board. Roseville Rail Yard  Study. Stationary Source
Division, October 14, 2004. This document is available electronically at:
http://www.arb.ca.gov/diesel/documents/rrstudy.htm  and State of California Air Resources
Board. Diesel Particulate Matter Exposure Assessment Study for the Ports of Los Angeles
and Long Beach, April 2006. This document is available electronically at:
http://www.arb.ca.gov/regact/marine2005/portstudy0406.pdf

204 Hand, R.; Pingkuan, D.; Servin, A.; Hunsaker, L.; Suer, C. (2004) Roseville rail yard
study.  California Air Resources Board.  [Online at
http://www.arb.ca.gov/diesel/documents/rrstudy.htm]

205 Di, P.; Servin, A.; Rosenkranz, K.; Schwehr, B.; Tran, H. (2006) Diesel particulate matter
exposure assessment study for the Ports of Los Angeles and Long Beach.  California Air
Resources Board.  [Online at
http://www.arb.ca.gov/msprog/offroad/marinevess/marinevess.htm]

206 Chronic exposure is defined in the glossary of the Integrated Risk Information (IRIS)
database (http://www.epa.gov/iris) as repeated exposure by the oral, dermal, or inhalation
route for more than approximately 10 of the life span in humans (more than approximately
90 days to 2 years in typically used laboratory animal species).

207 Defined in ^ jRjg Database as exposure to a substance spanning approximately 10 of the
lifetime of an organism.

208 Defined in the IRIS database as exposure by the oral, dermal, or inhalation route for 24
hours or less.
                                   A2-39

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Draft Regulatory Impact Analysis
209 U.S. EPA. 2000. Integrated Risk Information System File for Benzene. This material is
available electronically at http://www.epa.gov/iris/subst/0276.htm

210 International Agency for Research on Cancer, IARC monographs on the evaluation of
carcinogenic risk of chemicals to humans, Volume 29, Some industrial chemicals and
dyestuffs, International Agency for Research on Cancer, World Health Organization, Lyon,
France, p. 345-389, 1982.

211 Irons,  R.D.; Stillman, W.S.; Colagiovanni, D.B.; Henry, V.A.  (1992) Synergistic action of
the benzene metabolite hydroquinone on myelopoietic stimulating activity of
granulocyte/macrophage colony-stimulating factor in vitro, Proc. Natl. Acad. Sci. 89:3691-
3695.

212Aksoy, M. (1989). Hematotoxicity and carcinogenicity of benzene. Environ. Health
Perspect. 82: 193-197.

213 Goldstein, B.D.  (1988). Benzene toxicity.  Occupational medicine.  State of the Art
Reviews. 3: 541-554.

214Rothman, N., G.L. Li, M. Dosemeci, W.E. Bechtold, G.E. Marti, Y.Z. Wang, M. Linet,
L.Q. Xi, W. Lu, M.T. Smith, N. Titenko-Holland, L.P. Zhang, W. Blot, S.N. Yin, and R.B.
Hayes (1996) Hematotoxicity among Chinese workers heavily exposed to benzene. Am. J.
Ind. Med. 29: 236-246.

215 EPA 2002 Toxicological Review of Benzene (Noncancer Effects). Environmental
Protection Agency, Integrated Risk Information System (IRIS), Research and Development,
National  Center for Environmental Assessment, Washington DC. This material is available
electronically at http://www.epa.gov/iris/subst/0276.htm.

216 Qu, 0.; Shore, R.; Li, G.; Jin, X.; Chen, C.L.; Cohen, B.; Melikian, A.; Eastmond, D.;
Rappaport, S.; Li, H.; Rupa, D.; Suramaya, R.; Songnian, W.;  Huifant, Y.; Meng, M.;
Winnik, M.; Kwok, E.; Li, Y.; Mu, R.; Xu, B.; Zhang, X.; Li, K.  (2003). HEI Report 115,
Validation & Evaluation of Biomarkers in Workers Exposed to Benzene in China.

217 Qu, Q., R. Shore, G. Li, X. Jin, L.C. Chen, B. Cohen, et al. (2002).  Hematological
changes among Chinese workers  with a broad range of benzene exposures.  Am. J.  Industr.
Med. 42: 275-285.

218 Lan, Qing, Zhang, L., Li, G., Vermeulen, R., et al. (2004).  Hematotoxically in Workers
Exposed  to Low Levels of Benzene.  Science 306: 1774-1776.

219Turtletaub, K.W. and Mani, C. (2003). Benzene metabolism in rodents at doses relevant
to human exposure from Urban Air.  Research Reports Health Effect Inst. Report No.l 13.
                                   A2-40

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          Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
220 U.S. EPA. 2002. Health Assessment of 1,3-Butadiene. Office of Research and
Development, National Center for Environmental Assessment, Washington Office,
Washington, DC. Report No. EPA600-P-98-001F. This document is available electronically
at http://www.epa.gov/iris/supdocs/buta-sup.pdf.

221 U.S. EPA. 2002 "Full IRIS Summary for 1,3-butadiene (CASRN 106-99-0)"
Environmental Protection Agency, Integrated Risk Information System (IRIS), Research and
Development, National Center for Environmental Assessment, Washington, DC
http://www.epa.gov/iris/subst/0139.htm.

222Bevan, C.; Stadler, J.C.;  Elliot, G.S.; et al.  (1996) Subchronic toxicity of 4-
vinylcyclohexene in rats and mice by inhalation. Fundam. Appl. Toxicol. 32:1-10.

223 U.S. EPA. 1987. Assessment of Health Risks to Garment Workers and Certain Home
Residents from Exposure to Formaldehyde, Office of Pesticides and Toxic Substances, April
1987.

224 Hauptmann, M..; Lubin,  J. H.; Stewart, P. A.; Hayes, R. B.; Blair, A. 2003.  Mortality
from lymphohematopoetic malignancies among workers in formaldehyde industries. Journal
of the National Cancer Institute 95: 1615-1623.

225 Hauptmann, M..; Lubin,  J. H.; Stewart, P. A.; Hayes, R. B.; Blair, A. 2004.  Mortality
from solid cancers among workers in formaldehyde industries. American Journal of
Epidemiology 159: 1117-1130.

226 Pinkerton, L. E. 2004. Mortality among a cohort of garment workers exposed to
formaldehyde: an update. Occup. Environ. Med. 61: 193-200.

227 Coggon, D, EC Harris, J Poole, KT Palmer. 2003. Extended follow-up of a cohort of
British chemical workers exposed to formaldehyde. J National Cancer Inst. 95:1608-1615.


228 Conolly, RB, JS Kimbell, D Janszen, PM Schlosser, D Kalisak, J Preston, and FJ Miller.
2003. Biologically motivated computational modeling of formaldehyde carcinogenicity in
the F344 rat. Tox Sci 75: 432-447.

229 Conolly, RB, JS Kimbell, D Janszen, PM Schlosser, D Kalisak, J Preston, and FJ Miller.
2004. Human respiratory tract cancer risks of inhaled formaldehyde: Dose-response
predictions derived from biologically-motivated computational modeling of a combined
rodent and human dataset.  Tox Sci 82: 279-296.
                                   A2-41

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Draft Regulatory Impact Analysis
230 Chemical Industry Institute of Toxicology (CUT). 1999. Formaldehyde: Hazard
characterization and dose-response assessment for carcinogenicity by the route of inhalation.
CUT, September 28, 1999. Research Triangle Park, NC.

231 Health Canada (2001) Priority Substances List Assessment Report. Formaldehyde.
Environment Canada, Health Canada, February 2001.  The document may be accessed at
http://www.hc-sc.gc.ca/ewh-semt/pubs/contaminants/psl2-lsp2/form aldehyde/index_e.html.

232 U.S. EPA (2004) National Emission Standards for Hazardous Air Pollutants for Plywood
and Composite Wood Products Manufacture: Final Rule. (69 FR 45943, 7/30/04)

233 U.S. EPA (1988). Integrated Risk Information System File of Acetaldehyde. Research
and Development, National Center for Environmental Assessment, Washington, DC. This
material is available electronically at http://www.epa.gov/iris/subst/0290.htm.

234 U.S. EPA (1988). Integrated Risk Information System File of Acetaldehyde. Research
and Development, National Center for Environmental Assessment, Washington, DC.  This
material is available electronically at http://www.epa.gov/iris/subst/0290.htm.

235 Integrated Risk Information System File of Acrolein. Research and Development, National
Center for Environmental Assessment, Washington, DC. This material is available at
http://www.epa.gov/iris/subst/0364.htm

236 Perera, P.P.; Rauh, V.; Tsai, W-Y.; et al.  (2002) Effect of transplacental exposure to
environmental pollutants on birth outcomes in a multiethnic population.  Environ Health
Perspect. 111:201-205.

237 Perera, P.P.; Rauh, V.; Whyatt, R.M.; Tsai, W.Y.; Tang, D.; Diaz, D.; Hoepner, L.; Barr,
D.; Tu, Y.H.; Camann, D.; Kinney, P. (2006) Effect of prenatal exposure to airborne
polycyclic aromatic hydrocarbons on neurodevelopment in the first 3 years of life among
inner-city children. Environ Health Perspect 114: 1287-1292.

238 U. S. EPA. 2004. Toxicological Review of Naphthalene (Reassessment of the Inhalation
Cancer Risk), Environmental Protection Agency, Integrated Risk Information System,
Research and Development, National Center for Environmental Assessment, Washington,
DC.  This material is available electronically at http://www.epa.gov/iris/subst/0436.htm.

239 Oak Ridge Institute for Science and Education.  (2004). External Peer Review for the
IRIS Reassessment of the Inhalation Carcinogenicity of Naphthalene.  August 2004.
http://cfpub2.epa.gov/ncea/cfm/recordisplay.cfm?deid=86019

240 International Agency for Research on Cancer (IARC).  (2002). Monographs on the
Evaluation of the Carcinogenic Risk of Chemicals for Humans. Vol. 82. Lyon, France.
                                   A2-42

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          Chapter 2 Appendices: Air Quality and Resulting Health and Welfare Effects
241U. S. EPA. 1998. Toxicological Review of Naphthalene, Environmental Protection
Agency, Integrated Risk Information System, Research and Development, National Center
for Environmental Assessment, Washington, DC. This material is available electronically at
http://www.epa.gov/iris/subst/0436.htm
                                   A2-43

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                                                                 Chapter 3: Inventory
 EMISSION INVENTORY	2
3.1 Commercial Marine Diesel Engines	2
3.1.1 General Methodology.	3
3.1.2 Baseline (Pre-Control) Inventory Development	6
3.1.3 Control Inventory Development	30
3.1.4 Projected Commercial  Marine Emission Reductions of Proposal	51
3.2 Recreational Marine Diesel Engines	55
3.2.1GeneralMe1hodology.	55
3.2.2 Baseline (Pre-Control) Inventory Development	57
3.2.3 Control Inventory Development	62
3.2.4 Projected Recreational  Marine Emission Reductions of Proposal	66
3.3 Locomotives	68
3.3.1 General Methodology.	68
3.3.2 Baseline (Pre-Control) Inventory Development	72
3.3.3 Control Inventory Development	83
3.3.4 Projected Locomotive Emission Reductions from the Proposed Rule	90
3.4 Projected Total Emission Reductions from the Proposed Rule	94
3.5 Contribution of Marine Diesel Engines and Locomotives to Baseline National
Emission Inventories	100
3.5.1 Categories and Sources of Data	100
3.5.2 PM2.5 Contributions to Baseline	101
3.5.3 NOx Contributions to Baseline	101
3.5.4 VOC Contributions to Baseline	101
3.5.5 CO Contributions to Baseline	102
3.5.6 SO2 Contributions to Baseline	102
3.6 Contribution of Marine Diesel Engines and Locomotives to Non-Attainment Area
Emission Inventories	108
3.7 Emission Inventories Used for Air Quality Mo deling	110
3.7.1 Comparison of Air Quality and Proposed Rule Inventories	110
3.7.2 OnroadInventory Changes	Ill
3.7.3 Nonroad Inventory Changes	112
3.7.4 Locomotive Inventory  Changes	112
3.7.5 Commercial Marine Vessel Inventory Changes	113

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Draft Regulatory Impact Analysis
Emission Inventory

       This chapter presents our analysis of the emission impact of the proposed rule for the
three source categories affected: commercial marine diesel engines, recreational marine
diesel engines, and locomotives. The proposed control requirements include NOX and PMa
emission standards for Category 1 and Category 2 commercial marine diesel engines  (both
above and below 37 kilowatts [kW]). New NOX and PM emission standards would also
apply to all recreational marine diesel engines and locomotives. There are no new standards
for HC or CO; however, the PM standards are also expected to decrease HC emissions.

       Section 3.1 describes the methodology and presents the resulting baseline and
controlled inventories for commercial marine diesel engines, including the projected
emission reductions from the proposed rule. Sections 3.2 and 3.3 present similar information
for recreational marine diesel engines and locomotives, respectively. The baseline
inventories represent current and future emissions with only the existing standards. The
controlled inventories incorporate the new standards in the proposed  rule.  Section 3.4
follows with the total projected emission reductions from all three affected source categories.
Section 3.5 and section 3.6 then describe the contribution of these source categories to
national and selected local inventories,  respectively. Section 3.7 concludes the chapter by
describing the  changes in the inputs and resulting emission inventories between the baseline
and control scenarios used for the air quality modeling and the updated baseline and control
scenarios in this proposed rule.

       The inventory estimates reported in this chapter are for the 50-state geographic area.
Inventories are presented for the following pollutants: particulate matter (PM2.s and PMi0),
oxides of nitrogen (NOX), sulfur dioxide (S02), volatile organic compounds (VOC), carbon
monoxide (CO), and mobile source air toxics.  The specific air toxics are benzene,
formaldehyde, acetaldehyde, 1,3-butadiene, acrolein, napthalene, and 15 other compounds
grouped together as polycyclic organic matter (POM).  The PM inventories include directly
emitted PM only,  although secondary sulfates are taken into account in the air quality
modeling.

3.1 Commercial Marine Diesel Engines

       This section describes the methodology and presents the resulting baseline and
controlled inventories for commercial marine diesel engines, including the projected
emission reductions from the proposed rule. Separate inventories were developed for the
following commercial marine diesel engine categories: Category 1 commercial propulsion,
Category 1 marine auxiliary, Category 2 commercial propulsion, less than (<) 37kW
commercial propulsion, and <37kW marine auxiliary.  Category 1 and 2 only include engines
greater than or equal to (>) 37kW, so it was necessary to  include separate categories for those
a PM in this document refers to PMi0, which are particles less than 10 microns in diameter.

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                                                                Chapter 3: Inventory
engines less than 37kW. Note that the auxiliary categories include engines used on either
commercial or recreational vessels; however, given the expected small number of
recreational auxiliary engines in comparison to commercial auxiliary engines, and our
inability to separate the auxiliary categories by end use, the auxiliary categories have been
included in the broader commercial marine category. Category 2 marine auxiliary engines
are not included here, since they are used on Category 3 ocean-going vessels that are
primarily foreign-flagged and not subject to U.S. regulations.  Emissions from Category 2
auxiliary engines are therefore part of the Category 3 inventories.

3.1.1 General Methodology

       The general methodology for calculating commercial marine diesel engine
inventories for HC, CO, NOX, and PM is first described.  This  is followed by the
methodologies used to calculate fuel consumption, SOz, VOC, PM2.5,  and air toxic
inventories.

       Commercial marine diesel engine inventories for HC, CO, NOX, and PM are
estimated using the equation:

                             Equation 1  I = N*P*L*A*EF

where each term is defined as follows:
       I = the emission inventory (gram/year)
       N = engine population (units)
       P = average rated power (kW)
       L = load factor (average fraction of rated power used during operation; unitless)
       A = engine activity (operating hours/year)
       EF = emission factor  (gram/kW-hr)

       Emissions are then converted and reported as short tons/year.

       The average rated power, load factor, and activity inputs remain constant in any given
simulation year. However, populations and emission factors vary by year and age.
Populations for a given base calendar year are first calculated, along with the corresponding
age distribution, and then projected from that base year into the future. For most of the
commercial marine diesel categories, the base year is 2002. The pollutant emission factors
vary by age to account for the current and proposed regulations, as well as emissions
deterioration. PM emission factors also have an additional adjustment to account for the in-
use fuel sulfur level, which is described in more detail below.

       Three variables are used to project emissions over time: the annual population growth
rate, the engine median life/scrappage, and the relative deterioration rate. Collectively, these
variables represent population growth, changes in the population  age distribution, and
emission deterioration.

       Annual Population Growth Rate (percent/year). The  population growth rate
represents the percentage increase in the total calendar year engine population from year (n)
to year (n+1). It is a compound growth rate. These growth rates vary by category.

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Draft Regulatory Impact Analysis
       Engine Median Life (years) and Scrappage. The engine median life defines the
length of time engines remain in service.  Engines persist in the population over two median
lives; during the first median life, 50 percent of the engines are scrapped, and over the
second, the remaining 50 percent of the engines are scrapped. Engine median lives also vary
by category.  The age distribution is defined by the median life and the scrappage algorithm.
For commercial marine diesel engines, the scrappage algorithm in the NONROAD model
was used for all categories.1

       Relative Deterioration Rate (percent increase in emission factor/percent median life
expended). A deterioration factor can be  applied to the emission factor to account for in-use
deterioration.  The deterioration factor varies by age and is calculated as:

                            Equation 2   DF = 1 + A*(age/ML)

       where each term is defined as follows:
       DF = the deterioration factor for a given pollutant at a given age
       A = the relative deterioration rate for a given pollutant (percent increase in emission
            factor/percent useful life expended)
       age = the age of a specific model year group of engines in the simulation year (years)
       ML = the median life of the given model year cohort (years)

       A given model year cohort is represented as a fraction of the entire population.  The
deterioration factor adjusts the emission factor for engines in a given model year cohort in
relation to the proportion of median life expended. Deterioration is linear over one median
life.  Following the first median life, the deteriorated emission factor is held constant over the
remaining life for engines in the cohort. This is consistent with the diesel deterioration
applied in the NONROAD model.2

       Sulfur Adjustment for PM Emissions.  For Tier 2 and prior engines, a sulfate
adjustment is added to the PM emissions to account for differences in fuel sulfur content
between the certification fuel and the episodic (calendar year) fuel, using the following
equation:

            Equation 3   SPM adj =FC * 7.1 *  0.02247 * 224/32 * (soxdsl - soxbas) * 1/2000

       where each term is defined as follows:
       SPM adj = PM sulfate adjustment  (tons)
       FC = fuel consumption (gallons)
       7.1 = fuel density (Ib/gal)
       0.02247 = fraction of fuel sulfur converted to sulfate
       224/32 = grams PM sulfate/grams PM sulfur
       soxdsl = episodic fuel sulfur weight fraction (varies by calendar year)
       soxbas = certification fuel sulfur weight fraction
       2000 = conversion from Ib to ton

       For Tier 3 and later engines, no sulfur adjustment is applied.  These engines will be
certified to a fuel sulfur level at or lower than the episodic fuel sulfur levels expected when
these engines are introduced.

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                                                               Chapter 3: Inventory
       Estimation of fuel consumption. Annual fuel consumption is estimated using the
following equation:

                     Equation 4 FC = (BSFC * N * P * L *A)/(7.1 * 454)

       where each term is defined as follows:
       FC = fuel consumption (gallons)
       BSFC = brake specific fuel consumption (g/kW-hr)
       N = engine population (units)
       P = average rated power (kW)
       L = load factor (average fraction of rated power used during operation; unitless)
       A = engine activity (operating hours/year)
       7.1 = fuel density (Ib/gal)
       454  = conversion from Ib to g
       Estimation ofSOz emissions. Annual SOz inventories are estimated using the
following equation:

               Equation 5  SO2 = FC * 7.1 * (1-0.02247) * 64/32 * soxdsl * 1/2000

       where each term is defined as follows:
       S02 = sulfur dioxide inventory (tons)
       FC = fuel consumption (gallons)
       7.1 = fuel density (Ib/gal)
       (1-0.02247) = fraction of fuel sulfur converted to S02
       64/32 = grams SCVgrams sulfur
       soxdsl = episodic fuel sulfur weight fraction (varies by calendar year)
       2000 = conversion from Ib to ton

       The calendar year fuel sulfur levels (soxdsl) were taken from the Clean Air Nonroad
Diesel Rule.4

       Estimation of VOC and PM2 5 emissions. To estimate VOC emissions, an
adjustment factor of 1.053 is applied to the HC output. Similarly, to estimate PM2.s
emissions, an adjustment factor of 0.97 is applied to the PMio output. These adjustment
factors are consistent with those used in the NONROAD model3'2 and the Clean Air Nonroad
Diesel Rule.4

       Estimation of air toxic emissions.  The air toxic baseline  emission inventories for this
proposal are based on information developed for EPA's Mobile Source Air  Toxics (MS AT)
final rulemaking.5 That rule calculated air  toxic emission inventories for all nonroad engines.
The gaseous air toxics are correlated to VOC emissions, while POM is correlated to  PMio
emissions. To calculate the air toxics emission inventories and reductions for this proposal,
the percent reductions in VOC and PMio emissions will be applied to the baseline gaseous
and POM air toxic inventories, respectively.

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Draft Regulatory Impact Analysis
3.1.2 Baseline (Pre-Control) Inventory Development

       This section describes the inputs and provides the resulting baseline inventories for
commercial marine engines.

3.1.2.1 Category 1 Propulsion

       The inventory inputs of base year population, average power, load factor, and activity
for Category 1 commercial propulsion engines are given in Table 0-1 and Table 0-2.  These
inventory inputs are used to develop both baseline and control inventories.  As a result, there
are displacement, power density, and kilowatt subcategories, which are required to model
both the current and proposed standards in this rule.

       The current emission standards vary only by displacement (disp) category, which is
expressed as liters per cylinder (L/cyl) . There are four displacement categories for Category
1 engines:  1) less than 0.9 L/cyl (and power greater than or equal to 37kW), 2) greater than or
equal to 0.9 L/cyl and less than 1.2 L/cyl, 3) greater than or equal to 1.2 L/cyl and less than
2.5 L/cyl, and 4) greater than or equal to 2.5 L/cyl and less than 5 L/cyl.  For simplification,
these will be referred to as  1) disp <0.9, 2) 0.9< disp <1.2, 3) 1.2< disp <2.5, and 4) 2.5< disp
       In order to model the proposed Tier 3 standards, the 2.5< disp <5 category is further
broken out into 2.5< disp <3.5 and 3.5< disp <5 categories. The Tier 3 standards also have
cut points at 75kW and 3700kW, so it was necessary to break out the disp<0.9 category into
3775kW categories.  Since there are no Category 1 engines greater than
3700kW, this cut point was not necessary to include. Finally, there are different Tier 3
standards for standard power density and high power density engines. Standard power
density engines are less than 35 kW per liter (kW/L), and the high power density engines are
greater than or equal to 35 kW/L.  The inputs for the standard power density engines are
given in Table 0-1 and the inputs for the high power density engines in Table 0-2.

       The proposed Tier 4 standards that apply to Category 1  engines vary by the following
kW categories: <600kW, 6003700kW.
As a result, these power categories were also added, with the exception of the >3700kW
category, since there are no Category 1 engines in this power range.

       The base year populations by displacement category are generated using historical
sales estimates in conjunction with the scrappage algorithm described above. Other
inventory inputs that affect scrappage are load factor, activity, and median life.  The
historical sales estimates for calendar years 1973-2002 were obtained from  Power Systems
Research (PSR) .  These populations by displacement category were further broken out into
power density and kilowatt categories using the 2002 population and engine data from PSR.

       The average power estimates were population-weighted, using the 2002 engine and
population data from  PSR. The load factor and activity estimates were 0.45 and 943 hours
per year, respectively for engines <560 kW (750 hp). These are the estimates for commercial
marine propulsion engines provided by PSR. For engines >560 kW, the load factor  and

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                                                                Chapter 3: Inventory
activity estimates used were 0.79 and 4,503 hours per year.  These latter estimates were taken
from the 1999 Marine Diesel FRM.6 Higher load factors and activities were assigned to
these larger engines based on information provided by the manufacturers for the previous
rule, and supported by more recent discussions with the American Waterways Operators
about how these larger engines typically operate.7 This power break point is not related to
the kW categories in the proposed standards.

       Load factors for each subcategory were developed by first identifying the engines in
the PSR population dataset corresponding to each subcategory. Load factors for each engine
in a subcategory were assigned based on the criteria above.  An average load factor for each
subcategory was then obtained by weighting the individual engine load factors by population
and power. A similar approach was followed to obtain activity estimates for each
subcategory, with the exception that the weightings were population, power, and load factor.
The average power, load factors and activities needed to be estimated using these weightings
to ensure that the total inventory from this source category is correctly calculated.

       The median life for all Cl propulsion engines used is 13 years, which is the estimate
provided by PSR. The annual population growth rate is 1.009, which is the estimate from the
Energy and Information Administration (EIA) for domestic shipping.8

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Draft Regulatory Impact Analysis
                               Table 0-1 Inventory Inputs for Cl Propulsion Standard Power Density Engines
DISPLACEMENT CATEGORY
DISP<0.9 AND 3775KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
TOTAL
<35 W/L
<=600KW
2002
POPULATION
1,665
1,102
19,255
23,561
5,898
205
51,687
AVG
KW
43
154
128
294
397
404

LOAD
FACTOR
0.45
0.45
0.45
0.51
0.45
0.45

ACTIVITY,
HOURS
943
943
943
1,905
943
943

60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
TOTAL
<35 KW/L
10001400KW*
2002
POPULATION
0
0
0
0
0
1,264
1,264
AVG
KW





1,492

LOAD
FACTOR





0.79

ACTIVITY,
HOURS





4,503

TOTAL
POPULATION
0
0
0
1,013
186
1,476
2,675
Grand Total                  53,098




* No populations >3700KW
3,041
56,139

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                                                                                                            Chapter 3: Inventory
                                 Table 0-2 Inventory Inputs for Cl Propulsion High Power Density Engines
DISPLACEMENT CATEGORY
DISP<0.9 AND 3775KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
TOTAL
>35 KW/L
<=600KW
2002
POPULATION
0
3,151
21
1,338
0
0
4,510
AVG
KW

165
313
341



LOAD
FACTOR

0.45
0.45
0.45



ACTIVITY,
HOURS

943
943
943



60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
TOTAL
>35 KW/L
10001400KW*
2002
POPULATION
0
0
0
0
0
361
361
AVG
KW





1,765

LOAD
FACTOR





0.79

ACTIVITY,
HOURS





4,503

TOTAL
POPULATION
0
0
0
0
0
575
575
Grand Total                  4,724




* No populations >3700KW
463
                                              5,187

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Draft Regulatory Impact Analysis
       The baseline emission factors are given in Table 0-3 and Table 0-4.  The
emission factors are provided for three technology types:  Base, Tier 1, and Tier 2.
The base technology type includes all pre-control engines. Tier 1 refers to the first
round of existing standards for NOX only that begin in 2000.  Tier 2 refers to the
second round of existing standards for HC+NOX and PM that began in 2004 to 2007,
depending on the displacement category.
       Table 0-3 Baseline PM10 and NOX Emission Factors for Cl Propulsion Engines*
DISPLACEMENT
CATEGORY
DISP<0.9
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
PMio G/KW-HR
BASE
0.54
0.47
0.34
0.30
0.30
TIER1
0.54
0.47
0.34
0.30
0.30
TIER 2
0.23
0.12
0.13
0.13
0.13
NOX G/KW-HR
BASE
10
10
10
10
11
TIER1
9.8
9.8
9.8
9.1
9.2
TIER 2
5.7
6.1
6.0
6.0
6.0
* Deterioration is applied to the PM emission factors (EFs); see text for details. The NOX EFs are not
subject to deterioration.
        Table 0-4 Baseline HC and CO Emission Factors for Cl Propulsion Engines*
DISPLACEMENT
CATEGORY
DISP<0.9
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
HC G/KW-HR
BASE
0.41
0.32
0.27
0.27
0.27
TIER1
0.41
0.32
0.27
0.27
0.27
TIER 2
0.41
0.32
0.19
0.19
0.19
CO G/KW-HR
BASE
1.6
1.6
1.6
1.6
1.8
TIER1
1.6
1.6
1.6
1.6
1.8
TIER 2
1.6
0.9
1.1
1.1
1.1
* The HC and CO emission factors (EFs) are not subject to deterioration.
       The base emission factors were taken from the 1999 Marine Diesel
rulemaking, and are based on emission data for uncontrolled engines.6 For Tier 1, the
NOX emission factors were estimated using 2006 certification data. The certification
data for engines using the E3 cycleb were sales-weighted to obtain Tier 1 NOX
emission factors for each displacement category. Since the Tier 1 standards only
affect NOX, the Tier 1 emission factors for the other pollutants are equal to the base
' The E3 duty cycle is designated for propulsion marine diesel engines.
                                           10

-------
                                                         Chapter 3: Inventory
emission factors. For Tier 2, the same 2006 certification data were used to estimate
PM, NOX, and HC emission factors.

       For Cl engines, PM is the only pollutant for which deterioration factors are
applied. The relative deterioration rate  (A) is 0.473, which is used for both pre-
control and all regulatory tiers.  As a result, the maximum PM deterioration factor is
1.473.  This is consistent with the diesel deterioration assumed in the NONROAD
model.2

       The certification fuel sulfur levels, which are used to estimate the PM sulfate
adjustments, are 3300ppm for the Base  (pre-control) technology type, and 350ppm
for Tier 1 and Tier 2. The Base level was taken from the NONROAD model.2 The
Tier 1 and Tier 2 levels were estimated  from  reviewing the marine certification data
and fuel requirements.

       For calculating fuel consumption,  estimates of brake specific fuel
consumption (BSFC) are also required.  For this analysis, a value of 213 g/kW-hr was
used.  This value is consistent with published estimates of BSFC and those for heavy-
duty diesel engines.9

       The resulting baseline 50-state emission inventories for Category 1 propulsion
engines are given in Table 0-5.
                                         11

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Draft Regulatory Impact Analysis
        Table 0-5 Baseline (50-State) Emissions for Cl Propulsion Engines (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
13,328
13,690
13,807
13,873
13,872
12,230
10,961
10,710
10,304
9,916
9,471
9,003
8,587
8,155
7,718
7,346
7,058
6,805
6,632
6,538
6,470
6,422
6,388
6,368
6,359
6,363
6,381
6,410
6,451
6,499
6,552
6,611
6,671
6,731
6,791
6,852
6,914
6,976
7,039
PM2.5
12,928
13,279
13,393
13,457
13,456
11,863
10,632
10,388
9,995
9,619
9,187
8,733
8,330
7,910
7,487
7,126
6,846
6,601
6,433
6,342
6,276
6,229
6,197
6,177
6,168
6,173
6,190
6,218
6,258
6,304
6,356
6,413
6,471
6,529
6,588
6,647
6,707
6,767
6,828
NOX
335,561
336,369
332,798
328,810
324,900
316,663
308,524
300,509
292,651
284,979
277,551
270,764
264,634
258,879
253,538
249,327
246,339
243,964
242,764
242,677
242,990
243,640
244,563
245,736
247,141
248,720
250,474
252,384
254,450
256,608
258,851
261,181
263,532
265,903
268,297
270,711
273,148
275,606
278,086
voc
9,488
9,573
9,561
9,550
9,540
9,415
9,291
9,170
9,051
8,934
8,821
8,711
8,606
8,507
8,415
8,347
8,304
8,272
8,269
8,293
8,326
8,367
8,414
8,466
8,523
8,584
8,649
8,719
8,792
8,868
8,946
9,026
9,107
9,189
9,272
9,356
9,440
9,525
9,610
HC
9,010
9,091
9,080
9,069
9,060
8,941
8,824
8,708
8,595
8,484
8,377
8,273
8,173
8,079
7,992
7,927
7,886
7,855
7,852
7,876
7,907
7,946
7,990
8,040
8,094
8,152
8,214
8,280
8,349
8,421
8,495
8,572
8,649
8,727
8,805
8,885
8,965
9,045
9,127
CO
55,303
55,801
55,722
55,582
55,450
54,423
53,405
52,401
51,414
50,445
49,497
48,574
47,680
46,827
46,023
45,368
44,879
44,482
44,301
44,329
44,423
44,571
44,760
44,987
45,248
45,539
45,861
46,209
46,583
46,975
47,385
47,811
48,241
48,675
49,114
49,556
50,002
50,452
50,906
S02
36,201
36,528
36,862
37,192
36,827
19,121
6,299
6,355
4,705
3,513
1,862
664
799
857
865
872
879
886
893
900
907
915
923
931
939
946
954
962
970
978
986
995
1,006
1,015
1,023
1,032
1,040
1,050
1,059
                                            12

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                                                          Chapter 3: Inventory
3.1.2.2 Category 1 Auxiliary

       The methodology and data sources for Category 1 marine auxiliary engines
are essentially the same as those for Category 1 propulsion engines. For this source
category, however, the PSR data for marine auxiliary engines and the certification
data with the D2 auxiliary cycle0 were used instead.  The inventory inputs of base
year population, average power, load factor, and activity for Cl auxiliary engines are
given in Table 0-6 and Table 0-7.  The baseline emission factors are given in Table
0-8 and Table 0-9.

       For auxiliary engines, the load factor and activity estimates are 0.56 and 724
hours per year, respectively, for engines <560kW. These are the estimates for
auxiliary marine engines provided by PSR.  For engines >560kW, the load factor and
activity estimates used are 0.65 and 2,500 hours per year, taken from the 1999 FRM.6
The cut point of 560kW is that used for propulsion engines.

       The median life for all Cl auxiliary engines is 17 years, which is the estimate
provided by PSR. Estimates for the annual  growth rate, PM deterioration factor,
certification fuel sulfur levels, and BSFC are assumed to be the same as those for Cl
propulsion engines.

       The resulting baseline 50-state emission inventories for Category 1 auxiliary
engines are given in Table 0-10.
: The D2 steady-state duty cycle is designated for constant-speed engines.
                                          13

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Draft Regulatory Impact Analysis
                               Table 0-6 Inventory Inputs for Cl Auxiliary Standard Power Density Engines
DISPLACEMENT CATEGORY
DISP<0.9 AND 3775KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
TOTAL
<35 KW/L
<=600KW
2002
POPULATION
9,786
1,251
11,933
14,119
785
347
38,221
AVG
KW
44
83
109
324
332
356

LOAD
FACTOR
0.56
0.56
0.56
0.57
0.56
0.56

ACTIVITY,
HOURS
724
724
724
925
724
724

60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
TOTAL
<35 KW/L
10001400KW*
2002
POPULATION
0
0
0
0
0
96
96
AVG
KW





1,527

LOAD
FACTOR





0.65

ACTIVITY,
HOURS





2,500

TOTAL
POPULATION
0
0
0
0
14
364
378
Grand Total                  38,503




* No populations >3700KW
1,090
39,593
                                                                   14

-------
                                                                                                           Chapter 3: Inventory
                                 Table 0-7 Inventory Inputs for Cl Auxiliary High Power Density Engines
DISPLACEMENT CATEGORY
DISP<0.9 AND 3775KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
TOTAL
>35 KW/L
<=600KW
2002
POPULATION
215
218
0
0
0
0
433
AVG
KW
75
141





LOAD
FACTOR
0.56
0.56





ACTIVITY,
HOURS
724
724





60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
TOTAL
>35 KW/L
10001400KW*
2002
POPULATION
0
0
0
39
0
0
39
AVG
KW



1,531



LOAD
FACTOR



0.65



ACTIVITY,
HOURS



2,500



TOTAL
POPULATION
0
0
11
39
0
0
50
Grand Total




* No populations >3700KW
444
39
                                                                                              483
                                                                   15

-------
Draft Regulatory Impact Analysis
         Table 0-8 Baseline PM10 and NOX Emission Factors for Cl Auxiliary Engines*
DISPLACEMENT
CATEGORY
DISP<0.9
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
PMio G/KW-HR
BASE
0.84
0.53
0.34
0.32
0.30
TIER1
0.84
0.53
0.34
0.32
0.30
TIER 2
0.23
0.21
0.15
0.15
0.15
NOX G/KW-HR
BASE
11
10
10
10
11
TIER1
9.8
9.8
9.8
9.1
9.2
TIER 2
5.7
5.4
6.1
6.1
6.1
* Deterioration is applied to the PM emission factors (EFs);  see text for details.  The NOX EFs are not
subject to deterioration.
          Table 0-9 Baseline HC and CO Emission Factors for Cl Auxiliary Engines*
DISPLACEMENT
CATEGORY
DISP<0.9
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
HC G/KW-HR
BASE
0.41
0.32
0.27
0.27
0.27
TIER1
0.41
0.32
0.27
0.27
0.27
TIER 2
0.41
0.32
0.21
0.21
0.21
CO G/KW-HR
BASE
2.0
1.7
1.5
1.5
1.8
TIER1
2.0
1.7
1.5
1.5
1.8
TIER 2
1.6
0.8
0.9
0.9
0.9
* The HC and CO emission factors (EFs) are not subject to deterioration.
                                               16

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                                                     Chapter 3: Inventory
Table 0-10 Baseline (50-State) Emissions for Cl Auxiliary Engines (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
2,714
2,773
2,791
2,786
2,769
2,482
2,263
2,230
2,170
2,115
2,052
1,993
1,952
1,907
1,860
1,806
1,746
1,685
1,625
1,576
1,543
1,520
1,504
1,495
1,489
1,486
1,484
1,484
1,486
1,489
1,493
1,499
1,506
1,514
1,524
1,535
1,547
1,561
1,574
PM2.5
2,632
2,690
2,708
2,703
2,686
2,407
2,195
2,163
2,105
2,052
1,990
1,933
1,893
1,850
1,805
1,752
1,693
1,634
1,576
1,528
1,497
1,474
1,459
1,451
1,445
1,441
1,440
1,440
1,441
1,444
1,448
1,454
1,461
1,469
1,478
1,489
1,501
1,514
1,527
NOX
60,641
60,959
60,482
59,774
59,073
58,048
57,030
56,020
55,022
54,038
53,069
52,118
51,185
50,277
49,399
48,589
47,849
47,160
46,531
46,079
45,840
45,706
45,683
45,756
45,875
46,035
46,228
46,452
46,703
46,980
47,283
47,611
47,962
48,332
48,721
49,126
49,553
49,991
50,436
voc
1,767
1,783
1,785
1,788
1,791
1,787
1,783
1,779
1,776
1,773
1,770
1,767
1,765
1,763
1,761
1,760
1,759
1,759
1,760
1,764
1,771
1,778
1,788
1,799
1,811
1,824
1,837
1,851
1,865
1,880
1,895
1,911
1,927
1,943
1,960
1,977
1,995
2,013
2,031
HC
1,678
1,693
1,696
1,698
1,700
1,697
1,693
1,690
1,686
1,684
1,681
1,678
1,676
1,674
1,673
1,672
1,671
1,671
1,672
1,675
1,681
1,689
1,698
1,709
1,720
1,732
1,745
1,758
1,771
1,785
1,800
1,815
1,830
1,845
1,861
1,878
1,894
1,911
1,928
CO
9,624
9,710
9,668
9,585
9,503
9,331
9,160
8,989
8,820
8,654
8,489
8,327
8,167
8,010
7,857
7,708
7,563
7,426
7,298
7,198
7,134
7,088
7,066
7,067
7,077
7,094
7,117
7,145
7,178
7,215
7,257
7,303
7,353
7,407
7,464
7,524
7,588
7,654
7,721
S02
6,553
6,613
6,673
6,733
6,667
3,461
1,140
1,150
852
636
337
120
145
155
157
158
159
160
162
163
164
166
167
169
170
171
173
174
176
177
179
180
182
184
185
187
188
190
192
                                    17

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Draft Regulatory Impact Analysis
3.1.2.3 Category 2 Propulsion

       The methodology used for C2 propulsion engines is the same as that used for
Cl propulsion engines, as described in section 3.1.1. However, the engine
population, average rated power, load factor and engine activity terms shown in
Equation 1 of that section were consolidated into a single term for total kW-hr/year
for all C2 vessels.10 The total kW-hr value for C2 propulsion engines in 2002 was
estimated at 30,246,809,539 kW-hr. The total kW-hr value was then allocated to the
necessary displacement and horsepower categories, using the PSR engine data.

       The median life for all C2 propulsion engines is 23 years.11 The emission
factors used for all C2 propulsion engines are largely those we used for the original
commercial  marine rulemaking analysis.6 The one exception to this is for Tier 1
NOx, which was updated based on an analysis of 2006 certification data.  The C2
emission factors are shown in Table 0-11. Estimates for the annual growth rate, PM
deterioration factor, and certification fuel sulfur levels are assumed to be the same as
those for Cl propulsion engines.

             Table 0-11 Baseline Emission Factors for C2 Engines (g/kW-hr)*
Tier
BASE
TIER1
TIER 2
PMio
0.32
0.32
0.32
NOX
13.36
10.55
8.33
HC
0.134
0.134
0.134
CO
2.48
2.48
2.00
 Deterioration is applied to the PM emission factors (EFs); see text for details. The NOx, HC and CO
EFs are not subject to deterioration.

       The resulting baseline 50-state emission inventories for Category 2 propulsion
engines are given in Table 0-12.
                                          18

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                                                      Chapter 3: Inventory
Table 0-12 Baseline (50-State) Emissions for C2 Propulsion Engines (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
12,850
13,112
13,376
13,641
13,907
14,174
14,436
14,706
14,975
15,245
15,515
15,727
14,475
13,635
13,883
13,986
14,127
14,228
14,365
14,613
14,850
15,059
15,243
15,423
15,599
15,772
15,943
16,114
16,283
16,451
16,618
16,786
16,952
17,119
17,286
17,453
17,620
17,787
17,954
PM2.5
12,464
12,719
12,975
13,232
13,490
13,748
14,003
14,264
14,525
14,787
15,050
15,255
14,041
13,226
13,466
13,566
13,703
13,801
13,934
14,175
14,405
14,607
14,786
14,960
15,131
15,299
15,465
15,630
15,794
15,957
16,120
16,282
16,444
16,605
16,767
16,929
17,091
17,253
17,416
NOX
432,306
431,973
431,683
431,417
431,195
427,380
423,601
419,857
416,169
412,537
408,943
405,428
401,970
398,593
395,295
392,101
388,988
386,000
383,155
380,458
377,990
376,313
375,430
374,784
374,343
374,086
374,039
374,219
375,126
376,727
378,567
380,573
382,749
385,076
387,519
390,097
392,794
395,609
398,527
voc
4,701
4,743
4,786
4,829
4,872
4,916
4,960
5,005
5,050
5,096
5,141
5,188
5,234
5,281
5,329
5,377
5,425
5,474
5,523
5,573
5,623
5,674
5,725
5,777
5,829
5,881
5,934
5,987
6,041
6,096
6,150
6,206
6,262
6,318
6,375
6,432
6,490
6,549
6,607
HC
4,464
4,504
4,545
4,586
4,627
4,669
4,711
4,753
4,796
4,839
4,883
4,927
4,971
5,016
5,061
5,106
5,152
5,199
5,245
5,293
5,340
5,388
5,437
5,486
5,535
5,585
5,635
5,686
5,737
5,789
5,841
5,893
5,946
6,000
6,054
6,108
6,163
6,219
6,275
CO
82,621
83,364
84,115
84,872
85,635
85,621
85,611
85,605
85,609
85,621
85,639
85,665
85,701
85,746
85,800
85,864
85,937
86,020
86,116
86,222
86,341
86,475
86,626
86,790
86,974
87,178
87,406
87,672
88,078
88,623
89,207
89,820
90,457
91,119
91,799
92,500
93,219
93,956
94,707
S02
36,868
37,193
37,528
37,866
38,207
38,550
38,837
39,204
39,559
39,920
40,278
39,905
21,334
7,888
7,958
6,238
4,998
3,277
2,031
2,185
2,258
2,279
2,299
2,319
2,339
2,359
2,379
2,399
2,421
2,442
2,463
2,485
2,507
2,529
2,551
2,573
2,595
2,618
2,641
                                     19

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Draft Regulatory Impact Analysis
3.1.2.4 Under 37 kW Propulsion and Auxiliary

       Category 1 commercial marine engines are defined as being greater than or
equal to (>) 37kW and less than (<) 5.0 liters/cylinder; however, there are commercial
marine engines <37kW. The majority of these small power engines are used as
auxiliary engines, although there are some propulsion engines that fall into this
category. Commercial marine engines <37kW are covered under this proposal;
therefore, inventories have been estimated.

       Emissions were estimated using a special version of the NONROAD2005
model, with Source Classification Codes (SCCs) and associated inputs added for both
the commercial and auxiliary engines. An SCC of 2280002030 was assigned to the
<37kW propulsion engines, with an SCC of 2280002040 assigned to the <37kW
auxiliary engines.

       The inventory inputs of base year population, average power, load factor,
activity, and median life are given in Table 0-13 below. These inputs were generated
using the same methodology and data sources as the Cl propulsion and Cl auxiliary
categories. Horsepower (hp) is used as the unit for power in the NONROAD model,
so the inputs for power and emission factors are hp and g/hp-hr, respectively. The
2002 base year populations are assigned to one or more of the following hp categories
in NONROAD:  0-11,  11-16, 16-25, 25-40, and 40-50. The propulsion engines all
fall within the 25-40hp category, whereas there are auxiliary engines in each hp
category. The average power values in the table below are population-weighted
estimates.

        Table 0-13 Inventory Inputs for <37kW Commercial Marine Diesel Engines
INPUTS
2002
POPULATION
AVGHP
LOAD
FACTOR
ACTIVITY,
HOURS
MEDIAN
LIFE, YEARS
PROPULSION
1,232
34.8
0.45
943
13
AUXILIARY
67,708
24.9
0.56
724
17
       The baseline emission factors are given in Table 0-14 and Table 0-15.  These
engines are subject to EPA nonroad diesel regulations that have established two tiers
of emission standards.12 Tier 1 phased in from 1999-2000, depending on the
horsepower category, with Tier 2 phased in from 2004-2005. The "Base" entries in
the tables refer to emissions from pre-controlled engines.  These emission factors are
used for both propulsion and auxiliary engines.
                                         20

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                                                         Chapter 3: Inventory
   Table 0-14 Baseline PM10 and NOX Emission Factors and Deterioration Factors for <37kW
                         Commercial Marine Diesel Engines
HP
RANGE
0-11
11-16
16-25
25-50
DF ("A")
PMio G/HP-HR
BASE
1.00
0.90
0.90
0.80
0.473
TIER1
0.45
0.27
0.27
0.34
0.473
TIER 2
0.38
0.19
0.19
0.23
0.473
NOX G/HP-HR
BASE
10.00
8.50
8.50
6.90
0.024
TIER1
5.23
4.44
4.44
4.73
0.024
TIER 2
4.39
3.63
3.63
3.71
0.009
    Table 0-15 Baseline HC and CO Emission Factors and Deterioration Factors for <37kW
                         Commercial Marine Diesel Engines
HP
RANGE
0-11
11-16
16-25
25-50
DF ("A")
HC G/HP-HR
BASE
1.50
1.70
1.70
1.80
0.047
TIER1
0.76
0.44
0.44
0.28
0.036
TIER 2
0.68
0.21
0.21
0.54
0.034
CO G/HP-HR
BASE
5.00
5.00
5.00
5.00
0.185
TIER1
4.11
2.16
2.16
1.53
0.101
TIER 2
4.11
2.16
2.16
1.53
0.101
       The emission factors for the base and Tier 1 technology types are consistent
with those used in the NONROAD model.2 Tier 2 emission factors were estimated
using nonroad engine certification data. The deterioration factors by pollutant and
technology type are also given in the tables above. The deterioration factors are those
used for diesel engines in the NONROAD model.2

       The certification fuel sulfur levels are 3300ppm for the base and Tier 1
technology type and 350ppm for Tier 2. Brake specific fuel consumption (BSFC)
values were taken from the NONROAD model and are 0.408 Ib/hp-hr for all hp
categories.2 The annual population growth rate is 1.009, which is the growth rate
used for all commercial diesel engines.

       The resulting baseline  50-state emission inventories for <37kW commercial
marine engines (propulsion  and auxiliary combined) are given in Table 0-16.
                                         21

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Draft Regulatory Impact Analysis
  Table 0-16 Baseline (50-State) Emissions for <37kW Commercial Marine Engines (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
728
710
692
671
648
596
551
526
499
472
444
417
392
368
348
332
320
310
301
294
288
284
280
278
276
275
275
275
275
276
278
279
282
284
286
289
291
294
296
PM2.5
706
689
671
651
629
578
534
511
484
458
431
404
381
357
337
322
311
301
292
285
279
275
272
269
268
267
267
267
267
268
269
271
273
275
278
280
282
285
287
NOX
5,517
5,448
5,350
5,229
5,101
4,973
4,846
4,719
4,594
4,472
4,351
4,234
4,120
4,011
3,917
3,846
3,790
3,744
3,704
3,675
3,659
3,654
3,654
3,658
3,670
3,685
3,703
3,723
3,746
3,771
3,798
3,828
3,859
3,891
3,924
3,958
3,992
4,026
4,061
voc
1,273
1,222
1,179
1,128
1,075
1,022
969
916
864
813
763
715
668
624
588
564
546
531
519
507
497
491
485
481
479
478
478
478
479
481
484
488
492
496
500
504
509
513
517
HC
1,209
1,161
1,120
1,071
1,021
970
920
870
821
772
725
679
634
592
559
535
518
504
493
482
472
466
461
457
455
454
454
454
455
457
460
463
467
471
475
479
483
487
491
CO
3,783
3,680
3,576
3,460
3,339
3,216
3,093
2,970
2,846
2,724
2,603
2,484
2,369
2,259
2,170
2,109
2,063
2,027
1,997
1,972
1,952
1,940
1,932
1,926
1,926
1,929
1,934
1,942
1,952
1,963
1,977
1,992
2,009
2,026
2,044
2,061
2,079
2,097
2,115
S02
731
738
745
752
745
387
128
129
95
71
38
14
16
18
18
18
18
18
18
18
18
19
19
19
19
19
19
20
20
20
20
20
21
21
21
21
21
21
22
                                            22

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                                                         Chapter 3: Inventory
3.1.2.5 Commercial Marine Diesel Baseline Inventory Summary

3.1.2.5.1 PMio, PM25, NOX, VOC, CO, and SO2 Emissions
       Table 0-17 thru Table 0-22 present the resulting 50-state consolidated
commercial marine baseline inventories by pollutant and category, for calendar years
2002-2040.

3.1.2.5.2 Air Toxics Emissions

       The baseline air toxics inventories for the consolidated commercial marine
diesel engines were taken from the Mobile Source Air Toxics Rule  (MSAT)5 and are
provided in Table 0-23. Inventories are provided for calendar years 1999, 2010,
2015, 2020, and 2030.
                                         23

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Draft Regulatory Impact Analysis
     Table 0-17 Baseline (50-State) PM10 Emissions for Commercial Marine Diesel Engines
                                     (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
13,328
13,690
13,807
13,873
13,872
12,230
10,961
10,710
10,304
9,916
9,471
9,003
8,587
8,155
7,718
7,346
7,058
6,805
6,632
6,538
6,470
6,422
6,388
6,368
6,359
6,363
6,381
6,410
6,451
6,499
6,552
6,611
6,671
6,731
6,791
6,852
6,914
6,976
7,039
Cl
AUXILIARY
2,714
2,773
2,791
2,786
2,769
2,482
2,263
2,230
2,170
2,115
2,052
1,993
1,952
1,907
1,860
1,806
1,746
1,685
1,625
1,576
1,543
1,520
1,504
1,495
1,489
1,486
1,484
1,484
1,486
1,489
1,493
1,499
1,506
1,514
1,524
1,535
1,547
1,561
1,574
Cl
TOTAL
16,041
16,463
16,598
16,659
16,641
14,712
13,224
12,940
12,474
12,031
11,522
10,996
10,539
10,062
9,579
9,152
8,804
8,490
8,257
8,114
8,013
7,942
7,893
7,864
7,849
7,849
7,865
7,895
7,937
7,988
8,045
8,110
8,177
8,245
8,315
8,387
8,461
8,537
8,613
C2
PROPULSION
12,850
13,112
13,376
13,641
13,907
14,174
14,436
14,706
14,975
15,245
15,515
15,727
14,475
13,635
13,883
13,986
14,127
14,228
14,365
14,613
14,850
15,059
15,243
15,423
15,599
15,772
15,943
16,114
16,283
16,451
16,618
16,786
16,952
17,119
17,286
17,453
17,620
17,787
17,954
<37KW
728
710
692
671
648
596
551
526
499
472
444
417
392
368
348
332
320
310
301
294
288
284
280
278
276
275
275
275
275
276
278
279
282
284
286
289
291
294
296
TOTAL
29,619
30,285
30,666
30,972
31,196
29,481
28,211
28,172
27,948
27,748
27,482
27,140
25,406
24,066
23,809
23,470
23,250
23,028
22,923
23,021
23,151
23,284
23,416
23,564
23,724
23,897
24,083
24,283
24,495
24,715
24,941
25,175
25,411
25,648
25,887
26,129
26,372
26,617
26,864
                                            24

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                                                         Chapter 3: Inventory
Table 0-18 Baseline (50-State) PM2.5 Emissions for Commercial Marine Diesel Engines
                                (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
12,928
13,279
13,393
13,457
13,456
11,863
10,632
10,388
9,995
9,619
9,187
8,733
8,330
7,910
7,487
7,126
6,846
6,601
6,433
6,342
6,276
6,229
6,197
6,177
6,168
6,173
6,190
6,218
6,258
6,304
6,356
6,413
6,471
6,529
6,588
6,647
6,707
6,767
6,828
Cl
AUXILIARY
2,632
2,690
2,708
2,703
2,686
2,407
2,195
2,163
2,105
2,052
1,990
1,933
1,893
1,850
1,805
1,752
1,693
1,634
1,576
1,528
1,497
1,474
1,459
1,451
1,445
1,441
1,440
1,440
1,441
1,444
1,448
1,454
1,461
1,469
1,478
1,489
1,501
1,514
1,527
Cl
TOTAL
15,560
15,969
16,100
16,159
16,142
14,270
12,827
12,552
12,100
11,670
11,177
10,666
10,223
9,760
9,291
8,878
8,539
8,235
8,009
7,871
7,773
7,703
7,656
7,628
7,613
7,614
7,629
7,658
7,699
7,748
7,804
7,867
7,932
7,998
8,066
8,136
8,207
8,281
8,355
C2
PROPULSION
12,464
12,719
12,975
13,232
13,490
13,748
14,003
14,264
14,525
14,787
15,050
15,255
14,041
13,226
13,466
13,566
13,703
13,801
13,934
14,175
14,405
14,607
14,786
14,960
15,131
15,299
15,465
15,630
15,794
15,957
16,120
16,282
16,444
16,605
16,767
16,929
17,091
17,253
17,416
<37KW
706
689
671
651
629
578
534
511
484
458
431
404
381
357
337
322
311
301
292
285
279
275
272
269
268
267
267
267
267
268
269
271
273
275
278
280
282
285
287
TOTAL
28,730
29,377
29,746
30,042
30,260
28,596
27,364
27,327
27,109
26,916
26,657
26,326
24,644
23,344
23,095
22,766
22,553
22,337
22,236
22,330
22,457
22,585
22,714
22,857
23,012
23,180
23,361
23,555
23,760
23,973
24,193
24,420
24,648
24,879
25,111
25,345
25,581
25,819
26,058
                                        25

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Draft Regulatory Impact Analysis
     Table 0-19 Baseline (50-State) NOX Emissions for Commercial Marine Diesel Engines
                                     (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
335,561
336,369
332,798
328,810
324,900
316,663
308,524
300,509
292,651
284,979
277,551
270,764
264,634
258,879
253,538
249,327
246,339
243,964
242,764
242,677
242,990
243,640
244,563
245,736
247,141
248,720
250,474
252,384
254,450
256,608
258,851
261,181
263,532
265,903
268,297
270,711
273,148
275,606
278,086
Cl
AUXILIARY
60,641
60,959
60,482
59,774
59,073
58,048
57,030
56,020
55,022
54,038
53,069
52,118
51,185
50,277
49,399
48,589
47,849
47,160
46,531
46,079
45,840
45,706
45,683
45,756
45,875
46,035
46,228
46,452
46,703
46,980
47,283
47,611
47,962
48,332
48,721
49,126
49,553
49,991
50,436
Cl
TOTAL
396,202
397,328
393,280
388,583
383,973
374,710
365,554
356,529
347,673
339,017
330,621
322,882
315,819
309,156
302,937
297,916
294,188
291,123
289,295
288,756
288,831
289,346
290,245
291,492
293,016
294,755
296,703
298,836
301,153
303,588
306,134
308,792
311,494
314,236
317,017
319,838
322,701
325,597
328,522
C2
PROPULSION
432,306
431,973
431,683
431,417
431,195
427,380
423,601
419,857
416,169
412,537
408,943
405,428
401,970
398,593
395,295
392,101
388,988
386,000
383,155
380,458
377,990
376,313
375,430
374,784
374,343
374,086
374,039
374,219
375,126
376,727
378,567
380,573
382,749
385,076
387,519
390,097
392,794
395,609
398,527
<37KW
5,517
5,448
5,350
5,229
5,101
4,973
4,846
4,719
4,594
4,472
4,351
4,234
4,120
4,011
3,917
3,846
3,790
3,744
3,704
3,675
3,659
3,654
3,654
3,658
3,670
3,685
3,703
3,723
3,746
3,771
3,798
3,828
3,859
3,891
3,924
3,958
3,992
4,026
4,061
TOTAL
834,025
834,749
830,313
825,229
820,269
807,063
794,001
781,105
768,436
756,026
743,915
732,544
721,910
711,760
702,150
693,862
686,966
680,867
676,154
672,889
670,480
669,313
669,329
669,934
671,029
672,525
674,445
676,778
680,025
684,087
688,500
693,193
698,103
703,203
708,460
713,892
719,486
725,233
731,111
                                            26

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                                                         Chapter 3: Inventory
Table 0-20 Baseline (50-State) VOC Emissions for Commercial Marine Diesel Engines
                                (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
9,488
9,573
9,561
9,550
9,540
9,415
9,291
9,170
9,051
8,934
8,821
8,711
8,606
8,507
8,415
8,347
8,304
8,272
8,269
8,293
8,326
8,367
8,414
8,466
8,523
8,584
8,649
8,719
8,792
8,868
8,946
9,026
9,107
9,189
9,272
9,356
9,440
9,525
9,610
Cl
AUXILIARY
1,767
1,783
1,785
1,788
1,791
1,787
1,783
1,779
1,776
1,773
1,770
1,767
1,765
1,763
1,761
1,760
1,759
1,759
1,760
1,764
1,771
1,778
1,788
1,799
1,811
1,824
1,837
1,851
1,865
1,880
1,895
1,911
1,927
1,943
1,960
1,977
1,995
2,013
2,031
Cl
TOTAL
11,255
11,356
11,346
11,338
11,331
11,202
11,074
10,949
10,826
10,707
10,591
10,479
10,371
10,270
10,176
10,107
10,063
10,031
10,029
10,057
10,097
10,145
10,202
10,265
10,334
10,408
10,487
10,570
10,657
10,748
10,841
10,937
11,034
11,133
11,232
11,333
11,435
11,537
11,641
C2
PROPULSION
4,701
4,743
4,786
4,829
4,872
4,916
4,960
5,005
5,050
5,096
5,141
5,188
5,234
5,281
5,329
5,377
5,425
5,474
5,523
5,573
5,623
5,674
5,725
5,777
5,829
5,881
5,934
5,987
6,041
6,096
6,150
6,206
6,262
6,318
6,375
6,432
6,490
6,549
6,607
<37KW
1,273
1,222
1,179
1,128
1,075
1,022
969
916
864
813
763
715
668
624
588
564
546
531
519
507
497
491
485
481
479
478
478
478
479
481
484
488
492
496
500
504
509
513
517
TOTAL
17,229
17,321
17,311
17,295
17,278
17,140
17,003
16,870
16,741
16,615
16,495
16,381
16,273
16,175
16,094
16,048
16,034
16,036
16,071
16,137
16,218
16,310
16,412
16,523
16,642
16,767
16,898
17,035
17,178
17,325
17,476
17,631
17,788
17,947
18,107
18,269
18,433
18,599
18,766
                                        27

-------
Draft Regulatory Impact Analysis
Table 0-21 Baseline (50-State) CO Emissions for Commercial Marine Diesel Engines (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
55,303
55,801
55,722
55,582
55,450
54,423
53,405
52,401
51,414
50,445
49,497
48,574
47,680
46,827
46,023
45,368
44,879
44,482
44,301
44,329
44,423
44,571
44,760
44,987
45,248
45,539
45,861
46,209
46,583
46,975
47,385
47,811
48,241
48,675
49,114
49,556
50,002
50,452
50,906
Cl
AUXILIARY
9,624
9,710
9,668
9,585
9,503
9,331
9,160
8,989
8,820
8,654
8,489
8,327
8,167
8,010
7,857
7,708
7,563
7,426
7,298
7,198
7,134
7,088
7,066
7,067
7,077
7,094
7,117
7,145
7,178
7,215
7,257
7,303
7,353
7,407
7,464
7,524
7,588
7,654
7,721
Cl
TOTAL
64,927
65,511
65,390
65,167
64,954
63,754
62,565
61,391
60,235
59,099
57,986
56,901
55,847
54,837
53,880
53,076
52,443
51,908
51,599
51,527
51,557
51,659
51,827
52,054
52,325
52,633
52,978
53,354
53,761
54,191
54,642
55,114
55,595
56,082
56,577
57,079
57,589
58,105
58,627
C2
PROPULSION
82,621
83,364
84,115
84,872
85,635
85,621
85,611
85,605
85,609
85,621
85,639
85,665
85,701
85,746
85,800
85,864
85,937
86,020
86,116
86,222
86,341
86,475
86,626
86,790
86,974
87,178
87,406
87,672
88,078
88,623
89,207
89,820
90,457
91,119
91,799
92,500
93,219
93,956
94,707
<37KW
3,783
3,680
3,576
3,460
3,339
3,216
3,093
2,970
2,846
2,724
2,603
2,484
2,369
2,259
2,170
2,109
2,063
2,027
1,997
1,972
1,952
1,940
1,932
1,926
1,926
1,929
1,934
1,942
1,952
1,963
1,977
1,992
2,009
2,026
2,044
2,061
2,079
2,097
2,115
TOTAL
151,331
152,556
153,080
153,499
153,928
152,591
151,269
149,966
148,690
147,444
146,227
145,050
143,917
142,842
141,851
141,049
140,443
139,954
139,712
139,720
139,851
140,073
140,384
140,771
141,226
141,740
142,318
142,968
143,791
144,776
145,825
146,926
148,060
149,227
150,419
151,640
152,887
154,158
155,449
                                            28

-------
                                                             Chapter 3: Inventory
Table 0-22 Baseline (50-State) SO2 Emissions for Commercial Marine Diesel Engines (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
36,201
36,528
36,862
37,192
36,827
19,121
6,299
6,355
4,705
3,513
1,862
664
799
857
865
872
879
886
893
900
907
915
923
931
939
946
954
962
970
978
986
995
1,006
1,015
1,023
1,032
1,040
1,050
1,059
Cl
AUXILIARY
6,553
6,613
6,673
6,733
6,667
3,461
1,140
1,150
852
636
337
120
145
155
157
158
159
160
162
163
164
166
167
169
170
171
173
174
176
177
179
180
182
184
185
187
188
190
192
Cl
TOTAL
42,754
43,141
43,535
43,925
43,493
22,583
7,440
7,506
5,557
4,148
2,199
784
943
1,012
1,021
1,030
1,038
1,046
1,055
1,063
1,072
1,081
1,090
1,099
1,109
1,118
1,127
1,136
1,146
1,155
1,165
1,175
1,188
1,198
1,208
1,218
1,228
1,240
1,251
C2
PROPULSION
36,868
37,193
37,528
37,866
38,207
38,550
38,837
39,204
39,559
39,920
40,278
39,905
21,334
7,888
7,958
6,238
4,998
3,277
2,031
2,185
2,258
2,279
2,299
2,319
2,339
2,359
2,379
2,399
2,421
2,442
2,463
2,485
2,507
2,529
2,551
2,573
2,595
2,618
2,641
<37KW
731
738
745
752
745
387
128
129
95
71
38
14
16
18
18
18
18
18
18
18
18
19
19
19
19
19
19
20
20
20
20
20
21
21
21
21
21
21
22
TOTAL
80,353
81,073
81,808
82,543
82,445
61,520
46,404
46,838
45,212
44,139
42,515
40,702
22,293
8,917
8,997
7,286
6,054
4,342
3,104
3,267
3,348
3,378
3,408
3,437
3,466
3,496
3,526
3,555
3,586
3,617
3,649
3,680
3,716
3,748
3,780
3,812
3,845
3,880
3,913
                                            29

-------
Draft Regulatory Impact Analysis
     Table 0-23 Air Toxics Emissions for Commercial Marine Diesel Engines (short tons)
HAP
BENZENE
FORMALDEHYDE
ACET ALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
1999
530
3,897
1,937
6
75
43
11
2010
556
4,091
2,033
6
79
39
10
2015
559
4,112
2,044
6
79
37
9
2020
572
4,208
2,091
6
81
36
9
2030
624
4,587
2,280
7
89
40
10
3.1.3 Control Inventory Development

       This section describes how the controlled emission inventories were
developed for the commercial marine diesel categories: Category 1 propulsion,
Category 1 auxiliary, Category 2 propulsion, and less than (<) 37kW. This section
will only describe the modifications to the emission factors, since the other inventory
inputs are unchanged.

3.1.3.1 Control Scenario(s) Modeled

       For commercial marine diesel engines, there are two tiers of proposed PM and
either combined HC+NOX or NOX only standards for the control scenario that was
modeled.

       The proposed emission standards for Category 1  engines are summarized in
Table 0-24 and Table 0-25.  These standards apply to both propulsion and auxiliary
engines.  There are separate emission standards for standard and high power density
engines.  Standard power density engines are less than 35 kW per liter (kW/L), and
the high power density engines are greater than or equal to 35 kW/L.  Within these
power density categories, there are also separate standards that vary by power and
displacement. There are no Tier 4 standards for engines less than 600 kW. Standards
are not shown in cases where there is zero engine population.

       The proposed emission standards for Category 2  engines are summarized in
Table 0-26. The standards vary by displacement and power. All Category 2 engines
are considered to be standard power density engines. These engines are subject to
both Tier 3 and Tier 4 emission standards.

       The proposed emission standards for <37kW propulsion and auxiliary engines
are given in Table 0-27.  This category is subject to Tier 3 standards which begin in
2009.
                                         30

-------
                                                                           Chapter 3: Inventory
Table 0-24 Proposed Standards (g/kW-hr) for Cl Standard Power Density Engines
DISPLACEMENT
CATEGORY
DISP<0.9 AND
3775KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
<35 KW/L
<=600KW
YEAR
2009
2014
2012
2013
2014
2018
2013
2018
2012
2018
TIERS
NOX
7.5
4.7
5.4
5.4
5.6

5.6

5.8

PM
0.30

0.13
0.12
0.11
0.09
0.11
0.09
0.11
0.09
YEAR
NO TIER
TIER 4
NOX

PM

4 STANDARDS


60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
<35 KW/L
10001400KW
TIERS
YEAR NOX PM

YEAR NO;
TIER 4
X PM
NO ENGINES IN THESE CATEGORIES

2012 5.8 0.11

2016

1.7 0.04
                                    31

-------
Draft Regulatory Impact Analysis
                              Table 0-25 Proposed Standards (g/kW-hr) for Cl High Power Density Engines
DISPLACEMENT
CATEGORY
DISP<0.9 AND
3775KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
>35 KW/L
<=600KW
YEAR
2009
2014
2012
2013
2014
TIERS
NOX
7.5
4.7
5.8
5.8
5.8
PM
0.30

0.15
0.13
0.12
NO ENGINES
YEAR

TIER
NOX

4
PM

NO TIER 4 STANDARDS



60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
>35 KW/L
10001400KW
YEAR
TIER
NOX
3
PM
YEAR
TIER
NOX
4
PM
NO ENGINES IN THESE CATEGORIES

2014
5.6
0.11
2016
1.7
0.04
NO ENGINES IN THIS CATEGORY
2012
5.8
0.11
2016
1.7
0.04
                                                                32

-------
                                                          Chapter 3: Inventory
                Table 0-26 Proposed Standards (g/kW-hr) for C2 Engines
DISPLACEMENT CATEGORY
5.0<=DISP<15 AND <600KW
5.0<=DISP<15 AND 600^7nnKW

15.0<=DISP<20.0 AND <1400KW
15.0<=DISP<20.0 AND 1400^7nnKW

20.0<=DISP<30.0
YEAR
2013
2013
2013
2013
TIERS
NOx+HC
6.2
6.2
6.2
6.2
PM
0.13
0.13
0.13
0.13

YEAR

2018
2017
2016
2014
2017
TIER 4
NOX

1.7
1.7
1.7
1.7

PM

0.04
0.04
0.04
0.12
0.05
NO ENGINES IN THIS CATEGORY
2014
7.0
0.34
2016
1.7
0.04
NO ENGINES IN THIS CATEGORY

2014
2017
1.7

0.25
0.05
NO ENGINES IN THIS CATEGORY
   Table 0-27 Proposed Standards (g/hp-hr) for <37kW Commercial Marine Diesel Engines
HP
RANGE
0-25
25-50
YEAR
2009
2009
2014
TIERS
NOx+HC
5.6
5.6
3.5
PM
0.30
0.22
0.22
3.1.3.2 Category 1 Propulsion

       The modeled Tier 3 and Tier 4 emission factors corresponding to the emission
standards are shown in Table 0-28 and Table 0-29.  These emission factors are
derived by applying the appropriate relative reductions from the Tier 2 standard to the
Tier 2 emission factors, using the following equations:

                Equation 3 Tier 3 EF = (Tier 3 std/Tier 2 std) x Tier 2 EF

                Equation 4 Tier 4 EF = (Tier 4 std/Tier 2 std) x Tier 2 EF

       For NOX, the standards used in the above equations are the combined
HC+NOX standards. For HC and PM, the PM standards are used.

       The resulting control case 50-state emission inventories for Category 1
propulsion engines are given in Table 0-30.
                                          33

-------
Draft Regulatory Impact Analysis
3.1.3.3 Category 1 Auxiliary

       The modeled Tier 3 and Tier 4 emission factors for Category 1 auxiliary
engines are shown in Table 0-31 and Table 0-32. The methodology described above
for Category 1 propulsion engines was used to derive these emission factors.

       The resulting control case 50-state emission inventories for Category 1
auxiliary engines are given in Table 0-33.
                                         34

-------
                                                                                             Chapter 3: Inventory
Table 0-28 Control PM10, NOx, and HC Emission Factors (g/kW-hr) for Cl Propulsion Standard Power Density Engines
DISPLACEMENT
CATEGORY
DISP<0.9 AND
3775KW
0.9<=DISP<1.2
1 9^- ni^p^-9 ^

? r.^ nTSP^ ^

^ ^ DTSP^^i 0

<35 KW/L
<=600KW
YEAR
2009
2014
2012
2013
2014
2018
2013
2018
2012
2018
TIERS
HC
0.30

0.14
0.13
0.10

0.10

0.10

NOX
5.70
3.56
4.08
4.54
4.69

4.69

4.81

PM
0.17

0.08
0.05
0.07
0.061
0.07
0.061
0.07
0.061
60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
<35 KW/L
10001400KW
TIERS _ A TIER 4
1 '"v HC NOX PM " ^v HC NOX PM
NO ENGINES IN THESE CATEGORIES
2012 0.10 4.81 0.07 2016 0.04 1.3 0.03
                                                     35

-------
Draft Regulatory Impact Analysis
               Table 0-29 Control PM10, NOx, and HC Emission Factors (g/kW-hr) for Cl Propulsion High Power Density Engines
DISPLACEMENT
CATEGORY
DISP<0.9 AND
3775KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
>35 KW/L
<=600KW
YEAR
TIERS
HC
NOX
PM
NO ENGINES
2012
2013
2014
0.15
0.14
0.11
4.38
4.89
4.81
0.08
0.05
0.08
NO ENGINES
60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
>35 KW/L
10001400KW
,T.r TIERS TIER 4
1LJ" HC NOX PM 1LJ"1X HC NOX PM
NO ENGINES IN THESE CATEGORIES
2012 0.10 4.81 0.07 2016 0.04 1.3 0.03
                                                                  36

-------
                                                        Chapter 3: Inventory
Table 0-30 Control Case (50-State) Emissions for Cl Propulsion Engines (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
13,328
13,690
13,807
13,873
13,872
12,230
10,961
10,709
10,304
9,916
9,409
8,859
8,291
7,700
7,065
6,463
5,911
5,388
4,938
4,562
4,208
3,873
3,552
3,263
3,013
2,808
2,644
2,512
2,417
2,352
2,310
2,284
2,265
2,254
2,248
2,250
2,256
2,268
2,282
PM2.5
12,928
13,279
13,393
13,457
13,456
11,863
10,632
10,388
9,995
9,618
9,127
8,593
8,042
7,469
6,853
6,269
5,734
5,226
4,790
4,425
4,082
3,756
3,446
3,165
2,923
2,724
2,565
2,436
2,344
2,282
2,241
2,215
2,197
2,186
2,181
2,182
2,189
2,200
2,214
NOX
335,561
336,369
332,798
328,810
324,900
316,663
308,524
300,509
292,651
284,979
276,209
267,453
257,691
248,317
236,292
223,265
209,717
196,847
185,242
174,843
164,971
155,589
146,696
138,521
131,195
124,763
119,185
114,708
111,660
109,766
108,624
107,896
107,443
107,233
107,236
107,444
107,834
108,376
109,054
VOC
9,488
9,573
9,561
9,550
9,540
9,415
9,291
9,169
9,050
8,933
8,708
8,433
8,042
7,658
7,228
6,784
6,334
5,898
5,496
5,126
4,772
4,433
4,111
3,826
3,589
3,400
3,252
3,134
3,049
2,991
2,953
2,927
2,911
2,902
2,901
2,906
2,919
2,936
2,957
HC
9,010
9,091
9,080
9,069
9,060
8,941
8,824
8,708
8,594
8,483
8,270
8,008
7,637
7,273
6,864
6,443
6,015
5,601
5,219
4,868
4,532
4,210
3,904
3,634
3,408
3,229
3,089
2,976
2,896
2,841
2,804
2,780
2,764
2,756
2,755
2,760
2,772
2,788
2,808
CO
55,303
55,801
55,722
55,582
55,450
54,423
53,405
52,401
51,414
50,445
49,497
48,574
47,680
46,827
46,023
45,368
44,879
44,482
44,301
44,329
44,423
44,571
44,760
44,987
45,248
45,539
45,861
46,209
46,583
46,975
47,385
47,811
48,241
48,675
49,114
49,556
50,002
50,452
50,906
S02
36,201
36,528
36,862
37,192
36,827
19,121
6,299
6,355
4,705
3,513
1,862
664
799
857
865
872
879
886
893
900
907
915
923
931
939
946
954
962
970
978
986
995
1,006
1,015
1,023
1,032
1,040
1,050
1,059
                                       37

-------
Draft Regulatory Impact Analysis
              Table 0-31 Control PM10, NOx, and HC Emission Factors (g/kW-hr) for Cl Auxiliary Standard Power Density Engines
DISPLACEMENT
CATEGORY
DISP<0.9 AND
3775KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
<35 KW/L
<600KW
YEAR
2009
2014
2012
2013
2014
2018
2013
2018
2012
2018
TIERS
HC
0.30

0.14
0.13
0.11

0.11

0.11

NOX
5.70
3.56
4.08
4.02
4.77

4.77

4.89

PM
0.17

0.08
0.08
0.08
0.070
0.08
0.070
0.08
0.070
60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
<35 KW/L
10001400KW
VT? A P VT? A P
iC~K HC NOX PM iC~K
TIER 4
HC NOX PM
NO ENGINES IN THESE CATEGORIES

2012 0.11 4.89 0.08 2016
0.04 1.3 0.03
                                                                  38

-------
                                                                                          Chapter 3: Inventory
Table 0-32 Control PM10, NOx, and HC Emission Factors (g/kW-hr) for Cl Auxiliary High Power Density Engines
DISPLACEMENT
CATEGORY
DISP<0.9 AND
3775KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
>35 KW/L
<600KW
YEAR
2009
2014
2012
TIERS
HC
0.30

0.15
NOX
5.70
3.56
4.38
PM
0.17

0.08
NO ENGINES IN THESE
CATEGORIES
60075KW
0.9<=DISP<1.2
1.2<=DISP<2.5
2.5<=DISP<3.5
3.5<=DISP<5.0
>35 KW/L
10001400KW
TIERS _ A TIER 4
1 '"v HC NOX PM " ^^ HC NOX PM
NO ENGINES IN THESE CATEGORIES
2014 0.11 4.77 0.08 2016 0.04 1.3 0.03
NO ENGINES IN THESE CATEGORIES
                                                   39

-------
Draft Regulatory Impact Analysis
      Table 0-33 Control Case (50-State) Emissions for Cl Auxiliary Engines (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
2,714
2,773
2,791
2,786
2,769
2,482
2,263
2,229
2,169
2,113
2,042
1,971
1,902
1,829
1,751
1,663
1,561
1,458
1,354
1,261
1,184
1,116
1,054
998
945
895
847
803
764
733
708
687
669
656
647
641
637
635
635
PM2.5
2,632
2,690
2,708
2,703
2,686
2,407
2,195
2,162
2,104
2,049
1,981
1,912
1,845
1,774
1,698
1,613
1,514
1,414
1,314
1,224
1,149
1,082
1,022
968
917
868
822
779
741
711
687
667
649
637
628
622
618
616
616
NOX
60,641
60,959
60,482
59,774
59,073
58,048
57,030
56,020
55,022
54,038
52,949
51,796
50,317
48,863
47,349
45,754
43,895
42,089
40,347
38,787
37,444
36,210
35,096
34,089
33,138
32,243
31,399
30,630
29,948
29,388
28,939
28,572
28,303
28,159
28,117
28,123
28,176
28,259
28,367
VOC
1,767
1,783
1,785
1,788
1,791
1,787
1,783
1,778
1,773
1,768
1,753
1,727
1,677
1,628
1,577
1,523
1,463
1,403
1,345
1,290
1,239
1,188
1,141
1,095
1,052
1,010
970
935
905
882
866
853
843
836
832
830
829
829
831
HC
1,678
1,693
1,696
1,698
1,700
1,697
1,693
1,688
1,684
1,679
1,664
1,640
1,593
1,546
1,497
1,446
1,389
1,333
1,278
1,225
1,176
1,129
1,083
1,040
999
959
921
888
859
838
823
810
801
794
790
788
787
788
789
CO
9,624
9,710
9,668
9,585
9,503
9,331
9,160
8,989
8,820
8,654
8,489
8,327
8,167
8,010
7,857
7,708
7,563
7,426
7,298
7,198
7,134
7,088
7,066
7,067
7,077
7,094
7,117
7,145
7,178
7,215
7,257
7,303
7,353
7,407
7,464
7,524
7,588
7,654
7,721
S02
6,553
6,613
6,673
6,733
6,667
3,461
1,140
1,150
852
636
337
120
145
155
157
158
159
160
162
163
164
166
167
169
170
171
173
174
176
177
179
180
182
184
185
187
188
190
192
                                           40

-------
                                                          Chapter 3: Inventory
3.1.3.4 Category 2 Propulsion

       The modeled Tier 3 and Tier 4 emission factors for Category 2 propulsion
engines are shown in Table 0-34. The methodology described above for Category 1
propulsion engines was used to derive these emission factors.

       The resulting control case 50-state emission inventories for Category 2
propulsion engines are given in Table 0-35.
     Table 0-34 Control PM10, NOx, and HC Emission Factors (g/kW-hr) for C2 Engines
DISPLACEMENT CATEGORY
5.0<=DISP<15 AND <600KW
5.0<=DISP<15 AND 6003700KW
15.0<=DISP<20.0 AND 14003700KW
YEAR
2013
2013
2013
2013
TIERS
HC
0.07
0.07
0.07
0.07
NOX
5.97
5.97
5.97
5.97
PM
0.11
0.11
0.11
0.11

2014
0.09
6.77
0.30

YEAR

2018
2017
2016
2014
2017
2016
2014
2017
TIER 4
HC

0.02
0.02
0.02
0.06
0.03
0.01
0.07
0.01
NOX

1.3
1.3
1.3
1.3
1.3
1.3
1.3
1.3
PM

0.03
0.03
0.03
0.10
0.04
0.04
0.23
0.05
                                          41

-------
Draft Regulatory Impact Analysis
          Table 0-35 Control Case (50-State) Emissions for C2 Propulsion Engines
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
12,850
13,112
13,376
13,641
13,907
14,174
14,436
14,706
14,975
15,245
15,515
15,569
14,031
12,996
12,865
12,482
12,130
11,748
11,394
11,108
10,804
10,465
10,094
9,710
9,315
8,909
8,493
8,071
7,644
7,211
6,776
6,342
5,909
5,482
5,089
4,756
4,466
4,220
4,039
PM2.5
12,464
12,719
12,975
13,232
13,490
13,748
14,003
14,264
14,525
14,787
15,050
15,102
13,610
12,606
12,479
12,107
11,766
11,396
11,052
10,775
10,480
10,151
9,791
9,419
9,035
8,641
8,238
7,829
7,414
6,995
6,573
6,152
5,732
5,318
4,936
4,613
4,332
4,093
3,918
NOX
432,306
431,973
431,683
431,417
431,195
427,380
423,601
419,857
416,169
412,537
408,943
404,127
392,503
380,939
365,582
350,179
334,823
319,586
304,523
289,618
274,971
261,143
248,136
235,393
222,855
210,526
198,433
186,645
175,655
165,474
155,629
146,134
136,983
128,247
120,169
113,689
108,659
104,710
101,729
VOC
4,701
4,743
4,786
4,829
4,872
4,916
4,960
5,005
5,050
5,096
5,141
5,150
5,082
5,014
4,896
4,729
4,563
4,396
4,230
4,066
3,901
3,738
3,576
3,415
3,254
3,094
2,935
2,777
2,622
2,468
2,317
2,169
2,025
1,885
1,757
1,651
1,562
1,488
1,434
HC
4,464
4,504
4,545
4,586
4,627
4,669
4,711
4,753
4,796
4,839
4,883
4,891
4,826
4,761
4,650
4,491
4,333
4,175
4,017
3,861
3,705
3,550
3,396
3,243
3,090
2,938
2,787
2,637
2,490
2,344
2,200
2,060
1,923
1,790
1,669
1,568
1,484
1,413
1,362
CO
82,621
83,364
84,115
84,872
85,635
85,621
85,611
85,605
85,609
85,621
85,639
85,665
85,701
85,746
85,800
85,864
85,937
86,020
86,116
86,222
86,341
86,475
86,626
86,790
86,974
87,178
87,406
87,672
88,078
88,623
89,207
89,820
90,457
91,119
91,799
92,500
93,219
93,956
94,707
S02
36,868
37,193
37,528
37,866
38,207
38,550
38,837
39,204
39,559
39,920
40,278
39,905
21,334
7,888
7,817
5,901
4,574
2,963
1,888
1,976
1,995
1,975
1,954
1,934
1,913
1,894
1,874
1,855
1,836
1,818
1,800
1,783
1,766
1,750
1,735
1,721
1,709
1,700
1,699
                                           42

-------
                                                         Chapter 3: Inventory
3.1.3.5 Less than 37 kW Propulsion and Auxiliary

       The modeled Tier 3 emission factors for less than (<) 37kW commercial
marine diesel engines are given in Table 0-36. These emission factors apply to both
propulsion and auxiliary engines. For HC, the methodology described for Category 1
propulsion engines was used.  For PM, a 20 percent compliance margin was applied
to the Tier 3 standard; however, if the resulting emission factor was greater than the
corresponding Tier 2 emission factor, the Tier 2 value was used for Tier 3.  Since the
proposed rule does not result in NOX control for this category, the Tier 3 NOX
emission factors were set equal to Tier 2.
  Table 0-36 Control PM10, NOX, and HC Emission Factors (g/hp-hr) for <37kW Commercial
                              Marine Diesel Engines
HP
RANGE
0-11
11 1C
11 ID
1 C OC
ID £0
9^ ^n
L J JU

YEAR
2009
2009
2014
2009
2014
2009
2014

HC
0.43
0.21
0.21
0.21
0.21
0.41
0.41
TIER 3
NOX
4.39
3.63
2.32
3.63
2.32
3.71
2.32

PM
0.24
0.19
0.19
0.19
0.19
0.18
0.18
       The resulting control case 50-state emission inventories for <37kW propulsion
and auxiliary engines are given in Table 0-37.

3.1.3.6 Commercial Marine Diesel Control Inventory Summary

3.1.3.6.1 PMW, PM25, NOX, VOC, CO, andSO2 Emissions

       Table 0-38 thru Table 0-43 present the resulting 50-state consolidated
commercial marine control case inventories for each pollutant and category, for
calendar years 2002-2040.

3.1.3.6.2 Air Toxics Emissions

       The control case  air  toxics inventories for commercial marine diesel engines
are provided in Table 0-44.  The gaseous air toxics are assumed to be controlled
proportionately to VOC, whereas POM is controlled proportionately to PM.
                                         43

-------
Draft Regulatory Impact Analysis
     Table 0-37 Control Case (50-State) Emissions for <37kW Commercial Marine Engines
                                    (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
728
710
692
671
648
596
551
524
495
466
437
409
383
357
334
317
303
291
280
271
263
257
252
248
244
242
241
240
240
240
241
242
244
245
247
249
251
253
255
PM2.5
706
689
671
651
629
578
534
509
480
452
424
397
371
346
324
308
294
282
272
263
255
249
244
240
237
235
234
233
233
233
234
235
236
238
240
242
244
246
248
NOX
5,517
5,448
5,350
5,229
5,101
4,973
4,846
4,719
4,594
4,472
4,351
4,234
4,073
3,917
3,777
3,658
3,556
3,462
3,377
3,301
3,240
3,188
3,144
3,103
3,070
3,042
3,018
2,998
2,982
2,978
2,983
2,993
3,007
3,022
3,040
3,058
3,079
3,100
3,123
VOC
1,273
1,222
1,179
1,128
1,075
1,022
969
911
853
797
741
688
636
586
545
515
492
472
454
438
423
411
401
393
387
383
381
379
378
378
380
381
384
387
389
392
395
398
402
HC
1,209
1,161
1,120
1,071
1,021
970
920
865
810
757
704
653
604
556
518
489
467
448
432
416
402
390
381
373
368
364
361
360
359
359
360
362
365
367
370
372
375
378
381
CO
3,783
3,680
3,576
3,460
3,339
3,216
3,093
2,970
2,846
2,724
2,603
2,484
2,369
2,259
2,170
2,109
2,063
2,027
1,997
1,972
1,952
1,940
1,932
1,926
1,926
1,929
1,934
1,942
1,952
1,963
1,977
1,992
2,009
2,026
2,044
2,061
2,079
2,097
2,115
S02
731
738
745
752
745
387
128
129
95
71
38
14
16
18
18
18
18
18
18
18
18
19
19
19
19
19
19
20
20
20
20
20
21
21
21
21
21
21
22
                                           44

-------
                                                           Chapter 3: Inventory
Table 0-38 Control Case (50-State) PM10 Emissions for Commercial Marine Diesel Engines
                                  (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
13,328
13,690
13,807
13,873
13,872
12,230
10,961
10,709
10,304
9,916
9,409
8,859
8,291
7,700
7,065
6,463
5,911
5,388
4,938
4,562
4,208
3,873
3,552
3,263
3,013
2,808
2,644
2,512
2,417
2,352
2,310
2,284
2,265
2,254
2,248
2,250
2,256
2,268
2,282
Cl
AUXILIARY
2,714
2,773
2,791
2,786
2,769
2,482
2,263
2,229
2,169
2,113
2,042
1,971
1,902
1,829
1,751
1,663
1,561
1,458
1,354
1,261
1,184
1,116
1,054
998
945
895
847
803
764
733
708
687
669
656
647
641
637
635
635
Cl
TOTAL
16,041
16,463
16,598
16,659
16,641
14,712
13,224
12,939
12,472
12,029
11,451
10,830
10,192
9,528
8,816
8,126
7,472
6,845
6,292
5,824
5,393
4,988
4,606
4,262
3,959
3,704
3,491
3,315
3,181
3,085
3,019
2,971
2,934
2,910
2,896
2,891
2,894
2,903
2,917
C2
PROPULSION
12,850
13,112
13,376
13,641
13,907
14,174
14,436
14,706
14,975
15,245
15,515
15,569
14,031
12,996
12,865
12,482
12,130
11,748
11,394
11,108
10,804
10,465
10,094
9,710
9,315
8,909
8,493
8,071
7,644
7,211
6,776
6,342
5,909
5,482
5,089
4,756
4,466
4,220
4,039
<37KW
728
710
692
671
648
596
551
524
495
466
437
409
383
357
334
317
303
291
280
271
263
257
252
248
244
242
241
240
240
240
241
242
244
245
247
249
251
253
255
TOTAL
29,619
30,285
30,666
30,972
31,196
29,481
28,211
28,169
27,942
27,740
27,404
26,808
24,606
22,881
22,015
20,925
19,905
18,885
17,967
17,203
16,460
15,710
14,952
14,219
13,518
12,855
12,225
11,626
11,065
10,537
10,036
9,555
9,087
8,638
8,232
7,895
7,611
7,376
7,211
                                         45

-------
Draft Regulatory Impact Analysis
   Table 0-39 Control Case (50-State) PM2.5 Emissions for Commercial Marine Diesel Engines
                                    (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
12,928
13,279
13,393
13,457
13,456
11,863
10,632
10,388
9,995
9,618
9,127
8,593
8,042
7,469
6,853
6,269
5,734
5,226
4,790
4,425
4,082
3,756
3,446
3,165
2,923
2,724
2,565
2,436
2,344
2,282
2,241
2,215
2,197
2,186
2,181
2,182
2,189
2,200
2,214
Cl
AUXILIARY
2,632
2,690
2,708
2,703
2,686
2,407
2,195
2,162
2,104
2,049
1,981
1,912
1,845
1,774
1,698
1,613
1,514
1,414
1,314
1,224
1,149
1,082
1,022
968
917
868
822
779
741
711
687
667
649
637
628
622
618
616
616
Cl
TOTAL
15,560
15,969
16,100
16,159
16,142
14,270
12,827
12,551
12,098
11,668
11,107
10,505
9,887
9,242
8,551
7,882
7,248
6,640
6,103
5,649
5,231
4,838
4,468
4,134
3,840
3,592
3,386
3,215
3,086
2,993
2,928
2,882
2,846
2,823
2,809
2,804
2,807
2,816
2,829
C2
PROPULSION
12,464
12,719
12,975
13,232
13,490
13,748
14,003
14,264
14,525
14,787
15,050
15,102
13,610
12,606
12,479
12,107
11,766
11,396
11,052
10,775
10,480
10,151
9,791
9,419
9,035
8,641
8,238
7,829
7,414
6,995
6,573
6,152
5,732
5,318
4,936
4,613
4,332
4,093
3,918
<37KW
706
689
671
651
629
578
534
509
480
452
424
397
371
346
324
308
294
282
272
263
255
249
244
240
237
235
234
233
233
233
234
235
236
238
240
242
244
246
248
TOTAL
28,730
29,377
29,746
30,042
30,260
28,596
27,364
27,324
27,104
26,908
26,582
26,004
23,868
22,195
21,354
20,297
19,308
18,318
17,428
16,687
15,966
15,239
14,503
13,793
13,113
12,469
11,858
11,277
10,733
10,221
9,735
9,269
8,815
8,378
7,985
7,658
7,383
7,155
6,995
                                            46

-------
                                                          Chapter 3: Inventory
Table 0-40 Control Case (50-State) NOX Emissions for Commercial Marine Diesel Engines
                                  (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
335,561
336,369
332,798
328,810
324,900
316,663
308,524
300,509
292,651
284,979
276,209
267,453
257,691
248,317
236,292
223,265
209,717
196,847
185,242
174,843
164,971
155,589
146,696
138,521
131,195
124,763
119,185
114,708
111,660
109,766
108,624
107,896
107,443
107,233
107,236
107,444
107,834
108,376
109,054
Cl
AUXILIARY
60,641
60,959
60,482
59,774
59,073
58,048
57,030
56,020
55,022
54,038
52,949
51,796
50,317
48,863
47,349
45,754
43,895
42,089
40,347
38,787
37,444
36,210
35,096
34,089
33,138
32,243
31,399
30,630
29,948
29,388
28,939
28,572
28,303
28,159
28,117
28,123
28,176
28,259
28,367
Cl
TOTAL
396,202
397,328
393,280
388,583
383,973
374,710
365,554
356,529
347,673
339,017
329,158
319,249
308,007
297,181
283,640
269,020
253,612
238,936
225,589
213,630
202,415
191,800
181,792
172,610
164,333
157,006
150,584
145,338
141,608
139,154
137,563
136,468
135,746
135,392
135,352
135,566
136,009
136,635
137,421
C2
PROPULSION
432,306
431,973
431,683
431,417
431,195
427,380
423,601
419,857
416,169
412,537
408,943
404,127
392,503
380,939
365,582
350,179
334,823
319,586
304,523
289,618
274,971
261,143
248,136
235,393
222,855
210,526
198,433
186,645
175,655
165,474
155,629
146,134
136,983
128,247
120,169
113,689
108,659
104,710
101,729
<37KW
5,517
5,448
5,350
5,229
5,101
4,973
4,846
4,719
4,594
4,472
4,351
4,234
4,073
3,917
3,777
3,658
3,556
3,462
3,377
3,301
3,240
3,188
3,144
3,103
3,070
3,042
3,018
2,998
2,982
2,978
2,983
2,993
3,007
3,022
3,040
3,058
3,079
3,100
3,123
TOTAL
834,025
834,749
830,313
825,229
820,269
807,063
794,001
781,105
768,436
756,026
742,453
727,609
704,584
682,037
652,999
622,856
591,991
561,984
533,489
506,550
480,625
456,131
433,072
411,106
390,259
370,574
352,035
334,981
320,245
307,605
296,175
285,596
275,735
266,661
258,561
252,314
247,747
244,445
242,273
                                         47

-------
Draft Regulatory Impact Analysis
   Table 0-41 Control Case (50-State) VOC Emissions for Commercial Marine Diesel Engines
                                    (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
9,488
9,573
9,561
9,550
9,540
9,415
9,291
9,169
9,050
8,933
8,708
8,433
8,042
7,658
7,228
6,784
6,334
5,898
5,496
5,126
4,772
4,433
4,111
3,826
3,589
3,400
3,252
3,134
3,049
2,991
2,953
2,927
2,911
2,902
2,901
2,906
2,919
2,936
2,957
Cl
AUXILIARY
1,767
1,783
1,785
1,788
1,791
1,787
1,783
1,778
1,773
1,768
1,753
1,727
1,677
1,628
1,577
1,523
1,463
1,403
1,345
1,290
1,239
1,188
1,141
1,095
1,052
1,010
970
935
905
882
866
853
843
836
832
830
829
829
831
Cl
TOTAL
11,255
11,356
11,346
11,338
11,331
11,202
11,074
10,947
10,823
10,701
10,461
10,160
9,719
9,286
8,805
8,307
7,796
7,302
6,841
6,416
6,010
5,621
5,252
4,922
4,640
4,410
4,223
4,068
3,953
3,874
3,819
3,781
3,754
3,738
3,733
3,736
3,748
3,765
3,787
C2
PROPULSION
4,701
4,743
4,786
4,829
4,872
4,916
4,960
5,005
5,050
5,096
5,141
5,150
5,082
5,014
4,896
4,729
4,563
4,396
4,230
4,066
3,901
3,738
3,576
3,415
3,254
3,094
2,935
2,777
2,622
2,468
2,317
2,169
2,025
1,885
1,757
1,651
1,562
1,488
1,434
<37KW
1,273
1,222
1,179
1,128
1,075
1,022
969
911
853
797
741
688
636
586
545
515
492
472
454
438
423
411
401
393
387
383
381
379
378
378
380
381
384
387
389
392
395
398
402
TOTAL
17,229
17,321
17,311
17,295
17,278
17,140
17,003
16,863
16,726
16,594
16,344
15,998
15,437
14,885
14,246
13,551
12,851
12,169
11,526
10,920
10,335
9,771
9,229
8,729
8,281
7,887
7,538
7,225
6,953
6,720
6,516
6,331
6,162
6,010
5,880
5,779
5,705
5,652
5,623
                                            48

-------
                                                          Chapter 3: Inventory
Table 0-42 Control Case (50-State) CO Emissions for Commercial Marine Diesel Engines
                                 (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
55,303
55,801
55,722
55,582
55,450
54,423
53,405
52,401
51,414
50,445
49,497
48,574
47,680
46,827
46,023
45,368
44,879
44,482
44,301
44,329
44,423
44,571
44,760
44,987
45,248
45,539
45,861
46,209
46,583
46,975
47,385
47,811
48,241
48,675
49,114
49,556
50,002
50,452
50,906
Cl
AUXILIARY
9,624
9,710
9,668
9,585
9,503
9,331
9,160
8,989
8,820
8,654
8,489
8,327
8,167
8,010
7,857
7,708
7,563
7,426
7,298
7,198
7,134
7,088
7,066
7,067
7,077
7,094
7,117
7,145
7,178
7,215
7,257
7,303
7,353
7,407
7,464
7,524
7,588
7,654
7,721
Cl
TOTAL
64,927
65,511
65,390
65,167
64,954
63,754
62,565
61,391
60,235
59,099
57,986
56,901
55,847
54,837
53,880
53,076
52,443
51,908
51,599
51,527
51,557
51,659
51,827
52,054
52,325
52,633
52,978
53,354
53,761
54,191
54,642
55,114
55,595
56,082
56,577
57,079
57,589
58,105
58,627
C2
PROPULSION
82,621
83,364
84,115
84,872
85,635
85,621
85,611
85,605
85,609
85,621
85,639
85,665
85,701
85,746
85,800
85,864
85,937
86,020
86,116
86,222
86,341
86,475
86,626
86,790
86,974
87,178
87,406
87,672
88,078
88,623
89,207
89,820
90,457
91,119
91,799
92,500
93,219
93,956
94,707
<37KW
3,783
3,680
3,576
3,460
3,339
3,216
3,093
2,970
2,846
2,724
2,603
2,484
2,369
2,259
2,170
2,109
2,063
2,027
1,997
1,972
1,952
1,940
1,932
1,926
1,926
1,929
1,934
1,942
1,952
1,963
1,977
1,992
2,009
2,026
2,044
2,061
2,079
2,097
2,115
TOTAL
151,331
152,556
153,080
153,499
153,928
152,591
151,269
149,966
148,690
147,444
146,227
145,050
143,917
142,842
141,851
141,049
140,443
139,954
139,712
139,720
139,851
140,073
140,384
140,771
141,226
141,740
142,318
142,968
143,791
144,776
145,825
146,926
148,060
149,227
150,419
151,640
152,887
154,158
155,449
                                         49

-------
Draft Regulatory Impact Analysis
   Table 0-43 Control Case (50-State) SO2 Emissions for Commercial Marine Diesel Engines
                                    (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
36,201
36,528
36,862
37,192
36,827
19,121
6,299
6,355
4,705
3,513
1,862
664
799
857
865
872
879
886
893
900
907
915
923
931
939
946
954
962
970
978
986
995
1,006
1,015
1,023
1,032
1,040
1,050
1,059
Cl
AUXILIARY
6,553
6,613
6,673
6,733
6,667
3,461
1,140
1,150
852
636
337
120
145
155
157
158
159
160
162
163
164
166
167
169
170
171
173
174
176
177
179
180
182
184
185
187
188
190
192
Cl
TOTAL
42,754
43,141
43,535
43,925
43,493
22,583
7,440
7,506
5,557
4,148
2,199
784
943
1,012
1,021
1,030
1,038
1,046
1,055
1,063
1,072
1,081
1,090
1,099
1,109
1,118
1,127
1,136
1,146
1,155
1,165
1,175
1,188
1,198
1,208
1,218
1,228
1,240
1,251
C2
PROPULSION
36,868
37,193
37,528
37,866
38,207
38,550
38,837
39,204
39,559
39,920
40,278
39,905
21,334
7,888
7,817
5,901
4,574
2,963
1,888
1,976
1,995
1,975
1,954
1,934
1,913
1,894
1,874
1,855
1,836
1,818
1,800
1,783
1,766
1,750
1,735
1,721
1,709
1,700
1,699
<37KW
731
738
745
752
745
387
128
129
95
71
38
14
16
18
18
18
18
18
18
18
18
19
19
19
19
19
19
20
20
20
20
20
21
21
21
21
21
21
22
TOTAL
80,353
81,073
81,808
82,543
82,445
61,520
46,404
46,839
45,212
44,139
42,515
40,702
22,293
8,917
8,855
6,949
5,630
4,028
2,961
3,058
3,085
3,074
3,063
3,052
3,041
3,031
3,020
3,010
3,002
2,993
2,985
2,978
2,975
2,969
2,964
2,961
2,958
2,962
2,971
                                            50

-------
                                                        Chapter 3: Inventory
 Table 0-44 Control Case (50-State) Air Toxic Emissions for Commercial Marine Diesel Engines
                                  (short tons)
HAP
BENZENE
FORMALDEHYDE
ACETALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
2010
556
4,088
2,032
6
79
38
10
2015
515
3,785
1,881
5
73
34
9
2020
410
3,018
1,500
4
58
26
7
2030
252
1,857
923
3
36
16
4
3.1.4 Projected Commercial Marine Emission Reductions of Proposal

       The PM2.5, NOX, and VOC emission reductions for each category and calendar
year are presented in Table 0-45 thru Table 0-47.  The air toxic emission reductions
by pollutant and calendar year are given in Table 0-48.
                                         51

-------
Draft Regulatory Impact Analysis
       Table 0-45 Projected Commercial Marine PM2.5 Emission Reductions (short tons)
YEAR
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
0
0
0
0
60
140
288
441
634
856
1,112
1,375
1,643
1,917
2,194
2,473
2,751
3,012
3,245
3,449
3,625
3,782
3,914
4,022
4,115
4,198
4,274
4,343
4,407
4,465
4,518
4,568
4,614
Cl
AUXILIARY
0
1
2
2
9
21
49
76
106
139
179
220
262
305
348
392
437
482
528
573
618
661
700
733
761
787
811
832
850
867
882
897
911
Cl
TOTAL
0
1
2
3
69
161
336
518
740
995
1,292
1,595
1,905
2,221
2,542
2,865
3,188
3,494
3,773
4,021
4,243
4,442
4,613
4,755
4,876
4,985
5,085
5,175
5,257
5,332
5,400
5,465
5,525
C2
PROPULSION
0
0
0
0
0
153
431
620
988
1,459
1,937
2,405
2,882
3,400
3,925
4,456
4,995
5,541
6,096
6,658
7,227
7,801
8,380
8,962
9,546
10,130
10,712
11,288
11,831
12,316
12,759
13,160
13,498
<37KW
0
2
4
5
6
8
9
11
13
15
16
18
20
22
24
26
28
29
31
32
33
33
34
35
35
36
37
37
38
38
39
39
40
TOTAL
0
3
6
8
76
321
776
1,149
1,740
2,469
3,245
4,019
4,808
5,644
6,491
7,347
8,210
9,064
9,899
10,711
11,503
12,277
13,027
13,752
14,458
15,151
15,834
16,500
17,126
17,686
18,198
18,664
19,063
                                           52

-------
                                                     Chapter 3: Inventory
Table 0-46 Projected Commercial Marine NOX Emission Reductions (short tons)
YEAR
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
0
0
0
0
1,342
3,311
6,944
10,562
17,246
26,061
36,621
47,117
57,522
67,833
78,019
88,051
97,867
107,215
115,946
123,957
131,290
137,676
142,790
146,842
150,228
153,285
156,089
158,671
161,061
163,268
165,314
167,230
169,033
Cl
AUXILIARY
0
0
0
0
121
322
868
1,414
2,051
2,835
3,954
5,071
6,184
7,292
8,397
9,495
10,586
11,667
12,737
13,792
14,829
15,822
16,755
17,592
18,343
19,039
19,659
20,173
20,604
21,004
21,377
21,732
22,069
Cl
TOTAL
0
0
0
0
1,463
3,633
7,812
11,976
19,297
28,896
40,576
52,187
63,705
75,126
86,416
97,546
108,453
118,882
128,683
137,749
146,119
153,498
159,545
164,434
168,571
172,324
175,748
178,844
181,665
184,271
186,692
188,962
191,102
C2
PROPULSION
0
0
0
0
0
1,301
9,467
17,654
29,714
41,922
54,165
66,413
78,633
90,840
103,020
115,170
127,293
139,391
151,488
163,559
175,606
187,573
199,471
211,253
222,938
234,439
245,767
256,829
267,350
276,408
284,135
290,899
296,798
<37KW
0
0
0
0
0
0
47
94
141
188
235
281
328
374
420
465
510
555
599
643
685
726
764
794
815
835
852
869
884
899
913
926
938
TOTAL
0
0
0
0
1,463
4,935
17,326
29,723
49,151
71,006
94,975
118,882
142,666
166,339
189,855
213,181
236,257
258,828
280,771
301,951
322,410
341,797
359,780
376,481
392,324
407,598
422,367
436,542
449,899
461,578
471,739
480,787
488,838
                                     53

-------
Draft Regulatory Impact Analysis
       Table 0-47 Projected Commercial Marine VOC Emission Reductions (short tons)
YEAR
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Cl
PROPULSION
0
0
1
1
113
279
564
849
1,187
1,563
1,970
2,374
2,773
3,167
3,555
3,934
4,303
4,639
4,934
5,184
5,397
5,585
5,743
5,876
5,993
6,099
6,197
6,287
6,371
6,449
6,521
6,589
6,654
Cl
AUXILIARY
0
2
3
5
17
40
88
135
185
237
297
356
415
474
532
590
647
704
760
814
867
917
961
998
1,029
1,058
1,084
1,107
1,128
1,147
1,166
1,183
1,200
Cl
TOTAL
0
2
4
6
130
319
652
984
1,372
1,800
2,267
2,730
3,188
3,640
4,087
4,524
4,950
5,343
5,694
5,998
6,264
6,501
6,704
6,874
7,022
7,157
7,281
7,394
7,499
7,596
7,687
7,772
7,854
C2
PROPULSION
0
0
0
0
0
37
152
268
433
648
863
1,078
1,293
1,508
1,722
1,936
2,149
2,362
2,575
2,787
2,999
3,210
3,420
3,628
3,834
4,037
4,237
4,433
4,618
4,781
4,928
5,060
5,173
<37KW
0
5
11
16
22
27
32
38
43
49
54
59
64
70
75
79
84
89
92
95
97
99
101
103
105
106
108
109
111
112
114
115
116
TOTAL
0
7
14
22
152
383
837
1,290
1,848
2,497
3,183
3,867
4,545
5,218
5,883
6,539
7,183
7,794
8,360
8,880
9,360
9,811
10,225
10,605
10,960
11,300
11,625
11,936
12,228
12,490
12,728
12,947
13,143
                                           54

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                                                        Chapter 3: Inventory
     Table 0-48 Projected Commercial Marine Air Toxic Emission Reductions (short tons)
HAP
BENZENE
FORMALDEHYDE
ACETALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
2010
0
4
2
0
0
0
0
2015
45
328
163
0
6
3
0
2020
162
1,190
591
2
23
10
2
2030
371
2,730
1,357
4
53
24
5
3.2 Recreational Marine Diesel Engines

       This section describes the methodology and presents the resulting baseline and
controlled inventories for recreational marine (pleasure craft)  diesel propulsion
engines, including the projected emission reductions from the proposed rule.  These
engines are already subject to existing emission control standards, so the baseline
inventories presented here account for those existing standards. Emissions from any
diesel auxiliary engines used on recreational marine vessels are covered above in the
section on engines less than 37 kW or the section on Category 1 engines, if they are
over 37 kW.

3.2.1 General Methodology

       The general methodology for calculating recreational marine diesel engine
inventories for HC, CO, NOX, PMio, S02, VOC, PM2.s, and fuel consumption uses the
EPA NONROAD2005 model with inputs modified to reflect the proposed standards
as well as updated baseline data.13 Air toxic inventories are not generated by the
NONROAD  model, so those are calculated separately. NONROAD separates
recreational diesel engines into two basic categories: inboard and outboard engines.
NONROAD  also subdivides these by power range. There are relatively few outboard
diesels, and they are all in the 25 - 40 hp range.

       The actual calculation methodology used by the NONROAD model is the
same as described above in section 3.1.1 for all other marine diesel engines.
Following is a summary of that.

                         Equations  I = N*P*L*A*EF

where each term is defined as follows:
       I = the emission inventory (gram/year)
       N = engine population (units)
       P = average rated power (kW)
       L = load factor (average fraction of rated power used during operation;
unitless)
                                        55

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Draft Regulatory Impact Analysis
       A = engine activity (operating hours/year)
       EF = emission factor (gram/kW-hr)

       Emissions are then converted and reported as short tons/year. In NONROAD
the inputs are expressed in terms of horsepower (hp) instead of kW, and gram/bhp-hr
instead of gram/kW-hr.

       Three variables  are used to project emissions over time: the engine population
growth, the engine median life/scrappage, and the relative emissions deterioration
rate.

       Engine Population Growth.  Unlike the commercial marine methodology
which uses a compound population growth rate, the NONROAD model uses a linear
growth assumption for recreational diesel engines, which is represented by a set of
growth indexes that provide a ratio of estimation year population relative to the base
year population.14 The growth used for recreational diesel engines is 3.3 percent per
year relative to a 1996 base year; i.e., each year the population grows by the same
number of engines, and that number is 3.3 percent of the 1996 population.

       Engine Median Life (years) and Scrappage.  The engine median life defines
the length of time engines remain in service. Engines persist in the population over
two median lives; during the first median life, 50 percent of the engines are scrapped,
and over the second, the remaining 50 percent of the engines are scrapped. Engine
median lives also vary by category. The median life of both inboard and outboard
engines is assumed to be 20 years, but due to the different activities used for these
two categories (200 and 150 hours/year, respectively), the corresponding median  life
inputs for the model are 1400 and  1050 hours at full load. The age distribution is
defined by the median life and the  scrappage algorithm.  The same basic scrappage
algorithm is used for recreational and commercial marine diesel engines.1

       Relative Deterioration Rate (percent increase in emission factor/percent
median life expended).  A deterioration factor can be applied to the emission factor to
account for in-use deterioration. The deterioration factor varies by age and is
calculated as:

                        Equation 6   DF = 1 + A*(age/ML)

       where each term is defined as follows:
       DF = the deterioration factor for a given pollutant at a given age
       A = the relative  deterioration rate for a given pollutant (percent increase in
            emission factor/percent useful life expended)
       age = the age of a specific model year group of engines in the simulation year
(years)
       ML = the median life of the given model year cohort  (years)

       A given model year cohort is represented as a fraction of the entire population.
In the NONROAD model the deterioration factor adjusts the  emission factor for
engines in a given model year cohort in relation to the proportion of median life
                                         56

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                                                         Chapter 3: Inventory
expended.2 Deterioration is linear over one median life. Following the first median
life, the deteriorated emission factor is held constant over the remaining life for
engines in the cohort.

       Sulfur Adjustment for PM Emissions. For Tier 2 and prior engines, a sulfate
adjustment is added to the PM emissions to account for differences in fuel sulfur
content between the certification fuel and the episodic (calendar year) fuel, using the
following equation:

        Equation 3  SPM adj =FC * 7.1 * 0.02247 * 224/32 * (soxdsl - soxbas) * 1/2000

       where each term is defined as follows:
       SPM adj = PM sulfate adjustment (tons)
       FC = fuel consumption (gallons)
       7.1 = fuel density  (Ib/gal)
       0.02247 = fraction of fuel sulfur converted to sulfate
       224/32 = grams PM sulfate/grams PM sulfur
       soxdsl = episodic fuel sulfur weight fraction (varies by calendar year)
       soxbas = certification fuel sulfur weight fraction
       2000 = conversion from Ib to ton

       For engines prior to Tier 2 the base fuel sulfur  (soxbas) is assumed to be 3300
ppm.  For Tier 2 engines less than or equal to 50 hp (37 kW) it is set at 2000 ppm, as
described in the Clean Air Nonroad Diesel Rule.4, since these smaller engines are
subject to the same standards as land-based diesel engines. For Tier 2 engines greater
than 50 hp (37 kW) it is set at 350 ppm, based on the most recent certification data for
these engines.  For Tier 3 and later engines, no sulfur adjustment is applied. These
engines will be certified to a fuel sulfur level at or lower than the episodic fuel sulfur
levels expected when these engines are introduced.

       The calendar year fuel sulfur levels  (soxdsl) were taken from the Clean Air
Nonroad Diesel Rule.4

       Estimation of air toxic emissions. The air toxic baseline emission inventories
for this proposal are based on information developed for EPA's Mobile Source Air
Toxics (MSAT) final rulemaking.5  That rule calculated air toxic emission inventories
for all nonroad engines. The gaseous air toxics are correlated to VOC emissions,
while POM is correlated to PMio emissions. To calculate the air toxics emission
inventories and reductions for this proposal, the percent reductions in VOC and
emissions will be applied to the baseline gaseous and POM air toxic inventories,
respectively.

3.2.2  Baseline (Pre-Control) Inventory Development

3.2.2.1 Baseline Inventory Inputs

       This section describes the NONROAD model inputs that were used to
generate the baseline emission inventories for recreational marine diesel engines.
                                         57

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Draft Regulatory Impact Analysis
       Table 0-49 and Table 0-50 list the base engine populations, average hp by
power range, annual activity, load factor, and median life.  These also apply to the
control case, and are unchanged from the default inputs in the NONROAD model.
                 Table 0-49 Recreational Marine Diesel Modeling Inputs
NONROAD MODEL INPUT
POPULATION (year 2000)
HP AVERAGE
ACTIVITY HRS/YEAR
LOAD FACTOR
MEDIAN LIFE (hrs at full load)
MEDIAN LIFE (years)
RECREATIONAL MARINE DIESEL
INBOARD
291,387*
*
200
0.35
1400
20
OUTBOARD
9,819
32.25
150
0.35
1050
20
* See TABLE 0-50 for breakout by individual power ranges.
               Table 0-50 Recreational Marine Inboard Diesel Population
POWER RANGE
MIN < HP <= MAX
0-11
11-16
16-25
25-40
40-50
50-75
75-100
100-175
175-300
300 - 600
600 - 750
750-1000
1000-1200
1200-2000
2000 - 3000
TOTAL
DIESEL REC MARINE INBOARD
HPAVG
9.736
14.92
21.41
31.2
42.4
56.19
94.22
144.9
223.1
387.1
677
876.5
1154
1369
2294

POPULATION
9,126
4,478
9,908
5,421
1,002
8,784
7,397
60,632
99,703
73,546
2,902
5,502
448
1,573
964
291,387
       The baseline emission factors are given in Table 0-51 and Table 0-52.  "Zero
Hour" emission factors represent the emissions from new engines that have been
broken in, but before any significant deterioration occurs.  The Deterioration Factor is
                                          58

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                                                        Chapter 3: Inventory
used to calculate how emissions change as the engine and emission control system
deteriorate over time, as explained above in Equation 2.  Engines under 50 hp are
subject to EPA nonroad diesel regulations that have established two tiers of emission
standards.12  Tier 1 phased in from 1999-2000, depending on the hp category, and
Tier 2 phased in from 2004-2005. Engines above 50 hp are subject to separate
standards (shown in the Tier 2 column) that take effect in 2008-2012, depending on
hp category. The "Base" entries in the tables refer to emissions from pre-controlled
engines. All these emission factors are used for both inboard and outboard diesel
engines, although the outboards are all under 50 hp.

       The emission factors for the base and Tier 1 technology types are unchanged
from what has been in the NONROAD model.2 Tier 2 emission factors were updated
from those in the NONROAD model using all the nonroad engine certification data
available in mid-2006. The deterioration factors by pollutant and technology type are
also given in the tables above, and they are unchanged from what has been in the
NONROAD model.2

       The certification fuel sulfur levels  are 3300ppm for the base and Tier 1
technology type and 350ppm for Tier 2. Brake Specific Fuel Consumption (BSFC)
values in the NONROAD model are 0.408 Ib/hp-hr for all hp categories.2
 Table 0-51 Baseline PM10 and NOX Zero Hour Emission Factors and Deterioration Factors for
                        Recreational Marine Diesel Engines
HP
RANGE
0-11
11-16
16-25
25-50
50-75
75-100
100-175
175-300
300-600
600-750
750-1200
>1200
DF ("A")
PMio G/HP-HR
BASE
1.00
0.90
0.90
0.80
0.16
0.16
0.16
0.16
0.16
0.16
0.16
0.16
0.473
TIER1
0.45
0.27
0.27
0.34
0.16
0.16
0.16
0.16
0.16
0.16
0.16
0.16
0.473
TIER2
0.38
0.19
0.19
0.23
0.13
0.13
0.13
0.090
0.082
0.082
0.082
0.082
0.473
NOX G/HP-HR
BASE
10.00
8.50
8.50
6.90
6.67
6.67
6.67
6.67
6.67
6.67
6.67
6.67
0.024
TIER1
5.23
4.44
4.44
4.73
6.67
6.67
6.67
6.67
6.67
6.67
6.67
6.67
0.024
TIER2
4.39
3.63
3.63
3.71
3.82
3.82
3.82
4.46
4.42
4.42
4.42
4.42
0.009
                                         59

-------
Draft Regulatory Impact Analysis
  Table 0-52 Baseline HC and CO Zero Hour Emission Factors and Deterioration Factors for
                         Recreational Marine Diesel Engines
HP
RANGE
0-11
11-16
16-25
25-50
50-75
75-100
100-175
175-300
300-600
600-750
750-1200
>1200
DF ("A")
HC G/HP-HR
BASE
1.50
1.70
1.70
1.80
0.22
0.22
0.22
0.22
0.22
0.22
0.22
0.22
0.047
TIER1
0.76
0.44
0.44
0.28
0.22
0.22
0.22
0.22
0.22
0.22
0.22
0.22
0.047
TIER2
0.68
0.21
0.21
0.54
0.20
0.20
0.20
0.25
0.33
0.33
0.33
0.33
0.034
CO G/HP-HR
BASE
5.00
5.00
5.00
5.00
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.185
TIER1
4.11
2.16
2.16
1.53
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.101
TIER2
4.11
2.16
2.16
1.53
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.101
3.2.2.2 Recreational Marine Diesel Baseline Inventory

3.2.2.2.1 PMio, PM25, NOX, VOC, CO, andSO2 Emissions

       Table 0-53 shows the baseline 50-state emission inventories for recreational
marine diesel engines (inboard and outboard combined) resulting from the baseline
model inputs presented above.

3.2.2.2.2 Air Toxics Emissions

       The baseline air toxics inventories for recreational marine diesel engines were
taken from the final MSAT rule5 and are summarized in Table 0-54.  Inventories are
provided for calendar year 1999, and are projected for 2010, 2015,  2020, and 2030.
                                          60

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                                                             Chapter 3: Inventory
Table 0-53 Baseline (50-State) Emissions for Recreational Marine Diesel Engines (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
1,130
1,161
1,192
1,223
1,247
1,054
915
937
935
938
934
935
952
969
984
998
1,011
1,024
1,037
1,050
1,063
1,075
1,087
1,099
1,112
1,127
1,143
1,159
1,175
1,192
1,208
1,226
1,243
1,260
1,278
1,295
1,313
1,331
1,349
PM2.5
1,096
1,126
1,156
1,186
1,210
1,023
888
909
907
910
906
907
924
940
954
968
981
994
1,006
1,019
1,031
1,043
1,054
1,066
1,079
1,093
1,108
1,124
1,140
1,156
1,172
1,189
1,205
1,222
1,239
1,256
1,274
1,291
1,308
NOX
40,437
41,572
42,704
43,835
44,089
44,307
44,513
44,648
44,772
44,880
44,977
45,064
45,139
45,208
45,270
45,327
45,378
45,427
45,477
45,531
45,586
45,649
45,729
45,842
46,114
46,549
47,030
47,551
48,102
48,671
49,257
49,861
50,477
51,106
51,748
52,399
53,062
53,735
54,417
VOC
1,540
1,578
1,618
1,656
1,720
1,783
1,846
1,912
1,979
2,045
2,112
2,179
2,246
2,313
2,380
2,448
2,516
2,584
2,653
2,723
2,793
2,862
2,932
3,000
3,064
3,124
3,184
3,242
3,299
3,356
3,412
3,468
3,524
3,579
3,634
3,689
3,744
3,798
3,852
HC
1,462
1,499
1,536
1,573
1,633
1,693
1,753
1,816
1,879
1,942
2,006
2,069
2,133
2,196
2,260
2,325
2,389
2,454
2,520
2,586
2,652
2,718
2,784
2,849
2,910
2,967
3,023
3,079
3,133
3,187
3,240
3,294
3,346
3,399
3,451
3,503
3,555
3,607
3,659
CO
6,467
6,642
6,816
6,989
7,161
7,331
7,499
7,665
7,829
7,991
8,150
8,308
8,464
8,618
8,771
8,922
9,073
9,223
9,374
9,525
9,675
9,825
9,975
10,124
10,279
10,439
10,601
10,765
10,930
11,095
11,262
11,429
11,596
11,765
11,933
12,102
12,272
12,442
12,613
S02
5,145
5,290
5,436
5,582
5,621
2,967
993
1,017
764
578
311
113
136
150
153
156
156
159
162
165
168
171
174
177
180
183
186
189
192
195
199
202
205
208
211
214
217
220
223
                                           61

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Draft Regulatory Impact Analysis
  Table 0-54 Baseline Air Toxics Emissions for Recreational Marine Diesel Engines (short tons)
HAP
BENZENE
FORMALDEHYDE
ACETALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
1999
30
176
79
3
5
0
1
2010
34
199
89
3
5
0
0
2015
34
197
88
3
5
0
0
2020
34
195
87
3
5
0
0
2030
35
201
90
3
5
0
0
3.2.3 Control Inventory Development

3.2.3.1 Control Scenario(s) Modeled

       Table 0-55 shows the control case exhaust emission standards that were
modeled for recreational marine diesel engines.

       Table 0-55 Modeled Standards (g/hp-hr) for Recreational Marine Diesel Engines
HP
RANGE
0-25
9^ mn
L J 1UU
100-175
175-300
300-750
750-1200
1200-2680
>2680
TIER 3
YEAR
2009
2009
2014
2012
2013
2014
2013
2012
2012
NOx+HC
5.6
5.6
3.5
4.3
4.3
4.3
4.3
4.0
4.0
PM
0.30
0.22
0.22
0.11
0.10
0.09
0.09
0.09
0.09
TIER 4
YEAR

2016
NOX
PM
NO TIER 4
STANDARDS
1.27
0.03
3.2.3.2 Control Inventory Inputs

       Table 0-56 shows the NONROAD model emission factor inputs that were
used to generate the control case emission inventories for recreational marine diesel
engines.  These emission factors were applied to engines beginning with the model
years shown in Table 0-55.  No sulfur adjustment is applied to the Tier 3 or Tier 4
PM calculations, since these engines will be certified to a fuel sulfur level at or lower
than the episodic fuel sulfur levels expected when these engines are introduced. The
Tier 4 modeled emission factors are identical to the Tier 4 emission factors used for
Category 1 standard power density propulsion engines.  However, the NONROAD
                                         62

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                                                        Chapter 3: Inventory
model does not have a hp bin corresponding to greater than 2000 kW (2680 hp), so
the 2000-3000 hp bin was used to model the effects of the Tier 4 standard.

       All other modeling inputs are the same as shown above for the base case
inventory development. Table 0-49 and Table 0-50 list the base engine populations,
average hp by power range, annual activity, load factor, and median life.  These are
unchanged from the default inputs in the NONROAD model.
        Table 0-56 Control Emission Factors for Recreational Marine Diesel Engines
HP RANGE
0-11
11-16
16-25
OK c;n
L J JU
50-75
ye i nn
/ J 1UU
100-175
175-300
300-600
600-750
750-1200
1200-2000
>2000
DF ("A")
TIER 3 EMISSION FACTORS
G/HP-HR
PMio
0.24
0.19
0.19
0.18
0.18
0.13
0.13
0.13
0.13
0.088
0.080
0.072
0.072
0.072
0.072
0.072
0.473
NOX
4.39
3.63
3.63
3.71
2.32
3.82
2.39
3.82
2.39
3.34
3.90
3.98
3.98
3.70
3.70
3.70
0.009
HC
0.43
0.21
0.21
0.41
0.41
0.20
0.20
0.20
0.20
0.13
0.22
0.29
0.29
0.29
0.29
0.29
0.034
CO
4.11
2.16
2.16
1.53
1.53
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.95
0.101
TIER 4 EMISSION FACTORS
G/HP-HR
PMio NOX HC CO
NO TIER 4 STANDARDS
0.022 0.97 0.03 0.95
0.473 0.009 0.034 0.101
3.2.3.3 Recreational Marine Diesel Control Inventory

3.2.3.3.1 PMio, PM25, NOX, VOC, CO, andSO2 Emissions

       The control case 50-state emission inventories for recreational marine diesel
engines (inboard and outboard combined) resulting from the control case model
inputs presented above are shown in Table 0-57.
                                         63

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Draft Regulatory Impact Analysis
3.2.3.3.2 Air Toxics Emissions

       The control case air toxics inventories for recreational marine diesel engines
are provided in Table 0-58. Gaseous air toxics and POM are reduced proportionately
to VOC and PM2.5, respectively.
                                         64

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                                                         Chapter 3: Inventory
Table 0-57 Control Case (50-State) Emissions for Recreational Marine Diesel Engines
                                (short tons)
YEAR
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PMio
1,130
1,161
1,192
1,223
1,247
1,054
915
937
935
938
931
930
944
957
967
976
985
993
1,001
1,008
1,015
1,022
1,028
1,033
1,041
1,049
1,058
1,068
1,077
1,088
1,098
1,110
1,123
1,136
1,150
1,164
1,179
1,193
1,208
PM2.5
1,096
1,126
1,156
1,186
1,210
1,023
888
909
907
910
903
902
916
928
938
947
955
963
971
978
985
991
997
1,002
1,009
1,018
1,026
1,036
1,045
1,055
1,066
1,077
1,089
1,102
1,115
1,129
1,143
1,158
1,172
NOX
40,437
41,572
42,704
43,835
44,089
44,307
44,513
44,648
44,772
44,880
44,931
44,864
44,681
44,490
44,248
43,998
43,742
43,479
43,218
42,957
42,697
42,443
42,206
42,001
41,955
42,072
42,237
42,443
42,683
42,946
43,241
43,584
43,979
44,412
44,875
45,359
45,864
46,382
46,915
VOC
1,540
1,578
1,618
1,656
1,720
1,783
1,846
1,912
1,978
2,044
2,104
2,159
2,206
2,252
2,294
2,337
2,379
2,421
2,465
2,508
2,552
2,595
2,638
2,680
2,717
2,751
2,784
2,816
2,847
2,879
2,911
2,946
2,983
3,021
3,061
3,102
3,143
3,185
3,227
HC
1,462
1,499
1,536
1,573
1,633
1,693
1,753
1,816
1,878
1,941
1,998
2,051
2,095
2,139
2,179
2,219
2,259
2,300
2,341
2,382
2,423
2,465
2,505
2,545
2,581
2,613
2,644
2,674
2,704
2,734
2,765
2,797
2,832
2,869
2,907
2,946
2,985
3,025
3,064
CO
6,467
6,642
6,816
6,989
7,161
7,331
7,499
7,665
7,829
7,991
8,150
8,308
8,464
8,618
8,771
8,922
9,073
9,223
9,374
9,525
9,675
9,825
9,975
10,124
10,279
10,439
10,601
10,765
10,930
11,095
11,262
11,429
11,596
11,765
11,933
12,102
12,272
12,442
12,613
S02
5,145
5,290
5,436
5,582
5,621
2,967
993
1,017
764
578
311
113
136
150
153
156
156
159
162
165
168
171
174
177
180
183
186
189
193
196
199
202
205
208
211
214
217
220
223
                                        65

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Draft Regulatory Impact Analysis
     Table 0-58 Control Case Air Toxic Emissions for Recreational Marine Diesel Engines
                                  (short tons)
HAP
BENZENE
FORMALDEHYDE
ACETALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
2010
34
198
89
3
5
0
0
2015
33
192
86
3
5
0
0
2020
31
181
81
3
5
0
0
2030
30
174
78
3
4
0
0
3.2.4 Projected Recreational Marine Emission Reductions of Proposal

       The PM2.5, NOX, and VOC emission reductions by calendar year are shown in
Table 0-59. The air toxic emission reductions by pollutant and calendar year are
given in Table 0-60.
                                        66

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                                                    Chapter 3: Inventory
Table 0-59 Projected Recreational Marine Emission Reductions (short tons)
YEAR
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PM2.5
0
0
0
1
3
5
8
12
16
21
25
30
35
41
46
52
58
63
70
76
82
88
95
101
107
112
116
120
124
127
130
133
136
NOX
0
0
0
0
47
200
458
718
1,022
1,328
1,637
1,947
2,260
2,574
2,889
3,206
3,524
3,842
4,160
4,477
4,793
5,108
5,419
5,725
6,016
6,277
6,498
6,693
6,873
7,039
7,199
7,353
7,502
VOC
0
1
1
2
8
20
40
61
86
111
137
163
188
215
241
267
294
320
347
373
400
426
452
477
501
523
541
558
573
587
600
613
626
                                   67

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Draft Regulatory Impact Analysis
Table 0-60 Projected Air Toxic Reductions from Recreational Marine Diesel Engines (short tons)
HAP
BENZENE
FORMALDEHYDE
ACETALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
2010
0
0
0
0
0
0
0
2015
1
5
2
0
0
0
0
2020
2
14
6
0
0
0
0
2030
5
28
12
0
1
0
0
3.3 Locomotives

3.3.1 General Methodology

       Given the quality of the data available, it was possible to develop more
detailed estimates of fleet composition and emission rates. Locomotive emissions
were calculated based on estimated current and projected fuel consumption rates.
Emissions were calculated separately for the following locomotive categories:

•  Large Railroad Line-Haul Locomotives

•  Large Railroad Switching (including Class II/III Switch railroads owned by Class
   I railroads)

•  Other Line-Haul Locomotives (i.e., local and regional railroads)

•  Other Switch/Terminal Locomotives

•  Passenger/Commuter Locomotives

       We used the following approach for all categories, except for the small
railroads (see 3.3.2.3).  For each calendar year, locomotives are tracked separately by
model year and then the activity is summed (in terms of work, fuel, and emissions)
for all model years in the fleet. Seven basic steps were used to determine emissions
in any calendar year:

1. Start with the fleet from the previous calendar year.

2. Determine which model years would be due to be remanufactured or scrapped.

3.  Update the fleet to remove locomotives that would be scrapped.

4. Determine the amount of work that would be done by the remaining locomotives
   from the previous year's fleet.
                                         68

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                                                         Chapter 3: Inventory
5. Determine the number of freshly manufactured locomotives that would be
   purchased, and add them to the fleet.

6. Determine the total amount of work that would be done by all the locomotives in
   the fleet.

7. Determine total emissions from the work and brake-specific emission factors.

3.3.1.1 Base Fleet

       As is described later, the base fleet was estimated for 2005 from a variety of
industry sources.  A new base fleet is calculated for each subsequent calendar year
based on the scrappage rates and sales. The base fleet is a sum of multiple model
years that are described by the number of locomotives in the fleet, the average work
that has been accumulated since the last rebuild  (in megawatt-hours or MW-hr), the
average horsepower, and the Tier of standards to which they are certified.

3.3.1.2 Useful Life

       In this analysis, all locomotives are assumed to be either remanufactured  or
scrapped when they reach or exceed their useful life. The useful life in MW-hrs  is set
equal to the rated horsepower of the locomotive  multiplied by 7.5. Thus a 4000
horsepower locomotive would have a useful life of 30,000 MW-hrs. Annual
accumulation of MW-hrs is projected based on the assumed rated hp of the
locomotive and the relative use rate (which is a function of locomotive age). At the
end of this second step, the projected fleet is adjusted to reflect a year's worth of use
beyond the previous base fleet.

3.3.1.3 Scrappage

       For each future calendar year, there will generally be some locomotive model
years that will be projected to have reached the end of their current useful life. For
example, we estimate that there will be 243 line-haul freight locomotives in use in
2010 that:

•  Were originally manufactured in model year 1986.

•  Will be accumulating about 2000 MW-hrs per year.

•  Will reach the end of their useful lives during 2011.

       According to our scrappage curve, we estimate that 15 of these locomotives
will be scrapped in 2011.  The remaining 228 are projected to be remanufactured.
We perform  this analysis for each model year, then update that fleet to remove
locomotives  that would be scrapped and change  the emission levels for locomotives
that are remanufactured to new standards.
                                         69

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Draft Regulatory Impact Analysis
3.3.1.4 Work Done by Old Fleet

       Once the existing fleet is adjusted for each new calendar year, we determine
the amount of work that would be done by the remaining locomotives from the
previous year's fleet.  First we calculate the amount of work done by each model
year's fleet as follows:

                      Equation 7    W| = H*LF*Ni*Pi*RUFi

       Wi = Combined annual work output for all locomotives remaining in the fleet
       that were originally manufactured in model year i.

       H = Number of hours per year that a newly manufactured locomotive is
       projected to be used (approximately 4000 to 5000 hrs/yr).

       L = Typical average load factor.

       Ni = Number of locomotives remaining in the fleet that were originally
       manufactured in model year i.

       PI = Average rated power of locomotives remaining in the fleet that were
       originally manufactured in model year i.

       RUFj = Relative use factor for locomotives remaining in the fleet that were
       originally manufactured in model year i.

       The total work done by the remaining fleet  (Wr)  is calculated by summing the
work done by each model year (Wi).

3.3.1.5 New Sales

       Sales of newly manufactured locomotives are projected for each calendar year
after the remaining fleet has been analyzed.  These newly manufactured locomotives
are added to the remaining locomotives to comprise a new total fleet. The number is
calculated based on the amount of fuel that is projected to be used in that calendar
year:

                Equations New Sales = (TotalFuel/BSFC-Wr)/H/LF/P

       Where BSFC is the estimated brake specific fuel consumption rate (Gal/MW-
hr)

3.3.1.6 Total Work

       The total amount of work that would be done by all the locomotives in the
fleet is calculated for each calendar year by summing the work projected to be done
by the newly manufactured locomotives and the work projected to be done by the
remaining locomotives. The total work is calculated separately for each tier of
                                        70

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                                                          Chapter 3: Inventory
locomotives.
3.3.1.7 Emissions

       Emissions are determined from the work calculated in section 3.3.1.6
(converted to hp-hrs) and brake-specific emission factors:

             Equation 9     Total emissions = Total Work * Emission factor

       The emission factors used are the estimated average in-use emissions for each
tier of standards, which are shown in Table 0-61 and Table 0-62. They take into
account deterioration of emissions throughout the useful life, production variations,
and the compliance margins that manufacturers incorporate into their designs.  For
this analysis, we are generally assuming that average in-use emission levels will be 10
percent below the applicable standards.

                Table 0-61 Baseline Line-Haul Emission Factors (g/bhp-hr)

UNCONTROLLED
TIERO
TIER1
TIER2
PMio
0.32
0.32
0.32
0.18
HC
0.48
0.48
0.47
0.26
NOX
13.0
8.60
6.70
4.95
CO
1.28
1.28
1.28
1.28
                 Table 0-62 Baseline Switch Emission Factors (g/bhp-hr)

UNCONTROLLED
TIERO
TIER1
TIER 2
PMio
0.44
0.44
0.43
0.19
HC
1.01
1.01
1.01
0.51
NOX
17.4
12.6
9.9
7.3
CO
1.83
1.83
1.83
1.83
       These PMio emission factors reflect the emission rates expected from
locomotives operating on current in-use fuel with sulfur levels at 3000 ppm. The
emission inventories described in this chapter, however, account for the reductions in
sulfate particulate expected to result from using lower sulfur fuels after 2007. We
estimate that the PMio emission rate for locomotives operating on nominally 500 ppm
sulfur fuel will be 0.029 g/bhp-hr lower than the PMio emission rate for locomotives
operating on 3000 ppm sulfur fuel. Similarly we estimate that the PMio emission rate
for locomotives operating on nominally 15 ppm sulfur fuel will  be 0.033 g/bhp-hr
lower than the PMio emission rate for locomotives operating on 3000 ppm sulfur fuel.
                                          71

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Draft Regulatory Impact Analysis
       To estimate VOC emissions, an adjustment factor of 1.053 is applied to the
HC output. Similarly, to estimate PM2.s emissions, an adjustment factor of 0.97 is
applied to the PMio output. These adjustment factors are the same as those used for
marine engines.

3.3.2 Baseline (Pre-Control) Inventory Development

       In developing the baseline inventory, we collected fuel consumption estimates
from the regulated industries, including publicly available estimates for Class I and
commuter railroads. We used the same estimated average in-use emission factors and
load factors as we used in the previous rulemaking.

       We are using a projection by the Energy Information Administration (ElA)
that locomotive fuel consumption will grow 1.6 percent annually.8  We are assuming
that this fuel growth applies equally across all categories of locomotives and is
directly proportional to engine work performed by the fleet.

              Table 0-63 Summary of Locomotive Emission Analysis Inputs

2005 FUEL
CONSUMPTION
(GAL/YR)
HOURS USED PER
YEAR WHEN NEW
YEARS AFTER
WHICH USAGE
BEGINS TO
DECLINE
HOURS PER YEAR
AT END OF LIFE
AGE AFTER WHICH
SCRAPPAGE
BEGINS
AGE AFTER WHICH
NO LOCOMOTIVES
REMAIN IN FLEET
LOAD FACTOR
(AVG HP/RATED
HP)
AVG HP/GAL
Large
Line-Haul
3.910
BILLION

4350

8



1740 @ 40
YRS
20


40


0.275

20.8
Large
Switch
310
MILLION

4450

50



3115 @ 70
YRS
50


70


0.100

15.2
Small
Line-Haul
105
MILLION

NA

NA



NA

NA


NA


0.275

18.2
Small
Switch
39
MILLION

NA

NA



NA

NA


NA


0.100

15.2
Passenger/
Commuter
142
MILLION

3900

20



2340@30YRS

20


30


0.275

20.8
3.3.2.1 Large Line-Haul

       The large line-haul category includes line-haul freight locomotives that are
fully subject to the standards being proposed. Locomotives that are owned and
operated by railroads that qualify as small businesses are addressed separately, as
described in 3.3.2.3. The large line-haul analysis is based primarily on data collected
                                         72

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                                                          Chapter 3: Inventory
for Class I railroads.  However, as described in 3.3.2.3, the total fuel includes one-
third of the estimated Class II and Class III fuel use to account for those Class II and
III railroads that do not qualify as small businesses. The estimate of current Class I
total fuel use came from the AAR Railroad Facts booklet.  This was reduced by 7
percent to reflect fuel used in switching rather than line-haul operation. The fleet
composition for all large railroads was estimated based on a contractor analysis.  The
contractor estimated that this fleet included 19,757 locomotives with more than 2500
hp. (Locomotives with 2500 hp or less were assumed to be used primarily in
switching operations.) Usage and scrappage patterns were developed to fit the fuel
use and fleet composition data. The average in-use load factor was assumed to be the
same as the load factor for a typical line-haul duty cycle test.

3.3.2.2 Large Switch

       We generally used the same approach to  calculate switch emissions as we
used to calculate line-haul emissions, but we used different inputs.  We also made one
change to the analysis of future sales. We assumed that the majority of growth in
switching activity will be achieved by using switch locomotives more rather than by
adding new switch locomotives to the fleet. More specifically, we assumed that 1.2
percent of the annual 1.6 percent growth in activity will be achieved by using the
existing switchers more, while only 0.4 percent of the growth will be achieved by
increasing the number of switchers in the fleet.

       As shown  in Table 0-63, we believe that  switch locomotives tend to last
longer in the fleet and have a lower in-use load factor than line-haul locomotives.
Thus the  average age of switch locomotives is much older then for line-haul. We also
estimate that switching operation will use approximately seven percent of total large
railroad fuel, and will grow at the same rate as line-haul operation. The switch fleet
composition for all large railroads was estimated based on the same contractor
analysis used for the line-haul fleet.  The contractor estimated that this fleet included
5206 locomotives with 2500 hp or less. This included 1645 locomotives with 2250 to
2500 hp.  While we recognize that some of these locomotives will be used in branch
serviced, for this analysis they are assumed to be used primarily in switching
operations.

3.3.2.3 Small Railroads

       We used a simplified approach for small  railroads (that is railroads that are not
required to retrofit their locomotive with new emission controls because they qualify
as "small railroads" under the regulatory definition). We assume that these small
railroads are unlike the larger railroads in the following ways:
       d Branch service includes short-haul operations that would be considered intermediate to
intercity line-haul service and switch service.
                                          73

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Draft Regulatory Impact Analysis
    •   They do not purchase newly manufactured locomotive.

    •   They use their locomotives at a constant rate.

    •   They replace their existing locomotives at a constant rate of 3 percent per
       year.

       For this analysis, we considered small railroad activity in the same two
categories as the larger railroads: line-haul and switch. For small line-haul
operations, we are projecting that railroads will scrap and replace their oldest
locomotives with 25 year-old locomotives purchased from the larger railroads. Thus
the inventory analysis has these railroads obtaining Tier 1 locomotives starting in
2026, and Tier 2 locomotives in 2030. For small switch operations, the railroads are
projected to replace their scrapped locomotives with only uncontrolled or Tier 0
locomotives purchased from the larger railroads.  This analysis runs only through
2040 and we consider it unlikely that any significant number of Tier 1 or later switch
locomotives will be available for small railroads before 2040.

       The analysis of small railroads is based on the survey information provided by
the American Shortline Railroad Association for Class II and Class III railroads.
These results had to be adjusted upward to correct for a response rate of
approximately 85 percent. We also had to adjust these estimates because not all Class
II and Class III railroads qualify as small railroads under the regulations.  We
estimate that one-third of these railroads are owned by Class I railroads or other large
businesses.  Finally, we estimated the fraction small railroad activity should be
characterized as line-haul service versus switching service. We estimate that Class II
railroads use 7 percent of their fuel in switching service  (the same as Class I
railroads), but that Class III railroads use 50 percent of their fuel in switching service.
When combined,  these factors result in our estimate that small railroads used a total
of 105 million gallons of diesel fuel in line-haul service in 2005, and 39 million
gallons of diesel fuel in switching service, as shown in Table 3-64.

 Table 0-64 Distribution of annual fuel consumption by Class II and Class III railroads (million
                                 gallons per year)


CLASS II
CLASS III
Amount of fuel used by railroads
that qualify as small railroads
LINE-HAUL
71.5
33.7
SWITCH
5.4
33.7
Fuel used by other Class II and
Class III railroads
LINE-HAUL
35.7
16.8
SWITCH
2.7
16.8
3.3.2.4 Passenger/Commuter

       We used the same approach to calculate passenger and commuter emissions as
we used to calculate large line-haul emissions, but we used different inputs. As shown
                                          74

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                                                       Chapter 3: Inventory
in the table, we believe that passenger/commuter locomotives tend to have an average
age that is slightly newer then for line-haul. We used estimates from AMTRAK and
APTA for current fuel consumption rates, and project that these will grow at the same
rate as line-haul operation.

3.3.2.5 Locomotive Baseline Inventory Summary

       The baseline locomotive inventory is shown separately for PMio, PM2.s, NOX,
VOC, HC, CO, and S02 in Table  0-65 through Table 0-71.

       The baseline air toxics inventories for locomotives were taken from the
MSAT rule and are provided in Table 0-72. Inventories are provided for calendar
years 1999, 2010, 2015, 2020, and 2030.
                                        75

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Draft Regulatory Impact Analysis
         Table 0-65 Baseline (50-State) PM10 Emissions for Locomotives (short tons)
Calendar
Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large Line-
haul
27,919
27,873
25,078
24,965
24,831
24,686
24,536
24,015
23,874
23,724
23,561
23,398
23,240
23,081
22,918
22,750
22,579
22,407
22,244
22,080
21,944
21,836
21,755
21,703
21,685
21,696
21,735
21,800
21,894
22,023
22,187
22,378
22,597
22,846
23,126
Large Switch
2,270
2,295
2,162
2,185
2,208
2,232
2,256
2,258
2,282
2,306
2,330
2,355
2,380
2,405
2,431
2,457
2,483
2,490
2,489
2,483
2,472
2,456
2,434
2,410
2,380
2,343
2,301
2,257
2,209
2,161
2,113
2,066
2,018
1,971
1,924
Small
Railroads
935
950
883
897
911
926
940
944
959
974
990
1,006
1,022
1,038
1,055
1,071
1,088
1,106
1,124
1,141
1,160
1,178
1,197
1,216
1,223
1,230
1,237
1,243
1,250
1,256
1,263
1,269
1,275
1,281
1,287
Passenger/
Commuter
1,023
1,011
901
888
874
859
845
817
802
787
771
756
741
726
711
696
681
666
651
636
624
614
607
602
598
597
598
600
603
608
613
618
623
628
633
Total
32,147
32,129
29,023
28,934
28,824
28,703
28,577
28,033
27,916
27,791
27,653
27,515
27,383
27,251
27,114
26,974
26,831
26,668
26,508
26,340
26,200
26,084
25,993
25,931
25,886
25,866
25,871
25,901
25,957
26,049
26,176
26,331
26,513
26,726
26,969
                                           76

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                                                    Chapter 3: Inventory
Table 0-66 Baseline (50-State) PM2.5 Emissions for Locomotives (short tons)
Calendar
Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large Line-
haul
27,082
27,037
24,325
24,216
24,086
23,946
23,800
23,294
23,157
23,012
22,854
22,696
22,542
22,389
22,230
22,067
21,902
21,734
21,577
21,417
21,286
21,181
21,102
21,052
21,034
21,045
21,083
21,146
21,238
21,362
21,521
21,707
21,919
22,160
22,432
Large Switch
2,202
2,226
2,097
2,120
2,142
2,165
2,188
2,190
2,213
2,237
2,260
2,284
2,309
2,333
2,358
2,383
2,409
2,415
2,415
2,408
2,398
2,382
2,361
2,338
2,308
2,273
2,232
2,190
2,143
2,096
2,050
2,004
1,958
1,912
1,866
Small
Railroads
907
922
856
870
884
898
912
916
930
945
960
975
991
1,007
1,023
1,039
1,056
1,073
1,090
1,107
1,125
1,143
1,161
1,180
1,186
1,193
1,200
1,206
1,212
1,219
1,225
1,231
1,237
1,243
1,248
Passenger/
Commuter
992
981
874
861
847
833
819
792
778
763
748
734
719
704
690
675
660
646
631
617
605
596
589
584
581
579
580
582
585
590
595
600
604
609
614
Total
31,183
31,166
28,153
28,066
27,959
27,842
27,720
27,192
27,079
26,957
26,823
26,690
26,561
26,433
26,301
26,165
26,026
25,868
25,713
25,550
25,414
25,301
25,213
25,153
25,109
25,090
25,094
25,124
25,178
25,267
25,391
25,541
25,718
25,925
26,160
                                   77

-------
Draft Regulatory Impact Analysis
          Table 0-67 Baseline (50-State) NOX Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large Line-
haul
779,842
770,409
761,768
755,490
745,431
735,641
730,031
726,116
722,365
718,800
714,893
711,364
708,525
706,475
704,353
702,449
700,505
698,881
697,737
696,922
696,845
697,488
698,814
700,893
703,847
707,554
711,989
717,100
722,959
729,705
737,374
745,744
754,836
764,711
775,388
Large Switch
86,861
87,803
87,623
88,573
88,625
89,586
88,909
89,872
89,090
90,055
89,682
90,653
90,875
91,859
89,367
90,332
89,231
89,395
87,896
85,521
85,305
84,961
84,538
84,058
83,458
82,732
81,917
81,067
80,141
79,228
78,332
77,455
76,596
75,766
74,931
Small
Railroads
37,690
38,293
38,906
39,528
40,161
40,803
41,456
42,119
42,793
43,168
43,544
43,921
44,299
44,609
44,917
45,224
45,529
45,832
46,134
46,433
46,730
46,863
46,989
47,107
47,062
47,002
46,929
46,842
46,739
46,622
46,488
46,339
46,172
45,989
45,788
Passenger/
Commuter
38,466
36,409
34,361
32,338
30,370
28,459
27,212
26,017
24,872
24,382
23,325
22,922
22,559
22,197
21,836
21,477
21,119
20,797
20,510
20,256
20,066
19,935
19,860
19,836
19,859
19,926
20,033
20,160
20,305
20,468
20,631
20,797
20,963
21,131
21,300
Total
942,858
932,914
922,658
915,929
904,587
894,490
887,608
884,125
879,121
876,405
871,445
868,860
866,258
865,139
860,474
859,481
856,383
854,905
852,277
849,133
848,946
849,248
850,202
851,894
854,226
857,214
860,868
865,168
870,144
876,023
882,826
890,334
898,567
907,596
917,407
                                           78

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                                                    Chapter 3: Inventory
Table 0-68 Baseline (50-State) VOC Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large Line-
haul
43,874
43,762
43,636
43,486
43,301
43,100
42,891
42,700
42,518
42,323
42,107
41,892
41,684
41,478
41,265
41,044
40,820
40,596
40,391
40,185
40,027
39,916
39,850
39,833
39,873
39,961
40,098
40,278
40,507
40,793
41,139
41,531
41,969
42,459
43,000
Large Switch
5,501
5,566
5,630
5,696
5,763
5,830
5,898
5,967
6,037
6,108
6,179
6,252
6,325
6,399
6,475
6,551
6,628
6,664
6,686
6,696
6,697
6,685
6,665
6,639
6,600
6,547
6,485
6,419
6,345
6,271
6,197
6,125
6,053
5,983
5,912
Small
Railroads
2,891
2,937
2,984
3,032
3,080
3,129
3,179
3,230
3,282
3,335
3,388
3,442
3,497
3,553
3,610
3,668
3,726
3,786
3,847
3,908
3,971
4,034
4,099
4,164
4,231
4,299
4,367
4,437
4,508
4,580
4,654
4,728
4,804
4,881
4,959
Passenger/
Commuter
1,609
1,589
1,568
1,546
1,523
1,500
1,476
1,453
1,429
1,404
1,380
1,356
1,332
1,307
1,283
1,259
1,235
1,212
1,188
1,165
1,146
1,132
1,121
1,114
1,110
1,109
1,111
1,116
1,123
1,132
1,141
1,150
1,159
1,169
1,178
Total
53,874
53,853
53,818
53,759
53,667
53,559
53,445
53,349
53,265
53,169
53,054
52,941
52,838
52,738
52,633
52,522
52,410
52,259
52,112
51,954
51,841
51,768
51,735
51,750
51,813
51,917
52,062
52,250
52,483
52,776
53,131
53,534
53,986
54,491
55,049
                                   79

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Draft Regulatory Impact Analysis
          Table 0-69 Baseline (50-State) HC Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large Line-
haul
41,665
41,559
41,439
41,297
41,122
40,930
40,733
40,550
40,378
40,192
39,988
39,783
39,586
39,391
39,188
38,978
38,766
38,553
38,358
38,162
38,013
37,907
37,844
37,828
37,866
37,950
38,079
38,250
38,468
38,740
39,068
39,440
39,857
40,322
40,836
Large Switch
5,225
5,285
5,347
5,409
5,473
5,537
5,601
5,667
5,733
5,800
5,868
5,937
6,007
6,077
6,149
6,221
6,294
6,329
6,350
6,359
6,360
6,349
6,330
6,305
6,268
6,218
6,159
6,096
6,025
5,955
5,885
5,817
5,748
5,682
5,614
Small
Railroads
2,745
2,789
2,834
2,879
2,925
2,972
3,019
3,068
3,117
3,167
3,217
3,269
3,321
3,374
3,428
3,483
3,539
3,595
3,653
3,711
3,771
3,831
3,892
3,955
4,018
4,082
4,148
4,214
4,281
4,350
4,419
4,490
4,562
4,635
4,709
Passenger/Co
mmuter
1,528
1,509
1,489
1,468
1,446
1,424
1,402
1,379
1,357
1,334
1,311
1,288
1,265
1,242
1,219
1,196
1,173
1,151
1,129
1,107
1,089
1,075
1,064
1,058
1,054
1,053
1,055
1,060
1,067
1,075
1,084
1,092
1,101
1,110
1,119
Total
51,163
51,143
51,109
51,053
50,965
50,863
50,755
50,664
50,584
50,493
50,384
50,277
50,179
50,084
49,984
49,879
49,772
49,628
49,489
49,339
49,232
49,162
49,131
49,145
49,205
49,304
49,441
49,621
49,841
50,120
50,457
50,839
51,269
51,749
52,278
                                           80

-------
                                                   Chapter 3: Inventory
Table 0-70 Baseline (50-State) CO Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
116,584
118,450
120,345
122,271
124,227
126,215
128,234
130,286
132,370
134,488
136,640
138,826
141,047
143,304
145,597
147,927
150,293
152,698
155,141
157,624
160,146
162,708
165,311
167,956
170,643
173,374
176,148
178,966
181,830
184,739
187,695
190,698
193,749
196,849
199,999
Large Switch
9,620
9,774
9,930
10,089
10,251
10,415
10,581
10,751
10,923
11,097
11,275
11,455
11,639
11,825
12,014
12,206
12,402
12,600
12,802
13,006
13,215
13,426
13,641
13,859
14,081
14,306
14,535
14,768
15,004
15,244
15,488
15,736
15,987
16,243
16,503
Small
Railroads
5,805
5,898
5,993
6,089
6,186
6,285
6,386
6,488
6,592
6,697
6,804
6,913
7,024
7,136
7,250
7,366
7,484
7,604
7,725
7,849
7,975
8,102
8,232
8,364
8,497
8,633
8,771
8,912
9,054
9,199
9,346
9,496
9,648
9,802
9,959
Passenger/
Commuter
4,201
4,234
4,268
4,302
4,337
4,371
4,406
4,442
4,477
4,513
4,549
4,585
4,622
4,659
4,696
4,734
4,772
4,810
4,849
4,887
4,926
4,966
5,006
5,046
5,086
5,127
5,168
5,209
5,251
5,293
5,335
5,378
5,421
5,464
5,508
Total
136,211
138,356
140,536
142,751
145,000
147,286
149,607
151,966
154,362
156,796
159,268
161,780
164,332
166,924
169,558
172,233
174,951
177,712
180,517
183,366
186,261
189,202
192,189
195,224
198,308
201,440
204,622
207,855
211,139
214,475
217,864
221,307
224,805
228,359
231,969
                                  81

-------
Draft Regulatory Impact Analysis
          Table 0-71 Baseline (50-State) SO2 Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
83,769
85,110
10,088
10,250
10,414
10,580
10,750
312
317
322
327
333
338
343
349
354
360
366
372
378
384
390
396
402
409
415
422
429
435
442
450
457
464
471
479
Large Switch
6,637
6,743
799
812
825
838
852
25
25
26
26
26
27
27
28
28
29
29
29
30
30
31
31
32
32
33
33
34
35
35
36
36
37
37
38
Small
Railroads
3,085
3,134
372
377
384
390
396
11
12
12
12
12
12
13
13
13
13
13
14
14
14
14
15
15
15
15
16
16
16
16
17
17
17
17
18
Passenger/
Commuter
3,018
3,042
358
361
364
366
369
11
11
11
11
11
11
11
11
11
11
12
12
12
12
12
12
12
12
12
12
12
13
13
13
13
13
13
13
Total
96,510
98,030
11,617
11,800
11,986
12,175
12,367
359
365
370
376
382
388
394
400
407
413
420
426
433
440
447
454
461
468
476
483
491
499
506
515
523
531
539
548
                                           82

-------
                                                         Chapter 3: Inventory
       Table 0-72 Baseline (50-State) Air Toxics Emissions for Locomotives (short tons)
HAP
BENZENE
FORMALDEHYDE
ACETALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
1999
92
1,467
640
107
104
58
35
2010
84
1,339
584
98
94
42
25
2015
82
1,318
575
96
93
40
24
2020
80
1,280
558
93
90
38
23
2030
76
1,214
530
88
86
34
20
3.3.3 Control Inventory Development

       Control inventories were developed in the same manner as the baseline
inventories.  The only change was in the emission factors.

3.3.3.1 Control Scenario Modeled

       The proposed regulations would apply in largely the same manner as the
existing program. Thus, the control scenario can be defined simply by the proposed
standards and the model years for which they would become effective. Two new sets
of emission standards are being proposed: line-haul locomotive standards and switch
locomotive standards. The line-haul standards would apply for freight and passenger
line-haul locomotives, while the switch standards would apply for freight and
passenger switch locomotives.  Note; we are not changing the emission standards for
CO.

       As in the baseline analysis, average in-use emission factors for the analysis of
the proposed standards were generally assumed to be  10 percent below the applicable
standards, to account for deterioration of emissions throughout the useful life,
production variations, and the compliance margins that manufacturers incorporate
into their designs. The exceptions to this general rule are the HC emissions for all
locomotives and the NOX emissions for Tier 4 locomotives. While we are not
proposing changes to the Tier 3 or earlier HC standards, we expect the emission
controls for PMio will generally achieve proportional  reductions in HC.  For Tier 4
NOX standards, we expect that manufacturers will need to have lower zero-hour
emission rates to account for potential deterioration and include larger compliance
margins (expressed as a percentage of the standards).

       The emission factors used to generate the control case inventories are given in
Table 0-73 and Table 0-74.
                                         83

-------
Draft Regulatory Impact Analysis
         Table 0-73 Projected Line-Haul Emission Factors with Proposed Standards
Tier
TIERO
TIER1
TIER 2
TIERS
TIER 4
Initial Model
Year
2008/20 10A
2008/2010
2013
2012
201 5/20 17B
NOX
(g/bhp-hr)
8.60
6.70
4.95
4.95
1.00
PM10
(g/bhp-hr)
0.20
0.20
0.09
0.09
0.027
HC
(g/bhp-hr)
0.30
0.29
0.13
0.13
0.04
AThe new Tier 0 standard would apply in 2008 where kits are available, and for all locomotives in 2010.
This is modeled as a 40/80/100 phase-in.
BThe Tier 4 NOx standard would not apply until 2017, while the other standards would apply starting in
2015. The Tier 4 NOx standard would apply, however, at remanufacture for model year 2015 and 2016
locomotives.
          Table 0-74 Projected Switch Emission Factors with Proposed Standards
Tier
TIERO
TIER1
TIER2
TIER3
TIER4
Initial Model
Year
2008
2008
2013
2012
2015
NOX
(g/bhp-hr)
12.60
9.90
7.30
5.40
1.00
PMio
(g/bhp-hr)
0.25
0.25
0.09
0.09
0.02
HC
(g/bhp-hr)
0.57
0.57
0.26
0.26
0.08
3.3.3.2 Locomotive Control Inventory Summary

       The control locomotive inventory is shown separately for PMio, PM2.5, NOX,
VOC, and HC in Table 0-75 through Table 0-79. See section 3.3.2.5 for CO and S02
inventories which are not projected to change as a result of the proposed standards.

       The control air toxic inventories for locomotives are provided in Table 0-80.
The gas phase air toxics are assumed to be controlled proportionately to VOC, while
POM is controlled proportionately to PM.
                                         84

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                                                Chapter 3: Inventory
Table 0-75 Control Case PM10 Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
27,919
27,873
24,919
24,393
23,777
22,544
21,311
20,030
19,279
18,377
17,108
15,849
14,965
14,113
13,567
13,014
12,427
11,831
11,246
10,656
10,098
9,561
9,045
8,553
8,092
7,656
7,243
6,851
6,501
6,181
5,905
5,661
5,451
5,277
5,140
Large Switch
2,270
2,295
2,111
2,134
2,109
2,128
2,068
2,069
2,015
2,029
1,968
1,981
1,954
1,968
1,851
1,862
1,793
1,774
1,687
1,557
1,518
1,473
1,425
1,374
1,321
1,263
1,200
1,136
1,069
1,001
934
866
799
733
665
Small
Railroads
935
950
883
897
911
926
940
944
959
974
990
1,006
1,022
1,038
1,055
1,071
1,088
1,106
1,124
1,141
1,160
1,178
1,197
1,216
1,223
1,230
1,237
1,243
1,250
1,256
1,263
1,269
1,275
1,281
1,287
Passenger/
Commuter
1,023
1,011
901
888
848
809
761
707
663
623
574
527
480
435
402
379
355
332
309
286
265
247
230
215
201
189
178
168
158
150
143
136
131
127
124
Total
32,147
32,129
28,814
28,311
27,645
26,407
25,081
23,750
22,916
22,003
20,639
19,363
18,422
17,554
16,874
16,326
15,664
15,043
14,366
13,641
13,041
12,459
11,896
11,358
10,837
10,337
9,858
9,398
8,978
8,589
8,244
7,933
7,656
7,417
7,216
                               85

-------
Draft Regulatory Impact Analysis
           Table 0-76 Control Case PM2.5 Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
27,082
27,037
24,171
23,661
23,063
21,868
20,672
19,429
18,701
17,826
16,594
15,373
14,516
13,690
13,160
12,623
12,054
11,476
10,909
10,336
9,795
9,274
8,773
8,297
7,849
7,426
7,026
6,645
6,306
5,996
5,728
5,491
5,287
5,118
4,985
Large Switch
2,202
2,226
2,048
2,070
2,046
2,064
2,006
2,007
1,954
1,968
1,909
1,922
1,896
1,909
1,795
1,806
1,740
1,721
1,637
1,511
1,473
1,429
1,382
1,332
1,281
1,225
1,164
1,102
1,037
971
906
840
775
711
645
Small
Railroads
907
922
856
870
884
898
912
916
930
945
960
975
991
1,007
1,023
1,039
1,056
1,073
1,090
1,107
1,125
1,143
1,161
1,180
1,186
1,193
1,200
1,206
1,212
1,219
1,225
1,231
1,237
1,243
1,248
Passenger/
Commuter
992
981
874
861
823
785
738
686
643
604
557
511
466
422
390
367
345
322
300
277
257
239
223
208
195
183
172
163
154
145
138
132
127
123
120
Total
31,183
31,166
27,950
27,462
26,816
25,614
24,329
23,037
22,228
21,343
20,020
18,782
17,869
17,027
16,368
15,836
15,194
14,592
13,935
13,232
12,650
12,085
11,539
11,017
10,512
10,027
9,562
9,116
8,709
8,331
7,997
7,695
7,426
7,195
6,999
                                           86

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                                                Chapter 3: Inventory
Table 0-77 Control Case NOX Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
779,842
770,409
757,789
751,364
731,807
705,203
692,606
679,298
673,879
670,297
658,944
628,992
608,010
588,239
569,144
549,859
529,725
490,882
451,535
431,091
411,268
391,811
372,842
354,485
336,949
320,021
303,667
287,812
272,853
258,735
246,204
234,905
224,870
216,190
208,892
Large Switch
86,861
87,803
87,056
87,999
87,513
88,324
86,614
87,409
85,623
86,221
84,610
85,186
84,612
85,177
80,769
81,278
78,845
78,025
74,751
70,098
68,538
66,724
64,743
62,635
60,285
57,681
54,892
52,013
48,969
45,924
42,882
39,846
36,814
33,806
30,761
Small
Railroads
37,690
38,293
38,906
39,528
40,161
40,803
41,456
42,119
42,793
43,168
43,544
43,921
44,299
44,609
44,917
45,224
45,529
45,832
46,134
46,433
46,730
46,863
46,989
47,107
47,062
47,002
46,929
46,842
46,739
46,622
46,488
46,339
46,172
45,989
45,788
Passenger/
Commuter
38,466
36,409
34,361
32,338
29,845
27,408
25,933
24,545
23,239
22,879
21,717
20,575
19,496
18,438
17,662
16,903
16,144
14,732
13,316
12,558
11,833
11,182
10,555
9,948
9,355
8,775
8,204
7,641
7,082
6,527
6,048
5,623
5,270
4,986
4,765
Total
942,858
932,914
918,111
911,229
889,326
861,738
846,609
833,372
825,533
822,565
808,815
778,674
756,417
736,463
712,492
693,264
670,243
629,471
585,735
560,179
538,369
516,581
495,130
474,175
453,651
433,480
413,692
394,307
375,643
357,807
341,622
326,713
313,127
300,970
290,205
                               87

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Draft Regulatory Impact Analysis
           Table 0-78 Control Case VOC Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
43,874
43,762
42,998
42,008
40,825
38,373
35,890
33,597
31,991
30,268
27,758
25,275
23,607
22,010
21,142
20,266
19,340
18,402
17,483
16,556
15,681
14,839
14,031
13,263
12,543
11,863
11,220
10,611
10,068
9,573
9,147
8,771
8,448
8,182
7,974
Large Switch
5,501
5,566
5,488
5,552
5,483
5,534
5,364
5,413
5,253
5,291
5,112
5,147
5,066
5,100
4,760
4,790
4,588
4,538
4,291
3,916
3,810
3,692
3,565
3,432
3,302
3,160
3,009
2,853
2,689
2,525
2,362
2,199
2,037
1,876
1,714
Small
Railroads
2,891
2,937
2,984
3,032
3,080
3,129
3,179
3,230
3,282
3,335
3,388
3,442
3,497
3,553
3,610
3,668
3,726
3,786
3,847
3,908
3,971
4,034
4,099
4,164
4,231
4,299
4,367
4,437
4,508
4,580
4,654
4,728
4,804
4,881
4,959
Passenger/
Commuter
1,609
1,589
1,568
1,546
1,470
1,395
1,301
1,210
1,122
1,045
952
861
771
683
623
586
549
512
476
439
406
377
351
328
307
288
270
255
241
228
217
207
199
193
188
Total
53,874
53,853
53,037
52,137
50,858
48,431
45,734
43,451
41,648
39,939
37,210
34,725
32,941
31,346
30,135
29,310
28,204
27,238
26,096
24,819
23,869
22,943
22,047
21,187
20,383
19,609
18,866
18,156
17,506
16,907
16,379
15,906
15,488
15,132
14,835

-------
                                                Chapter 3: Inventory
Table 0-79 Control Case HC Emissions for Locomotives (short tons)
Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
41,665
41,559
40,834
39,894
38,770
36,441
34,083
31,906
30,381
28,745
26,361
24,003
22,419
20,902
20,078
19,246
18,367
17,476
16,603
15,722
14,892
14,092
13,325
12,595
11,912
11,266
10,655
10,077
9,561
9,092
8,687
8,330
8,023
7,770
7,573
Large Switch
5,225
5,285
5,211
5,272
5,207
5,255
5,094
5,141
4,989
5,025
4,854
4,888
4,811
4,844
4,521
4,549
4,357
4,310
4,075
3,719
3,619
3,506
3,386
3,259
3,136
3,001
2,857
2,709
2,554
2,398
2,243
2,089
1,934
1,782
1,627
Small
Railroads
2,745
2,789
2,834
2,879
2,925
2,972
3,019
3,068
3,117
3,167
3,217
3,269
3,321
3,374
3,428
3,483
3,539
3,595
3,653
3,711
3,771
3,831
3,892
3,955
4,018
4,082
4,148
4,214
4,281
4,350
4,419
4,490
4,562
4,635
4,709
Passenger/
Commuter
1,528
1,509
1,489
1,468
1,396
1,325
1,236
1,149
1,065
993
904
817
732
648
591
556
521
487
452
417
386
358
334
311
291
273
257
242
229
216
206
197
189
183
178
Total
51,163
51,143
50,368
49,513
48,298
45,993
43,432
41,264
39,552
37,929
35,337
32,977
31,283
29,769
28,618
27,835
26,784
25,867
24,783
23,570
22,667
21,788
20,937
20,121
19,357
18,622
17,917
17,242
16,625
16,056
15,555
15,105
14,709
14,370
14,088
                               89

-------
Draft Regulatory Impact Analysis
         Table 0-80 Control Case Air Toxic Emissions for Locomotives (short tons)
HAP
BENZENE
FORMALDEHYDE
ACETALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
2010
79
1,269
554
92
90
40
24
2015
62
990
432
72
70
30
19
2020
46
733
320
53
52
22
14
2030
30
478
208
35
34
13
9
3.3.4 Projected Locomotive Emission Reductions from the Proposed Rule

       The projected emission reductions for PM 2.5, NOX and VOC for each category
and calendar year are given in Table 0-81, Table 0-82, and Table 0-83. Table 0-84
presents the air toxic emission reductions.
                                        90

-------
                                                  Chapter 3: Inventory
Table 0-81 Projected Locomotive PM2.5 Emission Reductions (short tons)
Calendar Year
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
154
555
1,023
2,078
3,128
3,865
4,457
5,186
6,260
7,323
8,026
8,699
9,070
9,444
9,848
10,258
10,668
11,081
11,490
11,907
12,329
12,755
13,185
13,619
14,057
14,501
14,932
15,366
15,794
16,215
16,632
17,042
17,447
Large Switch
49
50
96
101
182
183
259
269
352
363
413
425
563
577
669
694
778
898
926
953
979
1,006
1,027
1,048
1,068
1,087
1,106
1,125
1,144
1,163
1,182
1,201
1,220
Small
Railroads
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Passenger/
Commuter
0
0
24
49
81
107
135
159
191
222
253
283
300
308
316
324
332
339
348
356
365
375
385
396
407
419
432
445
457
467
477
486
494
Total
203
604
1,144
2,227
3,391
4,155
4,850
5,614
6,803
7,908
8,692
9,406
9,933
10,329
10,832
11,276
11,777
12,318
12,764
13,216
13,674
14,136
14,597
15,063
15,532
16,007
16,470
16,936
17,394
17,846
18,291
18,730
19,161
                                 91

-------
Draft Regulatory Impact Analysis
           Table 0-82 Projected Locomotive NOX Emission Reductions (short tons)
Calendar Year
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
3,978
4,126
13,624
30,439
37,425
46,819
48,487
48,503
55,949
82,372
100,515
118,236
135,209
152,589
170,780
207,999
246,202
265,831
285,577
305,677
325,972
346,408
366,898
387,533
408,322
429,288
450,106
470,970
491,170
510,838
529,966
548,521
566,497
Large Switch
568
575
1,111
1,261
2,295
2,463
3,468
3,834
5,072
5,467
6,263
6,681
8,598
9,054
10,386
11,370
13,144
15,424
16,767
18,237
19,795
21,423
23,173
25,050
27,025
29,054
31,171
33,304
35,451
37,609
39,782
41,960
44,171
Small
Railroads
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Passenger/
Commuter
0
0
526
1,051
1,278
1,472
1,634
1,503
1,608
2,347
3,063
3,759
4,175
4,574
4,975
6,065
7,195
7,699
8,233
8,753
9,305
9,888
10,504
11,151
11,828
12,519
13,223
13,941
14,584
15,173
15,693
16,145
16,534
Total
4,546
4,700
15,261
32,751
40,999
50,753
53,588
53,840
62,630
90,186
109,841
128,676
147,982
166,217
186,141
225,434
266,541
288,954
310,577
332,667
355,071
377,719
400,575
423,735
447,175
470,861
494,501
518,215
541,204
563,621
585,440
606,626
627,202
                                           92

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                                                     Chapter 3: Inventory
  Table 0-83 Projected Locomotive VOC Emission Reductions (short tons)
Calendar Year
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Large
Line-haul
638
1,477
2,476
4,727
7,002
9,102
10,527
12,054
14,349
16,617
18,078
19,468
20,122
20,778
21,480
22,194
22,908
23,629
24,346
25,077
25,819
26,570
27,329
28,099
28,878
29,667
30,439
31,220
31,992
32,759
33,521
34,276
35,026
Large Switch
143
144
279
296
534
554
784
817
1,067
1,104
1,259
1,299
1,714
1,760
2,040
2,126
2,395
2,780
2,887
2,993
3,100
3,207
3,297
3,387
3,477
3,566
3,656
3,745
3,835
3,926
4,016
4,107
4,198
Small
Railroads
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Passenger/
Commuter
0
0
52
105
175
242
307
359
428
495
561
625
661
674
687
699
713
726
740
754
770
786
803
822
841
861
882
904
924
943
960
976
990
Total
780
1,622
2,808
5,128
7,711
9,899
11,617
13,230
15,844
18,217
19,897
21,392
22,498
23,212
24,206
25,020
26,016
27,135
27,973
28,825
29,688
30,563
31,430
32,308
33,196
34,095
34,977
35,869
36,752
37,628
38,497
39,360
40,214
Table 0-84 Projected Locomotive Air Toxic Emission Reductions (short tons)
HAP
BENZENE
FORMALDEHYDE
ACETALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
2010
4
70
31
5
5
2
1
2015
20
328
143
24
23
10
5
2020
34
547
239
40
39
16
9
2030
46
736
321
54
52
20
12
                                    93

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Draft Regulatory Impact Analysis
3.4 Projected Total Emission Reductions from the Proposed Rule

       The total base and control inventories, as well as emission reductions by
calendar year, for PM2.5, NOX, and VOC are given in Table 0-85.  The totals include
emissions from the three major categories affected by this proposed rule: commercial
marine diesel engines, recreational marine diesel engines, and locomotives. The
results for PM2.5 and NOX are also illustrated in Figure 1 and Figure 2. Reductions by
pollutant and category are also provided in Table 0-86 thru Table  0-88.

       The total air toxics reductions are provided in Table 0-89.

       Calendar year 2040 was chosen as the end date for the analysis; however,
additional reductions are expected to occur beyond this date.
 Figure 1 Estimated PM2.5 Reductions from Locomotive and Marine Diesel Engine Standards
                                  (short tons)
                 2005    2010    2015    2020    2025    2030    2035    2040
                                         94

-------
                                                             Chapter 3: Inventory
Figure 2 Estimated NOx Reductions from Locomotive and Marine Diesel Engine Standards
                                    (short tons)
                   2005    2010   2015    2020    2025    2030    2035    2040
                                           95

-------
Draft Regulatory Impact Analysis
             Table 0-85 Total Emissions and Projected Reductions (short tons)
Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
PM2.5
Base
62,653
60,785
56,405
56,302
55,976
55,667
55,283
54,424
52,646
51,240
50,872
50,424
50,095
49,764
49,543
49,514
49,514
49,496
49,481
49,473
49,505
49,575
49,683
49,831
50,009
50,219
50,460
50,733
51,032
51,368
51,741
52,142
52,572
53,034
53,526
Control
62,653
60,785
56,202
55,694
54,826
53,431
51,813
49,943
47,011
44,466
42,313
40,026
38,133
36,308
34,767
33,501
32,145
30,821
29,436
28,027
26,772
25,572
24,424
23,330
22,290
21,303
20,363
19,462
18,612
17,812
17,097
16,482
15,953
15,507
15,166
Reduction
0
0
203
608
1,149
2,236
3,469
4,481
5,635
6,775
8,560
10,397
11,962
13,455
14,776
16,013
17,369
18,675
20,045
21,446
22,733
24,003
25,258
26,501
27,719
28,916
30,097
31,271
32,420
33,557
34,644
35,660
36,620
37,527
38,360
NOX
Base
1,807,216
1,784,284
1,761,171
1,741,683
1,717,796
1,695,396
1,676,501
1,661,733
1,646,170
1,633,374
1,618,865
1,608,049
1,598,602
1,591,433
1,582,106
1,577,901
1,572,450
1,569,867
1,567,335
1,564,909
1,566,090
1,568,322
1,571,677
1,576,224
1,582,353
1,589,972
1,598,625
1,608,222
1,618,723
1,630,331
1,643,034
1,656,625
1,671,116
1,686,564
1,702,935
Control
1,807,216
1,784,284
1,756,625
1,736,983
1,702,535
1,662,645
1,633,993
1,605,845
1,574,799
1,549,093
1,506,062
1,445,528
1,392,149
1,341,927
1,289,199
1,242,771
1,193,565
1,128,045
1,061,013
1,013,286
970,582
929,227
889,403
851,600
816,578
784,030
753,109
723,487
695,357
668,881
645,058
624,387
606,737
591,798
579,393
Reduction
0
0
4,546
4,700
15,261
32,751
42,508
55,888
71,371
84,281
112,803
162,520
206,453
249,506
292,907
335,130
378,885
441,821
506,322
551,623
595,508
639,095
682,274
724,624
765,775
805,941
845,516
884,735
923,366
961,451
997,976
1,032,239
1,064,379
1,094,766
1,123,542
VOC
Base
72,872
72,776
72,667
72,541
72,386
72,219
72,052
71,909
71,784
71,657
71,528
71,437
71,388
71,359
71,357
71,382
71,420
71,431
71,456
71,477
71,547
71,659
71,817
72,027
72,290
72,597
72,950
73,349
73,794
74,302
74,873
75,493
76,163
76,888
77,667
Control
72,872
72,776
71,887
70,912
69,562
67,068
64,182
61,608
59,291
57,077
53,750
50,613
48,170
45,937
44,126
42,738
41,090
39,604
37,963
36,228
34,867
33,581
32,369
31,228
30,184
29,208
28,293
27,432
26,651
25,939
25,320
24,787
24,337
23,968
23,684
Reduction
0
0
780
1,629
2,824
5,151
7,870
10,301
12,494
14,580
17,778
20,824
23,218
25,421
27,231
28,645
30,330
31,827
33,493
35,249
36,680
38,077
39,448
40,799
42,106
43,389
44,657
45,917
47,144
48,364
49,553
50,705
51,826
52,920
53,983
                                           96

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                                                Chapter 3: Inventory
Table 0-86 Projected Total PM2.5 Emission Reductions (short tons)
YEAR
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
COMMERCIAL
MARINE
0
3
6
8
76
321
776
1,149
1,740
2,469
3,245
4,019
4,808
5,644
6,491
7,347
8,210
9,064
9,899
10,711
11,503
12,277
13,027
13,752
14,458
15,151
15,834
16,500
17,126
17,686
18,198
18,664
19,063
RECREATIONAL
MARINE
0
0
0
1
3
5
8
12
16
21
25
30
35
41
46
52
58
63
70
76
82
88
95
101
107
112
116
120
124
127
130
133
136
LOCOMOTIVES
203
604
1,144
2,227
3,391
4,155
4,850
5,614
6,803
7,908
8,692
9,406
9,933
10,329
10,832
11,276
11,777
12,318
12,764
13,216
13,674
14,136
14,597
15,063
15,532
16,007
16,470
16,936
17,394
17,846
18,291
18,730
19,161
TOTAL
203
608
1,149
2,236
3,469
4,481
5,635
6,775
8,560
10,397
11,962
13,455
14,776
16,013
17,369
18,675
20,045
21,446
22,733
24,003
25,258
26,501
27,719
28,916
30,097
31,271
32,420
33,557
34,644
35,660
36,620
37,527
38,360
                               97

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Draft Regulatory Impact Analysis
             Table 0-87 Projected Total NOX Emission Reductions (short tons)
YEAR
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
COMMERCIAL
MARINE
0
0
0
0
1,463
4,935
17,326
29,723
49,151
71,006
94,975
118,882
142,666
166,339
189,855
213,181
236,257
258,828
280,771
301,951
322,410
341,797
359,780
376,481
392,324
407,598
422,367
436,542
449,899
461,578
471,739
480,787
488,838
RECREATIONAL
MARINE
0
0
0
0
47
200
458
718
1,022
1,328
1,637
1,947
2,260
2,574
2,889
3,206
3,524
3,842
4,160
4,477
4,793
5,108
5,419
5,725
6,016
6,277
6,498
6,693
6,873
7,039
7,199
7,353
7,502
LOCOMOTIVES
4,546
4,700
15,261
32,751
40,999
50,753
53,588
53,840
62,630
90,186
109,841
128,676
147,982
166,217
186,141
225,434
266,541
288,954
310,577
332,667
355,071
377,719
400,575
423,735
447,175
470,861
494,501
518,215
541,204
563,621
585,440
606,626
627,202
TOTAL
4,546
4,700
15,261
32,751
42,508
55,888
71,371
84,281
112,803
162,520
206,453
249,506
292,907
335,130
378,885
441,821
506,322
551,623
595,508
639,095
682,274
724,624
765,775
805,941
845,516
884,735
923,366
961,451
997,976
1,032,239
1,064,379
1,094,766
1,123,542
                                           98

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                                                Chapter 3: Inventory
Table 0-88 Projected Total VOC Emission Reductions (short tons)
YEAR
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
COMMERCIAL
MARINE
0
7
14
22
152
383
837
1,290
1,848
2,497
3,183
3,867
4,545
5,218
5,883
6,539
7,183
7,794
8,360
8,880
9,360
9,811
10,225
10,605
10,960
11,300
11,625
11,936
12,228
12,490
12,728
12,947
13,143
RECREATIONAL
MARINE
0
1
1
2
8
20
40
61
86
111
137
163
188
215
241
267
294
320
347
373
400
426
452
477
501
523
541
558
573
587
600
613
626
LOCOMOTIVES
780
1,622
2,808
5,128
7,711
9,899
11,617
13,230
15,844
18,217
19,897
21,392
22,498
23,212
24,206
25,020
26,016
27,135
27,973
28,825
29,688
30,563
31,430
32,308
33,196
34,095
34,977
35,869
36,752
37,628
38,497
39,360
40,214
TOTAL
780
1,629
2,824
5,151
7,870
10,301
12,494
14,580
17,778
20,824
23,218
25,421
27,231
28,645
30,330
31,827
33,493
35,249
36,680
38,077
39,448
40,799
42,106
43,389
44,657
45,917
47,144
48,364
49,553
50,705
51,826
52,920
53,983
                               99

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Draft Regulatory Impact Analysis
           Table 0-89 Projected Total Air Toxic Emission Reductions (short tons)
HAP
BENZENE
FORMALDEHYDE
ACETALDEHYDE
1,3-BUTADIENE
ACROLEIN
NAPHTHALENE
POM
2010
5
74
32
5
5
2
1
2015
66
661
308
24
30
13
6
2020
198
1,751
836
42
62
27
11
2030
422
3,494
1,691
58
105
44
17
3.5 Contribution of Marine Diesel Engines and Locomotives to
    Baseline National Emission Inventories

       This section provides the contribution of marine diesel engines and
locomotives to baseline nationwide emission inventories in 2001, 2020, and 2030.
The baseline represents current and future emissions with the existing standards.  The
calendar years correspond to those chosen for the air quality modeling.

       The pollutants included in this section are directly emitted PM 2.5, NOX, VOC,
CO, and S02. While we do not provide estimates for other pollutants here, it should
be noted that the affected engines also contribute to national ammonia (NH3) and air
toxics inventories.

3.5.1  Categories and Sources of Data

       As described more fully earlier in this chapter, our current inventories for
marine diesel engines and locomotives were developed using multiple methodologies,
but they all are based on combining engine populations, hours of use, average engine
loads, and in-use emissions factors.  Locomotive emissions were calculated based on
estimated current and projected fuel consumption rates. Emissions were calculated
separately for the following locomotive categories:  Large Railroad Line-Haul
Locomotives, Large Railroad Switching (including Class  II/III Switch railroads
owned by Class I railroads), Other Line-Haul Locomotives (i.e., Class II/III local and
regional railroads), Other Switcher/Terminal Locomotives and Passenger
Locomotives. The inventories for marine diesel engines were created separately for
Category 1 and 2 propulsion and auxiliary engines, including those less than or equal
to 37 kW, and diesel fueled recreational marine propulsion engines.

       The locomotive, commercial marine (Cl & C2), and diesel recreational
marine values given for 2001 are actually 2002 estimates, since that is the base year
that was used for air quality modeling. The stationary, aircraft, onroad diesel, and C3
commercial marine values are from the PM NAAQS 2001 air quality modeling
platform, which is more recent than, but essentially the same as CAIR (2001
platform) for these sources.  The 2030 stationary source values are set equal to 2020,
                                        100

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                                                        Chapter 3: Inventory
since no specific estimates for 2030 stationary source emissions are available. All the
stationary source values exclude "non-manmade" sources, such as fires and fugitive
dust. Onroad gasoline vehicle values are from the National Mobile Inventory Model
(NMIM) outputs for the final Mobile Source Air Toxics rulemaking, which includes
the assumed implementation of Renewable Fuels Standards (RFS) and corrections for
cold-start HC effects.  Nonroad land-based diesel values are from the latest publicly
released version of EPA's nonroad model (NONROAD2005a). Nonroad spark-
ignition (SI) values in these tables (small SI, SI recreational marine, large SI, and SI
recreational vehicles)  are also from NONROAD2005a.  The NONROAD2005 model
runs were all run at the nationwide/annual level  using single default nationwide
temperature & RVP, using the full 50-state equipment population including all
California equipment.

3.5.2 PM2.5 Contributions to Baseline

       Table 0-90 provides the contribution of locomotives and diesel-fueled
recreational and commercial marine engines to mobile source diesel and to total man-
made PM2.5 emissions. PM2.5 emissions from these sources are 18 percent of the
mobile source diesel PM2.5 emissions in 2001, and this percentage increases to about
65 percent by 2030. PM2.s emissions from the affected sources decreases from 59,000
tons in 2002 to 50,000 tons in 2020 due to the existing emission standards. From
2020 to 2025 emissions remain relatively constant as growth offsets the effect of
continued turnover of older engines to engines meeting the existing emission
standards. These emissions begin to increase again around 2025 and exceed 2015
levels by 2035.

3.5.3 NOX Contributions to Baseline

       Table 0-91 provides the contribution of locomotives and diesel-fueled
recreational and commercial marine engines to mobile source NOX and to total man-
made NOX emissions.  NOX emissions from these sources are 16 percent of the mobile
source NOX emissions in 2001,  and this percentage increases to 35 percent by 2030.
NOX emissions from affected sources decrease from  1,993,000 tons in 2002 to
1,582,000 tons in 2020 due to the existing emission standards. From 2020 to 2025
emissions remain relatively constant as growth offsets the effect of continued
turnover of older engines to engines meeting the existing emission standards.  These
emissions begin to increase again in 2025 and by 2035 exceed 2015 emission levels.

3.5.4 VOC Contributions to Baseline

       Table 0-92 provides the contribution of locomotives and diesel-fueled
recreational and commercial marine engines to mobile source VOC and to total man-
made VOC  emissions. Due to the efficient combustion in diesel engines, mobile
source VOC emissions are dominated by spark-ignition  engines, and the VOC
emissions from the affected sources are only 0.8 percent of the mobile source VOC in
2001, increasing to 1.3 percent by 2030. VOC emissions from affected sources
                                        101

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Draft Regulatory Impact Analysis
increase from 67,000 tons in 2002 to 71,000 tons in 2020 and 72,000 tons in 2030,
since the existing emission standards are not aimed at controlling VOC.

3.5.5 CO Contributions to Baseline

       Table 0-93 provides the contribution of locomotives and diesel-fueled
recreational and commercial marine engines to mobile source carbon monoxide (CO)
and to total man-made CO emissions. As with VOC, mobile source CO emissions are
dominated by spark-ignition engines, so the CO emissions from the affected sources
are only 0.3 percent of the mobile source CO in 2001, increasing to 0.5 percent by
2030. CO emissions  from affected sources increase from 281,000 tons in 2002 to
319,000 tons in 2020 and 353,000 tons in 2030, since the existing emission standards
are not aimed at controlling CO.

3.5.6 SO2 Contributions to Baseline

       Table 0-94 provides the contribution of locomotives and diesel-fueled
recreational and commercial marine engines to mobile source SOz and to total man-
made S02 emissions. S02 emissions from these sources are 21 percent of the mobile
source  S02 emissions in 2001, and this percentage decreases significantly to about
one percent in 2020 and 2030 due to existing diesel fuel sulfur standards. S02
emissions from affected sources decrease from 162,000 tons in 2002 to 3,700 tons in
2020.  From  2020 to 2030 emissions increase to 4,200 tons due to continued projected
growth in these sectors.
                                        102

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                                                                         Chapter 3: Inventory
           Table 0-90 50-State Annual PM 2.s Baseline Emission Levels for Mobile and Other Source
                                               Categories
Category
Locomotive
Recreational Marine Diesel
Commercial Marine (Cl & C2)
Land-Based Nonroad Diesel
Commercial Marine (C3)**
Small Nonroad SI
Recreational Marine SI
SI Recreational Vehicles
Large Nonroad SI (>25hp)
Aircraft
Total Off Highway
Highway Diesel
Highway non-diesel
Total Highway
Total Diesel (distillate) Mobile
Total Mobile Sources
Stationary Point and Area
Sources
Total Man-Made Sources
2001*
short tons
29,660
1,096
28,730
164,180
20,023
25,575
17,101
12,301
1,610
5,664
305,941
109,952
50,277
160,229
333,619
466,170
1,963,264
2,429,434
%of
diesel
mobile
8.9%
0.3%
8.6%
49.2%
-






33.0%


100%



%of
total
1.2%
0.0%
1.2%
6.8%
0.8%
1.1%
0.7%
0.5%
0.1%
0.2%
12.6%
4.5%
2.1%
6.6%
13.7%
19.2%
80.8%
100%
2020
short tons
26,301
1,006
22,236
46,075
36,141
31,083
6,595
11,773
2,421
7,044
190,675
15,800
47,354
63,154
111,418
253,829
1,817,722
2,071,551
%of
diesel
mobile
23.6%
0.9%
20.0%
41.4%
-






14.2%


100%



%of
total
1.3%
0.0%
1.1%
2.2%
1.7%
1.5%
0.3%
0.6%
0.1%
0.3%
9.2%
0.8%
2.3%
3.0%
5.4%
12.3%
87.7%
100%
2030
short tons
25,109
1,140
23,760
17,934
52,682
35,761
6,378
9,953
2,844
8,569
184,130
10,072
56,734
66,806
78,015
250,936
1,817,722
2,068,658
%of
diesel
mobile
32.2%
1.5%
30.5%
23.0%
-






12.9%


100%



%of
total
1.2%
0.1%
1.1%
0.9%
2.5%
1.7%
0.3%
0.5%
0.1%
0.4%
8.9%
0.5%
2.7%
3.2%
3.8%
12.1%
87.9%
100%
* The locomotive, commercial marine (Cl & C2), and diesel recreational marine estimates are for calendar year
2002.
** This category includes emissions from Category 3 (C3) propulsion engines and C2/3 auxiliary engines used
on ocean-going vessels.
                                                      103

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        Draft Regulatory Impact Analysis
            Table 0-91 50-State Annual NOX Baseline Emission Levels for Mobile and Other Source
                                               Categories
Category
Locomotive
Recreational Marine Diesel
Commercial Marine (Cl & C2)
Land-Based Nonroad Diesel
Commercial Marine (C3)**
Small Nonroad SI
Recreational Marine SI
SI Recreational Vehicles
Large Nonroad SI (>25hp)
Aircraft
Total Off Highway
Highway Diesel
Highway non-diesel
Total Highway
Total Diesel (distillate) Mobile
Total Mobile Sources
Stationary Point and Area
Sources
Total Man-Made Sources
2001*
short tons
1,118,786
40,437
834,025
1,548,236
224,100
100,319
42,252
5,488
321,098
83,764
4,318,505
3,750,886
4,354,430
8,105,316
7,292,308
12,423,821
9,355,659
21,779,480
%of
mobile
source
9.0%
0.3%
6.7%
12.5%
1.8%
0.8%
0.3%
0.0%
2.6%
0.7%
34.8%
30.2%
35.0%
65.2%
58.7%
100%
-
-
%of
total
5.1%
0.2%
3.8%
7.1%
1.0%
0.5%
0.2%
0.0%
1.5%
0.4%
19.8%
17.2%
20.0%
37.2%
33.5%
57.0%
43.0%
100%
2020
short tons
860,474
45,477
676,154
678,377
369,160
98,620
83,312
17,496
46,319
105,133
2,980,523
646,961
1,361,276
2,008,237
2,907,578
4,988,760
6,111,866
11,100,626
%of
mobile
source
17.2%
0.9%
13.6%
13.6%
7.4%
2.0%
1.7%
0.4%
0.9%
2.1%
59.7%
13.0%
27.3%
40.3%
58.3%
100%
-
-
%of
total
7.8%
0.4%
6.1%
6.1%
3.3%
0.9%
0.8%
0.2%
0.4%
0.9%
26.9%
5.8%
12.3%
18.1%
26.2%
44.9%
55.1%
100%
2030
short tons
854,226
48,102
680,025
434,466
531,641
114,287
92,188
20,136
46,253
118,740
2,940,064
260,915
1,289,780
1,550,695
2,277,735
4,490,759
6,111,866
10,602,625
%of
mobile
source
19.0%
1.1%
15.1%
9.7%
11.8%
2.5%
2.1%
0.4%
1.0%
2.6%
65.5%
5.8%
28.7%
34.5%
50.7%
100%
-
-
%of
total
8.1%
0.5%
6.4%
4.1%
5.0%
1.1%
0.9%
0.2%
0.4%
1.1%
27.7%
2.5%
12.2%
14.6%
21.5%
42.4%
57.6%
100%
* The locomotive, commercial marine (Cl & C2), and diesel recreational marine estimates are for calendar year
2002.
** This category includes emissions from Category 3 (C3) propulsion engines and C2/3 auxiliary engines used
on ocean-going vessels.
                                                      104

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                                                                         Chapter 3: Inventory
            Table 0-92 50-State Annual VOC Baseline Emission Levels for Mobile and Other Source
                                               Categories
Category
Locomotive
Recreational Marine Diesel
Commercial Marine (Cl & C2)
Land-Based Nonroad Diesel
Commercial Marine (C3)**
Small Nonroad SI
Recreational Marine SI
SI Recreational Vehicles
Large Nonroad SI (>25hp)
Portable Fuel Containers
Aircraft
Total Off Highway
Highway Diesel
Highway non-diesel
Total Highway
Total Diesel (distillate) Mobile
Total Mobile Sources
Stationary Point and Area
Sources
Total Man-Made Sources
2001*
short tons
50,665
1,540
17,229
188,884
9,572
1,314,015
1,212,446
512,059
132,888
244,545
22,084
3,705,926
223,519
4,316,615
4,540,134
479,285
8,246,060
9,692,344
17,938,404
%of
mobile
source
0.6%
0.0%
0.2%
2.3%
0.1%
15.9%
14.7%
6.2%
1.6%
3.0%
0.3%
44.9%
2.7%
52.3%
55.1%
5.8%
100%
-
-
%of
total
0.3%
0.0%
0.1%
1.1%
0.1%
7.3%
6.8%
2.9%
0.7%
1.4%
0.1%
20.7%
1.2%
24.1%
25.3%
2.7%
46.0%
54.0%
100%
2020
short tons
52,633
2,653
16,071
76,047
18,458
999,810
688,774
454,979
12,429
254,479
27,644
2,603,977
123,449
2,646,363
2,769,812
270,844
5,373,789
8,475,443
13,849,232
%of
mobile
source
1.0%
0.0%
0.3%
1.4%
0.3%
18.6%
12.8%
8.5%
0.2%
4.7%
0.5%
48.5%
2.3%
49.2%
51.5%
5.0%
100%
-
-
%of
total
0.4%
0.0%
0.1%
0.5%
0.1%
7.2%
5.0%
3.3%
0.1%
1.8%
0.2%
18.8%
0.9%
19.1%
20.0%
2.0%
38.8%
61.2%
100%
2030
short tons
51,813
3,299
17,178
63,144
27,582
1,156,408
697,712
391,541
10,276
288,630
30,331
2,737,914
138,758
2,987,562
3,126,320
274,189
5,864,234
8,475,443
14,339,677
%of
mobile
source
0.9%
0.1%
0.3%
1.1%
0.5%
19.7%
11.9%
6.7%
0.2%
4.9%
0.5%
46.7%
2.4%
50.9%
53.3%
4.7%
100%
-
-
%of
total
0.4%
0.0%
0.1%
0.4%
0.2%
8.1%
4.9%
2.7%
0.1%
2.0%
0.2%
19.1%
1.0%
20.8%
21.8%
1.9%
40.9%
59.1%
100%
* The locomotive, commercial marine (Cl & C2), and diesel recreational marine estimates are for calendar year
2002.
** This category includes emissions from Category 3 (C3) propulsion engines and C2/3 auxiliary engines used
on ocean-going vessels.
                                                      105

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        Draft Regulatory Impact Analysis
            Table 0-93 50-State Annual CO Baseline Emission Levels for Mobile and Other Source
                                               Categories
Category
Locomotive
Recreational Marine Diesel
Commercial Marine (Cl & C2)
Land-Based Nonroad Diesel
Commercial Marine (C3)**
Small Nonroad SI
Recreational Marine SI
SI Recreational Vehicles
Large Nonroad SI (>25hp)
Aircraft
Total Off Highway
Highway Diesel
Highway non-diesel
Total Highway
Total Diesel (distillate) Mobile
Total Mobile Sources
Stationary Point and Area
Sources
Total Man-Made Sources
2001*
short tons
123,210
6,467
151,331
893,320
19,391
18,843,914
2,816,005
1,229,707
1,801,679
263,232
26,148,256
1,098,213
60,985,008
62,083,221
2,272,530
88,231,477
9,014,249
97,245,726
%of
mobile
source
0.1%
0.0%
0.2%
1.0%
0.0%
21.4%
3.2%
1.4%
2.0%
0.3%
29.6%
1.2%
69.1%
70.4%
2.6%
100%
-
-
%of
total
0.1%
0.0%
0.2%
0.9%
0.0%
19.4%
2.9%
1.3%
1.9%
0.3%
26.9%
1.1%
62.7%
63.8%
2.3%
90.7%
9.3%
100%
2020
short tons
169,558
9,374
139,712
310,258
37,459
27,269,797
2,136,234
1,922,020
304,532
327,720
32,626,663
248,689
32,503,404
32,752,093
877,583
65,378,756
8,641,678
74,020,434
%of
mobile
source
0.3%
0.0%
0.2%
0.5%
0.1%
41.7%
3.3%
2.9%
0.5%
0.5%
49.9%
0.4%
49.7%
50.1%
1.3%
100%
-
-
%of
total
0.2%
0.0%
0.2%
0.4%
0.1%
36.8%
2.9%
2.6%
0.4%
0.4%
44.1%
0.3%
43.9%
44.2%
1.2%
88.3%
11.7%
100%
2030
short tons
198,308
10,930
143,791
155,625
56,713
31,623,016
2,178,413
1,902,925
281,993
358,012
36,909,725
149,784
37,399,211
37,548,995
658,428
74,458,720
8,641,678
83,100,398
%of
mobile
source
0.3%
0.0%
0.2%
0.2%
0.1%
42.5%
2.9%
2.6%
0.4%
0.5%
49.6%
0.2%
50.2%
50.4%
0.9%
100%
-
-
%of
total
0.2%
0.0%
0.2%
0.2%
0.1%
38.1%
2.6%
2.3%
0.3%
0.4%
44.4%
0.2%
45.0%
45.2%
0.8%
89.6%
10.4%
100%
* The locomotive, commercial marine (Cl & C2), and diesel recreational marine estimates are for calendar year
2002.
** This category includes emissions from Category 3 (C3) propulsion engines and C2/3 auxiliary engines used
on ocean-going vessels.
                                                      106

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                                                                         Chapter 3: Inventory
             Table 0-94 50-State Annual SO2 Baseline Emission Levels for Mobile and Other Source
                                               Categories
Category
Locomotive
Recreational Marine Diesel
Commercial Marine (Cl & C2)
Land-Based Nonroad Diesel
Commercial Marine (C3)**
Small Nonroad SI
Recreational Marine SI
SI Recreational Vehicles
Large Nonroad SI (>25hp)
Aircraft
Total Off Highway
Highway Diesel
Highway non-diesel
Total Highway
Total Diesel (distillate) Mobile
Total Mobile Sources
Stationary Point and Area
Sources
Total Man-Made Sources
2001*
short tons
76,727
5,145
80,353
167,615
166,739
6,723
2,755
1,241
925
7,890
516,113
103,632
169,125
272,757
433,465
788,870
15,057,420
15,846,290
%of
mobile
source
9.7%
0.7%
10.2%
21.2%
21.1%
0.9%
0.3%
0.2%
0.1%
1.0%
65.4%
13.1%
21.4%
34.6%
54.9%
100%
-
-
%of
total
0.5%
0.0%
0.5%
1.1%
1.1%
0.0%
0.0%
0.0%
0.0%
0.0%
3.3%
0.7%
1.1%
1.7%
2.7%
5.0%
95.0%
100%
2020
short tons
400
162
3,104
999
272,535
8,620
2,980
2,643
905
9,907
302,255
3,443
35,195
38,638
8,108
340,893
8,215,016
8,555,909
%of
mobile
source
0.1%
0.0%
0.9%
0.3%
79.9%
2.5%
0.9%
0.8%
0.3%
2.9%
88.7%
1.0%
10.3%
11.3%
2.4%
100%
-
-
%of
total
0.0%
0.0%
0.0%
0.0%
3.2%
0.1%
0.0%
0.0%
0.0%
0.1%
3.5%
0.0%
0.4%
0.5%
0.1%
4.0%
96.0%
100%
2030
short tons
468
192
3,586
1,078
400,329
9,990
3,160
2,784
1,020
11,137
433,745
4,453
42,709
47,162
9,777
480,907
8,215,016
8,695,923
%of
mobile
source
0.1%
0.0%
0.7%
0.2%
83.2%
2.1%
0.7%
0.6%
0.2%
2.3%
90.2%
0.9%
8.9%
9.8%
2.0%
100%
-
-
%of
total
0.0%
0.0%
0.0%
0.0%
4.6%
0.1%
0.0%
0.0%
0.0%
0.1%
5.0%
0.1%
0.5%
0.5%
0.1%
5.5%
94.5%
100%
* The locomotive, commercial marine (Cl & C2), and diesel recreational marine estimates are for calendar year
2002.
** This category includes emissions from Category 3 (C3) propulsion engines and C2/3 auxiliary engines used
on ocean-going vessels.
                                                      107

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Draft Regulatory Impact Analysis
3.6 Contribution of Marine Diesel Engines and Locomotives to Non-
    Attainment Area Emission Inventories

       Table 0-95 and Table 0-96 show the percent contribution to mobile source
diesel PM2.5 and total mobile source NOX for certain non-attainment areas where there
are large rail yards and/or commercial marine ports. The county-level inventories
were estimated by allocating the nationwide baseline inventories to the counties using
the same county:national ratios as used in the 2002 National Emissions Inventory
(NEI).15 It can be seen that locomotives and diesel marine vessels make up a
substantial portion of the PM2.s and NOX mobile source inventories in these areas.
For instance, the combination of rail and commercial marine activity in the
Huntington-Ashland WV-KY-OH area yields a contribution over 50% of mobile
source diesel PM2.5 in 2002, increasing to 90% in 2030.

       These percentages are the same as shown in Chapter 2 of the Preamble of this
proposed rule.  Additional details, including the annual tons of PM2.5 and NOx from
locomotives, diesel marine engines, and all mobile sources within each of the
counties of these metropolitan areas are provided in Appendix 3A of this chapter.

Table 0-95 Locomotive and Diesel Marine Engine Contributions to Non-Attainment Area Mobile
                          Source Diesel PM2.5 Emissions
PM2 5 Metropolitan Area
Huntington- Ashland WV-KY-OH
Houston, TX
Los Angeles, CA
Cleveland-Akron-Lorain, OH
Chicago, IL
Cincinnati, OH
Chattanooga, TN
Kansas City, MO
Baltimore, MD
St. Louis, MO
Philadelphia, PA
Seattle, WA
Birmingham, AL
Minneapolis-St. Paul, MN
Boston, MA
San Joaquin Valley, CA
Atlanta, GA
Indianapolis, IN
Phoenix-Mesa, AZ
Detroit, MI
New York, NY
2002
LM%
52.9%
41.9%
31.3%
25.1%
24.6%
23.2%
21.1%
20.6%
22.5%
21.4%
19.6%
17.0%
16.3%
10.7%
7.8%
8.8%
5.2%
5.0%
4.9%
4.1%
3.5%
2020
LM%
82.1%
72.9%
49.3%
56.0%
54.9%
53.6%
56.3%
51.3%
52.6%
51.3%
47.0%
43.3%
46.6%
31.3%
22.9%
19.4%
19.6%
17.5%
17.3%
15.3%
11.1%
2030
LM%
90.4%
84.6%
72.1%
72.0%
70.0%
69.5%
69.5%
68.0%
67.8%
67.5%
63.9%
60.4%
57.5%
47.8%
40.5%
38.2%
29.9%
29.3%
26.8%
26.0%
20.3%
                                        108

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                                                           Chapter 3: Inventory
Table 0-96 Locomotive and Diesel Marine Engine Contributions to Non-Attainment Area Total
                           Mobile Source NOX Emissions
NOx Metropolitan Area
Houston, TX
Kansas City, MO
Birmingham, AL
Chicago, IL
Cleveland-Akron-Lorain, OH
Chattanooga, TN
Cincinnati, OH
Los Angeles, CA
St. Louis, MO
Huntington- Ashland WV-KY-OH
Seattle, WA
San Joaquin Valley, CA
Minneapolis-St. Paul, MN
Philadelphia, PA
Phoenix-Mesa, AZ
Atlanta, GA
Indianapolis, IN
Boston, MA
Baltimore, MD
Detroit, MI
New York, NY
2002
LM%
31.5%
19.3%
16.7%
19.9%
18.8%
15.6%
17.5%
18.1%
15.7%
38.1%
13.2%
8.4%
8.1%
13.4%
5.1%
4.2%
4.3%
6.3%
7.1%
2.8%
4.7%
2020
LM%
46.3%
39.3%
38.3%
37.8%
37.2%
35.7%
35.7%
30.8%
33.8%
41.9%
27.7%
16.0%
17.5%
19.7%
11.7%
10.7%
10.7%
10.6%
10.4%
7.2%
7.4%
2030
LM%
44.8%
43.2%
42.6%
41.1%
39.5%
39.1%
38.3%
37.2%
36.9%
36.2%
30.3%
25.7%
19.4%
18.8%
14.6%
12.8%
12.7%
10.8%
9.7%
8.2%
7.3%
                                          109

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Draft Regulatory Impact Analysis
3.7 Emission Inventories Used for Air Quality Modeling

3.7.1 Comparison of Air Quality and Proposed Rule Inventories

       The emission inventory estimates used to demonstrate the effect of the
proposed rule on air quality relied on the best estimates available at that time of the
emission contributions from all sources in the base calendar year and projections into
future calendar years. However, because of the long lead time necessary to prepare
inputs for the air quality models and to run the models, the emission inventory
estimates used in the air quality analysis are not the inventories that are now our best
estimate of the impacts  of the proposed rule. In all cases, the changes to the emission
inventory estimates reflect improvements made to the inventories which reflect new
information about the emission contributions from various sources that was not
available at the time the air quality analysis inventories were prepared. This section
describes the differences in the inventories used for the air quality analysis and the
inventories used for the proposed rule.  Chapter 2 of this document discusses the air
quality analysis results and addresses the likely impact of these differences (if any) on
the air quality outcomes from the proposed rule.

       In addition to the diesel locomotive, commercial marine vessel, and diesel
recreational marine sources, the air quality inventories include emission contributions
from all sources, including sources not directly affected by the proposed rule:

•  Stationary and area  sources

•  Aircraft

•  Oceangoing commercial marine vessels (Category 3)

•  Onroad (highway) mobile sources

•  Nonroad mobile sources other than diesel pleasure craft

       The emission inventory estimates used in the air quality analysis for aircraft,
oceangoing vessels, stationary and area sources were not updated between the air
quality analysis and the proposed rule.  However, changes were made in the onroad
and nonroad inventories and in the locomotive and commercial marine vessel
inventories for both the base (uncontrolled) and proposed rule control cases.

       Table 0-97, Table 0-98, and Table 0-99 summarize the differences between
the air quality inventories and the more updated proposed rule inventories for baseline
VOC, NOX, and PM2.5.  Similarly, Table 0-100, Table 0-101, and Table 0-102
summarize the differences between the air quality inventories and the more updated
proposed rule inventories for control case VOC, NOX, and PM2.5.  Lastly, Table
0-103, Table 0-104, and Table 0-105 summarize the differences in ton reductions for
                                         110

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                                                         Chapter 3: Inventory
these pollutants between the air quality inventories and the more updated proposed
rule inventories. Only the years 2020 and 2030 are shown for the latter two sets of
tables, since this proposal has no benefits prior to 2008. Although the actual
inventories change up to 20% depending on pollutant and year between the air quality
inventories and the later proposed rule inventories, the net effect of all the changes on
ton reductions of these pollutants ranges only from -4 percent to +3 percent. For the
final rule air quality analysis, we will be incorporating the changes described below,
as well as any future updates to the baseline estimates and control programs, which
we expect will have counterbalancing impacts on both baseline and control cases for
the final rule.

3.7.2 Onroad Inventory Changes

       The onroad (highway) emission inventory estimates used in the air quality
analysis were taken directly from the estimates used for the recent Clean Air
Interstate Rule (CAIR)16 using the National Mobile Inventory Model (NMIM) tool
and the March 25, 2004, version of the  NMIM County database (County20040325).

       The updated emission inventory estimates for onroad in the proposed rule
were originally calculated for use in the proposed Mobile Source Air Toxics (MSAT)
rule. The MSAT emission inventory estimates use the NMIM tool and the July 25,
2006 version of the NMIM County database  (NCD20060725MSATFinal). This new
database includes important corrections to the inputs for 13 states regarding the
implementation of California emission standards. The error in the old database
resulted in significantly over-predicted  NOX emissions for light-duty gasoline vehicles
in the onroad emission inventory estimates used in the air quality analysis, especially
in the projection years of 2020 (+995,000 tons, +60%) and 2030 (+995,000 tons,
+60%).  This resulted in an overprediction of the ozone levels in both the base and
control cases, and probably also a small overprediction of the air quality benefits of
this proposed rule. Using the corrected database, light-duty gasoline NOx emissions
decrease by 434,000 tons (-24%) in  2020 and 464,000 tons  (-26%) in 2030.

       The updated emission inventory estimates in the proposed rule for onroad also
made use of an in-house version of the EPA MOBILE6.2 emission factor model
which has been adapted to use new temperature correction factors for hydrocarbon
(HC) emissions for light duty gasoline vehicles.  These new temperature correction
factors were developed as part of the MSAT  rule. Using the new temperature
correction factors significantly increases the  HC inventories for light duty gasoline
vehicles, especially in the projection years of 2020 (+995,000 tons, +60%) and 2030
(+1,358,000 tons, +83%), during periods where temperatures are less than 75 degrees
Fahrenheit.

       These changes do not affect the estimated ton reductions from this proposed
rule, but they do affect the total emission inventory in both base and control cases.
This is shown in Table 0-97 through Table 0-102 in combination with the inventory
changes for nonroad equipment.
                                         Ill

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Draft Regulatory Impact Analysis
3.7.3 Nonroad Inventory Changes

       The air quality analysis for the nonroad emission inventory estimates for all
sources other than diesel pleasure craft (which are included in this proposed rule)
were taken directly from the estimates used for the recent Clean Air Interstate Rule
(CAIR) and are based on the 2004 version of the EPA NONROAD model.

       The updated nonroad inventory for the proposed rule is based on the recently
released 2005 version of the EPA NONROAD model. This newer nonroad model
includes many changes from the 2004 version, but the ones that most significantly
affect the estimated inventories are as follows:

•  Addition of new evaporative categories for tank permeation, hose permeation, hot
   soak, and running loss emissions.

•  Revised methodology for calculating diurnal emissions

•  Incorporated the effects of evaporative emission standards for recreational
   vehicles and large spark ignition engines.

•  Updated allocations from the national to the state and county level.

•  Updated the power range distributions and technology fractions for spark-ignition
   recreational marine engines.

•  Updated emission factors, deterioration factors, and technology mix for phase-2
   Class 1 small gasoline engines (< 25 hp).

       The net effect of these changes is a  55% increase in VOC from these  sources
(increase of 793,000 tons in 2020 and 820,000 tons in 2030). The corresponding
change in NOx is a small decrease of 13,000 tons (1.4%) in 2020  and 40,000 tons
(5%) in 2030.  These changes do not affect the estimated ton reductions from this
proposed rule,  but they do affect the total emission inventory in both base and control
cases.  This is shown in Table 0-97 through Table 0-102 in combination with the
onroad inventory changes described above in section 3.7.2.

3.7.4 Locomotive Inventory Changes

       The locomotive emission inventory estimates used in the air quality analysis
were calculated by EPA using a new national inventory estimation spreadsheet model
developed for this purpose. However, since the air quality analysis, changes have
been made in the emission rate estimates used in the model and the rate of turnover
for the locomotive switcher fleet. These changes affect the emission inventory
estimates for all pollutants and in all calendar years.

       In addition to the changes in the model, the inventory benefits of the proposed
rule were affected by a change in the assumptions for the effects of the rule.  The NOX
                                        112

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                                                         Chapter 3: Inventory
emissions of all Tier 0 engines were originally assumed to be affected by the rule in
the locomotive emission inventory estimates used in the air quality analysis. The
updated inventories assume that only 1994 and later model year Tier 0 engines are
affected by the rule.

       The last change to note is that the air quality inventory for locomotives treated
the calculated HC inventory as if it were VOC. In the updated inventory the HC
value is properly treated as Total Hydrocarbons (THC), and VOC is reported as 1.053
*THC.

       The net effect of these updates is a change in tons reduced from locomotives
ranging from -8 percent to +5 percent, depending on pollutant and year.

3.7.5 Commercial Marine Vessel Inventory Changes

       The commercial marine vessel (Category 1 and Category 2) emission
inventory estimates used in the air quality analysis were calculated by EPA using new
national inventory estimation spreadsheet models developed for this purpose.
However, since the air quality analysis, changes have been made in some of the
assumptions used in the model, including the load factors, the sulfur content of the
diesel certification fuel used for pleasure craft, and the sulfur content of diesel fuel
used by commercial marine vessels. These  changes did not affect the projected ton
reductions for marine diesel engines, since the baseline and control cases were
equally affected. These reductions are 5,000 tons VOC and  139,000 tons NOX in
2020, and 11,000 tons VOC and 346,000 tons NOX in  2030.
    Table 0-97 50-State Annual VOC Baseline Emission Levels for Mobile and Other Source
                                  Categories
CATEGORY
LOCOMOTIVE
MARINE DIESEL
ALL OTHER SOURCES
(MOBILE &
STATIONARY)
TOTAL MAN-MADE
SOURCES
2001*
AQ
MODELING
48,115
14,176
16,978,113
17,040,404
NPRM
50,665
18,768
17,868,970
17,938,403
% DIFF
5.3%
32.4%
5.2%
5.3%
2020
AQ
MODELING
49,039
13,677
11,736,377
11,799,094
NPRM
52,633
18,724
13,777,876
13,849,233
% DIFF
7.3%
36.9%
17.4%
17.4%
2030
AQ
MODELING
47,606
14,588
11,804,110
11,866,304
NPRM
51,813
20,477
14,267,387
14,339,677
% DIFF
8.8%
40.4%
20.9%
20.8%
* LOCOMOTIVE AND MARINE DIESEL VALUES IN THE "2001" COLUMN ARE ACTUALLY 2002 ESTIMATES.
                                        113

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Draft Regulatory Impact Analysis
    Table 0-98 50-State Annual NOX Baseline Emission Levels for Mobile and Other Source
                                      Categories
CATEGORY
LOCOMOTIVE
MARINE DIESEL
ALL OTHER SOURCES
(MOBILE &
STATIONARY)
TOTAL MAN-MADE
SOURCES
2001*
AQ
MODELING
1,118,786
711,656
19,854,001
21,684,444
NPRM
1,118,786
874,462
19,786,232
21,779,480
%DIFF
0.0%
22.9%
-0.3%
0.4%
2020
AQ
MODELING
844,932
606,021
10,006,926
11,457,878
NPRM
860,474
721,632
9,518,521
11,100,627
%DIFF
1.8%
19.1%
-4.9%
-3.1%
2030
AQ
MODELING
835,059
608,761
9,570,157
11,013,977
NPRM
854,226
728,127
9,020,273
10,602,626
%DIFF
2.3%
19.6%
-5.7%
-3.7%
* LOCOMOTIVE AND MARINE DIESEL VALUES IN THE "2001" COLUMN ARE ACTUALLY 2002 ESTIMATES.
    Table 0-99 50-State Annual PM2.5 Baseline Emission Levels for Mobile and Other Source
                                      Categories
CATEGORY
LOCOMOTIVE
MARINE DIESEL
ALL OTHER SOURCES
(MOBILE &
STATIONARY)
TOTAL MAN-MADE
SOURCES
2001*
AQ
MODELING
29,660
23,627
2,393,848
2,447,136
NPRM
29,660
29,827
2,369,947
2,429,434
%DIFF
0.0%
26.2%
-1.0%
-0.7%
2020
AQ
MODELING
25,843
20,087
2,044,184
2,090,114
NPRM
26,301
23,242
2,022,009
2,071,552
%DIFF
1.8%
15.7%
-1.1%
-0.9%
2030
AQ
MODELING
24,334
21,852
2,041,701
2,087,886
NPRM
25,109
24,900
2,018,649
2,068,658
%
DIFF
3.2%
13.9%
-1.1%
-0.9%
* LOCOMOTIVE AND MARINE DIESEL VALUES IN THE "2001" COLUMN ARE ACTUALLY 2002 ESTIMATES.
 Table 0-100 50-State Annual VOC Control Case Emission Levels for Mobile and Other Source
                                      Categories
CATEGORY
LOCOMOTIVE
MARINE DIESEL
ALL OTHER SOURCES
(MOBILE & STATIONARY)
TOTAL MAN-MADE
SOURCES
2020
AQ
MODELING
26,790
8,890
11,736,377
11,772,057
NPRM
30,135
13,991
13,777,876
13,822,002
% DIFF
12.5%
57.4%
17.4%
17.4%
2030
AQ
MODELING
17,394
3,969
11,804,110
11,825,474
NPRM
20,383
9,801
14,267,387
14,297,571
% DIFF
17.2%
146.9%
20.9%
20.9%
* AQ MODELING FOR LOCOMOTIVES USED THC AS VOC, INSTEAD OF USING ACTUAL VOC =1.053 *
THC.
                                            114

-------
                                                             Chapter 3: Inventory
 Table 0-101 50-State Annual NOX Control Case Emission Levels for Mobile and Other Source
                                     Categories
CATEGORY
LOCOMOTIVE
MARINE DIESEL
ALL OTHER SOURCES
(MOBILE & STATIONARY)
TOTAL MAN-MADE
SOURCES
2020
AQ
MODELING
690,885
467,327
10,006,926
11,165,138
NPRM
712,492
576,706
9,518,521
10,807,720
% DIFF
3.1%
23.4%
-4.9%
-3.2%
2030
AQ
MODELING
452,453
262,345
9,570,157
10,284,956
NPRM
453,651
362,927
9,020,273
9,836,851
% DIFF
0.3%
38.3%
-5.7%
-4.4%
Table 0-102 50-State Annual PM2.5 Control Case Emission Levels for Mobile and Other Source
                                    Categories
CATEGORY
LOCOMOTIVE
MARINE DIESEL
ALL OTHER SOURCES
(MOBILE & STATIONARY)
TOTAL MAN-MADE
SOURCES
2020
AQ
MODELING
15,318
15,367
2,044,184
2,074,870
NPRM
16,368
18,399
2,022,009
2,056,776
% DIFF
6.9%
19.7%
-1.1%
-0.9%
2030
AQ
MODELING
9,617
8,893
2,041,701
2,060,211
NPRM
10,512
11,778
2,018,649
2,040,939
% DIFF
9.3%
32.4%
-1.1%
-0.9%
 Table 0-103 50-State Annual VOC Ton Reductions for Mobile and Other Source Categories
CATEGORY
LOCOMOTIVE
MARINE DIESEL
ALL OTHER SOURCES
(MOBILE & STATIONARY)
TOTAL MAN-MADE
SOURCES
2020
AQ
MODELING
22,249
4,787
0
27,036
NPRM
22,498
4,734
0
27,231
% DIFF
1.1%
-1.1%
0.0%
0.7%
2030
AQ
MODELING
30,211
10,619
0
40,830
NPRM
31,430
10,676
0
42,106
% DIFF
4.0%
0.5%
0.0%
3.1%
                                           115

-------
Draft Regulatory Impact Analysis
   Table 0-104 50-State Annual NOX Ton Reductions for Mobile and Other Source Categories
CATEGORY
LOCOMOTIVE
MARINE DIESEL
ALL OTHER SOURCES
(MOBILE & STATIONARY)
TOTAL MAN-MADE
SOURCES
2020
AQ
MODELING
154,047
138,694
0
292,741
NPRM
147,982
144,925
0
292,907
% DIFF
-3.9%
4.5%
0.0%
0.1%
2030
AQ
MODELING
382,606
346,416
0
729,022
NPRM
400,575
365,199
0
765,775
% DIFF
4.7%
5.4%
0.0%
5.0%
  Table 0-105 50-State Annual PM2.5 Ton Reductions for Mobile and Other Source Categories
CATEGORY
LOCOMOTIVE
MARINE DIESEL
ALL OTHER SOURCES
(MOBILE & STATIONARY)
TOTAL MAN-MADE
SOURCES
2020
AQ
MODELING
10,525
4,720
0
15,245
NPRM
9,933
4,843
0
14,776
% DIFF
-5.6%
2.6%
0.0%
-3.1%
2030
AQ
MODELING
14,717
12,959
0
27,675
NPRM
14,597
13,122
0
27,719
% DIFF
-0.8%
1.3%
0.0%
0.2%
                                           116

-------
                                             Chapter 3: Inventory
                         APPENDIX 3A
Locomotive and Diesel Marine Contributions to County-Specific Mobile
          Source Emissions in Non-attainment Areas
                              117

-------
Draft Regulatory Impact Analysis
 Table 0-106 2002 Locomotive and Diesel Marine PM2.5 Tons/Year and Percent of Total Diesel
                                  Mobile Sources
FIPS
13013
13015
13045
13057
13063
13067
13077
13089
13097
13113
13117
13121
13135
13139
13149
13151
13217
13223
13237
13247
13255
13297
24003
24005
24013
24025
24027
24510
1073
1117
1127
9007
25001
25005
25007
25009
25019
25021
25023
25025
25027
33011
MSA
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Birmingham
Birmingham
Birmingham
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
County
Barrow
Bartow
Carroll
Cherokee
Clayton
Cobb
Coweta
DeKalb
Douglas
Fayette
Forsyth
Fulton
Gwinnett
Hall
Heard
Henry
Newton
Paulding
Putnam
Rockdale
Spalding
Walton
Anne Arundel
Baltimore
Carroll
Harford
Howard
Baltimore
Jefferson
Shelby
Walker
Middlesex
Barnstable
Bristol
Dukes
Essex
Nantucket
Norfolk
Plymouth
Suffolk
Worcester
Hillsborough
ST
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
MD
MD
MD
MD
MD
MD
AL
AL
AL
CT
MA
MA
MA
MA
MA
MA
MA
MA
MA
NH
2002 PM2.5
Diesel
Locomotive
5.77
20.64
5.65
0.00
10.87
28.66
14.35
13.29
5.22
3.71
0.00
39.07
9.95
6.62
0.00
14.63
1.65
12.13
0.35
2.35
0.62
1.99
14.68
39.65
6.14
11.40
17.07
46.07
80.24
41.96
17.15
0.00
7.23
13.57
0.00
17.74
0.00
21.42
11.20
11.57
43.94
1.33
Diesel
Marine
0.01
0.20
0.08
0.19
0.03
0.08
0.06
0.05
0.01
0.04
0.39
0.11
0.07
0.65
0.09
0.04
0.05
0.03
0.30
0.03
0.03
0.01
1.82
1.22
0.04
1.18
0.41
313.45
1.08
0.29
1.08
1.70
20.34
14.82
133.61
4.90
19.79
6.80
4.99
57.64
1.04
0.42
Total
Diesel
Mobile
41
109
92
118
164
504
123
440
68
86
114
857
476
146
11
154
80
86
15
71
53
47
302
576
158
186
203
590
631
157
81
114
179
311
143
424
29
460
256
2,518
556
266
LM
Percent
14.3%
19.1%
6.2%
0.2%
6.7%
5.7%
1 1 .8%
3.0%
7.7%
4.4%
0.3%
4.6%
2.1%
5.0%
0.8%
9.5%
2.1%
14.2%
4.3%
3.4%
1 .2%
4.2%
5.5%
7.1%
3.9%
6.8%
8.6%
60.9%
12.9%
26.9%
22.4%
1 .5%
15.4%
9.1%
93.4%
5.3%
67.4%
6.1%
6.3%
2.7%
8.1%
0.7%
                                          118

-------
               Chapter 3: Inventory
FIPS
33015
47065
47115
47153
13047
13083
13295
17031
17043
17063
17089
17093
17097
17111
17197
18089
18127
18029
21015
21037
21117
39017
39025
39061
39165
39007
39035
39085
39093
39103
39133
39153
26093
26099
26115
26125
26147
26161
26163
48039
48071
48157
48167
48201
48291
MSA
Boston
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Houston
Houston
Houston
Houston
Houston
Houston
County
Rockingham
Hamilton
Marion
Sequatchie
Catoosa
Dade
Walker
Cook
DuPage
Grundy
Kane
Kendall
Lake
McHenry
Will
Lake
Porter
Dearborn
Boone
Campbell
Kenton
Butler
Clermont
Hamilton
Warren
Ashtabula
Cuyahoga
Lake
Lorain
Medina
Portage
Summit
Livingston
Macomb
Monroe
Oakland
St. Clair
Washtenaw
Wayne
B razor! a
Chambers
Fort Bend
Galveston
Harris
Liberty
ST
NH
TN
TN
TN
GA
GA
GA
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
IN
KY
KY
KY
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
Ml
Ml
Ml
Ml
Ml
Ml
Ml
TX
TX
TX
TX
TX
TX
2002 PM2.5
Diesel
Locomotive
1.00
40.53
5.67
0.00
12.28
11.66
0.00
708.71
200.17
13.55
70.19
8.97
37.26
20.29
186.94
129.22
45.64
6.21
8.45
16.05
30.93
45.48
1.96
44.25
6.75
30.49
83.10
21.22
50.28
15.82
31.34
25.49
2.47
3.83
18.09
15.09
7.39
4.04
29.94
18.79
1.07
26.30
13.07
68.97
28.79
Diesel
Marine
36.02
29.56
5.70
0.00
0.01
0.00
0.01
209.67
0.14
6.45
0.10
0.01
22.02
0.16
4.74
14.34
12.55
22.72
34.08
23.57
11.78
0.05
44.98
133.23
0.09
178.56
122.90
26.15
113.72
0.06
0.24
0.17
0.07
5.35
8.90
4.59
21.37
0.05
10.03
247.18
7.41
0.09
566.43
1,477.09
3.02
Total
Diesel
Mobile
263
283
63
7
52
46
48
3,661
812
114
371
78
406
189
498
541
216
92
133
95
147
279
181
737
192
310
1,119
190
414
166
198
392
174
437
198
781
224
269
1,140
463
57
270
751
3,940
112
LM
Percent
14.1%
24.7%
18.1%
0.0%
23.6%
25.3%
0.0%
25.1%
24.7%
17.6%
19.0%
1 1 .5%
14.6%
10.8%
38.5%
26.5%
26.9%
31 .3%
31 .9%
41 .5%
29.1%
16.3%
25.9%
24.1%
3.6%
67.4%
18.4%
25.0%
39.6%
9.6%
15.9%
6.5%
1 .5%
2.1%
13.6%
2.5%
12.8%
1 .5%
3.5%
57.4%
14.8%
9.8%
77.1%
39.2%
28.3%
119

-------
Draft Regulatory Impact Analysis
FIPS
48339
48473
21019
21127
39001
39053
39087
39145
54011
54053
54099
18011
18057
18059
18063
18081
18095
18097
18109
18145
20091
20103
20121
20209
29037
29047
29049
29095
29107
29165
29177
6037
6059
6065
6071
6111
27003
27019
27037
27053
27123
27139
27163
9001
MSA
Houston
Houston
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
New York
County
Montgomery
Waller
Boyd
Lawrence
Adams
Gallia
Lawrence
Scioto
Cabell
Mason
Wayne
Boone
Hamilton
Hancock
Hendricks
Johnson
Madison
Marion
Morgan
Shelby
Johnson
Leavenworth
Miami
Wyandotte
Cass
Clay
Clinton
Jackson
Lafayette
Platte
Ray
Los Angeles
Orange
Riverside
San
Bernardino
Ventura
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Fairfield
ST
TX
TX
KY
KY
OH
OH
OH
OH
WV
WV
WV
IN
IN
IN
IN
IN
IN
IN
IN
IN
KS
KS
KS
KS
MO
MO
MO
MO
MO
MO
MO
CA
CA
CA
CA
CA
MN
MN
MN
MN
MN
MN
MN
CT
2002 PM2.5
Diesel
Locomotive
22.38
6.50
11.13
10.86
0.39
3.44
12.48
27.95
24.48
6.12
30.53
6.78
0.16
5.17
18.14
0.91
16.17
31.30
0.41
7.35
55.73
14.29
81.56
30.24
16.72
28.19
0.00
90.00
23.25
22.68
44.83
241.14
63.57
109.12
359.75
12.49
21.27
0.05
12.70
31.68
12.03
2.70
23.15
0.00
Diesel
Marine
0.27
0.04
18.28
5.94
52.61
23.13
34.34
33.28
25.26
39.72
60.21
0.06
0.62
0.03
0.03
0.21
0.12
1.34
0.22
0.02
0.04
0.50
0.15
4.47
0.12
4.43
0.16
33.46
4.16
0.84
3.97
1,666.68
176.82
1.01
0.47
231.21
12.73
0.79
11.89
35.83
11.31
1.38
50.70
44.84
Total
Diesel
Mobile
300
45
65
33
88
62
86
124
112
92
133
120
224
107
188
115
156
662
93
102
481
84
139
148
110
188
49
646
124
151
108
5,016
1,696
872
1,040
524
232
82
278
870
349
94
237
705
LM
Percent
7.5%
14.5%
45.2%
51 .6%
60.0%
42.8%
54.5%
49.5%
44.5%
50.0%
68.1%
5.7%
0.3%
4.9%
9.7%
1 .0%
10.5%
4.9%
0.7%
7.2%
1 1 .6%
17.6%
58.6%
23.5%
15.3%
17.3%
0.3%
19.1%
22.1%
15.6%
45.2%
38.0%
14.2%
12.6%
34.6%
46.5%
14.7%
1 .0%
8.9%
7.8%
6.7%
4.3%
31.1%
6.4%
                                      120

-------
               Chapter 3: Inventory
FIPS
9005
34003
34013
34017
34019
34023
34025
34027
34029
34031
34035
34037
34039
36005
36047
36059
36061
36071
36081
36085
36087
36103
36119
10003
24015
24029
24031
34005
34007
34011
34015
34021
34033
42017
42029
42045
42101
4013
4021
6019
6029
6031
6039
6047
6077
MSA
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Phoenix
Phoenix
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
County
Litchfield
Bergen
Essex
Hudson
Hunterdon
Middlesex
Monmouth
Morris
Ocean
Passaic
Somerset
Sussex
Union
Bronx
Kings
Nassau
New York
Orange
Queens
Richmond
Rockland
Suffolk
Westchester
New Castle
Cecil
Kent
Montgomery
Burlington
Camden
Cumberland
Gloucester
Mercer
Salem
Bucks
Chester
Delaware
Philadelphia
Maricopa
Pinal
Fresno
Kern
Kings
Madera
Merced
San Joaquin
ST
CT
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
DE
MD
MD
MD
NJ
NJ
NJ
NJ
NJ
NJ
PA
PA
PA
PA
AZ
AZ
CA
CA
CA
CA
CA
CA
2002 PM2.5
Diesel
Locomotive
0.00
26.97
6.64
22.70
9.60
12.54
10.14
6.96
0.52
6.11
13.21
0.99
11.04
0.13
0.00
0.00
0.00
9.19
0.06
0.00
6.91
0.00
0.00
22.95
9.27
0.07
28.82
0.00
4.82
0.57
0.80
5.56
0.27
2.29
11.62
4.55
6.45
98.35
52.54
17.77
92.07
2.57
18.89
17.75
29.94
Diesel
Marine
0.89
3.48
0.99
27.96
0.33
4.94
29.48
0.53
13.26
0.51
0.02
0.63
17.95
0.75
1.30
11.73
0.54
2.55
2.02
2.29
2.69
39.17
3.76
47.44
1.70
1.41
0.53
54.50
21.83
55.22
29.18
6.66
16.91
1.20
0.16
193.17
339.10
0.78
0.17
0.58
0.22
0.02
0.16
0.46
30.32
Total
Diesel
Mobile
109
512
416
402
185
421
418
300
256
233
195
113
355
372
696
518
1,296
288
982
166
125
690
479
458
125
42
485
328
273
155
214
277
86
330
328
409
922
2,828
256
647
635
155
145
218
437
LM
Percent
0.8%
6.0%
1 .8%
12.6%
5.4%
4.1%
9.5%
2.5%
5.4%
2.8%
6.8%
1 .4%
8.2%
0.2%
0.2%
2.3%
0.0%
4.1%
0.2%
1 .4%
7.7%
5.7%
0.8%
15.4%
8.7%
3.6%
6.0%
16.6%
9.8%
36.0%
14.0%
4.4%
19.9%
1.1%
3.6%
48.4%
37.5%
3.5%
20.6%
2.8%
14.5%
1 .7%
13.2%
8.4%
13.8%
121

-------
Draft Regulatory Impact Analysis
FIPS
6099
6107
53029
53033
53035
53045
53053
53061
53067
17027
17083
17119
17133
17163
29055
29071
29099
29113
29183
29189
29219
29510
MSA
San Joaquin
San Joaquin
Seattle
Seattle
Seattle
Seattle
Seattle
Seattle
Seattle
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
County
Stanislaus
Tulare
Island
King
Kitsap
Mason
Pierce
Snohomish
Thurston
Clinton
Jersey
Madison
Monroe
St. Clair
Crawford
Franklin
Jefferson
Lincoln
St. Charles
St. Louis
Warren
St. Louis
ST
CA
CA
WA
WA
WA
WA
WA
WA
WA
IL
IL
IL
IL
IL
MO
MO
MO
MO
MO
MO
MO
MO
2002 PM2.5
Diesel
Locomotive
12.07
26.68
0.00
28.95
0.00
0.00
18.18
36.65
10.80
23.14
1.86
7.81
37.61
8.93
5.23
31.20
8.38
13.80
16.62
26.77
2.82
23.28
Diesel
Marine
0.24
0.16
19.63
191.88
1.27
0.58
173.52
29.32
12.02
0.08
19.07
10.33
16.72
19.78
0.04
2.36
16.93
6.69
15.02
19.32
2.31
261.28
Total
Diesel
Mobile
267
340
69
1,568
134
37
612
471
179
99
65
247
104
229
45
153
186
87
244
831
47
456
LM
Percent
4.6%
7.9%
28.5%
14.1%
0.9%
1 .6%
31.3%
14.0%
12.7%
23.5%
32.1%
7.4%
52.1%
12.5%
1 1 .6%
21.9%
13.6%
23.4%
13.0%
5.5%
10.9%
62.4%
                                      122

-------
                                                           Chapter 3: Inventory
Table 0-107 2020 Locomotive and Diesel Marine PM2.5 Tons/Year and Percent of Total Diesel
                                 Mobile Sources
FIPS
13013
13015
13045
13057
13063
13067
13077
13089
13097
13113
13117
13121
13135
13139
13149
13151
13217
13223
13237
13247
13255
13297
24003
24005
24013
24025
24027
24510
1073
1117
1127
9007
25001
25005
25007
25009
25019
25021
25023
25025
25027
33011
MSA
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Birmingham
Birmingham
Birmingham
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
County
Barrow
Bartow
Carroll
Cherokee
Clayton
Cobb
Coweta
DeKalb
Douglas
Fayette
Forsyth
Fulton
Gwinnett
Hall
Heard
Henry
Newton
Paulding
Putnam
Rockdale
Spalding
Walton
Anne Arundel
Baltimore
Carroll
Harford
Howard
Baltimore
Jefferson
Shelby
Walker
Middlesex
Barnstable
Bristol
Dukes
Essex
Nantucket
Norfolk
Plymouth
Suffolk
Worcester
Hillsborough
ST
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
MD
MD
MD
MD
MD
MD
AL
AL
AL
CT
MA
MA
MA
MA
MA
MA
MA
MA
MA
NH
2020 PM2.5
Diesel
Locomotive
5.45
19.49
5.28
0.00
10.27
26.96
13.55
12.49
4.86
3.50
0.00
36.74
9.33
5.67
0.00
13.81
1.56
11.45
0.31
2.22
0.59
1.88
10.36
34.68
5.34
8.84
12.62
46.50
75.36
39.49
14.91
0.00
6.28
11.82
0.00
15.42
0.00
18.39
9.78
9.83
37.77
1.15
Diesel
Marine
0.01
0.17
0.07
0.17
0.02
0.07
0.05
0.04
0.01
0.03
0.35
0.09
0.06
0.57
0.08
0.03
0.04
0.02
0.26
0.02
0.02
0.01
1.57
1.03
0.03
1.00
0.32
242.61
0.86
0.26
0.86
1.50
16.59
11.64
103.75
4.13
15.54
5.32
4.30
44.70
0.92
0.37
Total
Diesel
Mobile
11
35
19
23
41
137
33
103
16
20
24
224
118
31
2
41
15
24
3
16
10
10
73
154
37
46
56
328
188
65
30
22
55
79
106
101
18
114
65
688
142
56
LM
Percent
49.6%
56.9%
27.6%
0.7%
25.2%
19.8%
41.2%
12.1%
30.0%
18.0%
1 .5%
16.4%
8.0%
19.9%
4.4%
34.2%
10.4%
47.5%
17.2%
14.2%
6.4%
18.8%
16.4%
23.1%
14.6%
21.5%
22.9%
88.1%
40.6%
61 .4%
52.9%
6.7%
41.7%
29.6%
97.6%
19.4%
85.4%
20.9%
21.8%
7.9%
27.3%
2.7%
                                          123

-------
Draft Regulatory Impact Analysis
FIPS
33015
47065
47115
47153
13047
13083
13295
17031
17043
17063
17089
17093
17097
17111
17197
18089
18127
18029
21015
21037
21117
39017
39025
39061
39165
39007
39035
39085
39093
39103
39133
39153
26093
26099
26115
26125
26147
26161
26163
48039
48071
48157
48167
48201
48291
MSA
Boston
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Houston
Houston
Houston
Houston
Houston
Houston
County
Rockingham
Hamilton
Marion
Sequatchie
Catoosa
Dade
Walker
Cook
DuPage
Grundy
Kane
Kendall
Lake
McHenry
Will
Lake
Porter
Dearborn
Boone
Campbell
Kenton
Butler
Clermont
Hamilton
Warren
Ashtabula
Cuyahoga
Lake
Lorain
Medina
Portage
Summit
Livingston
Macomb
Monroe
Oakland
St. Clair
Washtenaw
Wayne
B razor! a
Chambers
Fort Bend
Galveston
Harris
Liberty
ST
NH
TN
TN
TN
GA
GA
GA
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
IN
KY
KY
KY
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
Ml
Ml
Ml
Ml
Ml
Ml
Ml
TX
TX
TX
TX
TX
TX
2020 PM2.5
Diesel
Locomotive
0.87
38.28
5.36
0.00
11.60
11.01
0.00
608.24
162.78
13.20
59.50
8.18
30.80
17.00
163.07
132.19
40.84
5.59
7.99
15.10
29.20
40.67
1.76
39.70
6.08
27.38
76.82
18.90
45.04
14.17
28.09
22.96
2.33
3.62
17.08
14.21
6.90
3.82
28.47
17.74
1.01
24.70
12.47
65.54
27.14
Diesel
Marine
28.09
22.98
4.45
0.00
0.01
0.00
0.01
164.40
0.12
5.01
0.09
0.01
19.13
0.14
3.70
12.15
10.56
17.59
26.40
18.27
9.12
0.04
34.82
103.13
0.08
138.54
96.57
21.00
88.60
0.05
0.21
0.15
0.06
4.26
6.95
3.58
16.67
0.04
7.97
191.47
5.88
0.08
438.65
1,143.23
2.35
Total
Diesel
Mobile
74
103
18
1
18
16
9
1,362
317
42
138
27
138
61
242
232
85
35
54
43
59
92
63
268
49
185
379
71
190
45
61
101
35
96
60
188
64
61
253
248
16
79
487
1,727
45
LM
Percent
39.1%
59.3%
53.8%
0.0%
63.7%
67.9%
0.1%
56.7%
51 .4%
43.5%
43.3%
30.5%
36.2%
28.0%
68.9%
62.3%
60.4%
65.7%
63.8%
77.4%
65.4%
44.2%
58.0%
53.3%
12.5%
89.5%
45.7%
56.4%
70.4%
31 .8%
46.1%
22.8%
6.8%
8.2%
39.7%
9.5%
37.1%
6.3%
14.4%
84.2%
44.1%
31 .5%
92.6%
70.0%
65.6%
                                      124

-------
               Chapter 3: Inventory
FIPS
48339
48473
21019
21127
39001
39053
39087
39145
54011
54053
54099
18011
18057
18059
18063
18081
18095
18097
18109
18145
20091
20103
20121
20209
29037
29047
29049
29095
29107
29165
29177
6037
6059
6065
6071
6111
27003
27019
27037
27053
27123
27139
27163
9001
MSA
Houston
Houston
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
New York
County
Montgomery
Waller
Boyd
Lawrence
Adams
Gallia
Lawrence
Scioto
Cabell
Mason
Wayne
Boone
Hamilton
Hancock
Hendricks
Johnson
Madison
Marion
Morgan
Shelby
Johnson
Leavenworth
Miami
Wyandotte
Cass
Clay
Clinton
Jackson
Lafayette
Platte
Ray
Los Angeles
Orange
Riverside
San
Bernardino
Ventura
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Fairfield
ST
TX
TX
KY
KY
OH
OH
OH
OH
WV
WV
WV
IN
IN
IN
IN
IN
IN
IN
IN
IN
KS
KS
KS
KS
MO
MO
MO
MO
MO
MO
MO
CA
CA
CA
CA
CA
MN
MN
MN
MN
MN
MN
MN
CT
2020 PM2.5
Diesel
Locomotive
21.14
6.14
10.44
9.43
0.35
3.09
11.20
25.08
22.84
5.31
28.80
5.92
0.15
4.58
16.27
0.88
14.62
27.99
0.40
6.54
52.60
13.49
77.03
28.47
15.70
26.78
0.00
85.15
21.96
21.42
42.28
217.08
56.50
93.21
321.96
11.01
19.93
0.05
11.92
29.88
11.29
2.55
21.74
0.00
Diesel
Marine
0.24
0.04
14.15
4.60
40.72
17.90
26.58
25.76
19.57
30.79
46.62
0.05
0.55
0.03
0.03
0.19
0.11
1.19
0.20
0.02
0.03
0.39
0.14
3.46
0.11
3.48
0.14
25.94
3.26
0.67
3.09
1,290.10
136.94
0.90
0.42
179.05
10.06
0.67
9.37
28.17
8.91
1.15
39.42
35.19
Total
Diesel
Mobile
68
15
31
17
49
28
44
63
54
47
85
34
54
28
55
26
45
166
19
29
155
29
92
56
37
64
12
223
49
51
61
2,697
729
380
574
298
72
20
80
242
89
25
96
184
LM
Percent
31 .6%
42.5%
79.9%
84.4%
84.4%
73.8%
85.6%
80.7%
78.0%
76.4%
88.8%
17.6%
1 .3%
16.2%
29.9%
4.2%
32.9%
17.5%
3.1%
22.3%
33.9%
47.4%
83.9%
57.5%
42.4%
47.6%
1 .2%
49.8%
51 .3%
42.9%
74.5%
55.9%
26.6%
24.8%
56.2%
63.8%
41 .9%
3.6%
26.5%
24.0%
22.8%
14.6%
63.8%
19.1%
125

-------
Draft Regulatory Impact Analysis
FIPS
9005
34003
34013
34017
34019
34023
34025
34027
34029
34031
34035
34037
34039
36005
36047
36059
36061
36071
36081
36085
36087
36103
36119
10003
24015
24029
24031
34005
34007
34011
34015
34021
34033
42017
42029
42045
42101
4013
4021
6019
6029
6031
6039
6047
6077
MSA
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Phoenix
Phoenix
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
County
Litchfield
Bergen
Essex
Hudson
Hunterdon
Middlesex
Monmouth
Morris
Ocean
Passaic
Somerset
Sussex
Union
Bronx
Kings
Nassau
New York
Orange
Queens
Richmond
Rockland
Suffolk
Westchester
New Castle
Cecil
Kent
Montgomery
Burlington
Camden
Cumberland
Gloucester
Mercer
Salem
Bucks
Chester
Delaware
Philadelphia
Maricopa
Pinal
Fresno
Kern
Kings
Madera
Merced
San Joaquin
ST
CT
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
DE
MD
MD
MD
NJ
NJ
NJ
NJ
NJ
NJ
PA
PA
PA
PA
AZ
AZ
CA
CA
CA
CA
CA
CA
2020 PM2.5
Diesel
Locomotive
0.00
22.36
5.18
19.90
7.47
11.14
6.84
5.01
0.41
4.28
11.03
0.96
8.53
0.12
0.00
0.00
0.00
8.01
0.06
0.00
6.33
0.00
0.00
23.49
7.73
0.06
21.88
0.00
3.47
0.55
0.83
4.55
0.25
1.95
9.26
3.76
5.74
89.13
48.94
15.98
80.81
2.13
17.29
15.33
26.62
Diesel
Marine
0.79
2.76
0.79
21.74
0.29
3.88
23.33
0.47
11.45
0.45
0.01
0.55
13.90
0.62
1.07
9.33
0.44
2.02
1.66
1.84
2.13
32.24
3.02
36.76
1.40
1.21
0.43
42.25
16.92
43.19
22.64
5.17
13.18
1.00
0.14
149.53
262.48
0.69
0.15
0.51
0.19
0.02
0.14
0.40
23.51
Total
Diesel
Mobile
23
146
95
120
41
106
114
73
58
54
51
23
97
75
146
139
364
63
228
39
37
193
123
144
30
12
127
100
72
65
63
64
28
78
81
199
383
709
92
236
265
56
63
84
184
LM
Percent
3.4%
17.2%
6.3%
34.7%
19.0%
14.1%
26.6%
7.6%
20.3%
8.7%
21.8%
6.6%
23.1%
1 .0%
0.7%
6.7%
0.1%
15.9%
0.8%
4.8%
22.9%
16.7%
2.5%
41.7%
30.2%
10.5%
17.6%
42.2%
28.3%
67.8%
37.2%
15.3%
47.6%
3.8%
1 1 .7%
77.0%
69.9%
12.7%
53.5%
7.0%
30.6%
3.8%
27.9%
18.6%
27.3%
                                      126

-------
               Chapter 3: Inventory
FIPS
6099
6107
53029
53033
53035
53045
53053
53061
53067
17027
17083
17119
17133
17163
29055
29071
29099
29113
29183
29189
29219
29510
MSA
San Joaquin
San Joaquin
Seattle
Seattle
Seattle
Seattle
Seattle
Seattle
Seattle
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
County
Stanislaus
Tula re
Island
King
Kitsap
Mason
Pierce
Snohomish
Thurston
Clinton
Jersey
Madison
Monroe
St. Clair
Crawford
Franklin
Jefferson
Lincoln
St. Charles
St. Louis
Warren
St. Louis
ST
CA
CA
WA
WA
WA
WA
WA
WA
WA
IL
IL
IL
IL
IL
MO
MO
MO
MO
MO
MO
MO
MO
2020 PM2.5
Diesel
Locomotive
10.69
24.00
0.00
27.06
0.00
0.00
16.97
33.68
9.33
21.27
1.73
8.44
33.99
9.49
4.54
29.11
7.90
13.04
15.70
25.09
2.66
22.18
Diesel
Marine
0.21
0.14
15.26
149.20
1.13
0.50
134.63
23.01
9.42
0.07
14.76
8.01
12.95
15.31
0.04
1.86
13.13
5.22
11.75
15.01
1.81
202.23
Total
Diesel
Mobile
101
133
25
484
27
7
238
140
48
41
28
67
60
69
12
54
49
34
73
214
14
256
LM
Percent
10.8%
18.1%
60.2%
36.4%
4.2%
7.1%
63.7%
40.4%
39.1%
51.8%
57.9%
24.7%
77.8%
36.2%
38.8%
57.6%
43.3%
53.8%
37.4%
18.8%
32.7%
87.7%
127

-------
Draft Regulatory Impact Analysis
 Table 0-108 2030 Locomotive and Diesel Marine PM2.5 Tons/Year and Percent of Total Diesel
                                  Mobile Sources
FIPS
13013
13015
13045
13057
13063
13067
13077
13089
13097
13113
13117
13121
13135
13139
13149
13151
13217
13223
13237
13247
13255
13297
24003
24005
24013
24025
24027
24510
1073
1117
1127
9007
25001
25005
25007
25009
25019
25021
25023
25025
25027
33011
MSA
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Birmingham
Birmingham
Birmingham
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
County
Barrow
Bartow
Carroll
Cherokee
Clayton
Cobb
Coweta
DeKalb
Douglas
Fayette
Forsyth
Fulton
Gwinnett
Hall
Heard
Henry
Newton
Paulding
Putnam
Rockdale
Spalding
Walton
Anne Arundel
Baltimore
Carroll
Harford
Howard
Baltimore
Jefferson
Shelby
Walker
Middlesex
Barnstable
Bristol
Dukes
Essex
Nantucket
Norfolk
Plymouth
Suffolk
Worcester
Hillsborough
ST
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
MD
MD
MD
MD
MD
MD
AL
AL
AL
CT
MA
MA
MA
MA
MA
MA
MA
MA
MA
NH
2030 PM2.5
Diesel
Locomotive
5.25
18.79
5.08
0.00
9.90
25.96
13.06
12.03
4.66
3.37
0.00
35.38
8.98
5.34
0.00
13.32
1.50
11.04
0.29
2.14
0.57
1.81
9.01
32.54
5.05
8.01
11.21
45.29
72.52
38.03
14.10
0.00
5.94
11.25
0.00
14.59
0.00
17.74
9.26
9.40
35.83
1.09
Diesel
Marine
0.01
0.20
0.08
0.19
0.03
0.08
0.06
0.05
0.01
0.04
0.40
0.11
0.07
0.65
0.09
0.04
0.05
0.03
0.30
0.03
0.03
0.01
1.77
1.15
0.04
1.11
0.35
259.26
0.94
0.29
0.93
1.70
18.19
12.53
111.06
4.59
16.73
5.72
4.83
47.81
1.04
0.42
Total
Diesel
Mobile
9
28
14
14
27
85
25
66
12
13
14
130
69
21
1
28
9
19
2
10
6
6
43
94
22
28
35
330
143
52
26
14
42
55
112
63
18
72
42
295
91
31
LM
Percent
60.3%
68.0%
37.1%
1 .3%
36.7%
30.8%
53.1%
18.2%
40.2%
26.9%
2.9%
27.4%
13.2%
29.0%
8.2%
47.3%
16.7%
58.6%
26.8%
22.0%
10.2%
28.3%
24.8%
36.0%
23.1%
32.2%
33.5%
92.2%
51.5%
73.3%
58.7%
12.3%
58.0%
43.6%
98.9%
30.3%
93.2%
32.7%
33.7%
19.4%
40.4%
4.9%
                                          128

-------
               Chapter 3: Inventory
FIPS
33015
47065
47115
47153
13047
13083
13295
17031
17043
17063
17089
17093
17097
17111
17197
18089
18127
18029
21015
21037
21117
39017
39025
39061
39165
39007
39035
39085
39093
39103
39133
39153
26093
26099
26115
26125
26147
26161
26163
48039
48071
48157
48167
48201
48291
MSA
Boston
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Houston
Houston
Houston
Houston
Houston
Houston
County
Rockingham
Hamilton
Marion
Sequatchie
Catoosa
Dade
Walker
Cook
DuPage
Grundy
Kane
Kendall
Lake
McHenry
Will
Lake
Porter
Dearborn
Boone
Campbell
Kenton
Butler
Clermont
Hamilton
Warren
Ashtabula
Cuyahoga
Lake
Lorain
Medina
Portage
Summit
Livingston
Macomb
Monroe
Oakland
St. Clair
Washtenaw
Wayne
B razor! a
Chambers
Fort Bend
Galveston
Harris
Liberty
ST
NH
TN
TN
TN
GA
GA
GA
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
IN
KY
KY
KY
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
Ml
Ml
Ml
Ml
Ml
Ml
Ml
TX
TX
TX
TX
TX
TX
2030 PM2.5
Diesel
Locomotive
0.82
36.91
5.16
0.00
11.18
10.61
0.00
583.11
150.13
12.86
55.63
7.87
28.70
15.86
154.37
129.63
39.03
5.39
7.70
14.53
28.15
38.73
1.68
38.03
5.88
26.16
73.82
17.97
42.97
13.67
26.81
21.98
2.25
3.49
16.47
13.69
6.63
3.80
29.36
17.11
0.97
23.77
13.22
67.89
26.15
Diesel
Marine
30.13
24.61
4.78
0.00
0.01
0.00
0.01
176.82
0.14
5.35
0.10
0.01
21.57
0.16
3.97
13.55
11.74
18.81
28.23
19.53
9.75
0.05
37.21
110.20
0.09
148.22
103.97
22.85
94.99
0.06
0.24
0.17
0.06
4.61
7.45
3.84
17.88
0.04
8.63
204.68
6.36
0.09
468.88
1,221.64
2.52
Total
Diesel
Mobile
56
85
15
1
15
14
5
1,069
227
29
91
16
96
37
195
186
68
30
46
40
49
64
53
216
26
185
280
57
165
30
45
63
20
56
42
108
44
35
151
242
12
52
500
1,557
37
LM
Percent
55.2%
72.5%
67.1%
0.0%
74.0%
76.7%
0.1%
71.1%
66.1%
62.4%
61 .3%
48.2%
52.5%
42.9%
81 .2%
77.1%
75.0%
79.5%
78.5%
85.6%
78.1%
60.4%
72.9%
68.7%
23.0%
94.4%
63.4%
71.2%
83.8%
45.8%
60.8%
35.3%
1 1 .7%
14.6%
56.9%
16.2%
55.4%
11.1%
25.1%
91 .5%
59.3%
45.9%
96.4%
82.8%
77.9%
129

-------
Draft Regulatory Impact Analysis
FIPS
48339
48473
21019
21127
39001
39053
39087
39145
54011
54053
54099
18011
18057
18059
18063
18081
18095
18097
18109
18145
20091
20103
20121
20209
29037
29047
29049
29095
29107
29165
29177
6037
6059
6065
6071
6111
27003
27019
27037
27053
27123
27139
27163
9001
MSA
Houston
Houston
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
New York
County
Montgomery
Waller
Boyd
Lawrence
Adams
Gallia
Lawrence
Scioto
Cabell
Mason
Wayne
Boone
Hamilton
Hancock
Hendricks
Johnson
Madison
Marion
Morgan
Shelby
Johnson
Leavenworth
Miami
Wyandotte
Cass
Clay
Clinton
Jackson
Lafayette
Platte
Ray
Los Angeles
Orange
Riverside
San
Bernardino
Ventura
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Fairfield
ST
TX
TX
KY
KY
OH
OH
OH
OH
WV
WV
WV
IN
IN
IN
IN
IN
IN
IN
IN
IN
KS
KS
KS
KS
MO
MO
MO
MO
MO
MO
MO
CA
CA
CA
CA
CA
MN
MN
MN
MN
MN
MN
MN
CT
2030 PM2.5
Diesel
Locomotive
20.38
5.92
10.05
8.93
0.34
2.94
10.68
23.91
21.94
5.03
27.75
5.59
0.18
4.35
15.52
1.02
13.96
26.79
0.46
6.23
50.70
13.00
74.26
27.42
15.11
27.23
0.00
85.76
21.17
20.65
42.32
214.05
57.93
87.56
306.89
10.79
19.16
0.05
11.47
28.80
10.87
2.46
20.93
0.00
Diesel
Marine
0.27
0.04
15.13
4.91
43.51
19.13
28.40
27.52
20.93
32.92
49.83
0.06
0.63
0.03
0.03
0.21
0.12
1.35
0.22
0.02
0.04
0.42
0.15
3.70
0.12
3.74
0.16
27.74
3.50
0.74
3.31
1,378.65
146.38
1.02
0.48
191.39
10.87
0.75
10.11
30.34
9.61
1.27
42.22
37.87
Total
Diesel
Mobile
49
10
29
15
48
26
43
58
49
42
82
19
26
16
33
14
29
98
10
17
101
21
81
43
26
48
6
171
36
35
53
2,053
433
189
400
247
51
10
51
153
56
14
81
112
LM
Percent
42.2%
58.2%
87.4%
90.7%
92.1%
85.9%
91 .2%
89.0%
86.9%
89.3%
95.0%
30.0%
3.1%
28.1%
46.7%
8.9%
47.9%
28.7%
6.6%
36.6%
50.4%
63.9%
91 .7%
71 .6%
59.1%
64.9%
2.9%
66.5%
68.5%
61 .6%
86.7%
77.6%
47.2%
46.8%
76.8%
81 .7%
59.0%
7.6%
42.4%
38.7%
36.4%
26.4%
78.3%
33.7%
                                      130

-------
               Chapter 3: Inventory
FIPS
9005
34003
34013
34017
34019
34023
34025
34027
34029
34031
34035
34037
34039
36005
36047
36059
36061
36071
36081
36085
36087
36103
36119
10003
24015
24029
24031
34005
34007
34011
34015
34021
34033
42017
42029
42045
42101
4013
4021
6019
6029
6031
6039
6047
6077
MSA
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Phoenix
Phoenix
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
County
Litchfield
Bergen
Essex
Hudson
Hunterdon
Middlesex
Monmouth
Morris
Ocean
Passaic
Somerset
Sussex
Union
Bronx
Kings
Nassau
New York
Orange
Queens
Richmond
Rockland
Suffolk
Westchester
New Castle
Cecil
Kent
Montgomery
Burlington
Camden
Cumberland
Gloucester
Mercer
Salem
Bucks
Chester
Delaware
Philadelphia
Maricopa
Pinal
Fresno
Kern
Kings
Madera
Merced
San Joaquin
ST
CT
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
DE
MD
MD
MD
NJ
NJ
NJ
NJ
NJ
NJ
PA
PA
PA
PA
AZ
AZ
CA
CA
CA
CA
CA
CA
2030 PM2.5
Diesel
Locomotive
0.00
20.91
4.68
18.73
6.78
10.49
5.78
4.44
0.36
3.75
10.24
1.10
7.68
0.12
0.00
0.00
0.00
7.53
0.05
0.00
6.09
0.00
0.00
23.04
7.20
0.06
19.61
0.00
3.05
0.64
0.83
4.21
0.26
1.82
8.44
3.48
5.93
85.15
46.98
15.23
76.62
1.98
16.55
14.48
25.33
Diesel
Marine
0.90
2.98
0.85
23.28
0.33
4.17
25.21
0.53
12.87
0.51
0.02
0.63
14.86
0.69
1.18
10.10
0.48
2.18
1.83
2.00
2.31
35.49
3.29
39.30
1.55
1.36
0.46
45.18
18.09
46.39
24.22
5.53
14.13
1.10
0.16
159.80
280.49
0.79
0.17
0.58
0.22
0.02
0.16
0.46
25.14
Total
Diesel
Mobile
13
89
50
79
25
63
75
42
39
30
32
13
59
38
77
78
168
39
103
19
23
118
61
105
20
6
78
76
49
58
45
38
22
44
46
188
347
425
71
101
145
21
32
41
100
LM
Percent
6.6%
26.9%
1 1 .0%
53.1%
28.1%
23.1%
41.6%
1 1 .9%
33.6%
14.0%
32.2%
12.9%
38.2%
2.1%
1 .5%
12.9%
0.3%
25.2%
1 .8%
10.3%
36.8%
30.1%
5.4%
59.6%
43.2%
22.2%
25.7%
59.6%
43.0%
81 .6%
55.3%
25.5%
65.7%
6.7%
18.8%
86.8%
82.6%
20.2%
66.3%
15.7%
52.9%
9.3%
52.1%
36.8%
50.3%
131

-------
Draft Regulatory Impact Analysis
FIPS
6099
6107
53029
53033
53035
53045
53053
53061
53067
17027
17083
17119
17133
17163
29055
29071
29099
29113
29183
29189
29219
29510
MSA
San Joaquin
San Joaquin
Seattle
Seattle
Seattle
Seattle
Seattle
Seattle
Seattle
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
County
Stanislaus
Tulare
Island
King
Kitsap
Mason
Pierce
Snohomish
Thurston
Clinton
Jersey
Madison
Monroe
St. Clair
Crawford
Franklin
Jefferson
Lincoln
St. Charles
St. Louis
Warren
St. Louis
ST
CA
CA
WA
WA
WA
WA
WA
WA
WA
IL
IL
IL
IL
IL
MO
MO
MO
MO
MO
MO
MO
MO
2030 PM2.5
Diesel
Locomotive
10.15
22.89
0.00
26.00
0.00
0.00
16.30
32.24
8.81
20.38
1.66
8.64
32.45
9.36
4.30
27.96
7.62
12.57
15.14
24.13
2.56
23.99
Diesel
Marine
0.23
0.16
16.34
159.80
1.28
0.57
144.03
24.77
10.12
0.08
15.78
8.56
13.84
16.36
0.04
2.00
14.04
5.60
12.62
16.08
1.95
216.11
Total
Diesel
Mobile
45
65
22
344
16
4
206
102
36
29
23
43
52
48
9
43
38
26
51
130
9
260
LM
Percent
23.3%
35.4%
75.7%
54.0%
8.1%
12.8%
77.8%
56.0%
53.2%
69.4%
76.4%
40.3%
88.4%
53.5%
50.9%
70.5%
57.1%
70.5%
54.2%
30.9%
49.3%
92.3%
                                      132

-------
                                                          Chapter 3: Inventory
Table 0-109 2002 Locomotive and Diesel Marine NOx Tons/Year and Percent of Total Mobile
                                    Sources
FIPS
13013
13015
13045
13057
13063
13067
13077
13089
13097
13113
13117
13121
13135
13139
13149
13151
13217
13223
13237
13247
13255
13297
24003
24005
24013
24025
24027
24510
1073
1117
1127
9007
25001
25005
25007
25009
25019
25021
25023
25025
25027
33011
33015
MSA
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Birmingham
Birmingham
Birmingham
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
County
Barrow
Bartow
Carroll
Cherokee
Clayton
Cobb
Coweta
DeKalb
Douglas
Fayette
Forsyth
Fulton
Gwinnett
Hall
Heard
Henry
Newton
Paulding
Putnam
Rockdale
Spalding
Walton
Anne Arundel
Baltimore
Carroll
Harford
Howard
Baltimore
Jefferson
Shelby
Walker
Middlesex
Barnstable
Bristol
Dukes
Essex
Nantucket
Norfolk
Plymouth
Suffolk
Worcester
Hillsbo rough
Rockingham
ST
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
MD
MD
MD
MD
MD
MD
AL
AL
AL
CT
MA
MA
MA
MA
MA
MA
MA
MA
MA
NH
NH
2002 NOx
Diesel
Locomotive
224.1
799.6
219.5
0.0
420.9
1,110.1
555.6
515.4
202.2
143.8
0.0
1,512.7
385.8
258.8
0.0
567.2
64.4
470.2
14.1
91.1
24.5
77.1
520.4
1,243.0
199.2
389.4
594.5
1,282.5
4,615.9
1,156.1
889.2
160.2
318.1
588.4
0.0
777.6
0.0
902.6
493.8
489.2
1,860.6
49.0
37.0
Diesel
Marine
0.5
7.0
3.0
6.8
1.0
2.8
2.0
1.8
0.5
1.3
14.1
3.8
2.5
23.1
3.3
1.3
1.8
1.0
10.6
1.0
1.0
0.5
63.4
41.5
1.3
40.2
12.7
1,670.4
268.9
10.4
116.8
121.4
474.3
238.7
1,589.6
197.2
282.5
163.4
169.6
855.0
36.5
15.0
1,112.9
Total
Mobile
2,039
5,172
4,762
5,828
9,512
23,542
5,727
26,283
3,952
3,977
4,418
39,991
21,343
6,452
465
6,479
3,584
3,801
630
3,158
2,584
2,211
15,497
24,021
5,995
7,894
8,160
23,591
32,416
6,159
3,687
282
8,446
15,719
2,042
21,303
596
22,498
12,655
38,095
26,614
12,444
1 1 ,846
LM
Percent
1 1 .0%
15.6%
4.7%
0.1%
4.4%
4.7%
9.7%
2.0%
5.1%
3.6%
0.3%
3.8%
1 .8%
4.4%
0.7%
8.8%
1 .8%
12.4%
3.9%
2.9%
1 .0%
3.5%
3.8%
5.3%
3.3%
5.4%
7.4%
12.5%
15.1%
18.9%
27.3%
99.8%
9.4%
5.3%
77.9%
4.6%
47.4%
4.7%
5.2%
3.5%
7.1%
0.5%
9.7%
                                         133

-------
Draft Regulatory Impact Analysis
FIPS
47065
47115
47153
13047
13083
13295
17031
17043
17063
17089
17093
17097
17111
17197
18089
18127
18029
21015
21037
21117
39017
39025
39061
39165
39007
39035
39085
39093
39103
39133
39153
26093
26099
26115
26125
26147
26161
26163
48039
48071
48157
48167
48201
48291
48339
48473
MSA
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Houston
Houston
Houston
Houston
Houston
Houston
Houston
Houston
County
Hamilton
Marion
Sequatchie
Catoosa
Dade
Walker
Cook
DuPage
Grundy
Kane
Kendall
Lake
McHenry
Will
Lake
Porter
Dearborn
Boone
Campbell
Kenton
Butler
Clermont
Hamilton
Warren
Ashtabula
Cuyahoga
Lake
Lorain
Medina
Portage
Summit
Livingston
Macomb
Monroe
Oakland
St. Clair
Washtenaw
Wayne
B razor! a
Chambers
Fort Bend
Galveston
Harris
Liberty
Montgomery
Waller
ST
TN
TN
TN
GA
GA
GA
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
IN
KY
KY
KY
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
Ml
Ml
Ml
Ml
Ml
Ml
Ml
TX
TX
TX
TX
TX
TX
TX
TX
2002 NOx
Diesel
Locomotive
1,569.2
220.0
0.0
475.9
452.1
0.0
24,769.1
7,028.5
479.6
2,446.9
310.8
1,301.3
700.7
6,401.5
4,656.8
1,588.7
216.3
327.3
621.1
1,197.5
1,581.9
68.2
1,540.5
235.3
1,062.3
2,914.2
738.0
1,749.1
551.8
1,090.9
888.7
95.5
148.2
700.2
584.1
285.7
154.9
1,133.9
728.4
41.6
1,019.2
491.0
2,609.1
1,115.9
867.4
252.5
Diesel
Marine
909.5
176.6
0.0
0.3
0.0
0.3
6,520.5
5.0
198.0
3.5
0.3
774.4
5.8
146.5
490.6
425.4
696.0
1,044.5
722.6
360.8
1.7
1,377.2
4,078.9
3.2
5,482.2
3,832.5
837.5
3,509.5
2.1
8.6
6.0
1.9
169.4
276.4
140.9
662.4
1.3
318.6
7,573.7
234.3
3.3
17,352.7
45,215.7
93.4
9.7
1.5
Total
Mobile
14,329
2,998
270
2,527
2,263
1,996
178,269
31,241
3,244
8,879
1,789
16,423
5,103
16,000
23,491
8,840
3,628
5,966
4,914
7,316
10,604
7,579
34,403
5,948
12,796
49,767
8,866
15,702
6,896
8,119
18,330
7,393
24,046
7,675
38,601
9,871
12,742
68,502
18,133
2,586
11,057
30,023
165,530
4,073
13,754
1,574
LM
Percent
17.3%
13.2%
0.0%
18.8%
20.0%
0.0%
17.6%
22.5%
20.9%
27.6%
17.4%
12.6%
13.8%
40.9%
21.9%
22.8%
25.1%
23.0%
27.3%
21 .3%
14.9%
19.1%
16.3%
4.0%
51.1%
13.6%
17.8%
33.5%
8.0%
13.5%
4.9%
1 .3%
1 .3%
12.7%
1 .9%
9.6%
1 .2%
2.1%
45.8%
10.7%
9.2%
59.4%
28.9%
29.7%
6.4%
16.1%
                                      134

-------
               Chapter 3: Inventory
FIPS
21019
21127
39001
39053
39087
39145
54011
54053
54099
18011
18057
18059
18063
18081
18095
18097
18109
18145
20091
20103
20121
20209
29037
29047
29049
29095
29107
29165
29177
6037
6059
6065
6071
6111
27003
27019
27037
27053
27123
27139
27163
9001
9005
34003
34013
MSA
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
New York
New York
New York
New York
County
Boyd
Lawrence
Adams
Gallia
Lawrence
Scioto
Cabell
Mason
Wayne
Boone
Hamilton
Hancock
Hendricks
Johnson
Madison
Marion
Morgan
Shelby
Johnson
Leavenworth
Miami
Wyandotte
Cass
Clay
Clinton
Jackson
Lafayette
Platte
Ray
Los Angeles
Orange
Riverside
San
Bernardino
Ventura
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Fairfield
Litchfield
Bergen
Essex
ST
KY
KY
OH
OH
OH
OH
WV
WV
WV
IN
IN
IN
IN
IN
IN
IN
IN
IN
KS
KS
KS
KS
MO
MO
MO
MO
MO
MO
MO
CA
CA
CA
CA
CA
MN
MN
MN
MN
MN
MN
MN
CT
CT
NJ
NJ
2002 NOx
Diesel
Locomotive
430.5
425.1
13.7
119.7
433.9
972.1
946.3
239.7
1,182.1
235.9
5.7
179.7
630.8
33.0
563.4
1,089.8
15.0
255.6
2,157.3
553.1
3,157.4
1,170.2
646.8
1,073.0
0.0
3,434.0
899.9
878.0
1,713.2
9,771.2
2,374.1
4,414.1
14,261.8
479.2
822.8
2.0
491.2
1,226.2
465.4
104.5
895.5
589.7
100.0
1,055.1
228.1
Diesel
Marine
559.8
181.8
1,610.6
708.1
1,051.2
1,018.7
774.1
1,218.0
1,844.2
2.1
22.6
1.2
1.2
7.6
4.3
48.3
8.0
0.9
1.4
15.5
5.5
137.0
4.4
137.9
5.8
1,026.2
129.2
26.9
122.5
42,754.8
2,363.7
56.3
26.3
4,087.6
399.5
27.0
371.9
1,117.3
353.7
46.1
1,560.4
257.5
31.6
193.9
51.3
Total
Mobile
3,171
1,317
3,248
2,184
3,946
4,780
9,978
2,909
4,489
3,600
7,413
3,342
5,968
4,964
6,314
33,822
3,634
3,130
18,312
2,984
4,481
7,329
3,752
8,204
1,517
30,133
3,796
5,793
3,190
257,574
68,174
45,019
56,392
18,815
10,508
2,563
11,559
42,042
18,199
2,947
9,536
28,368
4,615
23,136
21,624
LM
Percent
31 .2%
46.1%
50.0%
37.9%
37.6%
41 .7%
17.2%
50.1%
67.4%
6.6%
0.4%
5.4%
10.6%
0.8%
9.0%
3.4%
0.6%
8.2%
1 1 .8%
19.1%
70.6%
17.8%
17.4%
14.8%
0.4%
14.8%
27.1%
15.6%
57.5%
20.4%
6.9%
9.9%
25.3%
24.3%
1 1 .6%
1.1%
7.5%
5.6%
4.5%
5.1%
25.8%
3.0%
2.9%
5.4%
1 .3%
135

-------
Draft Regulatory Impact Analysis
FIPS
34017
34019
34023
34025
34027
34029
34031
34035
34037
34039
36005
36047
36059
36061
36071
36081
36085
36087
36103
36119
10003
24015
24029
24031
34005
34007
34011
34015
34021
34033
42017
42029
42045
42101
4013
4021
6019
6029
6031
6039
6047
6077
6099
6107
53029
53033
MSA
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Phoenix
Phoenix
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
Seattle
Seattle
County
Hudson
Hunterdon
Middlesex
Monmouth
Morris
Ocean
Passaic
Somerset
Sussex
Union
Bronx
Kings
Nassau
New York
Orange
Queens
Richmond
Rockland
Suffolk
Westchester
New Castle
Cecil
Kent
Montgomery
Burlington
Camden
Cumberland
Gloucester
Mercer
Salem
Bucks
Chester
Delaware
Philadelphia
Maricopa
Pinal
Fresno
Kern
Kings
Madera
Merced
San Joaquin
Stanislaus
Tulare
Island
King
ST
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
DE
MD
MD
MD
NJ
NJ
NJ
NJ
NJ
NJ
PA
PA
PA
PA
AZ
AZ
CA
CA
CA
CA
CA
CA
CA
CA
WA
WA
2002 NOx
Diesel
Locomotive
777.7
331.3
481.9
379.8
234.4
19.6
229.2
509.9
36.0
420.7
5.1
0.0
0.0
0.0
349.9
2.3
0.0
265.0
0.0
0.0
818.9
306.8
2.4
987.2
0.0
182.3
20.8
36.7
193.5
10.3
86.8
435.2
171.7
239.6
3,884.9
2,030.8
765.2
3,687.8
104.0
819.3
790.7
1,287.6
528.7
1,172.3
0.0
1,119.6
Diesel
Marine
1,486.3
11.7
282.2
682.3
18.7
435.6
18.1
0.6
22.2
1,084.1
203.9
1,713.6
586.4
1,207.0
80.2
2,056.4
2,386.5
16.6
1,361.4
127.5
2,545.5
56.0
48.8
16.9
1,178.2
471.7
1,242.9
633.3
144.7
374.9
40.0
5.7
5,914.4
10,381.6
28.0
6.2
32.2
12.0
1.1
8.9
25.4
603.0
12.5
8.9
2,098.3
5,906.0
Total
Mobile
16,558
7,327
19,497
17,750
13,461
12,234
11,334
8,259
4,546
14,897
18,301
36,548
22,268
44,035
13,475
39,760
8,667
4,886
27,455
16,193
21,119
5,150
984
23,771
13,449
13,996
5,472
10,121
12,609
3,009
13,732
12,150
18,361
44,901
105,636
10,844
24,853
27,768
4,389
5,469
9,353
18,977
12,862
13,310
3,999
68,488
LM
Percent
13.7%
4.7%
3.9%
6.0%
1 .9%
3.7%
2.2%
6.2%
1 .3%
10.1%
1.1%
4.7%
2.6%
2.7%
3.2%
5.2%
27.5%
5.8%
5.0%
0.8%
15.9%
7.0%
5.2%
4.2%
8.8%
4.7%
23.1%
6.6%
2.7%
12.8%
0.9%
3.6%
33.1%
23.7%
3.7%
18.8%
3.2%
13.3%
2.4%
15.1%
8.7%
10.0%
4.2%
8.9%
52.5%
10.3%
                                      136

-------
               Chapter 3: Inventory
FIPS
53035
53045
53053
53061
53067
17027
17083
17119
17133
17163
29055
29071
29099
29113
29183
29189
29219
29510
MSA
Seattle
Seattle
Seattle
Seattle
Seattle
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
County
Kitsap
Mason
Pierce
Snohomish
Thurston
Clinton
Jersey
Madison
Monroe
St. Clair
Crawford
Franklin
Jefferson
Lincoln
St. Charles
St. Louis
Warren
St. Louis
ST
WA
WA
WA
WA
WA
IL
IL
IL
IL
IL
MO
MO
MO
MO
MO
MO
MO
MO
2002 NOx
Diesel
Locomotive
0.0
0.1
703.0
1,279.7
369.2
801.1
64.8
287.0
1,288.0
325.2
204.7
1,206.1
324.2
534.3
643.6
1,035.3
109.1
866.5
Diesel
Marine
45.6
26.7
5,327.1
912.6
373.3
2.8
583.9
316.7
512.0
605.6
1.5
73.8
519.4
206.8
465.6
594.2
71.9
7,998.7
Total
Mobile
6,933
1,679
27,443
20,798
8,518
2,597
1,759
10,200
3,122
10,049
2,080
6,434
9,205
2,771
10,406
41,254
1,692
23,595
LM
Percent
0.7%
1 .6%
22.0%
10.5%
8.7%
31 .0%
36.9%
5.9%
57.7%
9.3%
9.9%
19.9%
9.2%
26.7%
10.7%
4.0%
10.7%
37.6%
137

-------
Draft Regulatory Impact Analysis
 Table 0-110 2020 Locomotive and Diesel Marine NOx Tons/Year and Percent of Total Mobile
                                     Sources
FIPS
13013
13015
13045
13057
13063
13067
13077
13089
13097
13113
13117
13121
13135
13139
13149
13151
13217
13223
13237
13247
13255
13297
24003
24005
24013
24025
24027
24510
1073
1117
1127
9007
25001
25005
25007
25009
25019
25021
25023
25025
25027
33011
33015
MSA
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Birmingham
Birmingham
Birmingham
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
County
Barrow
Bartow
Carroll
Cherokee
Clayton
Cobb
Coweta
DeKalb
Douglas
Fayette
Forsyth
Fulton
Gwinnett
Hall
Heard
Henry
Newton
Paulding
Putnam
Rockdale
Spalding
Walton
Anne Arundel
Baltimore
Carroll
Harford
Howard
Baltimore
Jefferson
Shelby
Walker
Middlesex
Barnstable
Bristol
Dukes
Essex
Nantucket
Norfolk
Plymouth
Suffolk
Worcester
Hillsbo rough
Rockingham
ST
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
MD
MD
MD
MD
MD
MD
AL
AL
AL
CT
MA
MA
MA
MA
MA
MA
MA
MA
MA
NH
NH
2020 NOx
Diesel
Locomotive
189.4
675.7
183.4
0.0
355.6
933.8
469.5
433.1
168.0
121.5
0.0
1,272.1
323.3
186.3
0.0
479.3
54.4
397.3
10.3
77.0
20.7
65.1
306.6
936.5
145.4
251.7
366.4
1,186.5
4,173.3
1,026.2
649.1
110.6
232.2
436.1
0.0
567.6
0.0
682.9
363.1
362.6
1,382.7
35.8
27.0
Diesel
Marine
0.6
8.5
3.6
8.1
1.2
3.3
2.4
2.1
0.6
1.5
16.9
4.5
3.0
27.8
3.9
1.5
2.1
1.2
12.7
1.2
1.2
0.6
71.4
45.1
1.5
42.9
10.6
1,357.0
221.1
12.5
97.7
121.2
490.2
214.3
1,332.0
201.2
256.8
140.1
191.5
703.7
43.9
18.0
928.5
Total
Mobile
682
1,838
1,404
1,834
3,382
7,245
1,995
7,494
1,353
1,333
1,392
15,332
6,226
1,919
128
2,241
996
1,372
202
1,026
728
664
8,342
11,487
2,579
3,608
3,859
15,594
12,112
2,492
1,530
233
4,681
7,364
1,732
9,768
530
10,197
6,163
17,700
12,067
6,327
6,652
LM
Percent
27.9%
37.2%
13.3%
0.4%
10.6%
12.9%
23.7%
5.8%
12.5%
9.2%
1 .2%
8.3%
5.2%
1 1 .2%
3.1%
21 .5%
5.7%
29.0%
1 1 .4%
7.6%
3.0%
9.9%
4.5%
8.5%
5.7%
8.2%
9.8%
16.3%
36.3%
41 .7%
48.8%
99.6%
15.4%
8.8%
76.9%
7.9%
48.4%
8.1%
9.0%
6.0%
1 1 .8%
0.8%
14.4%
                                          138

-------
               Chapter 3: Inventory
FIPS
47065
47115
47153
13047
13083
13295
17031
17043
17063
17089
17093
17097
17111
17197
18089
18127
18029
21015
21037
21117
39017
39025
39061
39165
39007
39035
39085
39093
39103
39133
39153
26093
26099
26115
26125
26147
26161
26163
48039
48071
48157
48167
48201
48291
48339
48473
MSA
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Houston
Houston
Houston
Houston
Houston
Houston
Houston
Houston
County
Hamilton
Marion
Sequatchie
Catoosa
Dade
Walker
Cook
DuPage
Grundy
Kane
Kendall
Lake
McHenry
Will
Lake
Porter
Dearborn
Boone
Campbell
Kenton
Butler
Clermont
Hamilton
Warren
Ashtabula
Cuyahoga
Lake
Lorain
Medina
Portage
Summit
Livingston
Macomb
Monroe
Oakland
St. Clair
Washtenaw
Wayne
B razor! a
Chambers
Fort Bend
Galveston
Harris
Liberty
Montgomery
Waller
ST
TN
TN
TN
GA
GA
GA
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
IN
KY
KY
KY
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
Ml
Ml
Ml
Ml
Ml
Ml
Ml
TX
TX
TX
TX
TX
TX
TX
TX
2020 NOx
Diesel
Locomotive
1,326.0
185.9
0.0
402.1
382.0
0.0
18,683.3
4,853.4
436.8
1,791.2
253.3
930.4
496.6
4,767.5
4,582.7
1,239.8
172.0
276.6
522.3
1,011.3
1,225.0
53.0
1,208.2
188.0
833.8
2,405.6
568.9
1,360.5
438.3
851.4
702.5
80.7
125.2
591.7
492.0
238.4
137.0
1,064.0
615.5
35.1
855.7
481.5
2,463.1
940.8
732.9
213.4
Diesel
Marine
749.8
148.4
0.0
0.3
0.0
0.3
5,549.0
5.9
161.9
4.2
0.3
886.7
7.0
122.8
527.6
449.0
565.9
850.5
588.4
293.3
2.0
1,117.4
3,308.4
3.8
4,487.1
3,286.2
773.0
2,917.8
2.5
10.3
7.2
2.3
151.8
231.4
117.6
552.6
1.6
284.1
6,160.6
208.0
4.0
14,101.9
36,663.4
77.6
11.6
1.8
Total
Mobile
5,500
1,048
73
953
814
555
69,728
11,856
1,367
3,786
774
6,916
1,870
7,685
12,632
4,478
1,708
3,457
2,204
2,771
3,504
3,185
13,388
1,673
9,441
18,923
3,859
8,463
1,945
2,483
4,985
2,010
7,234
2,799
12,011
4,414
3,811
23,915
12,492
1,047
4,021
24,831
88,044
1,866
4,332
593
LM
Percent
37.7%
31 .9%
0.0%
42.2%
46.9%
0.1%
34.8%
41 .0%
43.8%
47.4%
32.7%
26.3%
26.9%
63.6%
40.5%
37.7%
43.2%
32.6%
50.4%
47.1%
35.0%
36.7%
33.7%
1 1 .5%
56.4%
30.1%
34.8%
50.5%
22.7%
34.7%
14.2%
4.1%
3.8%
29.4%
5.1%
17.9%
3.6%
5.6%
54.2%
23.2%
21 .4%
58.7%
44.4%
54.6%
17.2%
36.3%
139

-------
Draft Regulatory Impact Analysis
FIPS
21019
21127
39001
39053
39087
39145
54011
54053
54099
18011
18057
18059
18063
18081
18095
18097
18109
18145
20091
20103
20121
20209
29037
29047
29049
29095
29107
29165
29177
6037
6059
6065
6071
6111
27003
27019
27037
27053
27123
27139
27163
9001
9005
34003
34013
MSA
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
New York
New York
New York
New York
County
Boyd
Lawrence
Adams
Gallia
Lawrence
Scioto
Cabell
Mason
Wayne
Boone
Hamilton
Hancock
Hendricks
Johnson
Madison
Marion
Morgan
Shelby
Johnson
Leavenworth
Miami
Wyandotte
Cass
Clay
Clinton
Jackson
Lafayette
Platte
Ray
Los Angeles
Orange
Riverside
San
Bernardino
Ventura
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Fairfield
Litchfield
Bergen
Essex
ST
KY
KY
OH
OH
OH
OH
WV
WV
WV
IN
IN
IN
IN
IN
IN
IN
IN
IN
KS
KS
KS
KS
MO
MO
MO
MO
MO
MO
MO
CA
CA
CA
CA
CA
MN
MN
MN
MN
MN
MN
MN
CT
CT
NJ
NJ
2020 NOx
Diesel
Locomotive
361.2
310.3
10.6
93.0
337.7
755.3
789.0
175.0
997.3
178.0
6.4
138.0
490.3
37.1
444.2
851.8
16.9
197.5
1,821.4
467.1
2,667.9
985.3
543.2
984.8
0.0
3,099.6
760.4
741.9
1,528.5
8,078.6
2,064.2
3,206.9
10,808.1
380.6
688.9
1.7
412.2
1,034.8
390.6
88.3
752.2
497.8
112.5
778.5
153.0
Diesel
Marine
454.4
147.8
1,305.9
574.4
852.5
826.2
630.5
993.3
1,498.1
2.5
27.1
1.4
1.4
9.1
5.2
58.0
9.6
1.0
1.7
13.3
6.6
111.7
5.2
118.0
7.0
837.4
109.5
25.2
101.4
34,699.8
1,935.3
67.6
31.6
3,334.9
350.5
29.2
322.9
960.2
306.8
47.8
1,287.7
269.3
37.9
164.7
43.8
Total
Mobile
1,599
706
2,379
1,310
2,252
2,737
10,401
2,088
3,047
1,171
2,259
1,042
1,989
1,445
2,073
11,238
1,015
1,011
6,851
1,177
3,085
2,919
1,476
3,214
435
12,014
1,724
2,964
2,106
126,737
27,820
18,781
26,747
9,593
4,088
848
4,372
16,513
6,337
1,053
4,813
13,775
2,050
1 1 ,244
11,579
LM
Percent
51 .0%
64.9%
55.3%
50.9%
52.8%
57.8%
13.6%
56.0%
81 .9%
15.4%
1 .5%
13.4%
24.7%
3.2%
21 .7%
8.1%
2.6%
19.6%
26.6%
40.8%
86.7%
37.6%
37.1%
34.3%
1 .6%
32.8%
50.5%
25.9%
77.4%
33.8%
14.4%
17.4%
40.5%
38.7%
25.4%
3.6%
16.8%
12.1%
1 1 .0%
12.9%
42.4%
5.6%
7.3%
8.4%
1 .7%
                                      140

-------
               Chapter 3: Inventory
FIPS
34017
34019
34023
34025
34027
34029
34031
34035
34037
34039
36005
36047
36059
36061
36071
36081
36085
36087
36103
36119
10003
24015
24029
24031
34005
34007
34011
34015
34021
34033
42017
42029
42045
42101
4013
4021
6019
6029
6031
6039
6047
6077
6099
6107
53029
53033
MSA
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Phoenix
Phoenix
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
Seattle
Seattle
County
Hudson
Hunterdon
Middlesex
Monmouth
Morris
Ocean
Passaic
Somerset
Sussex
Union
Bronx
Kings
Nassau
New York
Orange
Queens
Richmond
Rockland
Suffolk
Westchester
New Castle
Cecil
Kent
Montgomery
Burlington
Camden
Cumberland
Gloucester
Mercer
Salem
Bucks
Chester
Delaware
Philadelphia
Maricopa
Pinal
Fresno
Kern
Kings
Madera
Merced
San Joaquin
Stanislaus
Tulare
Island
King
ST
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
DE
MD
MD
MD
NJ
NJ
NJ
NJ
NJ
NJ
PA
PA
PA
PA
AZ
AZ
CA
CA
CA
CA
CA
CA
CA
CA
WA
WA
2020 NOx
Diesel
Locomotive
620.9
218.2
393.0
216.0
149.1
13.6
139.0
368.6
40.5
278.8
4.3
0.0
0.0
0.0
270.9
2.0
0.0
219.1
0.0
0.0
803.4
213.9
1.8
627.6
0.0
111.6
23.4
38.0
133.5
9.3
65.3
304.0
125.2
215.5
3,043.5
1,689.8
596.5
2,751.1
72.7
652.3
574.3
980.7
401.8
905.5
0.0
935.0
Diesel
Marine
1,217.1
14.0
235.8
617.7
22.5
500.0
21.8
0.7
26.7
880.2
170.4
1,397.7
506.2
980.8
70.5
1,679.8
1,942.3
19.6
1,342.6
117.2
2,069.6
56.2
53.8
15.6
963.9
385.6
1,063.5
520.5
119.1
315.8
40.8
6.8
4,798.6
8,420.9
33.6
7.5
38.7
14.4
1.4
10.6
30.5
496.4
14.8
10.6
1,709.1
4,874.1
Total
Mobile
8,314
2,859
9,099
8,620
6,081
6,071
5,226
3,670
1,901
7,151
8,855
18,231
11,407
31,145
6,487
22,109
4,992
2,500
14,755
7,870
11,598
2,142
541
12,024
6,299
7,049
3,128
6,743
5,604
1,442
6,119
5,242
12,519
28,921
36,074
4,626
9,566
11,518
1,747
2,530
3,697
7,856
4,881
5,493
2,406
26,130
LM
Percent
22.1%
8.1%
6.9%
9.7%
2.8%
8.5%
3.1%
10.1%
3.5%
16.2%
2.0%
7.7%
4.4%
3.1%
5.3%
7.6%
38.9%
9.6%
9.1%
1 .5%
24.8%
12.6%
10.3%
5.3%
15.3%
7.1%
34.8%
8.3%
4.5%
22.5%
1 .7%
5.9%
39.3%
29.9%
8.5%
36.7%
6.6%
24.0%
4.2%
26.2%
16.4%
18.8%
8.5%
16.7%
71.1%
22.2%
141

-------
Draft Regulatory Impact Analysis
FIPS
53035
53045
53053
53061
53067
17027
17083
17119
17133
17163
29055
29071
29099
29113
29183
29189
29219
29510
MSA
Seattle
Seattle
Seattle
Seattle
Seattle
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
County
Kitsap
Mason
Pierce
Snohomish
Thurston
Clinton
Jersey
Madison
Monroe
St. Clair
Crawford
Franklin
Jefferson
Lincoln
St. Charles
St. Louis
Warren
St. Louis
ST
WA
WA
WA
WA
WA
IL
IL
IL
IL
IL
MO
MO
MO
MO
MO
MO
MO
MO
2020 NOx
Diesel
Locomotive
0.0
0.1
586.2
1,050.1
267.7
653.3
54.0
321.8
1,017.1
339.2
149.4
1,005.6
273.6
451.5
543.8
867.4
92.1
874.5
Diesel
Marine
54.6
28.7
4,359.7
779.7
317.1
3.4
473.6
257.9
415.5
491.8
1.7
63.6
424.7
172.5
393.2
489.5
61.3
6,486.7
Total
Mobile
2,268
541
12,505
7,046
3,088
1,223
1,104
3,094
2,060
3,360
640
2,226
2,736
1,301
3,393
12,921
595
13,766
LM
Percent
2.4%
5.3%
39.6%
26.0%
18.9%
53.7%
47.8%
18.7%
69.5%
24.7%
23.6%
48.0%
25.5%
48.0%
27.6%
10.5%
25.8%
53.5%
                                      142

-------
                                                          Chapter 3: Inventory
Table 0-111 2030 Locomotive and Diesel Marine NOx Tons/Year and Percent of Total Mobile
                                    Sources
FIPS
13013
13015
13045
13057
13063
13067
13077
13089
13097
13113
13117
13121
13135
13139
13149
13151
13217
13223
13237
13247
13255
13297
24003
24005
24013
24025
24027
24510
1073
1117
1127
9007
25001
25005
25007
25009
25019
25021
25023
25025
25027
33011
33015
MSA
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Atlanta
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Baltimore
Birmingham
Birmingham
Birmingham
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
Boston
County
Barrow
Bartow
Carroll
Cherokee
Clayton
Cobb
Coweta
DeKalb
Douglas
Fayette
Forsyth
Fulton
Gwinnett
Hall
Heard
Henry
Newton
Paulding
Putnam
Rockdale
Spalding
Walton
Anne Arundel
Baltimore
Carroll
Harford
Howard
Baltimore
Jefferson
Shelby
Walker
Middlesex
Barnstable
Bristol
Dukes
Essex
Nantucket
Norfolk
Plymouth
Suffolk
Worcester
Hillsbo rough
Rockingham
ST
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
GA
MD
MD
MD
MD
MD
MD
AL
AL
AL
CT
MA
MA
MA
MA
MA
MA
MA
MA
MA
NH
NH
2030 NOx
Diesel
Locomotive
186.5
665.4
180.2
0.0
350.2
918.9
462.3
426.2
165.0
119.7
0.0
1,251.8
318.0
185.4
0.0
472.0
53.5
391.3
10.3
75.8
20.4
64.1
285.6
896.2
145.3
242.3
347.0
1,142.1
4,081.7
1,005.0
648.6
105.1
232.0
435.3
0.0
567.2
0.0
679.2
362.5
360.0
1,368.9
35.8
27.0
Diesel
Marine
0.7
9.2
3.9
8.8
1.3
3.6
2.6
2.3
0.7
1.6
18.3
4.9
3.3
30.1
4.3
1.6
2.3
1.3
13.8
1.3
1.3
0.7
76.7
48.2
1.7
45.7
10.7
1,365.5
223.2
13.6
99.0
127.5
518.9
220.7
1,350.2
212.4
265.1
142.8
205.8
710.3
47.6
19.5
940.3
Total
Mobile
583
1,596
1,168
1,502
2,912
5,714
1,676
5,791
1,146
1,109
1,115
13,644
4,804
1,581
100
1,860
800
1,152
169
848
597
550
8,572
11,329
2,442
3,508
3,770
17,705
10,639
2,211
1,403
234
4,797
7,523
1,773
9,820
551
10,138
6,197
16,310
11,980
6,461
6,892
LM
Percent
32.1%
42.3%
15.8%
0.6%
12.1%
16.1%
27.7%
7.4%
14.5%
10.9%
1 .6%
9.2%
6.7%
13.6%
4.3%
25.5%
7.0%
34.1%
14.2%
9.1%
3.6%
1 1 .8%
4.2%
8.3%
6.0%
8.2%
9.5%
14.2%
40.5%
46.1%
53.3%
99.4%
15.7%
8.7%
76.2%
7.9%
48.1%
8.1%
9.2%
6.6%
1 1 .8%
0.9%
14.0%
                                         143

-------
Draft Regulatory Impact Analysis
FIPS
47065
47115
47153
13047
13083
13295
17031
17043
17063
17089
17093
17097
17111
17197
18089
18127
18029
21015
21037
21117
39017
39025
39061
39165
39007
39035
39085
39093
39103
39133
39153
26093
26099
26115
26125
26147
26161
26163
48039
48071
48157
48167
48201
48291
48339
48473
MSA
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chattanooga
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Chicago
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cincinnati
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Cleveland
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Detroit
Houston
Houston
Houston
Houston
Houston
Houston
Houston
Houston
County
Hamilton
Marion
Sequatchie
Catoosa
Dade
Walker
Cook
DuPage
Grundy
Kane
Kendall
Lake
McHenry
Will
Lake
Porter
Dearborn
Boone
Campbell
Kenton
Butler
Clermont
Hamilton
Warren
Ashtabula
Cuyahoga
Lake
Lorain
Medina
Portage
Summit
Livingston
Macomb
Monroe
Oakland
St. Clair
Washtenaw
Wayne
B razor! a
Chambers
Fort Bend
Galveston
Harris
Liberty
Montgomery
Waller
ST
TN
TN
TN
GA
GA
GA
IL
IL
IL
IL
IL
IL
IL
IL
IN
IN
IN
KY
KY
KY
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
OH
Ml
Ml
Ml
Ml
Ml
Ml
Ml
TX
TX
TX
TX
TX
TX
TX
TX
2030 NOx
Diesel
Locomotive
1,305.7
183.1
0.0
395.9
376.2
0.0
18,514.9
4,720.6
427.7
1,750.8
250.2
906.2
488.4
4,733.7
4,451.2
1,230.3
171.1
272.4
514.0
995.8
1,215.2
52.6
1,200.0
187.1
826.5
2,374.0
563.9
1,350.4
435.4
844.5
696.4
79.5
123.3
582.6
484.2
234.3
135.7
1,061.8
606.1
34.6
841.8
483.0
2,459.9
926.1
721.7
210.1
Diesel
Marine
757.2
150.6
0.0
0.3
0.0
0.3
5,645.1
6.5
163.2
4.6
0.4
955.2
7.6
124.5
562.4
477.1
569.5
856.3
592.5
295.2
2.2
1,124.0
3,327.7
4.2
4,523.2
3,348.9
800.5
2,952.3
2.7
11.2
7.8
2.5
156.2
234.6
119.1
559.6
1.7
292.0
6,200.9
213.6
4.3
14,191.0
36,874.9
78.5
12.6
1.9
Total
Mobile
5,151
932
56
830
699
438
63,116
10,269
1,168
3,281
641
6,310
1,548
7,002
12,715
4,520
1,694
3,615
2,128
2,456
2,901
3,076
12,598
1,261
10,335
17,334
3,676
8,584
1,508
2,012
3,944
1,589
6,116
2,409
10,112
4,539
3,199
21,886
13,541
964
3,437
27,937
91,005
1,679
3,561
497
LM
Percent
40.1%
35.8%
0.0%
47.8%
53.8%
0.1%
38.3%
46.0%
50.6%
53.5%
39.1%
29.5%
32.0%
69.4%
39.4%
37.8%
43.7%
31 .2%
52.0%
52.6%
42.0%
38.2%
35.9%
15.2%
51 .8%
33.0%
37.1%
50.1%
29.1%
42.5%
17.9%
5.2%
4.6%
33.9%
6.0%
17.5%
4.3%
6.2%
50.3%
25.8%
24.6%
52.5%
43.2%
59.8%
20.6%
42.7%
                                      144

-------
               Chapter 3: Inventory
FIPS
21019
21127
39001
39053
39087
39145
54011
54053
54099
18011
18057
18059
18063
18081
18095
18097
18109
18145
20091
20103
20121
20209
29037
29047
29049
29095
29107
29165
29177
6037
6059
6065
6071
6111
27003
27019
27037
27053
27123
27139
27163
9001
9005
34003
34013
MSA
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Huntington
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Indianapolis
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Kansas City
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Los Angeles
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
Minneapolis
New York
New York
New York
New York
County
Boyd
Lawrence
Adams
Gallia
Lawrence
Scioto
Cabell
Mason
Wayne
Boone
Hamilton
Hancock
Hendricks
Johnson
Madison
Marion
Morgan
Shelby
Johnson
Leavenworth
Miami
Wyandotte
Cass
Clay
Clinton
Jackson
Lafayette
Platte
Ray
Los Angeles
Orange
Riverside
San
Bernardino
Ventura
Anoka
Carver
Dakota
Hennepin
Ramsey
Scott
Washington
Fairfield
Litchfield
Bergen
Essex
ST
KY
KY
OH
OH
OH
OH
WV
WV
WV
IN
IN
IN
IN
IN
IN
IN
IN
IN
KS
KS
KS
KS
MO
MO
MO
MO
MO
MO
MO
CA
CA
CA
CA
CA
MN
MN
MN
MN
MN
MN
MN
CT
CT
NJ
NJ
2030 NOx
Diesel
Locomotive
355.3
310.0
10.5
92.3
335.2
749.9
775.3
174.8
981.9
175.6
6.6
136.6
486.8
37.8
440.3
845.5
17.2
195.8
1,793.4
460.0
2,627.2
969.7
534.4
980.2
0.0
3,078.5
748.8
730.6
1,515.9
8,037.8
2,064.0
3,176.5
10,729.1
379.6
677.4
1.7
405.5
1,018.8
384.3
86.9
740.1
484.0
114.5
756.3
146.0
Diesel
Marine
457.1
148.8
1,313.4
577.8
857.5
831.1
634.9
1,000.4
1,507.4
2.7
29.4
1.6
1.6
9.9
5.6
62.9
10.4
1.1
1.8
13.6
7.1
112.5
5.7
120.2
7.6
843.5
111.3
26.2
102.4
34,907.8
1,951.1
73.4
34.3
3,359.2
359.0
31.1
330.0
979.0
313.5
50.7
1,300.7
285.7
41.2
167.5
44.6
Total
Mobile
1,606
704
2,628
1,377
2,351
2,788
13,900
2,292
3,047
922
1,804
816
1,616
1,158
1,721
9,848
785
797
5,960
1,012
2,928
2,648
1,248
2,864
320
10,916
1,515
2,855
1,995
110,332
22,503
12,138
20,287
8,627
3,678
683
3,860
15,108
5,585
871
4,730
13,975
2,010
11,281
13,693
LM
Percent
50.6%
65.2%
50.4%
48.7%
50.7%
56.7%
10.1%
51 .3%
81 .7%
19.3%
2.0%
16.9%
30.2%
4.1%
25.9%
9.2%
3.5%
24.7%
30.1%
46.8%
90.0%
40.9%
43.3%
38.4%
2.4%
35.9%
56.8%
26.5%
81.1%
38.9%
17.8%
26.8%
53.1%
43.3%
28.2%
4.8%
19.1%
13.2%
12.5%
15.8%
43.1%
5.5%
7.7%
8.2%
1 .4%
145

-------
Draft Regulatory Impact Analysis
FIPS
34017
34019
34023
34025
34027
34029
34031
34035
34037
34039
36005
36047
36059
36061
36071
36081
36085
36087
36103
36119
10003
24015
24029
24031
34005
34007
34011
34015
34021
34033
42017
42029
42045
42101
4013
4021
6019
6029
6031
6039
6047
6077
6099
6107
53029
53033
MSA
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
New York
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Philadelphia
Phoenix
Phoenix
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
San Joaquin
Seattle
Seattle
County
Hudson
Hunterdon
Middlesex
Monmouth
Morris
Ocean
Passaic
Somerset
Sussex
Union
Bronx
Kings
Nassau
New York
Orange
Queens
Richmond
Rockland
Suffolk
Westchester
New Castle
Cecil
Kent
Montgomery
Burlington
Camden
Cumberland
Gloucester
Mercer
Salem
Bucks
Chester
Delaware
Philadelphia
Maricopa
Pinal
Fresno
Kern
Kings
Madera
Merced
San Joaquin
Stanislaus
Tulare
Island
King
ST
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NJ
NY
NY
NY
NY
NY
NY
NY
NY
NY
NY
DE
MD
MD
MD
NJ
NJ
NJ
NJ
NJ
NJ
PA
PA
PA
PA
AZ
AZ
CA
CA
CA
CA
CA
CA
CA
CA
WA
WA
2030 NOx
Diesel
Locomotive
596.4
210.5
377.1
196.7
138.6
12.6
129.1
358.4
41.2
265.7
4.3
0.0
0.0
0.0
263.2
1.9
0.0
215.1
0.0
0.0
781.2
210.9
1.8
593.4
0.0
104.7
23.8
36.9
131.1
9.4
63.2
290.2
120.5
213.8
3,019.1
1,660.1
590.6
2,741.2
71.7
644.9
573.0
974.8
398.9
898.7
0.0
919.1
Diesel
Marine
1,227.0
15.2
238.9
637.0
24.4
539.0
23.6
0.8
29.0
885.6
172.6
1,407.8
516.6
987.0
72.3
1,692.5
1,955.3
21.3
1,408.8
121.2
2,083.0
59.2
57.6
16.1
971.5
388.6
1,083.2
525.2
120.3
320.5
43.1
7.4
4,827.0
8,470.2
36.5
8.1
42.0
15.7
1.5
11.5
33.1
501.1
16.0
11.5
1,720.9
4,923.0
Total
Mobile
1 1 ,022
2,703
10,943
8,926
5,958
6,186
5,198
3,620
1,794
8,205
9,872
23,002
11,386
17,781
6,601
24,125
6,930
2,459
14,851
8,399
12,157
2,059
506
12,274
6,198
7,322
3,125
7,922
5,616
1,393
6,003
5,004
13,735
31,412
18,989
4,001
5,860
7,256
902
1,488
2,108
5,322
2,978
3,414
2,318
23,930
LM
Percent
16.5%
8.4%
5.6%
9.3%
2.7%
8.9%
2.9%
9.9%
3.9%
14.0%
1 .8%
6.1%
4.5%
5.6%
5.1%
7.0%
28.2%
9.6%
9.5%
1 .4%
23.6%
13.1%
1 1 .7%
5.0%
15.7%
6.7%
35.4%
7.1%
4.5%
23.7%
1 .8%
5.9%
36.0%
27.6%
16.1%
41 .7%
10.8%
38.0%
8.1%
44.1%
28.7%
27.7%
13.9%
26.7%
74.2%
24.4%
                                      146

-------
               Chapter 3: Inventory
FIPS
53035
53045
53053
53061
53067
17027
17083
17119
17133
17163
29055
29071
29099
29113
29183
29189
29219
29510
MSA
Seattle
Seattle
Seattle
Seattle
Seattle
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
St. Louis
County
Kitsap
Mason
Pierce
Snohomish
Thurston
Clinton
Jersey
Madison
Monroe
St. Clair
Crawford
Franklin
Jefferson
Lincoln
St. Charles
St. Louis
Warren
St. Louis
ST
WA
WA
WA
WA
WA
IL
IL
IL
IL
IL
MO
MO
MO
MO
MO
MO
MO
MO
2030 NOx
Diesel
Locomotive
0.0
0.1
576.1
1,033.3
266.9
645.5
53.2
312.6
1,008.1
328.1
149.3
988.2
269.4
444.6
535.5
853.1
90.7
880.1
Diesel
Marine
59.2
30.6
4,394.7
793.9
322.4
3.7
476.4
259.6
417.9
494.8
1.9
64.9
428.0
174.7
399.3
494.2
62.4
6,524.3
Total
Mobile
1,921
449
12,254
6,039
2,775
1,056
1,134
2,469
2,049
2,832
526
1,850
2,271
1,179
2,847
11,003
503
14,654
LM
Percent
3.1%
6.8%
40.6%
30.3%
21 .2%
61 .4%
46.7%
23.2%
69.6%
29.1%
28.7%
56.9%
30.7%
52.5%
32.8%
12.2%
30.4%
50.5%
147

-------
Draft Regulatory Impact Analysis
                                          References
1 "Calculation of Age Distributions in the Nonroad Model: Growth and Scrappage," EPA420-R-05-
018, December 2005.  The report is available online at
http://epa.gov/otaq/models/nonrdmdl/nonrdmdl2005/420r05018.pdf

2 "Exhaust and Crankcase Emission Factors for Nonroad Engine Modeling—Compression-Ignition,"
EPA420-P-04-009, April 2004. The report is available online at
http://epa.gov/otaq/models/nonrdmdl/nonrdmdl2004/420p04009.pdf

3 "Conversion Factors for Hydrocarbon Emission Components," EPA420-R-05-015, December 2005.
The report is available online at http://epa.gov/otaq/models/nonrdmdl/nonrdmdl2005/420r05015.pdf

4 "Final Regulatory Analysis: Control of Emissions from Nonroad Diesel Engines," EPA420-R-04-
007, May 2004.  Docket EPA-HQ-OAR-2003-0012. The RIA is also available online at
http://epa.gov/nonroad-diesel/2004fr/420r04007.pdf

5 "National Scale Modeling of Air Toxics for the Mobile Source Air Toxics Rule; Technical Support
Document," EPA-454/R-06-002, January 2006. The report is available online at
http://www.epa.gov/otaq/regs/toxics/454r06002.pdf

6 "Final Regulatory Impact Analysis: Control of Emissions from Marine Diesel Engines," EPA-420-R-
99-026, November 1999. Docket A-97-50. The report is also available online at
http://www.epa.gov/otaq/regs/nonroad/marine/ci/fr/ria.pdf

7 Telephone conversation with Doug Scheffler, American Waterways Operators, May 4, 2006.

8 "Annual Energy Outlook 2006," Energy Information Administration, Report f :DOE/EIA-
0383(2006), February 2006, Table A7. The report is available online at
http://www.eia.doe.gov/oiaf/archive/aeo06/pdf/0383 (2006).pdf

9 Swedish Methodology for Environmental Data (SMED), "Methodology for calculating emissions
from ships: 1. Update of emission factors," November 4, 2004.

10  Eastern Research Group, Inc.  (ERG),  [insert final report date] Category 1 and 2 Marine Propulsion
Engine Activity, Port/Underway Splits and Category 2 County Allocation. Prepared for U.S
Environmental Protection Agency,  Office of Transportation and Air Quality.

11 "Commercial Marine Emissions Inventory for EPA Category 2 and 3 Compression Ignition Marine
Engines in the United States and Continental Waterways," EPA420-R-98-020, August, 1998. The
report is also available online at http://www.epa.gov/otaq/regs/nonroad/marine/ci/fr/r98020.pdf

12 EPA, "Control of Emissions of Air Pollution From Nonroad Diesel Engines," 63 FR 56967, October
23, 1998.  Docket A-96-40.  The Federal Register notice is also available online at
http://www.epa.gov/fedrgstr/EPA-AIR/1998/October/Day-23/a24836.htm

13 "NONROAD2005 CI Marine NPRM," U.S. EPA.

14 "Nonroad Engine Growth Estimates," NR-008c, EPA420-P-04-008, April 2004. The report is
available online at http://www.epa.gov/otaq/models/nonrdmdl/nonrdmdl2004/420p04008.pdf
                                               148

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                                                                  Chapter 3: Inventory
15 EPA, 2002 National Emissions Inventory (NEI). County-level fractions of locomotive and
commercial marine diesel emissions. NEI documentation is available online at
http://www.epa.gov/ttn/chief/net/2002inventory.html

16 Clean Air Interstate Rule (CAIR). Docket EPA-HQ-OAR-2003-0053. Documentation is also
available online at http://www.epa.gov/air/interstateairquality/index.html
                                               149

-------
                                        Chapter 4: Technological Feasibility
LOCOMOTIVE AND MARINE TECHNOLOGICAL FEASIBILITY
4.1 Overview of Emissions Standards and Emissions Control Technologies	2
4.2 Emissions Control Technologies for Remanufactured Engine Standards and
for Tier 3 New Engine Interim Standards	4
4.2.1 Diesel Combustion and Pollutant Formation	6
4.2.2 Engine-out Emissions Control	13
4.3 Feasibility of Tier 4 Locomotive and Marine Standards	24
4.3.1 Selective Catalytic Reduction (SCR) NOx Control Technology	25
4.3.2 PM and HC Exhaust Aftertreatment Technology	32
4.3.3 SCR and CDPF Packaging Feasibility	40
4.3.4 Stakeholder Concerns Regarding Locomotive NOx Standard Feasibility. 41
4.4 Feasibility of Marine NTE Standards	49

4.5 Conclusions	51
                                   4-1

-------
Draft Regulatory Impact Analysis
CHAPTER 4: Locomotive and Marine Technological
                  Feasibility

       In this chapter we describe in detail the emissions control technologies we
believe may be used to meet the standards we are proposing. Because of the range of
engines and applications we cover in this proposal, our proposed standards span a
range of emissions levels. Correspondingly, we have identified a number of different
emissions control technologies we expect may be used to meet the proposed
standards.  These technologies range from incremental improvements to existing
engine  components to highly advanced catalytic exhaust treatment systems.

       In this chapter we first summarize our current locomotive and marine diesel
engine  standards and provide an overview of existing and future emissions control
technologies.  We believe that further improvements in existing technologies may be
used to meet the standards we are proposing for  existing engines that are
remanufactured as new (i.e., Tier 0, Tier 1, Tier  2).  We then describe how
technologies similar to some of those already being implemented to meet our current
and upcoming heavy-duty highway and nonroad diesel engine emissions standards
may be applied to meet our proposed interim standards for new engines (i.e., Tier 3).
We conclude this section with a discussion of catalytic exhaust treatment
technologies that we believe may be used to meet our proposed Tier 4 standards.

       All of our analyses in this chapter include how we expect these technologies
to perform throughout their useful  life as well as how we believe they would be
implemented specifically into locomotive and marine applications.  Note that much of
this chapter's  content  is based upon the performance of currently available emissions
control technologies and results from testing that has already been completed. In
most cases the already-published results show that currently available emissions
control technologies can be implemented without further improvements to meet the
standards we are proposing. In a few cases, we are projecting that further
improvements to these technologies will be made between now and the Tier 4
standards implementation dates. These projected improvements will enable engine
manufacturers to meet the standards we are proposing.
4.1 Overview of Emissions Standards and Emissions Control
    Technologies

       Our current locomotive and marine diesel engine standards have already
decreased NOX emissions from unregulated levels. For example, since 1997, NOX
emissions standards for diesel locomotive engines have been reduced from an
unregulated level of about 13.5 g/bhp-hr to the current Tier 2 level of 5.5 g/bhp-hr - a
60% reduction when evaluated over the locomotive line-haul duty cycle. Similar
NOX reductions have been realized for Category 1 & 2 (Cl & C2) commercial marine
diesel engines. Our Tier 1 marine standards are equivalent to the International

                                    4-2

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                                          Chapter 4: Technological Feasibility
Maritime Organization's NOX regulation known as MARPOL Annex VI.  Beginning
in 2004, these standards became mandatory for Cl & C2 Commercial vessels, and
were voluntary in prior years. Beginning in 2007, EPA Tier 2 standards for Cl & C2
Commercial vessels will supersede these MARPOL-equivalent standards.  For a high-
speed marine diesel engine, NOX will be reduced from a Tier 1 level of 9.8 g/kW-hr to
7.5 g/kW-hr - a 23% reduction.  While these reductions in locomotive and marine
NOX emissions are significant, they do not keep pace with the 90% NOX reduction
(from 2.0 g/bhp-hr to 0.2 g/bhp-hr) set forth in the 2007 Heavy-Duty Highway Rule.1
Neither do these reductions keep pace with the approximately 85% NOX reductions
set forth in the Nonroad Tier 4 Standards for 56 kW to 560 kW engines and for
                          r\ q
generator sets above 560 kW ' . In a similar manner, locomotive and marine
particulate matter (PM) emission reductions also lag behind the Heavy-Duty Highway
and Nonroad Tier 4 Rules.  For line-haul and switcher locomotives, a 67% reduction
in PM already has been achieved in going from the Tier 0 to the Tier 2 standards. On
the marine side, PM emissions for Cl & C2 Commercial have been reduced from an
unregulated level prior to May 2005, to a 0.2-0.4 g/kW-hr level for Tier 2.

       A In contrast, the 2007 Heavy-Duty Highway Rule set forth PM reductions of
90% - from 0.1 g/bhp-hr to 0.01 g/bhp-hr.  Similarly post-2014 Nonroad Tier 4 PM
emissions will be reduced 85 to 95% compared to Tier 3 Nonroad PM emissions for
56 kW to 560 kW engines and for generator sets above 560 kW.2'3  In the  timeframe
of the Tier 3 and 4 Locomotive Standards that we are proposing, NOX and PM
emissions will continue to be a serious threat to public health, and,  on a percentage
basis, the locomotive and marine contributions to the nationwide inventory of these
pollutants would continue to increase relative to today's levels if current Tier 2
emission levels were maintained.  Please refer to Chapter 3 of the Regulatory Impact
Analysis for a more detailed discussion of the contribution of locomotive and marine
emissions to the NOX and PM inventory.

       To date, the Tier 0 through Tier 2 locomotive and Tier 1 through Tier 2
marine emissions reductions have  been achieved largely through engine calibration
optimization and engine hardware design changes (e.g. improved fuel injectors,
increased injection pressure, intake air after-cooling, combustion chamber design,
injection timing, reduced oil consumption, etc.).   To achieve the Tier 3 PM emission
standards we are proposing, further reductions in lubricating oil consumption will be
required. This will most likely be achieved via improvements to piston, piston ring,
and cylinder liner design, as well as improvements to the crankcase ventilation
system. To further reduce NOX and PM emission beyond Tier 3 levels, an exhaust
aftertreatment approach will be necessary.
A Tier 2 PM emission standards are dependent on an engine's volumetric displacement-per-cylinder.


                                     4-3

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Draft Regulatory Impact Analysis
       Selective catalytic reduction (SCR) is a commonly-used aftertreatment device
for meeting more stringent NOX emissions standards in worldwide diesel applications.
Stationary, coal-fired power plants have used SCR for three decades as a means of
controlling NOX emissions,  and currently, European heavy-duty truck manufacturers
are using this technology to meet the Euro IV and Euro V limits. To a lesser extent,
SCR has been introduced on diesels in the U.S. market, but the applications have
been limited to marine ferryboat and stationary power generation demonstration
projects in California and several northeast states. However, by 2010, when 100% of
the heavy-duty diesel trucks are required to meet the NOX limits of the 2007 heavy-
duty Highway Rule, several heavy-duty truck engine manufacturers have indicated
that they will use SCR technology to meet these standards.4'5  While other promising
N0x-reducing technologies such as lean NOX catalysts, NOX adsorbers, and advanced
combustion control continue to be developed - and may be viable approaches to the
standards we are proposing today - our analysis projects that SCR will be the
technology chosen by the locomotive and marine diesel industries to meet the Tier 4
NOX standards we are proposing. For a complete review of these other alternative
NOX emissions control technologies refer to the Regulatory Impact Analysis from our
Clean Air Nonroad diesel rule.6

       The most effective exhaust aftertreatment used for diesel PM emissions
control is the diesel particulate filter (DPF).  More than a million light diesel vehicles
that are OEM-equipped with DPF systems have been sold in Europe, and over
200,000 DPF retrofits to diesel engines have been conducted worldwide.7 Broad
application of catalyzed diesel particulate filter (CDPF) systems with greater than
90% PM control is beginning with the introduction of 2007 model year heavy-duty
diesel trucks in the United States. These systems use a combination of both passive
and active soot regeneration.  Our analysis projects that CDPF systems with a
combination of passive and active backup regeneration will be the primary
technology chosen by the locomotive and marine diesel industries to meet the Tier 4
PM standards we are proposing.

4.2 Emissions Control Technologies for Remanufactured Engine
    Standards and for Tier 3 New Engine Interim Standards

       To meet our proposed locomotive remanufactured engine standards, our
potential marine remanufactured engine standards, and our proposed Tier 3
locomotive and marine standards, we believe engine manufacturers will utilize
incremental improvements to existing engine components to reduce engine-out
emissions. This will be accomplished primarily via application of technology
originally developed to meet our current and upcoming standards for heavy-duty on-
highway trucks and nonroad diesel equipment. This is especially true for many of the
Category 1 and Category 2 marine engines, which are based on nonroad engine
designs. This will allow introduction of technology originally developed to meet
nonroad Tier 3 and Tier 4 standards to be used to meet the Tier 3 marine standards.
Table 4-1, Table 4-2 and Table 4-3 provide summaries of the technologies that we
believe may  be used meet the remanufactured engine and Tier 3 new engine interim
                                     4-4

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                                            Chapter 4: Technological Feasibility
standards for switch locomotives, line-haul locomotives and marine engines,
respectively.

          Table 4-1: Technologies for switch locomotive standards through Tier 3
Year
2010
2010
2013
2011
Standard
TO-
Remanufactured
Tl-
Remanufactured
T2-
Remanufactured
T3
NOX
(g/bhp-hr)
11.8
11.0
8.1
5.0
PM
(g/bhp-hr)
0.26
0.26
0.13
0.10
Technology added to engine
New power assemblies to improve oil
consumption, improved mechanical unit
injectors
New power assemblies to improve oil
consumption, electronic unit injection,
new unit injector cam profile
For high-speed engines: Same as Tier 3
nonroad engines
For medium-speed engines: Further
improvements to power assembly and
closed crankcase ventilation system to
reduce oil consumption, new
turbocharger, new engine calibration,
new unit injector cam profile
For high-speed engines: Same as Tier 3
nonroad engines
For medium-speed engines: Further
improvements to power assembly and
CCV to reduce oil consumption, high
pressure common rail injection with
post-injection PM clean-up, injection
timing retard, new turbocharger
          Table 4-2: Technologies for Line Haul Locomotive Standards up to Tier 3

Year

?010
(2008 if
available)
?010
(2008 if
available)

?01 3



2012



Standard


TO-
Remanufactured

Tl-
Remanufactured

T2-
Remanufactured


T3


NOX
(g/bhp-
hr)

7.4

7.4


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Draft Regulatory Impact Analysis
   Table 4-3: Technologies for Marine Category 1 and Category 2 to meet Tier 3 Standards
Year
2009-2014
2012-2018
2013
2012
Standard
Category 1
TierS
Marine
(< 75 kW)
Category 1
TierS
Marine
(75-3700
kW)
Category 2
TierS
Marine
7- 15
liters/cyl.
Category 2
TierS
Marine
15-30
liters/cyl.
HC+NOX
(g/bhp-
hr)
3.5-5.6
4.0-4.3
5.5
6.5-8.2
PM (g/bhp-
hr)
0.22-0.33
0.07-0.11
0.10
0.20
Technology added to engine
Same engine-out NOX technologies as
Tier 4 nonroad — with no Tier 4 PM
aftertreatment technologies
Recalibration on nonroad Tier 4
engines without aftertreatment
Same engine-out NOX technologies as
pre-2014, non-generator-set, Tier 4
nonroad — with no Tier 4 PM
aftertreatment technologies
Further improvements to power
assembly to reduce oil consumption,
electronic unit injection or high
pressure common rail injection, new
turbocharger
       In section 4.2.1.1 we will describe some of the fundamentals of diesel
combustion and pollutant formation. In section 4.2.2 we describe the manner in
which engine-out emissions can be controlled in order to meet the proposed
locomotive remanufactured engine standards, potential marine remanufactured engine
standards and the Tier 3 locomotive and marine standards.

4.2.1 Diesel Combustion and Pollutant Formation

       In this section we describe the mechanisms of pollutant formation.  In order to
lay the foundation for this discussion, we begin with a review of diesel combustion,
especially as it is related to 2-stroke cycle and 4-stroke cycle diesel engine  operation.
We describe both of these types of diesel engine operation because  both 2-stroke and
4-stroke engines are used in locomotive and marine applications. We then  describe
NOX, PM, HC, and CO formation mechanisms.

4.2.1.1 Diesel Combustion

       Category 1 marine diesel engines operate on a four-stroke cycle. The larger
displacement Category 2 marine diesel engines and locomotive diesel engines  operate
on either a two-stroke cycle or a four-stroke cycle. The four-stroke cycle consists of
an intake stroke, a compression stroke, an expansion (also called the power or
combustion) stroke, and an exhaust stroke.  The two-stroke cycle combines the intake
and exhaust functions by using forced cylinder scavenging. Figure 4-1 provides an
                                     4-6

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                                           Chapter 4: Technological Feasibility
overview and brief comparison of the two-stroke and four-stroke cycles used by
marine and locomotive diesel engines.

       The diesel combustion event provides the energy for piston work. An
example of the relationship between the different phases of diesel combustion and the
net energy released from the  fuel is shown in Figure 4.2. Combustion starts near the
end of compression and continues through a portion of the expansion stroke. Near
the end of the piston compression stroke, fuel is injected into the cylinder at high
pressure and mixes with the contents of the cylinder (air + any residual combustion
gases).  This period of premixing is referred to as ignition delay. Ignition delay ends
when the premixed cylinder contents self-ignite due to the high temperature and
pressure produced by the compression stroke in a relatively short, homogenous,
premixed combustion event.  Immediately following premixed combustion, diesel
combustion becomes primarily non-homogeneous and diffusion-controlled. The rate
of combustion is limited by the rate of fuel and oxygen mixing.  During this phase of
combustion, fuel injection  continues creating a region that consists of fuel only. The
fuel diffuses out of this region and air is entrained into this region creating an area
where the fuel to air ratio is balanced  (i.e., near stoichiometric conditions) to support
combustion. The fuel burns primarily in this region. One way to visualize this is to
roughly divide the cylinder contents into fuel-rich and fuel-lean sides of the reaction-
zone where combustion is taking place as shown in Figure 4-3.  As discussed in the
following subsections, the  pollutant rate of formation in a diesel engine is largely
defined by these combustion regions and how they evolve during the combustion
process.8
                                      4-7

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Draft Regulatory Impact Analysis
Figure 4-1:  A comparison of 2 complete revolutions of the four-stroke (top) and two-stroke
diesel combustion cycles.  Note that the two-stroke cycle relies on intake air-flow to scavenge the
exhaust products from the cylinder. In the case of uniflow scavenged two-stroke diesel engines,
cylinder scavenging is assisted by the use of a centrifugal or positive displacement blower to
pressurize the intake ports located on the sides of the cylinder. Exhaust exits the cylinder
through cam-actuated poppet valves in the cylinder head. Four-stroke diesel engines are the
predominant type of Category 1 marine engine. Both four-stroke and uniflow-scavenged two-
stroke diesel engines are used for Category 2 marine and locomotive applications.
   Intake-p^
  Air Fl
                             fuel injected near the top of
                               the compression stroke
  Four   «i
  Stroke
  Engine
1. Intake
                              2. Compression
                     3. Expansion
                             fuel injected near the top of
                               the compression stroke
                                               Exhaiijt "
                                                Flow1
                                          fuel injected near the top of
                                           the compression stroke
       (3,4) 1.  Expansion &
       Scavenging
       (combined intake
       and exhaust processes)
2. Compression       (3,4) 1. Expansion &    2. Compression
                     Scavenging
                     (combined intake
                     and exhaust processes)
                                            4-8

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                                                Chapter 4: Technological Feasibility
Figure 4-2: An idealized example of the net apparent rate of combustion heat release (derived
from high-speed cylinder pressure measurements) for a direct injection diesel engine with
indication of the major events and phases of combustion.
  -10
10
20
30
40
                 TDC
                        Degrees of Crankshaft Angle Rotation
Figure 4-3: An idealized physical schematic of the diesel combustion process.
                                Piston Bowl
                                   Piston Crown
                                  Combustion and
                                 Partial-Combustion
                                    Products
                              Fuel Lean
               Top View
                            Profile, Partial Cut-away
                                          4-9

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Draft Regulatory Impact Analysis
4.2.1.2 NOX Emissions

       Nitrogen oxides (NOX) are formed in diesel engines by the oxidation of
molecular nitrogen (Nz) in the stoichiometric combustion regions of the diffusion-
controlled and premixed diesel combustion phases, described in the previous section.
During the premixed phase of combustion, ignition and flame propagation occurs at
high temperatures and at near stoichiometric mixtures of fuel and air.  During
diffusion-controlled combustion, the reaction zone is also near stoichiometric
conditions.  At the high temperatures present during premixed combustion or in the
diffusion-controlled combustion reaction zone, a fraction of the nitrogen and oxygen
can dissociate, forming radicals which then combine through a series of reactions to
form nitric oxide (NO), the primary NOX constituent.  Nitrogen dioxide (NOz), the
other major NOX constituent, is formed from oxidation of NO in the flame region.
N02 formed during combustion rapidly decomposes to NO and molecular oxygen
unless the reaction is quenched by mixing with cooler cylinder contents.  Engine-out
emissions of NO are typically 80% or more of total NOX from direct injection diesel
engines.  The NOX formation rate has a strong exponential relationship to
temperature.  Therefore, high temperatures result in high NOX formation rates.8'9
Any changes to engine design that can lower the peak temperature realized during
combustion, the partial pressures of dissociated nitrogen and oxygen, or the duration
of time at these peak temperatures can lower NOX emissions. Most of the engine-out
NOX emission control technologies discussed in the following sections reduce NOX
emissions by reducing the peak combustion temperatures while balancing impacts on
PM emissions, fuel consumption and torque output.

4.2.1.3 PM Emissions

       Particulate matter (PM) emitted from diesel engines is a multi-component
mixture composed chiefly of elemental carbon (or soot), semi-volatile organic carbon
compounds, sulfate compounds (primarily sulfuric acid) with associated water, and
trace quantities of metallic ash.

       During diffusion-controlled combustion, fuel diffuses into a reaction zone and
burns.  Products of combustion and partial products of combustion diffuse away from
the reaction zone where combustion occurs.  At temperatures above 1300 K, fuel
compounds on the fuel-rich side of the reaction zone can be pyrolized to form
elemental carbon particles10.  Most of the elemental carbon formed by fuel pyrolysis
(80% to 98%) is oxidized during later stages of combustion.11'12 The remaining
elemental carbon agglomerates into complex chain-aggregate soot particles and
leaves the engine as a component of PM emissions.
                                    4-10

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                                           Chapter 4: Technological Feasibility
       From this description, the formation of elemental carbon particles during
combustion and emission as PM following the combustion event can be summarized
as being dependent upon three primary factors:

              1.     Temperature

              2.     Residence time

              3.     Availability of oxidants

Thus, in-cylinder control of elemental carbon PM is accomplished by varying engine
parameters that affect these variables while balancing the resultant effects on NOX
emissions and torque output.

       The combinations of organic compounds (volatile and semi-volatile) that
contribute to PM are referred to as the volatile organic fraction (VOF), the soluble
organic fraction (SOF), or as organic carbon PM, depending upon the analytical
procedure used to measure the compounds. Organic carbon PM primarily consists of
lubricating oil and partial combustion products of lubricating oil. Some of the higher
molecular weight fuel compounds from unburned or partially burned diesel fuel also
contribute to organic carbon PM. Oil can be entrained into the cylinder contents from
cylinder liner surfaces as they are uncovered by the piston and by leakage into the
cylinder past the valve stems. Uniflow-scavenged two-stroke diesel engines typically
have somewhat higher oil consumption and organic carbon PM emissions in part  due
to the lubricating oil entrained into the  scavenging flow from around the intake ports
in the cylinder wall. Compliance with  the closed crankcase ventilation provisions in
the Tier 0 and later locomotive and Tier 2 marine standards has typically been
accomplished by using coarse filtration to separate a fraction of the oil aerosol from
the crankcase flow and then entraining the crankcase flow directly into the exhaust
downstream of the turbocharger exhaust turbine (Figure 4-4). Incomplete separation
of the oil aerosol from the crankcase flow can increase the amount of lubricating oil
directly entrained into the exhaust with subsequent formation of organic carbon PM.

       Both organic carbon and sulfate PM are formed after cooling and air-dilution
of the exhaust. Sulfur dioxide (SO2) is formed via combustion of sulfur compounds
from the fuel and lubricating oil burned during combustion. In the absence of post-
combustion catalytic treatment of the exhaust, approximately 1 to 3 % of fuel sulfur is
oxidized to ionic sulfate (S03) and upon further cooling is present primarily as a
hydrated sulfuric acid aerosol. For example, sulfate PM currently accounts for
approximately 0.03 to 0.04 g/bhp-hr over the line-haul cycle for locomotive engines
using 3000 ppm sulfur nonroad diesel fuel.

       Diesel oxidation catalysts (DOC) and catalyzed diesel particulate filters
(CDPF) using platinum catalysts can oxidize the organic compounds thereby
lowering PM emissions but they can also oxidize 50% or more of the SOz emissions
to sulfate PM, depending on the exhaust temperature and the platinum content of  the
catalyst formulation that is used.
                                     4-11

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Draft Regulatory Impact Analysis
Figure 4-4: Crankcase ventilation system for a medium speed locomotive diesel engine. An
eductor uses compressed air to draw crankcase gases through a coarse coalescing filter (top left
photo). The outlet of the crankcase ventilation system can be clearly seen from the outlet of the
locomotive's exhaust stack (top right photo). The bottom photo shows tubing from a crankcase
ventilation system removed from downstream of a similar coarse coalescing filter. There was
considerable wetting of the inner wall of the tubing with lubricating oil.
                         Turbocharger
                         turbine outlet
                                          Crankcase flow vented to exhaust stack
4.2.1.4 HC Emissions

       Hydrocarbon (HC) emissions from diesel engines are generally much lower
compared to other mobile sources due to engine operation that, on a bulk-cylinder-
content basis, is significantly fuel-lean of the stoichiometric air-to-fuel ratio. HC
emissions primarily occur due to fuel and lubricant trapped in crevices (e.g., at the top
ring land and the injector sac) which prevents sufficient mixing with air for complete
combustion. Fuel related HC can also be emitted due to "over mixing" during
ignition delay, a condition where fuel in the induced swirl flow has mixed beyond the
lean flammability limit.  Higher molecular weight HC compounds adsorb to soot
particles or nucleate and thus contribute to the organic carbon PM. Lower molecular
weight HC compounds are primarily emitted in the gas phase.  During engine start-up
under cold ambient conditions or following prolonged engine idling, fuel-related HC
can be emitted as a concentrated, condensed aerosol ("white smoke").
                                      4-12

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                                           Chapter 4: Technological Feasibility
4.2.1.5 CO Emissions

       Carbon monoxide emissions (CO) from diesel engines are generally low
compared to other mobile sources due to engine operation that, on a bulk-cylinder-
content basis, is significantly fuel-lean of the stoichiometric air-to-fuel ratio.
Catalytic emission controls that effectively oxidize PM constituents and HC
emissions are also effective for oxidation of CO, reducing CO emissions to even
lower levels.

4.2.2 Engine-out Emissions Control

       Control of diesel emissions via modification of combustion processes is often
characterized by trade-offs in NOX emissions control vs. other parameters such as PM
emissions, fuel  consumption, and lubricating oil soot loading.  For example lower
oxygen content (lowering the air-to-fuel ratio) lowers NOX formation but increases
PM  formation.   Advanced  (earlier)  injection  timing  reduces PM emissions but
increases NOX formation. Retarded (later) injection timing reduces NOX formation but
increases PM formation, increases fuel consumption, and at high torque output levels
can  increase  soot   accumulation  within  the lubricating  oil.    During  engine
development, these  trade-offs are  balanced  against each other in order to obtain
effective  NOX and  PM control  while maintaining  acceptable power output,  fuel
efficiency and engine durability. The introduction of more-advanced fuel  injection
systems  and improved  turbocharging can improve these tradeoffs,  allowing for
reduced emisssions of both NOX and PM.

4.2.2.1 Ultra Low Sulfur Diesel Fuel

       We estimate  that the use of ultra low sulfur diesel fuel (<15 ppm S) will
reduce sulfate PM emissions  from locomotive and marine engines by approximately
0.03 to 0.04 g/bhp-hr, as compared to  PM emissions when -3000 ppm S fuel is used.
The use of ultra low sulfur fuel also reduces depletion of TEN in the oil and
substantially reduces condensation of acidic aerosols within cooled exhaust gas
recirculation systems (see section 4.2.2.5). In addition to the direct sulfate PM
emissions reductions realized through the use of ULSD, ULSD is also necessary to
enable the use of advanced aftertreatment technologies, as discussed later in this
chapter.  While we describe the emission reductions due to the use of lower sulfur
diesel fuel here, we should be clear that these reductions are part of our baseline
emissions inventory because  this rule does not change the fuel sulfur standard.

4.2.2.2 Turbocharger Improvements

       The majority of Category 1 and 2 marine diesel engines and Tier 0 and later
locomotive diesel engines are equipped with turbocharging and aftercooling.  Tier 0
and later  two-stroke  locomotive engines (and some Tier 1  and later marine engines)
are equipped with a  hybrid mechanical centrifugal supercharger/exhaust turbocharger
system. This system is gear driven up to approximately the notch 6 operating mode
and is exhaust driven at higher operating modes or higher numbered notches  (e.g.,


                                    4-13

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Draft Regulatory Impact Analysis
notches 7 and 8). This arrangement helps to provide sufficient scavenging boost at
lower notch settings where there is insufficient exhaust energy for the exhaust turbine
to drive the compressor.  Significant improvements have been made in recent years in
matching turbocharger turbine and compressor performance to the highway, nonroad,
marine, and locomotive diesel engines. Improvements to turbochargers and the
match of the turbocharger's design to the engine reduce the incidence of insufficient
oxygen during transients and help maintain sufficient air flow to the engine during
high load operation.  The corresponding improvements in oxygen availability
throughout the operational range of the engine reduce the formation of elemental
carbon PM. We expect that new Tier 0 and Tier 1 (remanufactured) locomotive
engines will include improvements to turbocharger design that are similar to those of
current Tier 2 locomotive designs. We also expect that engine manufacturers will
continue with incremental improvements in turbochargers and the match of the
turbocharger's design to Tier 3 locomotive and marine engines.

4.2.2.3 Charge Air Cooling

       Improvements in engine-out NOX emissions to meet our proposed locomotive
remanufactured engine standards and the Tier 3 locomotive and marine standards will
be accomplished in part via lowering charge air cooling temperature. This was one of
the primary methods of used by locomotive engine manufacturers to reduce NOX
emissions to meet the Tier 1 and Tier 2 locomotive standards  and the Tier 3 nonroad
diesel standards. Lowering the intake  manifold temperature lowers the peak
temperature of combustion and thus NOX emissions. The NOX reduction realized
from lowering the intake manifold temperature can vary depending upon the engine
design but one estimate suggests NOX emissions can be reduced by five to seven
percent with every 10 °C decrease in intake manifold temperature.13 Typically the
intake manifold temperature is lowered by cooling the intake  gases through a heat
exchanger,  also known as a charge air cooler or aftercooler, located between the
turbocharger compressor outlet and the intake manifold. Locomotive applications
typically use air-to-air aftercoolers.  Locomotive aftercoolers  use electrically powered
auxiliary fans since oftentimes conditions at high torque output require significant
intake air heat rejection, especially at speeds too low for effective passive air-flow.
Operation of the locomotive in multi-engine train configurations or "consist" can  also
impede air-flow to heat exchangers. Increased cooling capacity in locomotive
applications can be accomplished via increased air-flow through the air-to-air after
cooler, often through use of either variable speed or multiple-staged electric fans.
Marine applications with access to sea-water heat-exchanger coolant loops typically
have excess heat rejection capacity with respect to charge air  cooling.  This cooling
capacity can be limited within certain existing hull designs, but new hull designs can
typically overcome these existing hull limitations.

4.2.2.4 Injection Timing

       Electronic control of injection timing has been used by locomotive and marine
engine manufacturers to balance NOX emissions, PM emissions, fuel efficiency,
engine performance and engine durability for engines certified to the Tier 2

                                     4-14

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                                          Chapter 4: Technological Feasibility
locomotive and marine engine standards, Tier 3 nonroad standards, and the 1998 and
later heavy-duty highway standards. We expect similar systems to be used to comply
with our proposed remanufactured engine standards and will continue to be used to
comply with our proposed Tier 3 locomotive and marine standards.

       Delaying the start of fuel injection and thus the start of combustion can
significantly reduce NOX emissions from a diesel engine.  The effect of injection
timing on emissions and performance is well established.14'15'16'17 Delaying the start
of combustion by retarding injection timing aligns the heat release from the fuel
combustion with the portion of the power (or combustion) stroke of the engine cycle
after the piston has begun to move down.  This means that the cylinder volume is
increasing and that work (and therefore heat) is being extracted from the hot gases.
The removal of this heat through expansion lowers the temperature in the combustion
gases.  NOX is reduced because the premixed burning phase is shortened and because
cylinder temperature and pressure are lowered.  Timing retard typically increases HC,
CO, PM, and fuel consumption because the  end of injection comes later in the
combustion stroke where the time for extracting energy from fuel combustion is
shortened and the cylinder temperature and pressure are too low for more complete
oxidation of PM. This can be offset by increasing injection pressure, allowing an
earlier end of injection at the same torque output (i.e., shorter injection duration  for
the same quantity of fuel injected), and by using multiple injection events following
the primary diffusion-combustion event to enhance soot oxidation (see 4.2.2.6 High
Pressure Injection, Fuel injection Rate Shaping, Multiple Injections and Induced
Charge Motion).  We expect that these strategies will continue to be used to meet our
proposed remanufactured engine standards and our proposed Tier 3 locomotive and
marine diesel engine standards.

4.2.2.5 Exhaust Gas Recirculation

       Exhaust gas recirculation (EGR) reintroduces or retains a fraction of the
exhaust gases in the cylinder. Most highway diesel engine manufacturers used cooled
external EGR to meet the 2004 and later Heavy-Duty Highway emission standards of
2.5 g/bhp-hr HC + NOX  and 0.10 g/bhp-hr PM.  EGR has been a key technology used
to reduce engine-out NOX emissions to near 1.0 g/bhp-hr for CDPF-equipped 2007
heavy-duty truck and bus engines in the U.S. Although the  use of EGR will not be
needed to meet the Proposed Tier 3 locomotive and marine standards or
remanufactured engine standards, we expect that some Category 1 marine diesel
engines and high-speed  locomotive switch engines that are based on Tier 3 and Tier 4
nonroad engine families that already use EGR may also use EGR for their marine or
switch locomotive applications of these engines to provide additional engine
calibration flexibility.
                                    4-15

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Draft Regulatory Impact Analysis
       The use of EGR decreases NOX formation in three different ways:

          1.  EGR can thermally reduce peak combustion temperature. Increasing
              the mass of the cylinder contents by increasing carbon dioxide (CO2)
              and water vapor concentrations reduces peak cylinder temperatures
              during combustion.18

          2.  A fraction of the air within the cylinder is replaced with inert exhaust,
              primarily COz and water vapor.  This reduces the amount of molecular
              oxygen available for dissociation into atomic oxygen, an important
              step in NOX formation via the Zeldovich mechanism.9

          3.  The high temperature dissociation of C02 and water vapor is highly
              endothermic, and thus can reduce temperatures via absorption of
              thermal energy from the combustion process.19

EGR often is routed externally from the  exhaust system to the induction system.  The
use of externally plumbed EGR can increase the intake manifold temperature
substantially. This reduces intake charge density and lowers the fresh air/fuel ratio
for a given level of turbocharger boost pressure. The  result can be a large increase in
PM emissions if the boost pressure cannot be increased to compensate for the lower
intake charge density.   For this reason,  external EGR systems typically cool the
exhaust gases using a heat exchanger in the exhaust recirculation loop.  The
introduction of ultra low sulfur diesel fuel substantially reduces the risk of sulfuric
acid condensation within an EGR cooler. EGR can also be accomplished entirely in-
cylinder (internal EGR) through the use  of camshaft phasing or other electronically
controlled variable geometry valve-train systems, particularly when  applied to
varying two-stroke diesel engine exhaust scavenging, although it's use is limited by
the inability to effectively cool the residual gases in-cylinder. For both internal and
external EGR systems, the EGR rate is electronically  controlled to prevent temporary,
overly fuel-rich conditions that can lead to high PM emissions during transient engine
operation.

       Although we don't expect that EGR will be required to meet our proposed
remanufacturing standards or our proposed Tier 3 locomotive and marine standards,
we do believe that EGR is an effective emissions  control strategy that could be
selected by an engine manufacturer as a means to control NOX emissions.  EGR may
also provide increased flexibility in how engines are calibrated to meet emissions
standards with the potential for improvement in part-load fuel consumption.

4.2.2.6 High Pressure Injection, Fuel injection Rate Shaping, Multiple Injections
        and Induced Charge Motion

       Inducing turbulent mixing is one means of increasing the likelihood of soot
particles interacting with oxidants within the cylinder to decrease PM emissions.
Turbulent mixing can be induced or increased by a number of means including:
                                     4-16

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                                            Chapter 4: Technological Feasibility
          •   Changes to intake port/valve design and/or piston bowl design

          •   Increased (high) injection pressure

          •   Multiple/split injections using high pressure common rail injection or
              late post injection using electronic unit injection

       As diesel fuel is injected into the cylinder during combustion, the high
pressure fuel spray causes increased motion of the air and fuel within the cylinder.
This increased motion leads to greater air and fuel interaction and reduced particulate
matter emissions. Increasing fuel injection pressure increases the velocity of the fuel
spray and therefore increases the mixing introduced by the fuel spray.

       The most recent advances in fuel injection technology are high-pressure
common rail injection systems with the ability to use rate shaping or multiple
injections to vary the delivery of fuel over the course of a single combustion event.
These systems are in widespread use in heavy-duty on-highway diesel engines, and
they are used in many current nonroad diesel engines. These systems provide both
NOX and PM reductions.  Igniting a small quantity of fuel early limits the rapid
increase in pressure and temperature characteristic of premixed combustion and its
associated NOX formation.  Injecting most of the fuel into an established flame then
allows for a steady burn that limits NOX emissions. Rate shaping may be done either
mechanically or electronically. Rate shaping has been shown to reduce NOX
emissions by up to 20 percent.20  Multiple injection/split injection have also been
shown to significantly reduce particulate emissions, most notably in cases that use
retarded injection timing or a combination of injection timing retard and EGR to
control NOX.21'22'23'24 The typical diffusion-burn combustion event is broken up into
two events.  A main injection is terminated, and then followed by a short dwell period
with no injection, which is in turn followed by another short post-injection event, see
Figure 4-5. The second pulse of injected fuel induces late-combustion turbulent
mixing. The splitting of the injection event into two events  aids in breaking up and
entraining the "soot cloud" formed from the first injection event into the bulk cylinder
contents.

Figure 4-5: An example of using multiple fuel injection events to induce late-combustion mixing
and increase soot oxidation for PM control (Adapted form Pierpont, Montgomery and Reitz,
1995).
o
    5
    0
     -10   0    10   20   30   40
          (TDC)
                                      4-17

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Draft Regulatory Impact Analysis
       Increasing the turbulence of the intake air entering the combustion chamber
(i.e., inducing swirl) can also reduce PM by improving the mixing of air and fuel in
the combustion chamber. Historically, swirl was induced by routing the intake air to
achieve a circular motion in the cylinder. Heavy-duty on-highway and nonroad
engine manufacturers are increasingly using variations of "reentrant" piston designs
in which the top surface of the piston is cut out to allow fuel injection and air motion
in a smaller cavity in the piston to induce additional turbulence (Figure 4-6).
Manufacturers have also changed to three or four valves per cylinder for on-highway
and nonroad high-speed diesel engines, and to four valves per cylinder for medium-
speed locomotive engines, which reduces pumping losses and can also allow for
additional intake air charge motion generation. This valve arrangement also offers
better positioning of the fuel injector by allowing it to be placed in-line with the
centerline axis of the piston.

       At low loads, increased swirl reduces HC, PM, and smoke emissions and
lowers fuel consumption due to enhanced mixing of air and fuel.  NOX emissions
might increase slightly at low loads as swirl increases. At high loads, swirl  causes
slight decreases in PM emissions and fuel consumption, but NOX may increase
because of the higher temperatures associated with enhanced mixing and reduced
wall impingement.25 A higher pressure fuel system can be used to offset some of the
negative effects of swirl, such as increased NOX, while enhancing positive effects like
increased PM oxidation.  Intake air turbulence such as "swirl" can be induced using
shrouded intake valves or by use of a helical-shaped air intake port. Swirl is
important in promoting turbulent mixing of fuel and soot with  oxidants, but can also
reduce volumetric efficiency.

       Piston bowl design can be used to increase turbulent mixing.  Reentrant bowl
designs induce separation of the flow over the reentrant "ledge" of the piston and help
to maintain swirl through the compression stroke and into the expansion stroke.9
                                     4-18

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                                           Chapter 4: Technological Feasibility
Figure 4-6: Schematic examples of a straight-sided piston-bowl (A), a reentrant piston bowl (B),
and a deep, square reentrant piston bowl (C) for high-speed diesel engines.
            A)
B)
C)
       To meet our locomotive remanufactured engine standards and potential
marine remanufactured engine standards, we expect that manufacturers will use high
pressure electronically controlled unit injection and improvements to piston bowl
design. To meet the Tier 3 locomotive and marine standards, we expect that
manufacturers of high-speed Category 1 and 2 marine diesel engines, high-speed
switch locomotive engines and some Category 2 marine and locomotive medium
speed engines will use advanced electronic fuel systems, including in many cases
high-pressure common rail fuel injection systems.

4.2.2.7 Reduced Oil Consumption

       Reducing oil consumption not only decreases maintenance costs, but also
VOF and PM emissions.  Reducing oil consumption has been one of the primary
ways that heavy-duty truck diesel engines have complied with the 1994 U.S. PM
standard. Reducing oil consumption also reduces poisoning of exhaust catalysts from
exposure to zinc and phosphorous oil additives.

       Redesign of the power assembly (pistons, piston rings and cylinder liner)
played an important role in reducing organic carbon PM emissions from locomotive
engines in order to meet the Tier 2 locomotive standards.  Piston rings can be
designed to improve the removal of oil from the cylinder liner surface and drainage
back into the crankcase, reducing the amount of oil consumed. Valve stem seals can
be used to reduce  oil leakage from the lubricated regions of the engines valve train
into the intake and exhaust ports of the engine. Improvements to the closed-
crankcase ventilation systems that incorporate drain-back  to the crankcase of oil
separated from the crankcase flow and the use of high-efficiency filtration, either with
replaceable high-efficiency coalescing filters or multiple-disc inertial separation, will
reduce oil consumption and can remove oil-aerosol from the crankcase flow
sufficiently to allow introduction of the crankcase gases into the turbocharger
compressor inlet with little or no fouling of the turbocharger compressor, aftercooler
or the remainder of the induction system. Euro IV and U.S. 2004 and 2007 heavy-
duty truck engine  designs that incorporate these technologies have significantly
reduced engine-out organic carbon PM emissions.
                                     4-19

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Draft Regulatory Impact Analysis
       Particularly in the case of medium-speed engines, which have a relatively
high fraction of PM emissions due to organic carbon PM, reduced oil consumption
will be an effective means of meeting our proposed remanufactured locomotive
engine and Tier 3 locomotive and marine PM standards.  We expect Tier 0 and Tier 1
remanufactured locomotive engines to receive power assembly designs similar to
those of current Tier 2 locomotives. We expect that remanufactured Tier 2
locomotive engines and new Tier 3 locomotive and marine engines will receive
incremental improvements in the design of the power assembly, valve stem seals and
improved crankcase ventilation systems—especially if the crankcase ventilation
system routes the crankcase vent to the turbocharger inlet and incorporates high-
efficiency oil separation from the crankcase flow. When applying catalytic exhaust
controls to meet the Tier 4 standards, reduced oil consumption will improve the
durability of catalyst systems by reducing their exposure to zinc- and phosphorous-
containing oil additives.
4.2.2.8 Application Specific Differences in Emissions and Emissions Control

       In much of the preceding discussion we have relied on previous experience
primarily from high-speed (approximately >1600 rpm rated speed) on-highway and
nonroad engines to provide specific examples of emissions formation and engine-out
emissions control.  There are, however, some important operational and design
differences between these engines and locomotive and marine diesel engines,
particularly the medium speed locomotive and marine engines.

       High-speed diesel engines used in on-highway and nonroad applications (with
the exception of generator applications) undergo significant transient operation that
can create temporary conditions of insufficient availability  of oxidants due to the
inability of the air-supply from the turbocharger to follow engine transients. For
these applications, the majority of elemental carbon PM is emitted during these
transients of insufficient oxygen availability. Such transients are greatly reduced in
locomotive and marine applications. Marine propulsion engines operate primarily
along a propeller curve that effectively forms a narrower outer boundary within which
engine operation occurs. Marine generators and locomotive engines operate within
even narrower bounds.  Generators generally operate at close to a fixed engine speed
with varying load.  Locomotives operate at 8 distinct speed-load operational notches
with gradual transitions between each notch. Figure 4-7 illustrates the speed and
power ranges over which typical locomotives and marine engines operate.
                                     4-20

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                                            Chapter 4: Technological Feasibility
Figure 4-7: A comparison engine power output versus engine speed for a locomotive engine
operated over notches one through eight and for a Category 2 marine engine operated over the
E3 marine cycle, which approximates a propeller curve with a cubic relationship between speed
and load.  A cubic fit through the locomotive notch points is remarkably similar to the E3 prop-
curve. The specific example shown is for two similar versions of the EMD two-stroke medium-
speed diesel engine.
    4000
    3500
    3000
    2500
  5 2000
    1500
    1000
     500
EMD 16-710G3B-T2 Locomolive Engine (Notches 1-8|

EMD L16-71OG7C-T2 Category 2 Marine Engine (E3 Test Cycle Points)
              100    200    300     400     500    600
                                    Engine Speed (rpm)
                                                       700
                                                              800
                                                                     900
                                                                           1000
       In addition to operational differences, medium-speed diesel engines (750 to
1200 rpm rated speed) are the predominant type used in Category 2 marine and line-
haul locomotive applications. Medium-speed diesel engines are also predominant in
older switch locomotives, although the majority of locomotive switch families
certified to the Tier 2 locomotive standards now use high-speed diesel engines.
Medium speed diesel engines typically have even lower elemental carbon PM
emissions due to increased residence time available at high load conditions for late-
cycle burn-up of elemental carbon PM as compared to high-speed diesel applications
such as heavy-duty on-highway engines.  The increased duration of combustion also
increases NOX formation for medium-speed diesel engines.

       Large-bore locomotive and Category 2 medium speed diesel engines also have
significantly higher lubricating oil consumption than many high-speed diesel engines.
Lubricating oil consumption for current 2007 on-highway diesel truck engines is
approximately 0.09 to 0.13% of fuel consumed versus approximately 0.30 to 0.35%
for 2-stroke medium-speed diesel locomotive and marine engines and approximately
0.25% for 4-stroke medium-speed locomotive engines. To some degree, this higher
                                      4-21

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Draft Regulatory Impact Analysis
consumption of lubricating oil is by design. Higher lubricating oil consumption
allows for a reduced frequency of complete oil changes, while at the same time the
resulting frequent topping off of oil replenishes lubricant additives that maintain the
lubricating oil's total base number (TEN) to prevent acidic corrosion.  Frequent
topping off also maintains the oil's oxidation stability to maintain oil viscosity.
Because improvements in high-pressure fuel injection systems and electronic engine
management were used to reduce carbon PM emissions to meet Tier 2 locomotive
and marine engine PM standards, only moderate improvements in lubricating oil
consumption were necessary to meet the Tier 2 PM emission standards. This reduced
elemental  carbon PM, coupled with still moderately high lubricating oil consumption,
results in a PM composition of medium-speed diesel engines that is substantially
different than that of on-highway diesel engines and many nonroad diesel engines.
PM emissions from medium-speed diesel engines are dominated by organic carbon
PM emissions, with the relative contributions of organic carbon and elemental carbon
PM to total PM approximately reversed from those of on-highway and most non-road
diesel engines.  Figure 4-8 shows the relative contributions of elemental carbon,
organic carbon, and sulfate PM emission from recent tests of Tier 0, Tier 1 and Tier 2
locomotives.

       Another difference is that crankcase ventilation flow is considerably higher
from very large displacement medium-speed diesel engine compared with smaller,
high-speed engines.  This has complicated the design of crankcase ventilation systems
with effective oil-aerosol separation. Higher capacity, high efficiency inertial disc-
type separators are now being introduced in medium-speed marine applications to
reduce bilge water contamination and oil consumption. Inertial disc-type oil
separators originally developed for Euro IV and 2007 U.S. Heavy-duty On-highway
applications have  provided sufficient oil separation to allow introduction of filtered
crankcase gases into the turbocharger inlet without oil fouling of the turbocharger or
aftercooler system. Similar systems are now optionally available on Wartsila
medium-speed stationary generator and marine engines (Figure 4-9). We expect that
similar systems will  be used on Tier 3 and Tier 4 Category 2 marine engines and
remanufactured Tier 2 and new Tier 3 and Tier 4 locomotive systems.

       Improvements in oil formulation, including switching from Group 1 to Group
2 base oils with greatly improved oxidation stability also reduce the need for oil top-
off to replenish lubricant additives.  As Group 1 become unavailable in Europe, we
expect increased use of Group 2  base oil formulations for use with EMD medium-
speed engines in Europe.  Future reductions in fuel sulfur for Tier 3 and Tier 4
locomotive and marine engines will also reduce the need for TEN control.
                                     4-22

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                                              Chapter 4: Technological Feasibility
Figure 4-8:  Emissions for 6 locomotives tested using 3000 ppm sulfur nonroad diesel fuel.
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                                       4-23

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Draft Regulatory Impact Analysis
 Figure 4-9: Alfa Laval disc-type inertial oil-aerosol separation systems for use with closed
crankcase ventilation systems. The unit on the left is Alfdex system originally developed for
Euro IV and U.S. 2007 heavy-duty on-highway applications. This system was designed as "fit
for life", or essentially maintenance free for the useful life of the engine. A much higher volume
system (right) was recently developed for Wartsila medium-speed engines.
                                             Clean gas
                                              outlet
                                              Drain oil
                                              outlet
4.3 Feasibility of Tier 4 Locomotive and Marine Standards

       In this section we describe the emissions control technologies that we believe
may be used to meet our proposed Tier 4 locomotive and marine diesel engine
standards.  In general, these technologies involve the use of catalytic exhaust
treatment devices placed in an engine's exhaust system, downstream of an engine's
exhaust manifold or turbocharger turbine outlet.  The catalytic coatings of these
aftertreatment devices are oftentimes sensitive to other constituents in diesel exhaust.
For example, sulfur compounds within diesel fuel can decrease the effectiveness or
useful life of a catalyst.  For this reason, we will require the use of ultra-low sulfur
diesel fuel in engines that  will be designed to meet our proposed Tier 4 emissions
standards.  We also expect that engine manufacturers will specify new lubricating oil
formulations for these Tier 4 engines because of other trace compounds in some
currently used lubricating  oils,. These new oil formulations will help ensure that
catalytic exhaust aftertreatment devices will operate properly throughout their useful
life.  Because we have already finalized and begun implementation of similar
aftertreatment-forcing standards for both heavy-duty on-highway and nonroad diesel
engines, we are confident  that the application of similar, but appropriately designed,
aftertreatment systems for locomotive and marine applications is technologically
feasible, especially given the implementation timeframe that we are  proposing.
                                      4-24

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                                           Chapter 4: Technological Feasibility
4.3.1 Selective Catalytic Reduction (SCR) NOX Control Technology

       Recent studies have shown that an SCR system is capable of providing well in
excess of 80% NOX reduction efficiency in high-power, heavy-duty diesel
applications.26'27'28 As shown in Figure 4-10, Vanadium and base-metal (Cu or Fe)
SCR catalysts can achieve significant NOX reduction throughout much of exhaust gas
temperature operating range observed in heavy-duty diesel engines used in
locomotive and marine applications.  Collaborative research and development
activities between diesel engine manufacturers, truck manufacturers, and SCR
catalyst suppliers have also shown that SCR is a mature, cost-effective solution for
NOX reduction on heavy-duty diesel engines.  While many of the published studies
have focused on heavy-duty highway truck applications, similar trends, operational
characteristics, and NOX reduction efficiencies have been reported for heavy-duty
marine and stationary electrical power generation applications as well.29 An example
of the performance capability of SCR in marine applications is the Staten Island Ferry
Alice Austen. This demonstration project reports that 90-95% NOX reduction is
possible under steady-state conditions (where the exhaust gas temperature is above
270 °C.)30  Given the preponderance  of studies and data - and our analysis
summarized here -  we believe that this  technology is appropriate for both locomotive
and marine diesel applications.
                                     4-25

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Draft Regulatory Impact Analysis
Figure 4-10: SCR Catalyst NOX Reduction versus Exhaust Gas Temperature Using an
Ammonia-to-NOx Ratio of I:
                                                      Low-T Base Metal
                                                      Vanadium
                                                      High-T Base Metal
                    150
200      250      300     350
     Exhaust Gas T @ Catalyst Inlet (°C)
400
450
500
       An SCR catalyst reduces nitrogen oxides to Nz and water by using ammonia
(NHs) as the reducing agent.  The most-common method for supplying ammonia to
the SCR catalyst is to inject an aqueous urea-water solution into the exhaust stream.
In the presence of high-temperature exhaust gasses (>200 °C), the urea hydrolyzes to
form NHs and COz - the NHs is stored on the surface of the SCR catalyst where it is
used to complete the N0x-reduction reaction.  In theory, it is possible to achieve
100% NOX conversion if the NH3-to-NOx ratio (a) is 1:1 and the space velocity within
the catalyst is not excessive (i.e. there is ample time for the reactions to occur).
However, given the space limitations in packaging exhaust aftertreatment devices in
mobile applications, an a of 0.85-1.0 is often used to balance the need for high NOX
conversion rates against the potential for NH3 slip (where NH3 passes through the
catalyst unreacted).  Another approach to prevent NH3 slip is to  use an oxidation
catalyst downstream of the  SCR.  This catalyst, also referred to as a slip catalyst, is
able to oxidize the NH3 which passes through (or is released from) the SCR.  When
this approach is used, it is possible to operate the SCR system at near-peak efficiency
by optimizing the urea dosing rate to accomplish high NOX control (which provides
B The "High-T Base Metal" curve is based on a composite of low and high-space-velocity data
provided by catalyst manufacturers. It is meant to represent high-hour performance of a system at a
space velocity of 40,000 hr"1.
                                      4-26

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                                           Chapter 4: Technological Feasibility
adequate NH3 for NOX reduction).  Any excess NH3 (ammonia slip) that results from
such optimization is converted to N2 and water in the slip catalyst.

       The urea dosing strategy and the desired a are dependent on the conditions
present in the exhaust gas; namely temperature and the quantity of NOX present
(which can be determined by engine mapping, temperature sensors, and NOX sensors).
Overall NOX conversion efficiency, especially under low-temperature exhaust gas
conditions, can be improved by controlling the ratio of two NOX species within the
exhaust gas; N02 and NO.  This can be accomplished through use of an oxidation
catalyst upstream of the SCR catalyst to promote the conversion of NO to N02. The
physical size and catalyst formulation of the oxidation catalyst are the principal
factors which control the N02:NO  ratio, and by extension, improve the low-
temperature performance of the SCR catalyst.

       Published studies show that SCR systems will experience very little
deterioration in NOX conversion throughout the life-cycle of a diesel engine.33  The
principal mechanism of deterioration in an SCR catalyst is thermal sintering - the loss
of catalyst surface area due to the melting and growth of active catalyst sites under
high-temperature conditions (as the active sites melt and combine, the total number of
active sites at which catalysis can occur is reduced).  This effect can be minimized by
design of the SCR catalyst washcoat and substrate for the exhaust gas temperature
window in which it will operate. Another mechanism for catalyst deterioration is
catalyst poisoning - the plugging and/or chemical de-activation of active catalytic
sites.  Phosphorus from the engine oil and sulfur from diesel fuel are the primary
components in the exhaust stream which can de-activate a catalytic site. The risk of
catalyst deterioration due to sulfur poisoning will be all but eliminated with the 2012
implementation of ULSD fuel (<15 ppm S) for locomotive/marine applications.
Catalyst deterioration due to phosphorous poisoning can be reduced through the use
of lubricating oil with low sulfated-ash, phosphorus, and sulfur content (low-SAPS)
and through reduced oil consumption (as discussed in 4.2.2.7).  Low-SAPS oil will
improve the performance of catalyzed-DPF and SCR aftertreatment components in
locomotive and marine applications. The high ash content in current locomotive and
marine engine oils is related to the need for a high total base number (TEN) in the oil
formulation. This high-TBN oil has been necessary because of the high sulfur levels
typically present in diesel fuel - a high TEN is necessary to neutralize the  acids
created when fuel-borne sulfur migrates to the crankcase. With the use of ULSD fuel,
acid formation in the crankcase will not be a significant concern. This oil will be
available for use in heavy-duty  highway engines by October 2006 and is specified by
the American Petroleum Institute as "CJ-4."  The durability of other exhaust
aftertreatment devices, namely the DOC and  DPF, will also benefit from the use of
ULSD fuel and low-SAPS engine oil - less sulfur and phosphorous will improve
DOC effectiveness and less ash will increase the DPF ash-cleaning intervals.

       The onboard storage of the aqueous urea solution on locomotives and marine
vessels can be accomplished through segmenting of the existing fuel tanks or fitment
of a separate stainless steel or plastic urea tank.  To assure consistent SCR operation
between refueling stops, the volume of urea-water solution carried onboard will need

                                    4-27

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Draft Regulatory Impact Analysis
to be at least 5% of the diesel fuel tank capacity. At the appropriate intervals, the
crews will need to refill the urea tank.  For the railroad and marine industries, the
distribution and dispensing of urea is expected to benefit from any solutions put in
place by the trucking industry and heavy-duty highway engine and vehicle
manufacturers well in advance of the proposed Tier 4 locomotive and marine
regulations.

       We project that locomotive and marine diesel engine manufacturers will
benefit from any development taking place to implement DPF and SCR technologies
in advance of the heavy-duty truck NOX standards in Europe and the U.S. The urea
dosing systems for SCR, already  in widespread use across many different diesel
applications, are expected to become more-refined/robust/reliable in advance of our
proposed Tier 4 locomotive and marine standards.  Given the steady-state operating
characteristics of locomotive and marine engines, DPF regeneration strategies and
urea dosing controls will certainly be capable of controlling PM and NOX at the levels
necessary to meet our proposed standards.

4.3.1.1 Urea Infrastructure and Feasibility & Cost

       The preferred concentration for the aqueous urea solution is 32.5% urea,
which is the eutectic concentration (provides the lowest freezing point and the urea
concentration does not change if the solution is partially frozen). 4 With a freezing
temperature of -11 °C (12 °F), heaters and/or insulation may be  necessary in Northern
regions for urea storage/dispensing equipment and the urea dosing apparatus (tank,
pump, and lines) on the on the engine.  The centralized nature of locomotive and
marine refueling from either large centralized fuel storage tanks or from tanker  trucks
with long-term purchase agreements provides a working example of how urea could
also be distributed from storage tanks at centralized fueling facilities, tanker trucks
and/or multi-compartment fuel-oil/urea tanker trucks at remote fueling sites.  Given
that only a small percentage of the locomotive and marine fleet will require urea prior
to 2017, EPA believes that the infrastructure for supplying urea from centralized
refueling points and tank trucks can be established to serve the rail and marine
industries. Discussions concerning the urea infrastructure and specifications for an
emissions-grade urea solution are beginning to take place amongst stakeholders in the
light-duty and heavy-duty highway diesel industry. It is possible that these
discussions will result in a fully-developed urea infrastructure for light-duty and
heavy-duty diesel highway engine and vehicle applications by 2010. This would
allow seven years to expand and develop this framework to support the needs of the
railroad and marine industries.  Even without these developments underway in the
light-duty and heavy-duty highway industry, the centralized fueling nature of the
locomotive and marine industries lends itself well to adaptation to support a supply of
urea at their normal fueling locations.

       In 2015, urea  cost is expected to be ~$0.75/gallon for retail facilities
dispensing 200,000 -  1,000,000 gallons/month,  and ~$1.00/gallon for those
dispensing 80,000 - 200,000 gallons/month.35  The additional operating cost incurred
by the rail industry will also be dependent on the volume of urea dispensed at each

                                     4-28

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                                           Chapter 4: Technological Feasibility
facility, with smaller refueling sites experiencing higher costs. It is estimated that
87% of the locomotive fleet is refueled at fixed facilities and 13% at direct truck-to-
locomotive facilities.36  The type of urea storage/dispensing equipment, and the
ultimate cost-per-gallon, for railroad and marine industries will depend on the volume
of fuel & urea dispensed at each site. High-volume fixed sites may choose to mix
emissions-grade dry urea (or urea liquor) and de-mineralized water on-site, whereas
others may choose bulk or container delivery of a pre-mixed 32.5% urea-water
solution.  Again, with the possible implementation of SCR for light-duty and heavy-
duty highway applications in 2010, the economic factors for each urea supply option
may be well-known prior to implementation of the 2017 standards. Even without
these developments underway in the light-duty and heavy-duty highway industry, we
believe that the  urea supply options for the locomotive and marine  industries will be
numerous.

       Urea production capacity in the U.S. is more than sufficient to meet the
additional needs of the rail and marine industries.  For example, in  2003, the total
diesel fuel consumption for Class I railroads was approximately 3.8 billion gallons.37
If 100% of the Class I locomotive fleet were to be equipped with SCR catalysts,
approximately 190 million gallons-per-year of 32.5% urea-water solution would be
required.35 It is estimated that 190 million gallons of urea solution would require 0.28
million tons of dry urea (1 ton dry urea is needed to produce 667 gallons of 32.5%
urea-water solution).35 Currently, the U.S. consumes 14.7 million tons of ammonia
resources per year, and relies on imports for 41% of that total (of which, urea is the
principal derivative). In 2005 domestic ammonia producers operated their plants at
66% of rated capacity, resulting in 4.5 million tons of reserve production capacity.38
In the hypothetical situation above, where 100% of the locomotive fleet required  urea,
only 6.2% of the reserve domestic capacity would be needed to satisfy the additional
demand.  A similar analysis for the marine industry, with a yearly diesel fuel
consumption of 2.2 billion gallons per year, would not significantly impact the urea
demand-to-reserve capacity equation. Since the rate at which urea-SCR technology is
introduced to the railroad and marine markets will be gradual, the reserve urea
production will  be adequate to meet the expected demand in the 2017 timeframe of
the proposed Tier 4 standards.

4.3.1.2 Establishing the Tier 4 NOX Standard

       The basis for the proposed locomotive Tier 4 Line-Haul NOX standard is the
Tier 3 NOX emission standard  (5.5 g/bhp-hr) reduced by the following SCR catalyst
efficiency estimates at full useful life of the engine; 60% efficiency in operating mode
notch 2 (where exhaust gas temperature is near the minimum-level for NOX
conversion), 85% conversion efficiency in operating modes notches 3 and 4 (where
lower catalyst space velocities allow optimum reaction rates), and 83% conversion
                                     4-29

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Draft Regulatory Impact Analysis
efficiency in the high-load operating modes, notches 5 through 8.c When these
efficiencies are weighted according to the line-haul duty cycle emissions test, an
overall NOX reduction of 78% is obtained.

        Figure 4-11 illustrates EPA's projection of an "aged" locomotive/marine SCR
system at full useful life. When these levels of NOX reduction are applied to engine
out emissions from a typical Tier 2, 4-stroke-cycle locomotive diesel engine
producing 5.5  g/bhp-hr of NOX on the line-haul duty  cycle, the worst-case, full useful
life standard is established at 1.3 g/bhp-hr.D This standard includes a compliance
margin and we expect that emissions of a new engine - and the emissions throughout
much of the engine's life - will be closer to 0.8 g/bhp-hr.  Because marine diesel
engines will also operate under similar engine load/exhaust gas temperature
conditions  over their respective cycles, they also will be capable of similar NOX
reductions.  As shown in the shaded area of Figure 4-11, the E3 Marine Test Cycle
lies within  the peak performance range of an SCR catalyst.
c For conditions present in Tier 0-2 locomotives, SCR operation (and hence, NOX reduction) is not
possible at the low power notches (NI, LI, DB, and Nl) due to low exhaust gas temperatures.

D With an overall, duty-cycle-weighted, NOX conversion efficiency of 78%, the remainder NOX
emissions will be 22% of the engine-out level (i.e. the Tier 2 Standard is 5.5 g/bhp-hr; 5.5 x 0.22 = 1.2
g/bhp-hr).
                                      4-30

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                                           Chapter 4: Technological Feasibility
Figure 4-11: Typical 4-Stroke Diesel Locomotive Exhaust Gas Temperatures and Projected SCR
Catalyst Efficiency at Full Useful Life.
      500
    o
                                                     -©— •&• •-©
                                   f / Typical load-temperature operating
                                       regime for medium-speed diesel
                                       engine on the E3 Marine Test Cycle
                               Throttle Notch Setting
                 -•—Avg. Exh. Gas Temp. (GE Tier 2 locomotive engine
                 -O— Projected SCR NOx Conversion Efficiency
100

90 —
  s?
80 £

70 |

60 LU

50 |
                                                                      40 >
                                                                     ^1
                                                                      20 Z
                                                                     - 10

                                                                      0
       For applications requiring improved SCR performance at lower exhaust gas
temperatures, several options are available; throttling the engine airflow to increase
exhaust gas temperature, using an SCR formulation designed for the low-temperature
NOX conversion, or a heated urea dosing system (or some combination of all three
options).  Throttling of the intake airflow on refuse trucks - which often operate
under light-load conditions - has been shown to substantially increase exhaust gas
            39
temperatures.   Increasing the exhaust gas temperature at light load not only provides
an opportunity for extended SCR operation, it is also improves performance of the
DOC and DPF components. Low-temperature NOX conversion can also be enhanced
by use of a base-metal (Fe or Cu) zeolite SCR catalyst (see Figure 4-12).  Systems for
dosing urea at exhaust temperatures below 250 °C are being developed for heavy-
duty, highway truck applications. One such system utilizes an electrically-heated
bypass to hydrolyze the urea-water solution and produce NH3 when exhaust gas
temperatures are as low as 160 °C - providing an additional 5-25% NOX reduction
relative to a system which stops urea dosing at 250 °C.40 Use of a pre-turbocharger
location for a DOC located upstream of the SCR system can also improve low
temperature performance by driving NO to NOz conversion at lighter engine loads
than would be possible with more remote mounting of the DOC. Use of air-gap or
other types of insulated construction for exhaust system components can also improve
thermal management and increase exhaust gas and catalyst temperatures.  For further
discussion of manifold-mounting of the DOC and  exhaust system thermal
management, see section 4.3.2 PM and HC Exhaust Aftertreatment Technology.
                                     4-31

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Draft Regulatory Impact Analysis
       If no improvements were made to technologies which exists today, the 1.3
g/bhp-hr locomotive standard is technologically feasible.  With projected
improvements (that are currently more-difficult to quantify), we are confident in-use
operation and end of useful life NOX emission levels will be less than the 1.3 g/bhp-hr
standard proposed in this rulemaking.

4.3.2 PM and HC Exhaust Aftertreatment Technology

       The most effective exhaust aftertreatment used for diesel PM emissions
control is the diesel particulate filter (DPF).  More than a million light diesel vehicles
that are OEM-equipped with DPF systems have been sold in Europe, and over
200,000 DPF retrofits to diesel engines have been conducted worldwide.7 Broad
application of catalyzed diesel particulate filter (CDPF) systems with greater than
90% PM control is beginning with the introduction of 2007 model year heavy-duty
diesel trucks in the United States. These systems use a combination of both passive
and active soot regeneration.  CDPF systems utilizing metal substrates are a further
development that trades off a degree of elemental carbon soot control for reduced
backpressure, greater design and packaging flexibility, improvements in the ability of
the trap to clear oil ash, and better scaling to the large sizes needed for locomotive
and marine applications.  Metal-CDPFs were initially introduced as passive-
regeneration retrofit technologies for diesel engines designed to achieve
approximately 50 to 60% control of PM emissions.41 Recent data has shown that
metal-CDPF trapping efficiency for elemental carbon PM can exceed 70% for
engines with inherently low elemental carbon emissions.42 Data from locomotive
testing (Figure 4-12) confirms a relatively low elemental carbon fraction and
relatively high organic fraction for PM emissions from medium-speed Tier 2
locomotive engines.43 The use of a highly oxidizing PGM catalyst coated directly to
the CPDF combined with a highly oxidizing DOC mounted upstream of the CDPF
would provide 95% or greater removal of HC, including the semi-volatile organic
compounds that contribute to PM.

       A functional schematic of a metal-CDPF is shown in Figure 4-13.  In this
particular example, flow restrictions divert a portion of the particle laden exhaust
flow through the porous sintered metal walls. The  openings in the flow restrictions
are sufficient to allow accumulated ash to migrate through the CDPF substrate, either
reducing or eliminating the need for periodic ash cleaning.44 The metal-CDPF will
most likely be  used in combination with an upstream diesel oxidation catalyst (DOC).
A diesel oxidation catalyst mounted upstream of the metal-CDPF improves NO to
NOz oxidation for both passive soot regeneration within the CDPF and to increase the
NOX reduction efficiency of the SCR system, particularly during light-load and/or
under cold ambient conditions. The DOC would also assist with oxidation of organic
carbon PM, particularly at lower notch positions. The DOC effectively becomes mass
transport limited for NOz oxidation at notch 6 and above (approximately 80,000*
space velocity), but at that point exhaust temperatures at the location of the metal-
CDPF would be sufficient for NO to N02 oxidation and thus for passive soot
regeneration and also for oxidation of organic carbon. Some or all of the DOC
volume can be installed in a close-coupled position within the exhaust manifold,

                                    4-32

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                                            Chapter 4: Technological Feasibility
immediately downstream of the exhaust ports and upstream of the turbocharger's
exhaust turbine (Figure 4-14)  and within the  "vee" of V-type locomotive and marine
engines. Air-gapped construction can be used to provide faster warm-up and
retention of heat within exhaust components. Thermal insulation that is similar to
what is  already in common use with dry exhaust manifold configurations in Category
2 marine applications can be used to increase exhaust and catalyst temperatures
(Figure  4-15).

       Figure 4-16 shows the expected line-haul locomotive PM reductions for:

•  A 4-stroke line-haul Tier 2 locomotive due to reducing fuel sulfur content to 15
   ppm

•  A 4-stroke line-haul Tier 3 locomotive with  oil consumption reduced
   approximately 50% relative  to Tier  2 via  improvements to the power assembly
   and  closed-crankcase ventilation system

•  A 4-stroke line-haul Tier 4 locomotives with application of a DOC and metal-
   CDPF to the Tier 3 engine

•  A 4-stroke line-haul Tier 4 locomotives with application of a DOC and wall-flow-
   CDPF to the Tier 3 engine

Figure 4-17 shows the expected PM reductions over the E3 General Marine Duty
Cycle for:

•  A 2-stroke medium-speed Category 2 marine diesel engine due to reducing fuel
   sulfur content to 15 ppmE

•  A 2-stroke medium-speed Category 2 marine diesel engine with oil consumption
   reduced approximately 50% relative to Tier  2 via improvements to the power
   assembly and closed-crankcase ventilation system

•  A 2-stroke medium-speed Category 2 marine diesel engine with application of a
   DOC and metal-CDPF to the Tier 3 engine

   Due to the relatively high  organic carbon fraction and low elemental carbon
fraction in the PM emissions,  the difference in PM emissions between the metal-
E For this specific example, speciated data from an EMD 16-710G3C-T2 2-stroke medium speed
locomotive engine was used. This engine is offered in both Category 2 marine and line-haul
locomotive applications. The locomotive application has a slightly higher speed rating and lower NOx
emissions. A fit of the data to E3 points for the lower 4000 bhp @ 900 rpm EMD 16-710G7C-T2
marine rating was used to model PM emissions instead of the 4300 bhp @ 950 rpm rating. The G3C-
T2 and G7C-T2 engines are remarkably similar, if not identical, designs with very similar NOx and
PM emissions and appear to differ only with respect to rated power and rated speed.
                                      4-33

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Draft Regulatory Impact Analysis
CDPF and the wail-flow-CDPF is less than 0.01 g/bhp-hr (approximately 0.005
g/bhp-hr). The advantages of the metal-CDPF relative to the wall-flow-CDPF are
greatly reduced maintenance requirements and reduced exhaust back-pressure. We
estimate that the use of a metal CDPF would result in PM emissions of approximately
0.02 g/bhp-hr over the line-haul cycle. The results from a ceramic wall-flow trap
would be nearly identical at 0.015 g/bhp-hr. This will provide sufficient compliance
margin to meet the 0.03 g/bhp-hr Tier 3 line-haul  locomotive standard. Because PM
emissions concentrations downstream of a PM trap are characteristically flat or
relatively constant, we expect very similar PM reductions from marine engines that
utilize similar PM trap technology.

       Figure 4-18 shows the expected PM removal efficiency of going from Tier 3
to Tier 4  plotted vs. exhaust temperature for all notch positions.  The Tier 3 levels
were calculated based on a 4-stroke Tier 2 locomotive engine with improved
lubricating oil control. The Tier 4 levels were calculated based on the efficiency of a
DOC and metal-CDPF combination at the end of useful life and taking into account
removal efficiency for elemental and  organic carbon and expected sulfate make from
fuel and lubricant sulfur. Efficiency is similar or higher for Category 2 marine
applications due to a narrower range of exhaust temperatures (approximately 250 °C
to 350 °C over the E3 cycle) that are generally above the light-off temperatures for
HC and NO oxidation for typical precious-metal DOC and CDPF formulations and
yet are largely below the temperatures at which peak sulfate-make occurs.
                                    4-34

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                                               Chapter 4: Technological Feasibility
Figure 4-12: Brake-specific PM emissions speciated into soluble organic, soluble sulfate, and
insoluble elemental carbon over the Federal Line-Haul duty cycle.
f Tier 0 PM Standard: 0.60 g/bhp-hr
n ^9n





1 0.200 j
'to
m CM fin

 U.14U
CO
TO
0)
0 060



: I Tier 1 PM Standard: 0.45 g/bhp-hr





















D Organic (mostly lube oil)
D Sulfate (mostly sulfuric acid + water)
D Elemental Carbon (soot)




0.20 g/bhp-hr
(Tier 2 PM Standard)








_
























Tier 0 Tier 0 Tier 1
Locomotive Locomotive Locomotive









































Tier 1 Tier 2 Tier 2
Locomotive Locomotive Locomotive
                                         4-35

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Draft Regulatory Impact Analysis
Figure 4-13:  Cross-sectional functional schematic for a metal-CDPF (not to scale). Flow
restrictions force part of the particle laden exhaust flow through the porous sintered metal
layers. High efficiencies are possible at with engines having relatively low elemental carbon PM
emissions.
        Porous sintered metal layer
        Exhaust flow
       Legend
Flow through porous layer to adjoining channel
Re-entrained flow through porous layer
                                                                              Flow restriction
                                             2. Flow
                                           a portion of the partible-laden
                                     \.    flow tiupugh fhe* porous Payer
                                     -  ^v   jt?^<    ^C!
                                                               . Pajticle-laden
                                                                     •st-flew
                                           4-36

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                                               Chapter 4: Technological Feasibility
Figure 4-14: Metal-monolith dicsel oxidation catalysts (DOC) mounted within the exhaust
manifold of an EMD 710-series locomotive diesel engine. Use of a close-coupled DOC extends
the range of light-load operation where NO to NO2 oxidation can occur. Oxidation of engine-out
NO to NO2 assists with passive regeneration of the CDPF and increases the low temperature
performance of the urea SCR system.  The system also improves oxidation of organic carbon PM
at light load conditions (locomotive notches 1  through 6).
Figure 4-15: A two-stroke medium-speed Category 2 marine diesel engine with an insulated
exhaust manifold and exhaust turbine in use in New York Harbor.
                                         4-37

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Draft Regulatory Impact Analysis
Figure 4-16:  Brake-specific PM emissions over the line-haul duty cycle for a Tier 2 locomotive
and the expected reductions in PM emissions due to reduced fuel sulfur levels and application of
PM emissions controls.
   0.200
I" 0.190
.§• 0.180
^ 0.170
                                                                       Tier 2 0.20 g/bbp-hr PM Standard
             n Organic (mostly lube oil)

             D Sulfate (mostly sulfuric acid + water)

             • Elemental Carbon (soot)
 50% reduction — >85% i
   from Tier 2   —   from Tier 2
            Tier 2 GE Locomotive,
              3000 ppm S Fuel
                            Tier 2 GE Locomotive,
                               15ppmSFuel
Tier 3 GE Locomotive,
   15ppmSFuel
Tier 4 GE Locomotive,
15 ppm S Fuel, Metal-
  substrate CDPF
Tier 4 GE Locomotive,
 15 ppmS Fuel, Wall-
    flow CDPF
                                               4-38

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                                                     Chapter 4: Technological Feasibility
Figure 4-17: Brake-specific PM emissions over the E3 General Marine Duty Cycle for a Tier 2
medium-speed Category 2 diesel engineE and the expected reductions in PM emissions due to
reduced fuel sulfur levels and application of PM emissions controls.
  0.
  J=
  .p
  Q_
  O
  'o
  O)
  Q.
  00
  0)
  ^
  (C
  CD
  _
  g,
  O
0.2000
0.1900
0.1800
0.1700
0.1600
0.1500
0.1400
0.1300
0.1200
0.1100
0.1000
0.0900
0.0800
0.0700
0.0600
0.0500
0.0400
0.0300
0.0200
0.0100
0.0000
                Tier 2 0.20 g/bhp-hr (0.27 g/kW-hr) PM Standard
   >50% reduction
     from Tier 2
>90% reduction
  from Tier 2
                                Organic (mostly lube oil)
                                Suifate (mostly sulfuric acid + water)
                                Elemental Carbon (soot)
             Tier 2 EMD C2 Marine. 3000
                   ppm S Fuel
                              Tier 2 EMDC2 Marine, 15
                                   ppm S Fuel
                trapping
Tier 3 EMD C2 Marine. 15    Tier 4 EMD C2 Marine, 15
     ppm S Fuel        ppm S Fuel, Metal-substrate
                           CDPF
                                              4-39

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Draft Regulatory Impact Analysis
Figure 4-18: Expected PM reduction versus exhaust temperature for a combined DOC and
Metal-CDPF system using 15 ppm sulfur fuel when applied to a Tier 3 locomotive. Below 200
°C, PM is dominated by organic carbon emissions, which can only be removed via catalytic
oxidation and not by filtration because they are in the gas-phase in the raw exhaust.  Thus
(organic) PM removal is limited by the kinetically-limited HC oxidation rates over the precious
metal catalyst applied to the DOC and the CDPF.
                                 % PM Reduction
    90%
    80%
    70%
    60%
    50%
    40%
    30%
    20%
    10%
     0%
        50      100     150      200      250     300

                                Post-turbine Exhaust T (degC)
350
400
450
4.3.3 SCR and CDPF Packaging Feasibility

       We expect that locomotive and marine manufacturers may need to re-
package/re-design the exhaust system, turbocharger, and intake air aftercooling
components to accommodate the aftertreatment components. It is acknowledged that
the existing overall length, width, and height dimensions of the locomotive are
constrained by the existing infrastructure such as tunnel height, but our analysis
shows the packaging requirements are such that they can be accommodated within the
constraints of a locomotive. For commercial marine vessels, our discussions with
marine architects and engineers, along with our review of vessel characteristics,  leads
us to conclude for engines >600 kW on-board commercial marine vessels, adequate
engine room space can be made available to package aftertreatment components.
Packaging of these components, and analyzing their mass/placement effect on vessel
characteristics, will become part of design process undertaken by naval architecture
and marine engineering firms.45

       To achieve  an acceptable balance between SCR performance and exhaust
system backpressure, we estimate the volume of the SCR will need to be
approximately 2.5 times the engine displacement. This volume includes the volume
                                     4-40

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                                          Chapter 4: Technological Feasibility
required for an ammonia-slip-catalyst zone coated to the final 15% of the volume of
the SCR monoliths.  The SCR volume is determined by sizing the device so that
pollutants/reductants have adequate residence time within catalyst to complete the
chemical reactions under peak exhaust flow (maximum power) conditions. The term
used by the exhaust aftertreatment industry to describe the relationship between
exhaust flow rate and catalyst residence time is "space velocity".  Space velocity is
the ratio of the engine's peak exhaust flow (in volume units-per-hour) to the volume
to the aftertreatment device - this ratio is expressed as "inverse hours", or ta.  For
example, an engine with a displacement of 200 liters (L), 300,000 L/min of exhaust
flow, and a 450 L SCR would have a space velocity of 40,000 ta and a catalyst-to-
engine displacement ratio of 2.25:1.F Typical space velocities for SCR on existing
Euro 5 heavy-duty truck applications range from 60,000 to 80,000 ta.

       To achieve acceptable elemental carbon PM capture efficiency, organic
carbon PM oxidation efficiency and exhaust system backpressure, the volume of a
metal-CDPF will need to be approximately 1.7 times the engine displacement, which
would give a maximum space velocity of approximately 60,000hr. The exhaust-
manifold-mounted DOC located upstream of the metal CDPF will need to be
approximately 0.8 times the engine displacement with a maximum space velocity of
approximately 80,000 ta in notch 6 (approximately 120,000 ^ in notch 8). Typical
space velocity for combined DOC/CDPF systems for Euro 4, Euro 5, and U.S. 2007
heavy-duty truck applications range from approximately 60,000 to 80,000 ta.

4.3.4 Stakeholder Concerns Regarding Locomotive NOX Standard
      Feasibility

       One stakeholder has expressed a number of concerns regarding the feasibility
of the proposed 1.3 g/bhp-hr Tier 4 locomotive NOX standard. The issues raised by
the stakeholder can be summarized into three broad areas of concern:

           1.   Ammonia (urea)  dosing

           2.   Deterioration of SCR catalyst NOX control

           3.   Locomotive parity with the marine Tier 4 NOX standard

4.3.4.1 Ammonia/Urea dosing

       The dosing concern specified that variability in urea quality (concentration),
urea delivery  (dosing), and engine-out NOX level limits the maximum NOX reduction
potential of the SCR system in order to control ammonia slip to a level <20 ppm.
This concern is valid only if urea dosing is controlled in an "open-loop" manner (or
operated without consideration of - or inputs from - actual conditions present in the
 Space Velocity =300,000 L/min * 60 min/hr/450 L, Catalyst-to-Engine Displacement = 450 L/200 L.


                                    4-41

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Draft Regulatory Impact Analysis
exhaust system and within the SCR catalysts.)  If the urea dosing is controlled in a
"closed-loop" manner, where feedback from NOX and exhaust gas temperature
sensors before/after the SCR catalyst is used to adjust the urea dosing rate, the SCR
catalyst can operate at near-peak NOX conversion efficiency while minimizing NH3
slip. The use of an NH3 slip catalyst to clean up any ammonia released from the SCR
provides an additional level of robustness to the closed-loop urea dosing system.  For
example, if exhaust gas and SCR temperature conditions at a particular engine
speed/load point allowed for a maximum of 60% NOX conversion efficiency, it would
not be necessary to dose urea at an NH3-to-NOx ratio (a) of 1:1 (which would allow at
least 40% of the NH3 to  slip) when an a of -0.6 could achieve nearly the same level
of NOX control while minimizing NH3 slip.46 As shown in Figure 4-19, the
relationship between dosing ratio and  NOX conversion is linear up to a ratio of -0.95
(i.e. an a of 0.7 yields a NOX conversion of 70%, an a of 0.8 yields a NOX conversion
of 80%, and so on).  If the dosing ratio is increased beyond 0.95, the additional NH3
injected will not produce a corresponding increase in NOX conversion, but will begin
to result in NH slip.  An effective urea dosing system will operate at this "knee" in
curve to maximize NOX conversion while keeping slip below a designated target
value.
Figure 4-19: Effect of dosing ratio on NOX conversion efficiency and NH3 slip.
                                                            46
     c
     o
     CD
     C
     O
    O
    O
100

  90  -

  80  -

  70  -

  60  -
          50
              0.7
                0.8
0.9
1.0
                         NHJNOx Molar Ratio
                                                                25
                         -20  Q-
                                CL
                         -15  a
                                C/D
                         - 10  -|
                                o
                         -5   |

                           0   **•
1.1
       A NOX sensor before (or upstream of) the SCR can be used as a "feed
forward" control input to set the target urea dosing rate and a sensor after (or
downstream of)  the SCR can be used as "feedback" to fine-tune the dosing rate for
optimum NOX reduction while limiting ammonia slip. In addition, the feedback
control provided by a closed-loop urea dosing system also mitigates any variation in
concentration of the urea-water solution and engine-out NOX levels by adjusting the
control sytem to compensate by increasing/decreasing the urea dosing rate.  The
closed-loop system can also adjust to changes in the NOX conversion efficiency as the
                                    4-42

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                                          Chapter 4: Technological Feasibility
SCR ages - as efficiency drops, the a can adapt downward, preventing excessive
ammonia slip.

       Closed-loop urea injection systems are already under development for 2010
U.S. heavy-duty highway diesel engines, U.S. and European light-duty diesel
vehicles, and Euro V on-highway diesel trucks, and these applications have similar—
if not more dynamic—engine operation as compared to locomotive and marine
engine operation. Figure 4-20 illustrates a closed-loop urea-SCR control system
proposed for onroad diesel applications.47 Figure 4-21 illustrates a urea-SCR system
concept developed by Volkswagen to meet U.S Tier 2, Bin 5 passenger car emission
standards.48
Figure 4-20: Adapted from "SCR Technology for NOX Reduction: Series Experience and State
of Development".47
     SCR Technology for NOx Reduction
     System layout for HD/MD, non-air assisted
                                                             AdBlue - tank
                                                              PI-
                                                              AdBlue level
                                                              sensor
              OX I - cat
 A C  DS-CWEGT 17W2DD6 | •§ Robert Sosch GmbH
     such as copying and passing on to third parties.
SCR - cat
                         al rights even in the event of industrial property nflrtts. We n
Slip - cat
                                                e alJ rights a! disposal
                                                               BOSCH
                                    4-43

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Draft Regulatory Impact Analysis
Figure 4-21: Adapted from "LNT or Urea SCR Technology: Which is the right technology for
TIER 2 BIN 5 passenger vehicles?"48
       SCR-System Structure
                                                              AdBluH Tank
               T Sensor :  ECU   NO, Sen
                                      ,--"'        AclBluePipe
                                     Metering Valve
       To ensure accurate urea injection across all engine operating conditions, these
systems utilize NOX sensors to maintain closed-loop feedback control of urea dosing.
These N0x-sensor-based feedback control systems are similar to oxygen-sensor-based
systems that are used with three-way catalytic converters on virtually every gasoline
vehicle on the road today. The control logic to which the sensors provide input
allows for correction  of urea dosing to adequately compensate for both production
variation and in-use catalyst degradation. We believe these N0x-sensor-based
control systems are directly applicable to locomotive and marine engines.

       Ammonia emissions, which are already minimized through the use of closed-
loop feedback urea injection, can be all-but-eliminated with an ammonia slip catalyst
downstream of the SCR catalyst. Such catalysts are in use today and have been
shown to be 95% effective at reducing ammonia emissions.  Ammonia slip catalysts
that have been developed for Euro V and U.S. 2010 truck applications have reduced
selectivity for NOX formation from ammonia oxidation and can provide additional
SCR NOX conversion via reaction with ammonia within the slip catalyst itself.
Catalyst durability is  affected by sulfur and other chemicals that can be present in
some diesel fuel and lubricating oil. These  chemicals have been significantly reduced
in other applications by the use of ultra-low sulfur diesel fuel and low-SAPS  (sulfated
ash, phosphorous, and sulfur) lubricating oil. Locomotive and marine operators
already will be using  ultra low sulfur diesel fuel by the time urea NOX SCR systems
would be needed, and low SAPS oil can be  used in locomotive and marine engines.
Thermal and mechanical vibration durability of catalysts has been addressed through
                                     4-44

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                                          Chapter 4: Technological Feasibility
the selection of proper materials and the design of support and mounting structures
that are capable of withstanding the shock and vibration levels present in locomotive
and marine applications. More details on catalyst durability are available in the
remainder of this section.

4.3.4.2 Deterioration of NOX Control with Urea-SCR Systems

       A concern has been raised by the stakeholder that the iron-zeolite catalysts (as
compared to the vanadium-based catalyst used in trucks in Europe) age rapidly in the
presence of real exhaust and when exposed to elevated temperatures.  Part of this
concern is related to data provided by the stakeholder that had originally been
presented by researchers at Ford and General Motors.32'49 The data was characterized
as reaching two conclusions:

       1.  Fe-zeolite catalysts have NOX reduction efficiency of only 55% to 65%
when NOX emissions are predominantly NO.49

       2.  The NO to N02 conversion efficiency of PGM-based DOC's would rapidly
degrade to zero, and thus could not be relied upon to provide any degree of NO to
N02 oxidation to improve the efficiency of Fe-zeolite SCR catalysts.

       The first point may be the  case at for some Fe-zeolite catalysts when operated
at catalyst space velocities much higher than those that would be used for locomotive
applications (see Figure 4-22).  The research cited intentionally undersized the SCR
catalyst to accentuate the impact of NO:N02 ratio on NOX conversion When
comparing the Fe-Zeolite SCR catalyst example in Figure 4-22 to a similar, aged Fe-
Zeolite system at a lower space velocity (Figure 4-23),  the NOX conversion efficiency
increases to approximately 80% to 90% over the exhaust temperature range for a line-
haul locomotive application for the lower space velocity example with no conversion
of NO to N02. There are two likely reasons for the differences seen between the
results in Figure 4-22 and the results in Figure 4-23:

          1.  Differences in space velocity between the two SCR catalyst systems.

          2.  Differences in catalyst formulation and/or the supplier of the SCR
              catalyst system.

For an appropriately sized locomotive SCR system, >80% NOX conversion for
notches 2 through 8 is still possible even with no oxidation of NO to NO2  upstream
of the SCR catalyst.   Even when taking into consideration that the catalyst in Figure
4-22 is undersized, it was capable of greater than 75% NOX conversion with N02 as
25% of NOX and greater than 90% NOX conversion with N02 as 50%  of NOX.

       The second point cites N02 conversion of only  5-30% at the end of life for a
passenger car and then further extrapolates this conversion to near-zero over the life
of a locomotive.  Upon reviewing the research in question, it was apparent that the 5
to 30% range referred to average conversion over the light-duty FTP cycle, and that
the lower end of the range (5%) referred to results achieved when saturating the

                                    4-45

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Draft Regulatory Impact Analysis
catalyst with fuel-hydrocarbons. The graph in Figure 4-24 is from the same research
cited by the stakeholder, and shows the level of reduced effectiveness for NO to N02
of the up-front DOC in a compact-SCR system.  The four conditions plotted on the
curve all represent NO to N02 oxidation performance at the same level of thermal
aging but with increasing injection of hydrocarbons.  The lowest N02 oxidation levels
reported are for a condition during which the catalyst is completely saturated with
hydrocarbons from direct fuel injection into the exhaust. Once fuel injection ceased,
N02 oxidation returned to the efficiency represented by the upper curve on the chart.
The test was meant to show  how N02 oxidation degrades if the catalyst becomes
temporarily hydrocarbon saturated during PM trap forced-regeneration or during cold
start, and does not represent aged vs. non-aged DOC results for N02 oxidation since
all of the conditions shown represent approximately the same thermally-aged
condition. Furthermore, in the range of post-turbine  exhaust temperatures
encountered by 4-stroke line-haul locomotive engines in notches 2 through 8
(approximately 275 °C to 450 °C), NO to N02 oxidation ranged from approximately
20% to 50%.

Figure 4-22: A comparison of zeolite-based and vanadium based urea-SCR catalyst formulations
at a space velocity of 50,000 hr * while varying NO2 as a percentage of NOX. Adapted from
"Evaluation of Supplier Catalyst Formulations for the Selective Catalytic Reduction of NOX with
Ammonia".49

      Formulation  Dependence on  NO:NO2
               •*- 100% N02
               -*-  75% NO2
               *  50% NO2
               -»-  25% NO2
               *  0% NO2
        150   250   350  450   550

         Catalyst Inlet Temperature ("C)
150   250   350   450  550

 Catalyst Inlet Temperature (°C)
150   250  350   450  550

 Catalyst Inlet Temperature ("C)
           ** Cu-zeolite
   ** Fe-zeolite
** Vanadium-based
         Maximum NOX conversion for Fe, V at 50% N02 fraction
         Maximum NOX conversion for Cu at 75% IM02
         Cu-zeolite least sensitive to NO2 fraction at 225°C, where IMO/N02 matters
         Fe-zeolite best at high temperatures (>450°C)

                          ** Aged catalysts
                                     4-46

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                                           Chapter 4: Technological Feasibility
Figure 4-23: NOX conversion efficiency for an Fe-Zeolite urea-SCR catalyst system while varying
NO2 as a percentage of NOX.50 Note that the black line represents the case of NOX that is 100%
NO (0% NO2).
      100
     b 80
     E
     O
     '<£ 60
     0)
     >
     o 40
     O
     x
     2 20
                  SV=30K/hr, NH3=350ppm, (NO+NO,)=350ppm
                  Aging: 700C/50h/10%H2O
- NO/NOx=1

 NO/NOx=0.8

•N0/N0x=0.5

•N0/N0x=0.2
         100      200       300       400
                           Temperature (C)
    500
600
Figure 4-24: Oxidation of NO to NO2 using a PGM-containing DOC and increasing levels of
direct fuel hydrocarbon injection into the exhaust.  Exhaust temperatures representative of
operation of a 4-stroke line-haul locomotive are marked in red. Adapted from "Urea SCR and
DPF System for Tier 2 Diesel Light-Duty Truck".32


  DOC Performance Evaluation: NO Oxidation
                  120K mi Equivalent Lab Aging


7 no/
cno/ .




1 no/
nor .



Exhaust Temperatures


D NO2 Curve_HCL_COL
NO2 Curve HCM COL
NO2 Curve HCH COL
NO2 Curve HCH(LC) COL
_
30K hr1

DBBom[I| Increasing HC Concentration
$ jj1"*1 I»E_]I!aj Long Chain HCs -
I |xj: Y^ii^fa^^' — Clownstream Fuel Injectk
I;:r:J ^^^__^L
Tijz ll ililx x ^^z'^'f^aj.
0 100 200 300 400 500 600 7C
Temperature (°C)
                                     4-47

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Draft Regulatory Impact Analysis
       Figure 4-25 shows SCR system performance from the same work by Ford
researchers, which shows greater than 90% NOX control over exhaust temperatures
consistent with locomotive operation in notches 2 through 8. The results shown
following 20 hours of thermal aging at 700 °C are approximately representative of the
maximum thermal aging that would be encountered during the useful life of a
locomotive.0 The results for 40 hours of thermal aging at 700 °C (or roughly double
the thermal conditions encountered due to locomotive consist operation in tunnels)
still shows nearly identical NOX performance to the 20 hour results in the range of
temperatures representative of locomotive notches 2 through 8 and are generally
consistent with the results shown in Figure 4-23 at comparable N02 as a percentage
ofNOx.

Figure 4-25: NOX conversion efficiency with 20% conversion of NO to NO2 for Fe-Zeolite SCR
following different thermal aging conditions. The condition of 20 hours at 700 °C is
approximately equivalent to full-life thermal aging for a line-haul locomotive taking into account
that the highest temperatures encountered will be during tunnel operation as part of a consist.
Adapted from "Urea SCR and DPF System for Tier 2 Diesel Light-Duty Truck".32
                       SCR Catalyst  Durability:
                           High Temperature
                                Line-haul Locomotive
                                      20h700°C
                                      40h700°C
                                      20h725°C
                                      20h750°C
                                      20h800°C
approximately equal to line-haul
e full-life thermal aging based on
vteUcousist condition
       30K h '
       NCyNOx = 0.2
       NH,/NOx = 1
              150   200    250   300    350   400    450
                                 Temperature (DC)
                                                    500   550
                                                               600
        With 20% NO2/NOx feed, the catalyst is durable to 750 °C
G The typical maximum exhaust temperature for a locomotive is 450 °C. During tunnel operation in a
consist, this temperature can reach 700 °C. However, not all locomotives operate in tunnels, and only
select locomotives will ever experience this type of operation. Discussions with locomotive
manufacturers indicate that the typical, yearly accumulated time for units used in tunnel operation 2
hours.  If the locomotive life is 10 years, 20-hours will be the maximum time that an SCR will be
exposed to elevated exhaust gas temperature conditions.
                                      4-48

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                                          Chapter 4: Technological Feasibility
4.3.4.3 Locomotive Parity with the Marine Tier 4 NOX Standard

       The stakeholder also expressed concern that with everything else being equal,
a marine engine capable of achieving the 1.3 g/bhp-hr NOX when tested to the marine
duty cycle would only meet  1.7 g/bhp-hr NOX when tested to the locomotive duty
cycle.  This would be due primarily to the way that the respective duty cycles used for
emissions testing are conducted and weighted.  The E3 Marine Duty Cycle
operational points have exhaust temperatures that correspond to relatively high NOX
reduction efficiency with urea-SCR catalyst systems.  The line-haul locomotive test
cycle includes some operational points with exhaust temperatures that may be too low
for high SCR NOX reduction efficiency (low idle, high idle, dynamic brake and Notch
1).  But, all things aren't equal. The locomotive emissions test cycle allows
adjustments for reduced idle emissions from the new electronic control systems such
as "automated start/stop" that our proposal would require to be used by all
manufacturers. The Category 2 marine engines that are comparable to, or larger than,
line-haul locomotive engines will meet the same 1.3 Tier 4 NOX standard with SCR
three years sooner.  They will also be meeting the Tier 4 NOX standard from a higher
engine-out NOX emissions baseline since many  Category  2 Tier 2 Marine engines are
currently meeting a 7.3 g/bhp-hr NOX standard versus current Tier 2 locomotive
standard at 5.5 g/bhp-hr NOX.  Thus the Tier 4 standards actually represent a slightly
higher  82% NOX reduction for Tier 4 marine engines  vs. 77% for Tier 4 locomotives.
Therefore we believe that the Tier 4 NOX standards for marine diesel engines are
appropriate and represent roughly the same level of emissions stringency.

4.4 Feasibility of Marine NTE Standards

       We are proposing certain changes to the marine diesel engine NTE standards
based upon our understanding of in-use marine  engine operation and based upon the
underlying Tier 3 and Tier 4 duty cycle emissions standards that we are proposing.
As background, we determine NTE compliance by first applying a multiplier to the
corresponding duty-cycle emission standard, and then we compare to that value an
emissions result that is recorded when an engine runs within a certain range of engine
operation.  This range of operation  is called an NTE zone. Refer to 40 CFR §94.106
for details  on how we currently define this zone and how we currently apply the NTE
multipliers within that zone.

       Based upon our best information of in-use marine engine operation, we are
proposing  to broaden certain regions of the marine NTE zones, while narrowing other
regions. It should be noted that the first regulation of ours that included NTE
standards was the commercial marine diesel regulation, finalized in 1999. After we
finalized that regulation, we  promulgated other  NTE  regulations for both heavy-duty
on-highway and nonroad diesel engines.  We also finalized a regulation that requires
heavy-duty on-highway engine manufacturers to conduct field testing to demonstrate
in-use compliance with the on-highway NTE standards.  Throughout our
development of these other regulations, we have learned many details about how best
to specify NTE zones and multipliers that help ensure the greatest degree of in-use
emissions control, while at the same time help avoid  disproportionately stringent

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Draft Regulatory Impact Analysis
requirements for engine operation that has only a minor contribution to an engine's
overall impact on the environment.  Specifically, we are broadening the NTE zones in
order to better control emissions in regions of engine operation where an engine's
emissions rates (i.e. grams/hour, tons/day) are greatest; namely at high engine speed
and high engine load. This is especially important for controlling emissions from
commercial marine engines because they typically operate at steady-state at high-
speed and high-load. This also would make our marine NTE zones much more similar
to our on-highway and nonroad NTE zones.  Additionally, we analyzed different
ways to define the marine NTE zones, and we determined a number of ways to
improve and simplify the way we define and calculate the borders of these zones. We
feel that these improvements would help clarify when an engine is operating within a
marine NTE zone.  We are also proposing for the first time NTE zones for auxiliary
marine engines for both Tier 3 and Tier 4 standards. Because these engines are very
similar to constant-speed nonroad engines, we are proposing to adopt the same NTE
provisions for auxiliary marine engines as we have already adopted for constant-
speed nonroad engines. Note that we currently specify different duty cycles to which
a marine engine may be certified, based upon the engine's specific application (e.g.,
fixed-pitch propeller, controllable-pitch propeller, constant speed, etc.).
Correspondingly, we also have a unique NTE zone for each of these duty cycles.
These different NTE zones are intended to best reflect an engine's real-world range of
operation for that particular application.  Refer to the figures in our proposed changes
to 40 CFR Part 1042, Appendix III, for illustrations of the changes we are proposing.

       We are also proposing changes to the NTE multipliers. We have analyzed
how our proposed Tier 3 and Tier 4 emissions standards would affect the stringency
of our current marine NTE standards, especially in comparison to the stringency of
the underlying duty cycle standards. We recognized that in certain sub-regions of our
proposed NTE zones, slightly higher multipliers would be necessary because of the
way that our more stringent proposed Tier 3 and Tier 4 emissions standards would
affect the stringency of the NTE standards. For comparison, our current marine NTE
standards contain multipliers that range in magnitude from 1.2 to 1.5 times the
corresponding duty cycle standard.  In the changes we are proposing,  the new
multipliers would range from 1.2 to 1.9 times the standard.  Refer to the figures in our
proposed changes to 40 CFR Part 1042, Appendix III, for illustrations of the changes
we are proposing.

       We are also proposing to adopt other NTE provisions for marine engines that
are similar to our existing heavy-duty on-highway and nonroad diesel NTE standards.
We are proposing these particular changes to account for the implementation of
catalytic exhaust treatment devices on marine engines and to account for when a
marine engine rarely operates within a limited region of the NTE zone.

       Aftertreatment systems generally utilize  metallic catalysts, which become
highly efficient at treating emissions above a minimum exhaust temperature.  For the
most commonly used metallic catalysts, this minimum temperature occurs in the
range of about (150 to 250) °C.  In our recent on-highway and nonroad regulations,
we identified NOX adsorber-based aftertreatment technology as the most likely type of

                                     4-50

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                                          Chapter 4: Technological Feasibility
technology for on-highway and nonroad NOX aftertreatment. This NOX adsorber
technology utilizes barium carbonate metals that become active and efficient at
temperatures at or above 250 °C. Also, in our on-highway and nonroad rulemakings
we identified platinum and platinum/palladium diesel oxidation catalyst technology
for hydrocarbon emissions control. This technology also becomes active and efficient
at temperatures at or above 250 °C.  Therefore,  in our on-highway  and nonroad
rulemakings for NOX and hydrocarbons emissions, we set a lower exhaust
temperature NTE limit of 250 °C, as measured at the outlet of the last aftertreatment
device. We only considered engine operation at  or above this temperature as
potential NTE operation.

       For marine applications we have identified similar hydrocarbon aftertreatment
emissions  control technology (i.e. diesel oxidation catalyst or DOC). However, we
have identified different aftertreatment technology for NOX control,  as compared to
our on-highway and nonroad rulemakings.  Specifically, we have identified selective
catalytic reduction (SCR) NOX control technology, which we discussed in detail
earlier in this chapter.  We believe that the performance of this different technology
needs to be considered in setting the proper exhaust temperature limits for the marine
NTE standards. That is why we are proposing that the  NTE standards for NOX would
apply at exhaust temperatures equal to or greater than  150 °C, as measured within  12
inches of the last NOX aftertreatment device's outlet. For hydrocarbon aftertreatment
systems, this minimum temperature limit would be 250 °C, which is the same as our
on-highway and nonroad NTE standards.

4.5 Conclusions

       Even though our proposal covers a wide range  of engines and thus requires
the implementation of a range of emissions controls technologies, we believe we have
identified a range of technologically feasible emissions control technologies that
likely would be used to meet our proposed standards.  Some of these technologies  are
incremental improvements to existing engine components, and many of these
improved components  have already been applied to similar engines. The other
technologies we identified involve catalytic exhaust treatment systems. For these
technologies we carefully examined the catalyst technology, its applicability to
locomotive and marine engine packaging constraints, its durability with respect to  the
lifetime of today's locomotive and marine engines, and its impact on the
infrastructure of the rail and marine industries. From our analysis, based upon
numerous  data from automotive, truck, locomotive, and marine industries, we
conclude that incremental improvements to engine components and  the
implementation of catalytic PM and NOX exhaust treatment technology are
technologically feasible for locomotive  and marine applications, and thus may be
used to meet our proposed emissions standards.
                                    4-51

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Draft Regulatory Impact Analysis
                REFERENCES
1 Title 40, U.S. Code of Federal Regulations, Part 86, §86.007-11 "Emission standards and
supplemental requirements for 2007 and later model year diesel heavy-duty engines and vehicles",
2005.

2 Title 40, U.S. Code of Federal Regulations, Part 1039, §1039.101, Table 1, 2005.

3 Title 40, U.S. Code of Federal Regulations, Part 89, §89.112, Table 1, 2005.

4 "Review of SCR Technologies for Diesel Emission Control: European Experience and Worldwide
Perspectives," presented by Dr. Emmanuel Joubert, 10th DEER Conference, July 2004.

5 Lambert, C., "Technical Advantages of Urea SCR for Light-Duty and Heavy-Duty Diesel Vehicle
Applications," SAE 2004-01-1292, 2004.

6 Final Regulatory Analysis:  Control of Emissions from Nonroad Diesel Engines, U.S. EPA
Document number EPA420-R-04-007, Section 4.1.2 "NOx Control Technologies", May 2004.

7 "Diesel Particulate Filter Maintenance: Current Practices and Experience", Manufacturers of
Emission Controls Association, June 2005, http://meca.org/galleries/default-
file/Filter_Maintenance_White_Paper_605_final.pdf

8 Flynn,  P., et al, "Minimum Engine Flame Temperature Impacts on Diesel and Spark-Ignition Engine
NOx Production", SAE 2000-01-1177, 2000.

9 Heywood, John B., "Internal Combustion Engine Fundamentals", McGraw Hill 1988.

10 Dec, J.E. and C. Espey, "Ignition and early soot formation in a diesel engine using multiple 2-D
imaging diagnostics", SAE 950456, 1995.

11 Kittelson, et al, "Particle concentrations in a diesel cylinder: comparison of theory and experiment",
SAE 861569, 1986.

12 Foster, D.E. and D.R. Tree, "Optical measurements of soot particle size, number density and
temperature in a direct injection diesel engine as a function of speed and load", SAE 940270, 1994.

13 Dickey, D., Matheaus,A., Ryan, T., "NOx Control in Heavy-Duty Diesel Engines - What is the
Limit?", SAE 980174, 1998.

14 Herzog, P., et al, "NOx Reduction Strategies for DI Diesel Engines," SAE 920470, 1992.

15 Uyehara, 0., "Factors that Affect NOx and  Particulates in Diesel Engine Exhaust," SAE 920695,
1992.

16 Durnholz, M., G. Eifler, and H. Endres, "Exhaust-Gas Recirculation - A Measure to Reduce Exhaust
Emission of DI Diesel Engines," SAE 920725, 1992.

17 Bazari, Z. and B. French, "Performance and Emissions Trade-Offs for a HSDI Diesel Engine - An
Optimization Study," SAE 930592, 1993
                                          4-52

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                                                Chapter 4: Technological Feasibility
18 Ropke, S., G.W. Schweimer, and T.S. Strauss, "NOx Formation in Diesel Engines for Various Fuels
and Intake Gases" SAE 950213, 1995.

19 Kreso, A.M., et al, "A Study of the Effects of Exhaust Gas Recirculation on Heavy-Duty Diesel
Engine Emissions" SAE 981422, 1998.

20 Ghaffarpour, M. and R. Baranescu, "NOx Reduction Using Injection Rate Shaping and Intercooling
in Diesel Engines," SAE 960845, 1996.

21 Tow, T.C., D.A. Pierpont, and R.D. Reitz, "Reducing Particulate and NOx Emissions by Using
Multiple Injections in a Heavy Duty D.I. Diesel Engine", SAE 940897, 1994.

22 Pierpont, D.A., D.T. Montgomery, and R.D. Reitz, "Reducing Particulate and NOx Emissions Using
Multiple Injections and EGR in a D.I. Diesel Engine", SAE 950217,  1995

23 Ricart, L.M. and R.D. Reitz, "Visualization and Modeling of Pilot  Injection and Combustion in
Diesel Engines", SAE 960833, 1996.

24 Mather, O.K. and R.D. Reitz, "Modeling the Influence of Fuel Injection Parameters on Diesel
Engine Emissions",  SAE 980789, 1998.

25 Bazari, Z. and B. French, "Performance and Emissions Trade-Offs for a HSDI Diesel Engine - An
Optimization Study", SAE 930592, 1993.

26 Walker, A.P. et al., "The Development and In-Field Demonstration of Highly Durable SCR Catalyst
Systems," SAE 2004-01-1289.

27 Conway, R. et al., "Combined SCR and DPF Technology for Heavy Duty Diesel Retrofit," SAE
2005-01-1862, 2005.

28 "The Development and On-Road Performance and Durability of the Four-Way Emission Control
SCRTTM System," presented by Andy Walker, 9* DEER Conference, August, 2003.

29 Telephone conversation with Gary Keefe, Argillon, June 7, 2006.

30 M.J. Bradley & Associates, "Alice Austen Vessel SCR Demonstration Project - Final Report,"
August 2006, www.mjbradley.com/documents/Austen_Alice_Report_Final_31Aug06.pdf.

31 "SCRT® Technology for Retrofit of Heavy Duty Diesel Applications," presented by Ray Conway,
11th DEER Conference, August, 2005.

32 "Urea SCR and DPF System for Tier 2 Diesel Light-Duty Trucks," presented by Christine Lambert,
12th DEER Conference, August 2006.

33 Conway, R. et al., "NOx and PM Reduction Using Combined SCR and DPF Technology in Heavy
Duty Diesel Applications," SAE 2005-01-3548, 2005.

34 Miller, W. et al., "The Development of Urea-SCR Technology for  US Heavy Duty Trucks," SAE
2000-01-0190, 2000.

35 "Viability of Urea Infrastructure for SCR Systems," presented by M.D. Jackson, U.S. EPA Clean
Diesel Engine Implementation Workshop, August 6, 2003.

                                         4-53

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Draft Regulatory Impact Analysis
36 Email message from Mike Rush, Association of American Railroads, to Jeff Herzog, U.S.
Environmental Protection Agency, July, 15, 2002.

37 "National Transportation Statistics - 2004," Table 4-5, U.S. Bureau of Transportation Statistics.

38 "Mineral Commodity Summaries 2006,"  page 118, U.S. Geological Survey,
www.minerals.usgs.gov/minerals/pubs/mcs/mcs2006.pdf.

39 "Diesel Particulate Filter Technology for Low-Temperature and Low-NOx/PM Applications",
presented by Sougato Chatterjee, 10th DEER Conference, July 2004.

40 Kowatari, T. et al, "A Study of a New Aftertreatment System (1): A New Dosing Device for
Enhancing Low Temperature Performance of Urea-SCR," SAE 2006-01-0642.

41 Jacobs, T., Chatterjee, S., Conway, R. Walker, A., Kramer, J., Mueller-Hass, K. "Development of
Partial Filter Technology for HDD Retrofit", SAE Technical Paper Series, No. 2006-01-0213, 2006.

42 Jacob, E., Lammerman, R., Pappenheimer, A., Rothe, D. "Exhaust Gas Aftertreatment System for
Euro 4 Heavy-duty Engines", MTZ, June, 2005.

43 Smith, B., Sneed, W., Fritz, S. "AAR Locomotive Emissions Testing 2005 Final Report".

44 Pace, L., Konieczny, R., Presti, M.  "Metal Supported Particulate Matter-Cat, A Low Impact and
Cost Effective Solution for a  1.3 Euro IV Diesel Engine", SAE Technical Paper Series, No. 2005-01-
0471,2005.

45 Telephone conversation between Brian King, Elliot Bay Design Group, and Brian Nelson, EPA, July
24, 2006.

46 Ming, C. et al., "Modelling and Optimization of SCR-Exhaust Aftertreatment Systems," SAE 2005-
01-0969, 2005.

47 "SCR Technology for NOx Reduction: Series Experience and State of Development," presented by
Manuel Hesser, 11* DEER Conference, August 2005.
        or ijrea SCR Technology: Which is the right technology for TIER 2 BIN 5 passenger
vehicles?," presented by Richard Dorenkamp, 12th DEER Conference, August 2006.

49 "Evaluation of Supplier Catalyst Formulations for the Selective Catalytic Reduction of NOx with
Ammonia", Presented by Steven J. Schmieg and Jong H. Lee at the U.S. DOE 9* CLEERS Workshop,
May 2-5, 2006.

50 Data provided to the U.S. EPA by Johnson Matthey Catalytic Systems Division, November 6, 2006.
                                          4-54

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                                     Chapter 5: Engineering Cost Estimates
CHAPTER 5: ENGINEERING COST ESTIMATES	3
5.1 Methodology for Estimating Engine and Equipment Engineering Costs	4
5.2 Engine-Related Engineering Costs for New Engines	7
  5.2.1 New Engine Fixed Engineering Costs	7
  5.2.2 New Engine Variable Engineering Costs	27
5.3 Equipment-Related Engineering Costs for New Pieces of Equipment	56
  5.3.1 New Equipment Fixed Engineering Costs	56
  5.3.2 New Equipment Variable Engineering Costs	60
5.4 Operating Costs for New and  Remanufactured Engines	63
  5.4.1 Increased Operating Costs Associated with Urea Use	63
  5.4.2 Increased Operating Costs Associated with DPF Maintenance	64
  5.4.3 Increased Operating Costs Associated with Fuel Consumption Impacts
  	65
  5.4.4 Total Increased Operating Costs	66
5.5 Engineering Hardware Costs  Associated with the Locomotive
Remanufacturing Program	73
5.6 Summary of Proposed Program Engineering Costs	79
  5.6.1 New Engine Engineering Costs	79
  5.6.2 New Equipment Engineering Costs	80
  5.6.3 Operating Costs for New and Remanufactured Engines	81
  5.6.4 Remanufacturing Program Engineering Hardware Costs	82
  5.6.5 Total Engineering Costs Associated with the Proposed Program	82
5.7 Engineering Costs Associated with a Possible Marine Remanufacturing
Program	84
5.8 Engineering Costs and Savings Associated with Idle  Reduction Technology86
5.9 Analysis of Energy Effects	93
5.10 Cost Effectiveness	94
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Draft Locomotive and Marine RIA
CHAPTER 5: Engineering Cost Estimates

       This chapter presents the engine and equipment engineering costs we have
estimated for meeting the new engine emissions standards.a Section 5.1 includes a
brief outline of the methodology used to estimate the engine and equipment costs.
Sections 5.2 and 5.3 present the projected costs of the individual technologies we
expect manufacturers to use to comply with the new emissions standards, along with
a discussion of fixed costs such as research, tooling, certification, and
equipment/vessel redesign.  Section 5.4 presents our estimate of changes in the
operating costs that would result from the proposed program and section 5.5 presents
costs associated with the locomotive remanufacturing program. Section 5.6
summarizes these costs and presents the total program costs.  Section 5.7 presents
costs associated with a possible marine remanufacturing program, although this
program is not being proposed.

       To maintain consistency in the way our emission reductions, costs, and cost-
effectiveness estimates  are calculated, our cost methodology relies on the same
projections of new locomotive and marine engine growth  as those used in our
emissions inventory projections.  Our emission inventory  analyses for marine engines
and for locomotives include estimates of future engine populations that are consistent
with the future engine sales used in this cost analysis.

       Note that the costs here do not reflect changes to the fuel used to power
locomotive and marine  engines. Our Nonroad Tier 4 rule controlled the sulfur level
in all nonroad fuel, including that used in locomotives and marine engines.b The
sulfur level in the fuel is a critical element of the proposed locomotive and marine
program. However, since the costs of controlling locomotive and marine fuel sulfur
have been considered in our Nonroad Tier 4 rule, they are not considered here.  This
analysis considers only those costs associated with the proposed locomotive and
marine program.

       Additionally, the costs presented here do not reflect any savings that are
expected to occur because of the engine ABT program and the various flexibilities
included in the program.  These program features have the potential to provide
savings for both engine and locomotive/vessel manufacturers. While we fully expect
companies to use them to reduce compliance costs, we do not factor them into the
cost analysis because they are voluntary programs. This analysis of compliance costs
       a We use the term "engineering costs" to differentiate from "social costs." Social costs are
discussed in Chapter 7 of this draft RIA. For simplicity, the terms "cost" and "costs" throughout the
discussion in this Chapter 5 should be taken as referring to "engineering costs."

       b See the Regulatory Impact Analysis for the Nonroad Tier 4 final rule, EPA420-R-04-007,
May 2004.
                                      5-2

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                                        Chapter 5: Engineering Cost Estimates
relates to regulatory requirements that are part of the proposed rule for Tiers 3 and 4
emissions standards for locomotive and marine engines. Unless noted otherwise, all
costs are in 2005 dollars ($2005).
5.1 Methodology for Estimating Engine and Equipment Engineering
    Costs

       This analysis makes several simplifying assumptions regarding how
manufacturers will comply with the new emission standards. First, for each tier of
emissions standards within a given category of engine, we assume a single
technology recipe. For example, all Tier 4 engines in the locomotive category are
estimated to be fitted with a selective catalytic reduction (SCR) system, a diesel
particulate filter (DPF), and a diesel oxidation catalyst (DOC).  However, we expect
that each manufacturer will evaluate all possible technology avenues to determine
how to best balance costs while ensuring compliance. As noted, for developing cost
estimates, we have assumed that the industry does not make use of the  averaging,
banking, and trading program, even though this program offers industry the
opportunity for significant cost reductions. Given these simplifying assumptions, we
believe the projections presented here overestimate the costs associated with different
compliance approaches manufacturers may ultimately take.

       Through our background work for this locomotive and marine rule, our past
locomotive and marine rules, and our recent highway and nonroad diesel rules, we
have sought input from a large section of the regulated community regarding the
future costs of applying the emission control technologies expected for diesel engines
within the context of this proposed program.  Under contract with EPA, ICF
International (formerly ICF Consulting) provided questions to several engine and
parts manufacturers regarding costs associated with emission control technologies for
diesel engines. The responses to these questions were used to estimate costs for
"traditional" engine technologies such as EGR, fuel-injection systems,  and for
marinizing systems for use in a marine environment.1'2

       Costs for exhaust emission control devices (e.g., catalyzed DPFs, SCR
systems, and DOCs) were estimated using the methodology used in our 2007 heavy-
duty highway rulemaking.  In that rulemaking effort, surveys were provided to nine
engine manufacturers seeking information relevant to estimating the  costs for and
types of emission-control technologies that might be  enabled with low-sulfur diesel
fuel. The survey responses were used as the first step in estimating the costs for
advanced emission control  technologies anticipated for meeting the 2007 heavy-duty
highway standards. We then built upon these costs based on input from members of
the Manufacturers of Emission Controls Association  (MECA). We also used this
approach as the basis for estimating costs for our recent nonroad tier 4 (NRT4)
rulemaking effort. Because the anticipated emission  control technologies for use on
locomotive and marine engines are the same  as, or similar to, those expected for
highway and nonroad engines, and because the suppliers of the technologies are the
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Draft Locomotive and Marine RIA
same for of these engines, we have used that analysis as the basis for estimating the
costs of these technologies in this rulemaking.3

       Costs of control include variable costs (for new hardware, its assembly, and
associated markups) and fixed costs (for tooling, research, redesign efforts, and
certification). For technologies sold by a supplier to the engine manufacturers, costs
are either estimated based on a direct cost to manufacture the system components plus
a 29 percent markup to account for the supplier's overhead and profit or, when
available, based on estimates from suppliers on expected total costs to the
manufacturers (inclusive of markups).4 Estimated variable costs for new technologies
include a markup to account for increased warranty costs. Variable costs are
additionally marked up to account for both manufacturer and dealer overhead and
carrying costs.  The manufacturer carrying cost—estimated to be four percent of the
direct costs—accounts for the capital cost of the extra inventory and the incremental
costs of insurance, handling, and storage. The dealer carrying cost—estimated to be
three percent of their direct costs—accounts for the cost of capital tied up in extra
inventory. We adopted this same approach to markups in the 2007 heavy-duty
highway rule and the NRT4 rule, based on industry input.5

       We have also identified various factors that cause  costs to decrease over time,
making it appropriate to distinguish between near-term and long-term costs.
Research on the costs of manufacturing has consistently shown that, as manufacturers
gain experience in production, they are able to apply innovations to simplify
machining and assembly operations, use lower cost materials, and reduce the number
or complexity of component parts. This analysis incorporates the effects of this
learning curve as described in Section S.2.2.6

       Fixed costs for engine research are estimated to be incurred over the five-year
period preceding introduction of the engine. Fixed costs for engine tooling and
certification are estimated to be incurred one year ahead of initial production.  Fixed
costs for equipment redesign are also estimated to be incurred one year ahead of
production.  We have also included lifetime operating costs where applicable.  These
include costs associated with fuel consumption impacts and urea use, and increased
maintenance demands resulting from the addition of new emission-control hardware.
We have also included incremental costs associated with an increase in
remanufacturing costs due to the inclusion of additional hardware as part of the
remanufactured engine.

       A simplified overview of the methodology used to estimate engine and
equipment costs is as follows:

•  For engine research, we have estimated the total dollars that we believe each
   engine manufacturer will spend on research to make DPF and SCR systems work
   together.  We refer to such efforts as corporate research. Also for engine
   research, we have estimated the dollars spent to tailor the corporate research to
   each individual engine line in the manufacturer's product mix. We refer to such
   efforts as engine-line research.
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                                         Chapter 5: Engineering Cost Estimates
•  For engine-related tooling costs, we have estimated the dollars that we believe
   each engine manufacturer will spend on tooling for each of its engine lines. This
   amount varies depending on whether the manufacturer makes only locomotive
   and/or marine engines or also makes highway and/or nonroad engines.  This
   amount also varies depending on the emissions standards to which the engine line
   is certified (i.e., Tier 3 or 4).

•  For engine variable costs (i.e., emission-control hardware), we use a three-step
   approach:

   •   First, we estimate the cost per piece of technology/hardware. As described in
       detail in Section 5.2.2, emission-control hardware costs tend to be directly
       related to engine characteristics—for example, most emission control devices
       are sized according to engine displacement so costs vary by displacement.
       Because of this relationship, we are able to determine a variable cost equation
       as a function of engine displacement.

   •   Second, we determine a sales weighted baseline technology package using a
       database from Power Systems Research of all locomotive and marine engines
       sold in the United States.7  That database lists engine characteristics for every
       one of over 40,000 locomotive and marine engines sold in the United States in
       any given year. Using the baseline engine characteristics of each engine, the
       projected technology package for that engine, and the variable cost equations
       described in Section 5.2.2, we calculate a variable cost for the sales weighted
       average engine in each of several different engine categories.

   •   Third, this weighted average variable cost is multiplied by the appropriate
       projected sales in each year after the new standards take effect to give total
       annual costs for each engine category.  The sum total of the annual costs for
       all engines gives the fleetwide variable costs per year.

•  Equipment related costs—i.e., marine vessels or locomotives—are generated
   using the same methodology to estimate the fixed costs for equipment redesign
   efforts and the variable costs for new brackets, bolts, and sheet metal that we
   expect will be required.

       This chapter addresses a number of costs including: Engine costs - fixed
costs then variable costs; equipment costs - fixed costs then variable costs; and,
operating costs - urea, maintenance, and fuel consumption impacts; and,
remanufacturing program costs. A summation of these costs is presented in Section
5.6. Variable cost estimates for both engines and equipment represent an expected
incremental cost of the engine or piece of equipment in the model year of
introduction.  Variable costs per engine decrease in subsequent years as a result of
several factors, as described below, although these factors do not apply to equipment
variable costs. All costs are presented in 2005 dollars.
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Draft Locomotive and Marine RIA
5.2 Engine-Related Engineering Costs for New Engines

5.2.1 New Engine Fixed Engineering Costs

       Engine fixed costs consist of research, tooling, and certification. For these
costs, we have made a couple of simplifying assumptions with regard to the timing of
marine-related expenditures due to the complexity of the roll out of the marine engine
standards. We have estimated that, in general, the marine engine fixed costs would
be incurred during the years prior to 2012 (for Tier 3 related costs) and 2016 (for Tier
4 related costs). While this approach impacts the timing of marine-related
expenditures and, thus, the annual costs during the early years of implementation, it
has no impact on the total costs we would estimate in association with the proposed
standards. However, while having no impact on the total costs we estimate would be
incurred, this approach does have a very minor impact on the net present value of
costs since some early costs (e.g., those for <75 kW Tier 3 engines and >3,700 kW
Tier 4 NOX) are effectively pushed back a couple of years. We believe that the
approach taken makes it easier to follow the presentation of costs while having no
impact on the results of the analysis.

5.2.1.1 Engine and Emission Control Device Research

       As noted, we estimate costs for  two types of engine research—corporate
research, or that research conducted by manufacturers using test engines to learn how
NOX and PM control technologies work and how they work together in a system; and,
engine line research, or that research done to tailor the corporate knowledge to each
particular engine line. For the Tier 3 standards, we are estimating no corporate
research since the technologies expected for Tier 3 are "existing" technologies and
are well understood.  However, we have estimated engine-line research associated
with Tier 3 since those technologies will still need to be tailored to each engine-line.
For Tier 4, we have estimated considerable corporate research since the technologies
expected for Tier 4 are still considered  "new" technologies in the diesel engine
market. We have also estimated more engine-line research for Tier 4 so that the
corporate research may be tailored to each engine.

       We start this discussion with the more global corporate research.  The
technologies described in Chapter 4 represent those technologies we believe will be
used to comply with the proposed emission standards.  These technologies are also
part of an ongoing research and development effort geared toward compliance with
the 2007 heavy-duty highway and the nonroad Tier 4 standards and, to some extent,
the current and future light-duty diesel vehicle standards in the US and Europe.
Those engine manufacturers making research expenditures toward compliance with
either highway or nonroad emission standards will have to undertake some research
effort to transfer emission-control technologies to engines they wish to sell into the
locomotive and/or marine markets.  These research efforts will allow engine
manufacturers to develop and optimize these new technologies for maximum
emission control effectiveness, while continuing to design engines with good
performance, durability, and fuel efficiency characteristics. However, many engine
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                                        Chapter 5: Engineering Cost Estimates
manufacturers are not part of the ongoing research effort toward compliance with
highway and/or nonroad emission standards because they do not sell engines into the
highway or nonroad markets.  These manufacturers-i.e., the locomotive/marine-only
manufacturers-are expected to learn from the research work that has already occurred
and will continue through the coming years through their contact with highway and
nonroad manufacturers, emission-control device manufacturers, and the independent
engine research laboratories conducting relevant research. Despite these
opportunities for learning, we expect the research expenditures for these loco/marine-
only manufacturers to be higher than for those manufacturers already conducting
research in response to the highway and nonroad rules.

       We are projecting that SCR systems and DPFs will be the most likely
technologies used to meet the new Tier 4 emission standards. Because these
technologies are being researched for implementation in the highway and nonroad
markets well before the locomotive and marine emission standards take effect, and
because engine manufacturers will have had several years complying with the
highway and nonroad standards, we believe that the technologies used to comply with
the locomotive and marine Tier 4 standards will have undergone significant
development before reaching locomotive and marine production.  This ongoing
research will likely lead to reduced costs in three ways.  First, we expect research will
lead to enhanced effectiveness for individual technologies, allowing manufacturers to
use simpler packages of emission-control technologies than we would predict today,
given the current state of development. Second, we anticipate that the continuing
efforts to improve the emission-control technologies will include innovations that
allow lower-cost production. And finally, we believe manufacturers will focus
research efforts on any drawbacks, such as fuel economy impacts or maintenance
costs, in an effort to minimize or overcome any potential negative effects.

       We anticipate that manufacturers will introduce  a combination of primary
technology upgrades to meet the new emission standards. Achieving very low NOX
emissions requires basic research on NOX emission-control technologies and
improvements in engine management.  Manufacturers are expected to address this
challenge by optimizing the engine and exhaust emission-control system to realize the
best overall performance. This will entail optimizing the engine and emission control
system for both emissions and fuel economy performance in light of the presence of
the new exhaust emission control  devices and their ability to control pollutants
previously controlled only via in-cylinder means or with exhaust gas recirculation.
The NOX control technology in particular is expected to benefit from re-optimization
of the engine  management system to better match the NOX catalyst's performance
characteristics.  The majority of the dollars we have estimated for corporate engine
research is expected to be spent on developing this synergy between the engine and
NOX exhaust emission-control systems. Therefore, for engines where we project use
of exhaust aftertreatment devices, we have attributed two-thirds of the research
expenditures to NOX+NMHC control, and one-third to PM control. This approach is
consistent with that taken in our 2007 heavy-duty highway and NRT4 rules.
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Draft Locomotive and Marine RIA
       To estimate corporate research costs, we begin with our 2007 heavy-duty
highway rule. In that rule, we estimated that each engine manufacturer would expend
$35 million for corporate research toward successfully implementing diesel
particulate filters (DPF) and NOX control catalysts.  For this locomotive/marine
analysis, we express all monetary values in 2005 dollars which means our starting
point equates to just under $39 million.8 For their locomotive/marine research efforts,
engine manufacturers that also sell into the highway and/or nonroad markets will
incur some level of research expense but not at the level incurred for the highway
rule. In many cases, the  engines used by highway/nonroad manufacturers in marine
products are based on the same engine platform as those engines used in their
highway/nonroad products.  This is also true for locomotive switchers. However,
power and torque characteristics are often different, so manufacturers will need to
expend some effort to accommodate those differences. For these manufacturers, we
assume that they will incur an average corporate research expense of roughly $4
million. This $4 million expense allows for the transfer of learning from
highway/nonroad research to their locomotive/marine engines. For reasons noted
above, two-thirds of this money is attributed to NOX+NMHC control and one-third to
PM control.

       For those engine  manufacturers that sell engines only into the locomotive
and/or marine markets, and where those engines will be meeting the proposed Tier 4
standards, we believe they will incur a corporate research expense approaching that
incurred by highway manufacturers for the 2007 highway rule although not quite at
the same level. These manufacturers will be able to learn from the research efforts
already underway for both the 2007 highway and nonroad Tier 4 rules (66 FR 5002
and 69 FR 38958, respectively),  and for the Tier 2 light-duty highway rule (65 FR
6698) and analogous rules in Europe. This learning may come from seminars,
conferences, technical publications regarding diesel engine technology (e.g., Society
of Automotive Engineers technical papers), and contact with highway manufacturers,
emission-control  device manufacturers, and the independent engine research
laboratories conducting relevant research.  In the NRT4 rule, we estimated that this
learning would result in nonroad-only manufacturers incurring 70 percent of the
expenditures as highway manufacturers for the 2007 highway rule. Similarly, we
would expect that locomotive/marine-only manufacturers would incur 70 percent of
the expenditures incurred by nonroad-only manufacturers for the NRT4 rule.
Therefore, we have assumed that locomotive/marine-only manufacturers will incur 49
percent of that spent by highway manufacturers in their highway efforts. This lower
number—roughly $19 million versus $39 million in the highway rule—reflects the
transfer of knowledge to locomotive/marine-only manufacturers from the many
stakeholders in the diesel industry. Two-thirds of this corporate research is attributed
to NOX+NMHC control and one-third to PM control.

       The $4 million and $19 million  estimates represent our estimate of the average
corporate research expenditures for engine manufacturers. Each manufacturer may
incur more or less than these average figures.

       These corporate research estimates are outlined in Table 5-1.
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                                        Chapter 5: Engineering Cost Estimates
   Table 5-1 Estimated Corporate Research Expenditures by Type of Engine Manufacturer
                       Totals per Manufacturer over Five Years
                                   (SMillion)

Manufacturer sells into highway and/or
nonroad markets
Manufacturer sells only into locomotive
and/or marine markets
% allocated to PM
% allocated to NOX+NMHC
Manufacturer sells only Tier
3 engines
$0
$0
n/a
n/a
Manufacturer sells Tier 4
engines
$4
$19
33%
67%
Note: Since we expect that the majority of the dollars we have estimated for corporate engine research
would be spent on developing the synergy between the engine and NOX exhaust emission-control
systems, we have attributed two-thirds of the corporate research expenditures to NOX+NMHC control
and one-third to PM control.
       The PSR database shows that there were 47 engine manufacturers that sold
engines into the locomotive and marine markets in 2002.  Of these 47, 12 sold
engines into the market segments proposed to meet the Tier 4 standards (i.e.,
proposed to need exhaust aftertreatment devices and, therefore, need to conduct this
research).  Of those 12, three sold exclusively into the locomotive and/or marine
markets, while the other nine sold engines into the highway and/or nonroad markets
in addition to the locomotive and/or marine markets. As a result, we estimate that
three manufacturers will need to spend the full $19 million conducting research and
nine will spend $4 million, for a total corporate research expenditure of just  over $92
million.

       Further, six of these 12 manufacturers sold into both the locomotive and
marine markets and, therefore, will spend a portion of their corporate research dollars
during the five years prior to 2015 (for DPF research to support locomotive engines),
a portion during  the five years prior to 2016 (for SCR and DPF research to support
marine engines)  and the remaining portion during the five years prior to 2017 (for
SCR research to  support locomotive engines).  Of the six remaining manufacturers,
five sold only into the marine market so will spend their dollars during the five years
prior to 2016 (for SCR and DPF research to support marine engines). The remaining
manufacturer sold only into the  locomotive market and will spend a portion  of its
corporate research dollars during the five years prior to 2015 (for DPF research) and
the remaining portion during the five years prior to 2017 (for SCR research). Further
allocation of corporate research  into marine Cl, marine C2, locomotive switcher, and
locomotive line-haul segments based on the segments into which each manufacturer
sold in 2002 results in the total corporate research expenditures by market segment
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Draft Locomotive and Marine RIA
shown in Table 5-2.c We then spread these costs over the five years in advance of the
applicable standards to get the annual costs shown in Table 5-3.
 Table 5-2 Estimated Corporate Research Expenditures Allocated by Market Segment (SMillion)
Market Segment
Locomotive Switcher/Passenger
Locomotive Line-Haul
Marine Cl
Marine C2
Total Industry Expenditure
Total Corporate Research
Expenditure
$ 10.4
$19.1
$37.3
$25.6
$92.3
PM
$3.4
$6.3
$ 12.3
$8.4
$30.5
NOX+NMHC
$7.0
$12.8
$25.0
$17.1
$61.8
Notes:  Since we expect that the majority of the dollars we have estimated for corporate engine
research would be spent on developing the synergy between the engine and NOX exhaust emission-
control systems, we have attributed two-thirds of the corporate research expenditures to NOX+NMHC
control and one-third to PM control.  Marine Cl includes recreational marine > 2000 kW.
        0 Note that, throughout this discussion of costs, recreational marine engines over 2000 kW
are included in the Cl marine category unless otherwise noted. As such, when referring to the
recreational marine category, we mean recreational marine engines less than 2000 kW unless otherwise
noted.
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                                                       Chapter 5: Engineering Cost Estimates
Table 5-3 Estimated Corporate Research Expenditures by Year (SMillions)
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Draft Locomotive and Marine RIA
       As shown in Table 5-3, the net present value of the corporate research is
estimated at $73 million using a three percent discount rate,  and $54 million using a
seven percent discount rate.d We can estimate these expenditures on a per engine
basis considering the time value of money and engine sales for 2006 through 2040, as
shown in Table 5-4.
                   Table 5-4 Estimated Corporate Research per Engine

Locomotive
Switcher/Passenger
Locomotive Line Haul
Marine Cl >600 kW
Marine C2
Total
Estimated Cost Allocation
(SMillions)
$8.1
$14.9
$29.4
$20.2
$72.7
Estimated Sales from
2006 to 2040
3,212
19,258
25,597
6,647
54,715
$/engine
$ 2,530
$780
$ 1,150
$ 3,040
$ 1,330
Note: Marine Cl >600 kW includes recreational marine > 2000 kW. Net present values of sales are
calculated using zero as the sales figure for 2006.
       For engine line research—those engine research efforts done to tailor the
corporate research to each particular engine line—we have first determined the
number of engine lines by considering that, typically, the same basic diesel engine
design can be increased or decreased in size by simply adding or subtracting
cylinders. As a result, a four-, six-, or eight-cylinder engine may be produced from
the same basic  engine design. While these engines have different total displacement,
they each have the same displacement per cylinder.  Using the PSR database, we
grouped each engine manufacturer's engines into distinct engine lines using
increments of 0.5 liters per cylinder. This way, engines having similar displacements
per cylinder are grouped together and are considered to be one engine line. Doing
this, we found there  to be 88 engine lines that will need Tier 3 engine line research
and 31 engine lines that will need Tier 4  engine line research.  Of the 88 Tier 3 engine
lines, eight are  locomotive switcher lines, two are locomotive line haul lines, 13 are
C2 marine lines, and 65 are  other marine lines which, due to their size, generally span
at least two of the three categories of Cl  marine, recreational, and small marine.  For
these 65 marine lines, we have weighted each manufacturer's estimated engine line
research costs according to total engine lines sold into each of these three categories
       d Throughout Chapter 5 of this draft RIA, net present value (NPV) calculations are based on
the period 2006-2040, reflecting the period when the analysis was completed.  This has the
consequence of discounting the current year costs, 2007, and all subsequent years are discounted by an
additional year. The result is a smaller stream of engineering costs than by calculating the NPV over
2007-2040 (3% smaller for 3% NPV and 7% smaller for 7% NPV).
                                      5-12

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                                          Chapter 5: Engineering Cost Estimates
by the particular manufacturer. Of the 31 Tier 4 engine lines, four engine lines had
sales in both the locomotive and the marine markets, so we have split evenly the
engine line research between the appropriate segments; two of these four were
marine-C I/locomotive-switcher engine lines, while the other two were marine-
C2/locomotive-line haul engine lines.

       Consistent with our NRT4 rule, for those engine lines adding aftertreatment
devices (i.e., the Tier 4 engine lines) we have estimated the engine line research at
$3.2 million per line for those engines under 600 kW and $6.5 million per line for
engines over 600 kW range.  For engine line research associated with the Tier 3
standards, we have  estimated the expenditure per engine line at $1.6 million. This
value is lower than the amount estimated for Tier 4 since the Tier 3 effort should
amount to recalibration work which is less costly than the work expected for Tier 4
engine lines. The estimated engine line research expenditures by type of engine
manufacturer are shown in Table 5-5 and by market segment for Tier 3 in Table 5-6
and for Tier 4 in Table 5-7.
   Table 5-5 Estimated Engine Line Research Expenditures by Type of Engine Manufacturer
                    Totals per Engine Line for Tiers 3 & 4 (SMillion)

Manufacturer sells into highway
and/or nonroad markets
Manufacturer sells only into
locomotive and/or marine
markets
% allocated to PM
% allocated to NOX+NMHC
Tier 3 engine line
$ 1.6
$1.6
33%
67%
Tier 4 engine line
<600 kW
$3.2
$3.2
33%
67%
Tier 4 engine line
>600 kW
$6.5
$6.5
33%
67%
Note: Since we expect that the majority of the dollars we have estimated for engine line research
would be spent on developing the synergy between the engine and NOX exhaust emission-control
systems, we have attributed two-thirds of the engine line research expenditures to NOX+NMHC control
and one-third to PM control.
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Draft Locomotive and Marine RIA
      Table 5-6 Tier 3 Engine Line Research Expenditures by Market Segment (SMillion)
Segment
Small Marine
Recreational Marine
Marine Cl
Marine C2
Locomotive
Switcher/Passenger
Locomotive Line Haul
Total
Engine Lines
<600 kW
Engine Lines
>600 kW
65
0
6*
0
63
13
2
2
25
Tier3
$/line
$1.6
$ 1.6
$1.6
$ 1.6

Total
$104
$20.8
$ 12.8
$3.2
$ 140.8
* Note that we have developed hardware costs for switchers based on a single large engine of,
generally, over 2000 hp.  However, many switchers are powered by several nonroad engines placed in
series to arrive at a large horsepower locomotive. Perhaps it would have been more appropriate to
assume research costs for those engines to be $0 since the effort is, presumably, being done for the
nonroad Tier 4 rule. However, to be conservative, we have included engine line research costs for
these engines.
      Table 5-7 Tier 4 Engine Line Research Expenditures by Market Segment (SMillion)
Segment
Marine Cl
Marine-C I/Loco-
Switcher/Passenger
Locomotive Switcher/Passenger
Marine C2
Marine-C2/Loco-LineHaul
Locomotive Line Haul
Total
Engine Lines
<600 kW
n/a
0
6*
0
0
0
6
Engine Lines
>600 kW
10
2
0
11
2
0
25
Tier 4
$/line
$6.5
$6.5
$3.2
$6.5
$6.5
$6.5

Total
$65.0
$13.0
$ 19.2
$71.5
$ 13.0
$0
$ 181.7
* Note that we have developed hardware costs for switchers based on a single large engine of,
generally, over 2000 hp.  However, many switchers are powered by several nonroad engines placed in
series to arrive at a large horsepower locomotive. We could have assumed research costs for those
engines to be $0 since the effort is, presumably, being done for the nonroad Tier 4 rule. However, to
be conservative, we have included engine line research costs for these engines.
        We estimate that these engine line research expenditures will be made over a
five year period in advance of the standard for which the cost is incurred.  Spreading
the costs this way results in the annual cost streams shown in Table 5-8 for Tier 3 and
Table 5-9 for Tier 4 and Table 5-10 for the proposed program (i.e., Tiers 3 and 4).e
        e Note that we show the Tier 3 engine-line research costs beginning in calendar year 2007
even though this rule will not be final until the end of 2007 at the earliest. While we usually do not
account for investments made prior to a rule being finalized, we understand that manufacturers have
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Chapter 5: Engineering Cost Estimates

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Draft Locomotive and Marine RIA
                            Table 5-8 Estimated Tier 3 Engine Line Research Expenditures by Year (SMillions)
Calendar
Year
2006
2007
2008
2009
2010
201 1
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027 	
2028
	 2029 	
2030
2031 	
2032
2033
2034
2035
2036
2037
2038
2039
2040
Total
NPVat7%
NPVat3%
Locomotive Switchers
PM N°x+ Subtotal
NMHC
$0.8 $T7T $2.6
$0.8 IIIjITT $2.6
$0.8 I $1.7 I $2.6
$0.8 $1.7 f $2.6
$0.8 | $1.7 j $2.6
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$4.2 ! $8.6 $12.8
$'3T2 I 	 $6.6 ' $9.8
$3.8 I $7.6 " $1 1 .4
Locomotive Line Haul
PM N°x+ Subtotal
NMHC
$ -
$0.2
$0.2
$0.2
$0.2
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
	 $ 	 -""'
$ -
	 $ 	 -""'
$ -
	 $ 	 -""'
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$1.1
$as
$a'9
$ - $ -
$0.4 $0.6
$0.4 $0.6
$0.4 1 $0.6
$0.4 " $0.6
$0.4 J $0.6
$ - = q> -
$6.9 $13.9 $20.8
$6.9 $13.9 $20.8
$6.9 $13.9 $20.8
$6.9 | $13.9 $20.8
$6.9 | $13.9 | $20.8
$ - $ - $ -
$ - $ - $ -
$ - I $ - $ -
$ - | $ - I $ -
$ - $ - $ -
$ - $ - $ -
$ - 1 q>
$ - i $ - i $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - $ - $ -
$ - I $ - $ -
$ - i $ - i $ -
$ - $ - $ -
$ - $ - $ -
$ - I $ - $ -
$ - i $ - i $ -
$ - $ - $ -
$ - $ - $ -
$34.3 $69.7 | $104.0
$26.3 | $53.4 | $79.7
$30.5 \ $62.0 \ $92.5
Marine C2
PM N°x+ Subtotal
NMHC
$ -
$1.4
$1.4
$1 .4
$1 .4
$1.4
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
-
-
$ -
$ -
$ -
$ -
-
-
$ -
$ -
$ -
$ -
-
$6.9
$5.3
$6.1
$ -
$2.8
$2.8
$2.8
$2.8
$2.8
$ -
-
$ -
$ -
-
"$ 	 -
$ -
-
-
$
$ -
$ -
-
$
-
-
-
$
-
-
-
-
$ -
$ -
-
$13.9
$10.7
$12.4
$ -
$4.2
$4.2
$4.2
$4.2
$4.2
$ -
$ :
$ -
$ -
-
$ -
$ -
-
-
$
	 $ 	 - 	
$ -
-
$
$ -
$ -
-
$
-
$ -
$ -
-
$ -
$ -
-
$20.8
$15.9
$18.5
Totals
Total RM NOX+
sPent NMHC
$ -
$28.2
$28.2
$28.2
$28.2
$28.2
$ -
$ -
$ -
$ -
-
	 $ -
$ -
-
-
$
	 $ 	 -""
$ -
-
$
$ -
$ -
-
$
-
$ -
$ -
-
$ -
$ -
-
$140.8
$107.9
$125.2
$ - ! $ -
$9.3 $18.9
$9.3 $18.9
$9.3 I $TsT9
$9.3 $18.9
$9.3 | $18.9
$ - I $ -
J - J -
5:^±
5: 5:
$46.5 ,__$943
$35.6 | $72.3
$41 .3 ] $83T9
                                                            5-16

-------
                                                           Chapter 5: Engineering Cost Estimates
Table 5-9 Estimated Tier 4 Engine Line Research Expenditures by Year (SMillions)
Calendar
Year
2006
2007
2008
2009
2010
201 1
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027 	
2028
2029
2030
2031 	
2032
2033
2034
2035
2036
2037
2038
2039
2040
Total
NPVat7%
NPVat3%
Locomotive Switchers
PM N°x+ Subtotal
NMHC
$ - i 	 $ :
$ fl-
ip -
$ - * $ -
$1.7 I $ -
$1.7 ! $ -
$1.7 | $3.4
$1.7 I $3.4
$1.7 t $3.4
$ - [ $3.4
$ - $3.4
$0-
ip -
$0-
ip -
$0-
ip -
$0-
ip -
$0-
ip -
Str-
ip -
$0-
ip -
$ fl-
ip -
$0-
ip -
Str-
ip -
fl- _ I Si -
$ fl-
ip -
fl- _ I Si -
Str-
ip -
$ fl-
ip -
$8.5 | $17.2
$5.3 | $9.4
$6.9 \ $13.2
$ -
-
$
-
$1.7
$1.7
$5.1
$5.1
$5.1
$3.4
$3.4
-
	 $ 	 - 	
$ -
-
-
$
	 $ 	 - 	
$ -
-
$
$ '.'"
$ -
-
$
-
$ -
$ -
-
$ -
$ -
-
$25.7
$147
$20.1
Locomotive Line Haul
PM N°x+ Subtotal
NMHC
$ -
$ -
$ -
-
$0.4
$0.4
$0.4
$0.4
$0.4
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$2.1
	 $T'3"
$1.7
$ -
$ -
$ - $a'4
$ - | $0.4
$0.9 i $1.3
$0.9 $1.3
$0.9 $1.3
$0.9 | $0.9
$0.9 $0.9
$ -
$ -
$ -
$ -
$ 600 kW
PM N°x+ Subtotal
NMHC
$ - ! 	 $ 	 : 	
$
-------
Draft Locomotive and Marine RIA
                        Table 5-10 Estimated Tier 3 & Tier 4 Engine Line Research Expenditures by Year (SMillions)
Calendar
Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027 	
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Total
NPVat7%
NPVat3%
Locomotive Switchers
PM N°x+ Subtotal
NMHC
$ -
$0.8
$0.8
$0.8
$2.5
$2.5
$1.7
$1.7
$1.7
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$12.7
$8.5
$10.7
$ -
$1 .7
$1.7 H
$1 .7
$1 .7
$1 .7
$3.4 "
$3.4 "
$3.4
$3.4
$3.4 "
	 $ - "
$
$ -
	 $ - .
$"
-
-
$ - '
$ -
$ -
£
* ' ,
	 $ 	 :.....
-
-
	 s 	
* -
$ -.
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -.
-
$25.8
$16.0
$20.8 1 '
$ -
$2.6
$2.6
$2.6
$4.3
$4.3
$5.1
$5.1
$5.1
$3.4
$3A
-
-
$ - 	
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
-
$ -
$ -
-
$38.5
$245
$3175
Locomotive Line
PM N°x+
NMHC
$ -
$6.2
	 $a'2
$0.2
$0.6
$0.6
$0.4
$0.4
$0.4
$ -
$ -
$ -
$ -
$ -
$ -
-
	 $ 	 -"
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$3.2
$272
$27
$ -
$0.4
$a'4
$0.4
$0.4
$0.4
$0.9
$0.9
$0.9
$0.9
$0.9
-
$ -
$ -
-
-
$
Haul
Subtotal
$ -
$0.6
$0.6
$6?6
$1.1
$1.1
$1.3
$1.3
$1.3
$0.9
$679
-
$ -
$ :
-
$ -
$ -
$ -
$ -
-
$
$ -
$ -
-
$
-
$ -
$ -
-
$ -
$ -
-
$6.5
$40
$5^2
-
$
$ 	 - 	
$ :
-
$
-
$ -
$ -
-
$ -
$ -
-
$9.7
$672
$7^9
Marine C1; Rec;
PM N°x+
NMHC
$ -
$6.9
$6.9
$6.9
$6.9
$11.6
$4.7
$4.7
$4.7
$4.7
$ -
$ -
-
	 $ -
$ -
-
-
$
	 $ -
$ -
-
$
$ -
$ -
-
$
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$57.9
$40.1
$49.2
$ -
$13.9
$1379
$13.9
$13.9
$23.5
$9.6
$9.6
$9.6
$9.6
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
.$ -
-
$"
-
$ -
$ -
-
$ -
$ -
$ -
-
'$ -
$ -
$ -
-
$117.6
$81.4
$9~978
small
Subtotal
$ -
$20.8
$20.8
$20.8
$20.8
$35.1
$14.3
$14.3
$14.3
$14.3
$ -
$ -
	 $ 	 -""
$ -
-
-
$
	 $ 	 -""
$ -
-
$
$ -
$ -
-
$
-
$ -
$ -
-
$ -
$ -
-
$175.5
$12175
$149.0
Marine C2
PM N°x+
NMHC
$ -
$1.4
$1.4
$1.4
$1.4
$6.5
$5.1
$5.1
$5.1
$5.1
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
-
$
$ -
$ -
-
$
-
$ -
$ -
-
$ -
$ -
-
$32.6
$20.3
$26.4
$ -
$2.8
$2.8
$2.8
$2.8
$13.2
$10.5
$10.5
$10.5
$10.5
$ -
-
$ -
$ -
-
$ -
$ -
$ -
$ -
-
$
$ -
$ -
-
$
-
$ -
$ -
-
$ -
$ -
-
$66.2
$4172
$5377
Subtotal
$ -
$4.2
$4.2
$4.2
$4.2
$19.8
$15.6
$15.6
$15.6
$15.6
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$98.8
$61.5
$80.1
Total
Spent
$ -
$28.2
$28.2
$28.2
$30.3
$60.2
$36.3
$36.3
$36.3
$34.2
$4.3
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
-
-
$
* '
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$322.5
$213.8
$268.5
Totals
PM N°x+
NMHC
$ -
	 $973"""
$9.3
$9.3
$1 1 .4
$21.3
$12.0
$12.0
$12.0
$9.9
$ -
$ -
$ -
$ -
-
-
$
$ -
$ -
-
$
$ -
$ -
	 $ 	 -""'
$ -
-
$ -
$ -
-
$ -
$ -
-
$106.4
$7l7l
$8879
$ -
$18.9
$18.9
$18.9
$18.9
$38.9
$24.3
$24.3
$24.3
$24.3
$4.3
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$'
-
-
$ -'
$ -
$ -'
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$216.1
$142.7
$179.6
                                                             5-18

-------
                                        Chapter 5: Engineering Cost Estimates
       Table 5-10 shows the total estimated costs associated with engine line
research. This table combines the costs for Tier 3 (Table 5-8) and Tier 4 (Table 5-9).
As shown in Table 5-10, the net present value of the engine line research is estimated
at $269 million using a three percent discount rate and $214 million using a seven
percent discount rate.  We can estimate these expenditures on a per engine basis
considering the time value of money and engine sales for 2006 through 2040, as
shown in Table 5-11.
                 Table 5-11 Estimated Engine Line Research per Engine

Locomotive Switcher/Passenger
Locomotive Line Haul
Small Marine
Recreational Marine
Marine Cl <600 kW
Marine Cl >600 kW
Marine C2
Total
Estimated Cost Allocation
(SMillions)
$31.5
$7.9
$7.1
$23.8
$44.5
$73.6
$80.1
$ 268.5
Estimated Sales from
2006 to 2040
3,212
19,258
324,403
432,523
303,024
25,597
6,647
1,114,666
$/engine
$ 9,800
$410
$20
$60
$ 150
$ 2,870
$12,050
$240
Note: Marine Cl >600 kW includes recreational marine > 2000 kW. Net present values of sales are
calculated using zero as the sales figure for 2006.
5.2.1.2 Engine-Related Tooling Costs

       Once engines are ready for production, new tooling will be required to
accommodate the assembly of the new engines. In the 2007 heavy-duty highway
rule, we estimated approximately $1.6 million per engine line for tooling costs
associated with DPF/NOX aftertreatment systems.  For the NRT4 rule, we estimated
that a manufacturer that sold only into the landbased nonroad market would incur the
same amount - $1.65 million expressed in 2002 dollars - for each engine line that
required a DPF/NOX aftertreatment system. In this rule, we estimate the same level of
tooling costs associated with DPF/NOX aftertreatment for those manufacturers selling
only into the locomotive/marine markets, or $1.8 million in 2005 dollars. We have
estimated the same level of tooling costs as in the 2007 highway and NRT4 rules
because we expect new locomotive/marine engines to use technologies with similar
tooling needs (i.e., a DPF and a NOX aftertreatment device). For those manufacturers
that sell into the highway and/or nonroad markets and have, therefore, already made
considerable tooling investments, we have estimated an expenditure of 25 percent of
this amount, or $450,000, for those engine lines that will require DPF/NOX
aftertreatment systems for the locomotive/marine market. These costs are assigned
equally to NOX+NMHC control and PM control since the tooling for one should be no
more costly than that for the other.
                                     5-19

-------
Draft Locomotive and Marine RIA
       The tooling estimates discussed above represent our estimates, per engine line,
for engine lines expected to meet the Tier 4 requirements. As noted above in our
discussion of engine line research, we estimate 31 engine lines that will incur these
costs. Of those 31 lines, we estimate that five belong to manufacturers selling
exclusively into the locomotive and/or marine markets.  The remaining 26 lines
belong to manufacturers that also sell into the highway and/or nonroad markets.  The
resultant tooling expenditures associated with the Tier 4 standards are then $22.1
million.

       For meeting the Tier 3 requirements, we have estimated lower costs per line
because the engines will require far less in terms of new hardware and, in fact, are
expected only to require upgrades to  existing hardware (i.e.,  new fuel systems). As
such, we have estimated that those manufacturers selling exclusively into the
locomotive and/or marine markets will spend $450,000 per engine line, while
manufacturers that also sell into the highway and/or nonroad markets will spend
$180,000 per engine line.  The PSR database shows 88 engine lines that we expect to
meet the Tier 3 standards, 13 of which belong to manufacturers that sell only into the
locomotive and/or marine markets. The resultant tooling expenditures associated
with the Tier 3 standards are  then $19.4 million. As with the Tier 4 tooling costs,
these costs are assigned equally to NOX control and PM control.

       We have applied tooling costs by engine line assuming that engines in the
same line are produced on the same production line.  Typically, the same basic diesel
engine design can be increased or decreased in size by simply adding or subtracting
cylinders. As a result, a four-, six-, or eight-cylinder engine  may be produced from
the same basic engine design. While these engines have different total displacement,
they each have the same displacement per cylinder. Using the PSR database, we
grouped each engine manufacturer's  engines into distinct engine lines using
increments of 0.5 liters per cylinder.  This way, engines having similar displacements
per cylinder are grouped together and are considered to be built on the same
production line. Note that a tooling expenditure for a single  engine line may cover
engines over several market segments.  To allocate the tooling  expenditure for a given
production line to a specific market segment, we have divided costs equally  among
the segments (i.e., an engine line used in both the marine Cl  and the locomotive
switchers segments would have its tooling costs split evenly  between those two
segments).

       We estimate that the tooling expenditures would be made one year in advance
of meeting the standards for which the money is spent. A summary of the tooling
costs per manufacturer are shown in Table 5-12.  The tooling costs by market
segment are shown in Table 5-13 and the annual cost streams are shown in Table
5-14.
                                     5-20

-------
                                             Chapter 5: Engineering Cost Estimates
         Table 5-12 Estimated Tooling Expenditures by Type of Engine Manufacturer
                             Totals per Engine Line (SMillion)

Manufacturer sells into highway and/or nonroad markets
Manufacturer sells only into locomotive and/or marine
markets
% allocated to PM
% allocated to NOX+NMHC
Tier 3 engine lines
$0.18
$0.45
50%
50%
Tier 4 engine lines
$0.45
$ 1.8
50%
50%
Note:  We have arbitrarily attributed the tooling costs equally to NOX+NMHC and PM control because
we have no reason to believe that the tooling costs would be greater for one than the other.
   Table 5-13 Estimated Engine Tooling Expenditures by Market Segment and Tier (SMillion)
Segment
Marine Cl <600 kW
Marine Cl >600 kW
Marine C2
Marine Recreational
Marine Small
Locomotive Switcher
Locomotive Line Haul
Total
TierS
$7.9
$ 1.9
$2.6
$4.2
$ 1.2
$1.0
$0.6
$19.4
Tier 4
$0
$7.8
$8.9
$0
$0
$3.1
$2.3
$22.1
Total
$7.9
$9.7
$11.5
$4.2
$ 1.2
$4.1
$2.8
$41.4
              Note: Marine Cl >600 kW includes recreational marine > 2000 kW.
                                         5-21

-------
Draft Locomotive and Marine RIA
                          Table 5-14 Estimated Tier 3 and Tier 4 Engine Tooling Expenditures by Year (SMillions)

Calendar Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Total
NPVat7%
NPVat3%

Switchers
$ -
$ -
$ -
$ -
$ -
$1.0
$ -
-
$1.6
-
$1.6
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$4.1
$2.3
$3.2
Locomotive
Line-Haul
-
$ -
$ -
$ -
$ -
$0.6
$ -
-
$1.1
-
$1.1
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$2.8
$1.5
$2.1

Subtotal
$ -
 -
$ - $ - $ - $ - $ -
IB - " $ - $ - IB - " $ -
$7.8 ! $8.9 i $ - ! $ - ! $16.7
9> - 9> - 9> - 9> - 9> -
$ - $ - $ - $ - : $ -
9> - 9> - 9> - " 9> - : 9> -
$ - $ - $ - $ - : $ -
9> - 9> - 9> - 9> - 9> -
$ - $ - $ - $ - : $ -
$- $-- $-: $-; $ -
9> - 9> - 9> - 9> - ' 9> -
$ - $ - $ - $ - $ -
9> - 9> - 9> - 9>- 9>-
$-: $- $-: $-i $-
*R *R *R *R *R
$ - $ - $ - $ - $ -
9>-" 9>- 9>- $- $-
$-: $-: $-: $-! $-
$- 9>- $- $- $-
$ - $ - $ - $ - $ -
$-" 9>- $- $-" $-
$-: $-" $-' $-: $-
$- 9>- $- $- $-
$ - $ - $ - $ - $ -
$- 9>- $- $-" $-
$- $- $-. $-i $-
$- 9>- $- $- $-
$- $-: $-: $-: $-
$17.6 : $11.5 I $4.2 ; $1.2 ; $34.5
$10.5 : $6.2 : $2.8 : $0.8 : $20.3
$14.0 j $8.8 j $3.5 \ $1.0 ! $27.3
Totals
Total Spent PM N°x+
NMHC
$E t t
- : 4> ~ 4>
$*R *R
*p *p
$ H>
$*R *R
*P *P
$t t
H> H>
$19.4 | $9.7 | $9.7
$ H>
$*R *R
*P *P
$2.7 $2.7 $ -
$16.7 | $8.3 | $8.3
$2.7 \ $ - \ $2.7
$
*P *P
$i  ~ [ H>
$! fl> fl>
-i *p ^p
$t t
H> H>
$*R *R
*P *P
$*R *R
*P *P
$ H>
$*R ': *R
»P - : *P ~
$ a>
*P *P
$a> a;
H> H>
$a> ! a>
»p - 1 *P ~
$E  - = q> -
$a> a>
*P *P
$a> a;
H> H>
$a> a>
*P *P
$a> a;
H> H>
$! a> a>
-i ^p *p
$a> a;
H> H>
$a> a>
*P *P
$a> a;
H> H>
$! a> a>
-i ^p ^p
$a> a;
H> H>
$a> a>
*P *P
$41.4 | $20.7 [ $20.7
$24.1 | $12.1 | $12.0
$32.6 j $16.4 j $16.2
                                                            5-22

-------
                                           Chapter 5: Engineering Cost Estimates
       As shown in Table 5-14, the net present value of the engine tooling
expenditures are estimated at $33 million using a three percent discount rate, and $24
million using a seven percent discount rate.  We can estimate these expenditures on a
per engine basis considering the time value of money and engine sales for 2006
through 2040, as shown in Table 5-15.
                  Table 5-15 Estimated Engine Tooling Costs per Engine

Locomotive Switcher/Passenger
Locomotive Line Haul
Small Marine
Recreational Marine
Marine Cl <600 kW
Marine Cl >600 kW
Marine C2
Total
Estimated Cost Allocation
(SMillions)
$3.2
$2.1
$ 1.0
$^ ^
J . J
$8.2
$5.8
$8.8
$32.6
Estimated Sales from
2006 to 2040
3,212
19,258
324,403
432,523
303,024
25,597
6,647
1,114,666
$/engine
$980
$ 110
$3
$ 10
$30
$230
$ 1,320
$30
Note: Net present values of sales are calculated using zero as the sales figure for 2006.
5.2.1.3 Engine Certification Costs

       Manufacturers would incur more than the normal level of certification costs
during the first few years of implementation because all engines would need to be
fully certified to the new emission standards rather than using the normal practice of
carrying certification data over from prior years/ Consistent with our past
locomotive and marine standard setting regulations, we have estimated engine
certification costs as shown in Table 5-16.  These costs are consistent with past
rulemakings, but have been updated to 2005 dollars. Certification costs (for engines
in all market segments) apply equally to all engine families for all manufacturers
regardless of the  markets into which the manufacturer sells.
f Note that all engines are certified every year, but most annual certifications involve carrying over test
data from prior years since the engine being certified has not changed in an "emissions-meaningful"
way. Since new standards preclude use of carry-over data, we estimate new certification costs for all
engines.  Note that this is, effectively, a conservative estimate since some engines would have changed
sufficiently absent our new standards to require new certification data.
                                       5-23

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Draft Locomotive and Marine RIA
                   Table 5-16 Certification Costs per Engine Family

Locomotive
Small marine
Marine Cl 0.92.5
Marine C2 L/cyl>5
$/engine family
$ 42,000
$ 32,000
$ 32,000
$ 43,000
$ 54,000
$ 54,000
# of engine families
46
24
7
19
13
5
       To determine the number of engine families to be certified, we looked at our
certification databases for the 2004 model year. For marine engines, our database
provides the number of engine families, the liters per cylinder for each, and specifies
whether it is certified as a Cl or a C2 engine.  For locomotive engines, the database
provides the engine displacement.  We have also split the Marine Cl certification
costs evenly between the Cl Marine and Recreational Marine market segments in the
Tier 3 timeframe. In the Tier 4 timeframe, only those Cl Marine engines over 600
kW, including those recreational marine engines over 2000 kW, would incur
certification costs since those Cl engines under 600 kW and the remaining
recreational marine engines will not be meeting the Tier 4 standards. For the small
marine segment, we have estimated the number of engine families at 24 based on an
estimated two families per each of 10 manufacturers selling into that market, and then
another four families sold by marinizers.  The costs for small marine would be
incurred only in the Tier 3 timeframe since they will not be meeting the Tier 4
standards.  Similarly, the locomotive certification costs have been split evenly
between locomotive switchers and locomotive line haul for both  Tiers 3 and 4.  The
resultant annual cost streams are shown in Table 5-17. As shown in the table, the
Tier 3 certification costs are estimated at $4.7 million, while the Tier 4 certification
costs are estimated at around $4.5 million. Despite fewer engines being certified in
the Tier 4 timeframe, the costs are roughly equal to the Tier 3 costs because, for the
Tier 4 standards, we have estimated that locomotive engines are certified twice,  once
for the new PM standard and a second time two years later for the new NOX standard.

       The total certification expenditures are estimated at $9.3 million, or $7.3
million at a three percent discount rate  and $5.5 million at a seven percent discount
rate. The table also makes clear what portion of costs are allocated to NOX+NMHC
and PM, with a 50/50 allocation associated with the Tier 3 standards and the marine
Tier 4 standards. The locomotive Tier  4 certification cost allocations align with the
Tier 4 standards  (PM costs first and NOX+NMHC costs two years later).

       We can estimate these expenditures  on a per engine basis considering the time
value of money and engine sales for 2006 through 2040, as shown in Table 5-18.
                                     5-24

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                                             Chapter 5: Engineering Cost Estimates
             Table 5-17 Estimated Engine Certification Costs by Year (SMillions)
Calendar
Year
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
2031
2032
2033
2034
2035
2036
2037
2038
2039
2040
Total
NPVat7%
NPVat3%
Locomc
Switchers
$ -
$ -
$ -
$ -
$ -
$1.0
HI $ -
-
$1 .0
-
$1 .0
$ -
$ -
$ -
$ -
-
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
-
$ -
$ -
-
$ -
$ -
-
$2.9
$1.6
$2.2
>tive
Line-
Haul
$ -
$ -
$ -
$ -
$ -
$1.0
$ -
-
$1.0
-
$1.0
$ -
$ -
$ -
$ -
-
	 $ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ -
$ 	 -_
-
$2.9
$1.6
$2.2
Marine
Marine Marine Recreationa| Sma||
\JiL. l_/1
$ ~ ' 4> ~ ' H>
$<£ <£ - <£
*P - , *P - ; *P
$ - q> - ; q> -
$ a>
*p *p *p
$ - ; q> - ; q> -
$03 $0.9 : $0.9 : $0.8
$ 4> H>
$*R *R *R
*p *p *p
$ - • 4> ~ • 4>
$03 $0.4 : $ - i $ -
$ - 4> 4>
$ - : q> - ; q> -
$t t t
4> - 4> 4>
$*R t • t
^P - - »P - ; *P ~
$(f i (f ; (f
»P ~ • *P - r *P
$t • t " t
4> - ~ 4> ~ ~ 4>
$*R *R *R
*p ^p ^p
$t t ' t
4> - - 4> ~ 4>
$- $-' $ - ; $-
$t t ' t
4> - 4> ~ 4>
$*R *R *R
*p ^p ^p
$t t " t
4> ~ : 4> ~ ; 4>
$- $-^ $-f $-
$ - 4> ~ ~ 4>
$
$*R - *R ; *R
- . »p - , *p - . »p
$ - q> - q> -
$*R *R *R
^p - *p ^p
$ ~
$ - ; q> - : q> -
$t t • t
4> 4> H>
$ -
$i q;
- i $ -
$1.9
$1.9
$0.7 ! $0.4
$1.9 ! $ -
$E  -
$ -
$ -
$! ff
- ! M> ~
$; a;
- ; *P ~
$E  -
$ -
$ -
$ -
$ -
$ -
$E t
- = q> -
$ -
$ -
$ -
$ -
$; a;
- i $ -
$E t
- = q> -
$ -
$ -
$ -
$ -
$ - : $ -
$ -
$ -
$! ff
- ! M> ~
$! a;
- i q> -
$ - ] $ -
$ -
$ -
$! ff
- ! ^P ~
$• t
- : $ -
$E  -
$9.3
$4.6
$5.5 | $2.8
$7.3 I $3.7
NOX+
NMHC
$ -
$ -
$ -
$ -
$ -
$2.4
-
$ -
$ -
$0.4
$1.9
$ -
$ -
$ -
$ -
-
$ -
$ -
-
-
$ -
$ -
-
-
$ -
$ -
$ -
$ -
-
-
$ -
$ -
$ -
$ -
-
$4.6
$2.7
$3.6
                 Table 5-18 Estimated Engine Certification Costs per Engine

Locomotive
Switcher/Passenger
Locomotive Line Haul
Small Marine
Recreational Marine
Marine Cl
Marine C2
Total
Estimated Total Cost
Allocation (SMillions)
$2.2
$2.2
$0.6
$0.7
$1.1
$0.4
$7.3
Estimated Sales from
2006 to 2040
3,212
19,258
324,403
432,523
328,621
6,647
1,114,666
$/engine
$700
$ 120
$2
$9
^
$3
$60
$10
Note:  Net present values of sales are calculated using zero as the sales figure for 2006.
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Draft Locomotive and Marine RIA
       Note that these certification costs may overestimate actual costs because they
assume all engines would be certified as a result of the proposed new emission
standards. However, some engines would have been scheduled for new certification
independent of the proposed new standards due to design changes or power increases
among other possible reasons. For such engines, the incremental certification cost
would be zero.  However, to remain conservative, here we have applied the
certification costs to all engine families.
5.2.2 New Engine Variable Engineering Costs

       Engine variable costs are those costs for new hardware required to meet the
new Tier 4 emission standards.  We have estimated no incremental hardware costs
associated with the Tier 3 standards. Unlike the Tier 4 standards, the proposed Tier 3
standards are not based on the introduction of new emission control technologies on
locomotive or marine diesel engines. Rather, the Tier 3 standards represent the
largest level of emission reductions possible from the emission control systems we
project that locomotive and marine engines will already have in the timeframe of Tier
3 implementation.  For example, the marine Tier  3 standards are predicated on the use
of the most modern nonroad Tier 4 base engine technologies without the use of the
nonroad Tier 4 aftertreatment based emission solutions. While these base engines
may represent significant technical advances from the marine Tier 2 engines they
replace—having better high pressure fuel systems, better injectors, improved
turbochargers, and more sophisticated electronic  control units—we  do not expect the
manufacturing costs for these individual components to increase over the cost of the
Tier 2 components they will replace. In fact, the  shift from the Tier 2 engine's
electronic unit pump system to the Tier 3 engine's common rail fuel system may
actually result in a fuel system that is cheaper to produce, not more  expensive.
Similarly, while the processing power of the Tier 3 engine control computer may
increase significantly, the cost of the computer chip that makes this possible is likely
to be lower.  This does not mean that the Tier 3 emission controls come for free. We
project there will be costs incurred to optimize the control strategies to meet the
stringent Tier 3 standards and further to test and certify these engines.  These costs
are accounted for as fixed costs described further in section  5.2.1 of this draft RIA.g
       8 To clarify, we have analyzed the fixed costs associated with the switch from unit injectors to
common rail fuel systems reflecting our belief that this transition will come in part because of our
regulation. Because we estimate that common rail fuel systems will be no more expensive than unit
injector systems, and may in fact be cheaper, we have made no estimate of an incremental increase in
variable costs due to this switch. Similarly, we have not made an estimate of what savings (if any)
might be realized from this switch.
                                      5-26

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                                        Chapter 5: Engineering Cost Estimates
       For the variable cost estimates presented here, we have used the same
methodology to estimate costs as was used in our 2007 highway and our NRT4 rules.
Because of the wide variation of engine sizes in the locomotive and marine markets,
we have chosen an approach that results not in a specific cost per engine for engines
within a given power range or market segment, but rather a set of equations that can
be used to determine the variable costs for any engine provided its displacement and
number of cylinders are known. Using the equations presented in this section, we
have then estimated the engine variable costs for the sales weighted average engine in
different power ranges within each market segment.11

       The discussion here considers both near-term and long-term cost estimates.
We believe there are factors that cause hardware costs to decrease over time, making
it appropriate to distinguish between near-term and long-term costs.  Research in the
costs of manufacturing has consistently shown that as manufacturers gain experience
in production, they are able to apply innovations to simplify machining and assembly
operations, use lower cost materials, and reduce the number or complexity of
component parts, all of which allows them to lower the per-unit cost of production.
These effects are often described as the manufacturing learning curve.9

       The learning curve is a well documented phenomenon dating back to the
1930s. The general concept is that unit costs decrease as cumulative production
increases. Learning curves are often characterized in terms of a progress ratio, where
each doubling of cumulative production leads to a reduction in unit cost to a
percentage "p" of its former value (referred to as a "p cycle"). Organizational
learning, which brings about a reduction in total cost, is caused by improvements in
several areas. Areas involving direct labor and material are usually the source of the
greatest savings.  Examples include, but are not limited to,  a reduction in the number
or complexity of component parts, improved component production, improved
assembly speed and processes,  reduced error rates, and improved manufacturing
process. These all result in higher overall production, less  scrappage of materials and
products, and better overall quality. As each successive p cycle takes longer to
complete, production proficiency generally reaches a relatively stable plateau, beyond
which increased production does not necessarily lead to markedly decreased costs.

       Companies and industry sectors learn differently. In a 1984 publication,
Button and Thomas reviewed the progress ratios for 108 manufactured items from 22
separate field studies representing  a variety of products and services.10  The
distribution of these progress ratios is shown in Figure 5-1. Except for one company
that saw increasing costs as production continued, every study showed cost savings of
at least five percent for every doubling of production volume. The average progress
ratio for the whole data set falls between 81 and 82 percent. Other studies (Alchian
1963, Argote and Epple 1990, Benkard 1999) appear to support the commonly used p
h For example, if two engines are sold with one being 100 hp and having 5 sales, the other being 200
hp and having 20 sales, the sales weighted horsepower of engines sold would not be 150 hp but would
instead be 180 hp (100x5 + 200x20 = 4,500; 4,500/25 = 180).


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Draft Locomotive and Marine RIA
value of 80 percent, i.e., each doubling of cumulative production reduces the former
cost level by 20 percent.
           Figure 5-1 Distribution of Progress Ratios (Button and Thomas 1984)
    15
    10  -
     5 -
                      Distribution of Progress Ratios
                                   Progress Ratio
   From 22 field studies (n = 108).
       The learning curve is not the same in all industries. For example, the effect of
the learning curve seems to be less in the chemical industry and the nuclear power
industry where a doubling of cumulative output is associated with 11 percent decrease
in cost (Lieberman 1984, Zimmerman 1982). The effect of learning is more difficult
to decipher in the computer chip industry (Gruber 1992).

       We believe the learning curve is appropriate to consider in assessing the cost
impact of diesel engine emission controls. The learning curve applies to new
technology, new manufacturing operations, new parts, and new assembly operations.
Neither locomotive nor marine diesel engines currently use any form of NOX or PM
aftertreatment except in very limited retrofit applications. Therefore, these are new
technologies for these engines and will involve some new manufacturing operations,
new parts, and new assembly operations beyond those anticipated in response to the
2007 highway and NRT4 rules. Since this will be a new product, we believe this is
an appropriate situation for the learning curve concept to apply.  Opportunities will
exist to reduce unit labor and material costs and increase productivity as discussed
above. We believe a similar opportunity exists for the new control systems that will
integrate the function of the engine and emission-control technologies.  While
impacted diesel engines beginning with Tier 3  compliance are expected to have the
basic components of this system—advanced engine control modules (computers),
advanced engine air management systems (cooled EGR,  and variable geometry
turbocharging), and advanced electronic fuel systems including common rail
                                     5-28

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                                        Chapter 5: Engineering Cost Estimates
systems—they will be applied in some new ways in response to the Tier 4 standards.
Additionally some new components will be applied for the first time.  These new
parts and new assemblies will involve new manufacturing operations. As
manufacturers gain experience with these new systems, comparable learning is
expected to occur with respect to unit labor and material costs.  These changes require
manufacturers to start new production procedures, which will improve with
experience.

       We have applied a p value of 80 percent beginning with the first year of
introduction of any new technology.  That is, variable costs were reduced by 20
percent for each doubling of cumulative production following the year in which the
technology was first introduced in a given market segment. Because the timing of the
emission standards in this final rule follows that of the 2007 highway and NRT4
rules, we have used the first stage of learning done  via those rules collectively as the
starting point of learning for locomotive and marine engines.  In other words, one
learning phase is factored into the baseline costs for locomotive/marine engines. We
have then applied one additional learning step from that baseline.  In the 2007
highway rule, we applied a second learning step following the second doubling of
production estimated to occur at the end of the 2010 model year. We could have
chosen that point as our baseline case for this rule and then applied a  single learning
curve effect from there.  Instead, to remain conservative, we have chosen to use only
the first learning step from the highway/nonroad rules. The approach taken here is
consistent with the approaches taken in our Tier 2 light-duty highway rule and the
2007 highway rule for heavy-duty gasoline engines. There, compliance was being
met through improvements to existing technologies rather than the development of
new technologies. We argued in those rules that, with existing technologies, there is
less opportunity for lowering production costs. For that reason, we applied only one
learning curve effect.  The situation is similar for locomotive and marine engines.
Because these will be existing technologies by the time they are introduced into the
market, there would arguably be less opportunity for learning than there will be for
the highway engines  on which the technologies were first introduced.

       Another factor that plays into our near-term and long-term cost estimates is
that for warranty claim rates. In our 2007  highway rule, we estimated a warranty
claim rate of one percent.  Subsequent to that rule, we learned from industry that
repair rates can  be as much as two to three times higher during the initial years of
production for a new technology relative to later years.11 As a result, in our NRT4
rule, we applied a three percent warranty claim rate during the first two years and
then one percent warranty claim rate thereafter.  We have used the same approach
here as used in the NRT4 rule. This difference in warranty claim rates, in addition to
the learning effects discussed above, is reflected in the different long-term costs
relative to near-term costs.
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Draft Locomotive and Marine RIA
5.2.2.1 SCR System Costs

       The NOX aftertreatment system anticipated for the Tier 4 standards is the
selective catalytic reduction (SCR) system.  For the SCR system to function properly,
a systems approach that includes a reductant metering system and control of engine-
out NOX emissions is necessary. Many of the new air handling and electronic system
technologies developed to meet past locomotive and marine standards, and past
highway and nonroad standards can be applied to accomplish the SCR system control
functions as well.  Some additional hardware for exhaust NOX or oxygen sensing may
also be required.

       We have used the same methodology to estimate costs associated with SCR
systems as was used in our 2007 highway and NRT4 rulemakings for other
aftertreatment devices. The basic components of the SCR system are well known and
include the following material elements:

•  a ceramic substrate upon which a NOX catalyst washcoating is applied;

•  a can to hold and support the substrate;

•  a urea dosing unit (urea injector and control computer);

•  a urea storage tank and associated brakets; and,

•  an exhaust gas sensor (e.g., a NOX sensor) used for control.
       Examples of these material costs are summarized in Table 5-19 and represent
costs to the engine manufacturers inclusive of supplier markups.  The manufacturer
costs shown in Table 5-19 include additional markups to account for both
manufacturer and dealer overhead and carrying costs. The application of overhead
and carrying costs is consistent with the approach taken in the 2007 highway and
NRT4 rulemakings.  In those rules, we estimated the markup for catalyzed emission-
control technologies based on input from catalyst manufacturers.  Specifically, we
were told that device  manufacturers could not mark up the cost of the individual
components within their products because those components consist of basic
commodities (for example, precious metals used in the catalyst could not be
arbitrarily marked up because of their commodity status). Instead, manufacturing
entities could mark up costs only where they add a unique value to the product. In the
case of catalyst systems, the underlying cost of precious metals, catalyst substrates,
PM filter substrates, and canning materials were well known to both buyer and seller
and no markup or profit recovery for those component costs could be realized by the
catalyst manufacturer. In essence, these are components to which the supplier
provides little value-added engineering.
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                                         Chapter 5: Engineering Cost Estimates
       The one component that is unique to each catalyst manufacturer (i.e., the
component where they add a unique value) is the catalyst washcoat support materials.
This mixture (which is effectively specialized clays) serves to hold the catalytic
metals in place and to control the surface area of the catalytic metals available for
emission control.  Although the price for the materials used in the washcoat is almost
negligible (i.e., perhaps one or two dollars), we have estimated a substantial cost for
washcoating based on the engineering value added by the catalyst manufacturer in
this step. This is reflected in the costs presented for SCR systems and DPF systems.
This portion of the cost estimate - the washcoating - is where the catalyst
manufacturer recovers the fixed cost for research and development as well as realizes
a profit. To these manufacturer costs, we have added a four percent carrying cost to
account for the capital cost of the extra inventory, and the incremental costs of
insurance, handling, and storage. A dealer carrying cost is also included to cover the
cost of capital tied up  in extra inventory. Considering input received from industry,
we have adopted this approach of estimating individually the manufacturer and dealer
markups in an effort to better reflect the value each  entity adds at various stages of the
supply chain.12 Also included is our estimate of warranty costs for the system.
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Draft Locomotive and Marine RIA
                 Table 5-19  SCR System Costs (costs shown are costs per SCR system for the given engine power/displacement)
Typical Engine Power (kW)
Typical Engine Displacement (Liter)
Material and component costs
Catalyst Volume (Liter)

Substrate
Washeoattng and Canning
PlgiSp Can Housing
Urea Dosing Unit (Injection Assembly w/ ECU)
Urea Solution Tank & Brackets
x sensor (1 sensor/engine)
DOC for cleanup
Direct Labor Costs

E?9nBr%fiIl(SFrlr5(urs
Labor Cost
Labor Overhead @ 40%
Total Direct Costs to Mfr.
Warranty Cost (3% claim rate)
Mfr. Carrying Cost - Near term
Total Cost to Dealer - Near term
Dealer Carrying Cost - Near term
Baseline Cost to Buyer - Near term
Loco/Marine Cost to Buyer (includes highway learning) - Near term
Warranty Cost (1 % claim rate)
Mfr. Carrying Cost - Long term
Total Cost to Dealer - Long term
Dealer Carrying Cost - Long term
Baseline Cost to Buyer - Long term
Baseline Cost to Buyer (includes Highway Learning) - Long term
Loco/Marine Cost to Buyer (includes Loco/Marine learning) - Long term
7
0.4

1.0
$29
$423
$0
$12
$500
$2
$200
$233

4
$18
$72
$29
$1,501
$111
$60
$1 ,672
$50
$1 ,722
$1,377
$37
$60
$1 ,598
$48
$1,646
$1,317
$1,053
25
1.5

3.8
$113
$517
$0
$12
$527
$8
$200
$245

4
$18
$72
$29
$1 ,723
$128
$69
$1,919
$58
$1 ,977
$1,581
$43
$69
$1 ,834
$55
$1,889
$1,511
$1,209
57
3.9

9.8
$294
$721
$0
$13
$585
$18
$200
$271

4
$18
$72
$29
$2,204
$164
$88
$2,456
$74
$2,530
$2,024
$55
$88
$2,347
$70
$2,418
$1 ,934
$1,547
187
7.6

19.1
$573
$1 ,035
$0
$15
$674
$60
$200
$312

4
$18
$72
$29
$2,971
$221
$119
$3,311
$99
$3,410
$2,728
$74
$119
$3,163
$95
$3,258
$2,606
$2,085
375
18.0

45.0
$1,350
$1,910
$0
$20
$922
$121
$200
$425

4
$18
$72
$29
$5,049
$377
$202
$5,628
$169
$5,797
$4,638
$126
$202
$5,377
$161
$5,538
$4,431
$3,544
746
34.5

86.3
$2,588
$3,302
$0
$28
$1,318
$240
$200
$605

8
$18
$145
$58
$8,484
$627
$339
$9,450
$283
$9,733
$7,787
$209
$339
$9,032
$271
$9,303
$7,442
$5,954
3730
188.0

470.0
$14,100
$16,258
$0
$100
$5,000
$1,200
$200
$2,280

8
$18
$145
$58
$39,341
$2,941
$1,574
$43,856
$1,316
$45,171
$36,137
$980
$1,574
$41 ,895
$1,257
$43,152
$34,521
$27,617
                                                             5-32

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                                        Chapter 5: Engineering Cost Estimates
       We have estimated the cost of this system based on information from several
reports.13'14'15 The individual estimates and assumptions used to estimate the cost
for the system are touched upon in the following paragraphs.

       SCR Catalyst Volume

       During development of this proposal, engine and aftertreatment device
manufacturers have indicated that SCR catalyst volumes could be from one to three
times engine displacement for locomotive and marine applications.  As explained in
Chapter 4 of this draft RIA, we have used a ratio of SCR volume to engine
displacement equal to 2.5:1.

       SCR Catalyst Substrate

       The ceramic flow-through substrates used for the SCR catalyst were estimated
to cost $30 per liter.

       SCR Catalyst Washcoating and Canning

       We have estimated a "value-added" engineering and material product, called
washcoating and canning, based on feedback from members of the Manufacturers of
Emission Control Association (MECA). By using a value-added component that
accounts for fixed costs (including R&D), overhead, marketing and profits from
likely suppliers of the technology, we can estimate this fraction of the cost for the
technology apart from other components that are more widely available as
commodities (e.g, precious metals and catalyst substrates). Based on conversations
with MECA, we understand this element of the product to represent the catalyst
manufacturer's value added and, therefore, their opportunity for markup.  As a result,
the washcoating and canning costs shown in Table 5-19 represent costs with
manufacturer markups included.  The washcoating and canning costs can be
expressed as $34(x) + $390, where x  is the catalyst volume in liters. This
washcoating cost is higher than our past rulemakings because of dual washcoating
process we anticipate will be used to "zone coat" the diesel oxidation function onto a
portion of the SCR catalyst (as discussed below).

       SCR Catalyst Precious Metals

       We expect that the SCR catalysts used in locomotive and marine applications
will contain no precious metals (e.g.,  the platinum group metals platinum, palladium,
and rhodium). As a result, we have estimated zero costs associated with these
commodities.

       SCR Can Housing

       The material cost for the can housing is estimated based on the catalyst
volume plus 20 percent for transition (inlet/outlet) cones, plus 20 percent for
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Draft Locomotive and Marine RIA
scrappage (material purchased but unused in the final product) and a price of $1 per
pound for 18 gauge stainless steel as estimated in a contractor report to EPA and
converted into $2005.16

       Urea Dosing Unit

       The costs for the urea dosing unit are based in part on our past contractor
report that estimated the costs at $250 to $300 for units meant for  12 to 26 liter
catalysts.  Here, we have adjusted the numbers based on recent conversations with
industry by estimating the costs for the smallest engines at $500 and the largest at
$5,000. We then used a linear interpolation to arrive at the costs for engines in
between.

       Urea Solution Tank and Brackets

       The estimated costs for the urea solution tank and brackets is based on
industry input that fuel tank size is roughly one gallon per engine horsepower and
urea dosing rate is roughly four percent of the fueling rate. We also estimated that a
urea tank would cost $60 per 10 gallons of volume. Using these estimates, the
needed urea tank size and associated cost can be estimated.

       NOX Sensor Cost

       We believe that one sensor will be needed per catalyst and have used an
estimated  cost of $200 per sensor based on today's cost of $300 for use in retrofit
applications (retrofit applications are typically considerably more  costly than new).
With increased NOX sensor sales volumes in future locomotive, marine, highway, and
nonroad markets, we believe that NOX sensor costs may well be in the $50 to $100
range, if not lower. For this analysis, we have chosen to remain conservative by
using the $200 per sensor estimate.

       DOC for Cleanup

       Included in the costs for the  SCR system are costs for a diesel oxidation
catalyst (DOC) for clean-up of possible excess ammonia emissions that might occur
as a result of excessive urea usage.  The methodology used to estimate DOC costs is
consistent with the SCR system cost methodology and is presented below in Table
5-20. These cost estimates use a DOC to engine displacement ratio of 0.5:1 because
the low emissions conversion demand placed on the DOC is not expected to require a
larger device.
                                     5-34

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                                                                         Chapter 5: Engineering Cost Estimates
Table 5-20 Diesel Oxidation Costs (costs shown are costs per SCR system for the given engine power/displacement)
Typical Engine Power (kW)
Typical Engine Displacement (Liter)
Material and component costs
Catalyst Volume (liter)

Substrate
Washcoating and Canning
PladWfcSPyst Can Housing
Direct Labor Costs

EitaT38t%rtlti;SFrfrourS
Labor Cost
Labor Overhead @ 40%
Total Direct Costs to Mfr.
Warranty Cost - Near Term (3% claim rate)
Mfr. Carrying Cost - Near Term
Total Cost to Dealer - Near Term
Dealer Carrying Cost - Near Term
Loco/Marine Cost to Buyer
7 i
0.4 :

0.2 ;
$0 i
$187
$1
$0 :

0.5
$18
$9 |
$4 :
$201
$17 I
$8 '
$226 :
$7
$233 |
25 !
1.5

0.8 ;
$0 j
$195 .
$4
$0 :

0.5
$18
$9
$4
$212
$18
$8
$238
$7
$245 ;
57 ;
3.9

2.0
$0 :
$212
$10
$0

0.5
$18
$9
$4
$235
$20
$9
$264
$8
$271 ;
187 ;
7.6

3.8
$0
$238
$19
$0

0.5
$18
$9
$4
$270
$22
$11
$303
$9
$312 ;
375 I
18.0

9.0
$0
$310
$46
$0

0.5
$18
$9
$4 •
$368
$30
$15 -
$413
$12
$425 ;
746 I
34.5

17.3
$0
$424
$88
$0

0.5
$18
$9
$4
$525
$41
$21
$588
$18
$605 ;
3730
188.0

94.0
$0
$1 ,491
$480
$0

0.5
$18
$9
$4
$1,984
$151
$79
$2,214
$66
$2,280
                                              5-35

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Draft Locomotive and Marine RIA
       Important to note here is that we expect the DOC function to be fulfilled
within the confines of the SCR catalyst using a process known as "zone coating" by
which the DOC washcoat is applied to the tail end of the SCR catalyst substrate. By
doing this, a physically separate DOC is not necessary.  We have remained
conservative in our cost analysis by including costs associated with canning of the
DOC.

       Direct Labor Costs

       The direct labor costs for the catalyst are estimated based on an estimate of the
number of hours required for assembly and established labor rates. Additional
overhead for labor was estimated as 40 percent of the labor costs.

       SCR Warranty Costs

       We have estimated both near-term and long-term warranty costs. Near-term
warranty costs are based on a three percent claim rate and an estimate of parts and
labor costs per incident, while long-term warranty costs are based on a one percent
claim rate and an estimate of parts and labor costs per incident.17 The labor rate is
assumed to be $50 per hour with four hours required per claim, and parts costs are
estimated to be 2.5 times the original manufacturing cost for the component. The
calculation of near-term warranty costs for the 7 kW engine shown in Table 5-19 is as
follows:

       [($29+$423+$12+$500+$2+$200+$233)(2.5) + ($50)(4hours)](3%) = $111
       Manufacturer and Dealer Carrying Costs

       The manufacturer's carrying cost was estimated at 4 percent of the direct
costs. This reflects primarily the costs of capital tied up in extra inventory, and
secondarily the incremental costs of insurance, handling and storage.  The dealer's
carrying cost was estimated at 3  percent of the incremental cost, again reflecting
primarily the cost of capital tied  up in extra inventory.

       SCR System Cost Estimation Function

       Using the example SCR system costs shown in the table, we calculated a
linear regression to determine the SCR system cost as a function of engine
displacement.  This way, the function can be applied to the wide array of engines in
the locomotive line haul and marine fleets to determine the total or per engine costs
for SCR hardware.  The functions calculated for SCR system costs in line-haul
locomotives and marine applications are shown in Table 5-21.
                                     5-36

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                                        Chapter 5: Engineering Cost Estimates
       For locomotive switcher applications, we have used the costs developed for
our NRT4 rulemaking because locomotive switchers tend to be powered by land
based nonroad engines. For this reason, it seemed most appropriate to use the same
costs developed for that rule. These costs are also shown in Table 5-21.
       Table 5-21 SCR System Costs as a Function of Engine Displacement, x, in Liters

Line haul locomotive; marine
Switcher locomotive

Near-term cost function
Long-term cost function
Near-term cost function
Long-term cost function
Linear Regression
$185(x) + $1,323
$142(x) + $1,012
$103(x) + $183
$83(x) + $160
R2
0.999
0.999
0.999
0.999
Note: Near term costs include a 3 percent warranty claim rate while long term costs include a 1
percent warranty claim rate and the learning effect.
       This table shows both a near-term and a long-term cost function for SCR
system costs. The near-term function incorporates the near-term warranty costs
determined using a three percent claim rate, while the long-term function incorporates
the long-term warranty costs determined using a one percent claim rate.  Additionally,
the long-term function incorporates learning curve effects.
5.2.2.2 DPF System Costs

       One means of meeting the proposed Tier 4 PM standard is to use a diesel
particulate filter (DPF) system like that expected to be used for highway and NRT4
applications.  However, as explained in Chapter 4 of this draft RIA, here we are
projecting a DPF volume to engine displacement ratio of 1.7:1. In the highway and
nonroad rules, we projected ratios of 1.5:1. For the DPF to function properly, a
systems approach that includes precise control of engine air-fuel ratio is also
necessary. Many of the new air handling and electronic fuel system technologies
developed in order to meet the highway, nonroad, and past locomotive/marine
standards can be applied to accomplish the DPF control functions as well.

       We have used the same methodology to estimate costs associated  with DPF
systems as was used in our 2007 highway and NRT4 rulemakings. The basic
components of the DPF are well known and include the following material elements:

•  An oxidizing catalyst, typically platinum;

•  a substrate upon which the catalyst washcoating is applied and upon which PM is
   trapped;
                                     5-37

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Draft Locomotive and Marine RIA
   a can to hold and support the substrate.
       Examples of these material costs are summarized in Table 5-22 and represent
costs to the engine manufacturers inclusive of supplier markups.  The total direct cost
to the manufacturer includes an estimate of warranty costs for the DPF system.
Hardware costs are additionally marked up to account for both manufacturer and
dealer overhead and carrying costs. The manufacturer's carrying cost was estimated
to be four percent of the direct costs accounting for the capital cost of the extra
inventory, and the incremental costs of insurance, handling, and storage. The dealer's
carrying cost was marked up three percent reflecting the cost of capital tied up in
inventory. We have adopted this approach of estimating individually the
manufacturer and dealer markups in an effort to better reflect the value added at each
stage of the supply chain based on industry input.18
                                     5-38

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                                                                      Chapter 5: Engineering Cost Estimates
Table 5-22 DPF System Costs (costs shown are costs per DPF system for the given engine power/displacement)
Typical Engine Power (kW)
Typical Engine Displacement (Liter)
Material and component costs
Filter Volume (Liter)

Filter Trap
Washcoating and Canning
PlafiHtflfiCan Housing
Differential Pressure Sensor
Direct Labor Costs

Estiaiateftiftt>($yhf)urs
Labor Cost
Labor Overhead @ 40%
Total Direct Costs to Mfr.
Warranty Cost — Near Term (3% claim rate)
Mfr. Carrying Cost - Near Term
Total Cost to Dealer — Near Term
Dealer Carrying Cost - Near Term
Savings by removing silencer
Baseline Cost to Buyer - Near Term
Loco/Marine Cost to Buyer (includes highway learning) - Near term
Warranty Cost - Long Term (1 % claim rate)
Mfr. Carrying Cost - Long Term
Total Cost to Dealer - Long Term
Dealer Carrying Cost — Long Term
Savings by removing muffler
Baseline Cost to Buyer - Long Term
Baseline Cost to Buyer (includes Highway Learning) - Long term
Loco/Marine Cost to Buyer (includes Loco/Marine learning) - Long term
7
0.4

0.7
$46
$96
$41
$9
$52

4
$18
$72
$29
$345
$21
$14
$380
$11
($52)
$340
$272
$7
$14
$366
$11
($52)
$325
$260
$208
25
1.5

2.6
$176
$111
$156
$10
$52

4
$18
$72
$29
$606
$41
$24
$671
$20
($52)
$640
$512
$14
$24
$644
$19
($52)
$611
$489
$391
57
3.9

6.7
$461
$143
$408
$11
$52

4
$18
$72
$29
$1,175
$84
$47
$1,306
$39
($52)
$1,293
$1,035
$28
$47
$1,250
$38
($52)
$1,236
$989
$791 I
187
7.6

13.0
$898
$192
$796
$12
$52

4
$18
$72
$29
$2,051
$149
$82
$2,282
$68
($52)
$2,298
$1,839
$50
$82
$2,182
$65
($52L.
$2,196
$1 ,757
$1,405 I
375
18.0 :

30.6 :
$2,117
$328
$1,874 -
$16 -
$52

4 -
$18
$72
$29
$4,488 '
$332
$180
$4,999 '
$150
($52)
$5,098
$4,078
$111
$180
$4,778
$143
($52)
$4,870
$3,896 -
$3,117 I
746
34.5 :

58.7 :
$4,057
$546
$3,592 :
$21
$52

8 i
$18
$145
$58
$8,471
$623
$339
$9,433
$283
($52)
$9,664
$7,731 !
$208
$339
$9,017
$271 :
($52)
$9,236
$7,389
$5,911 I
3730
188.0

319.6
$22,108
$2,571
$19,575
$74
$52

8
$18
$145
$58
$44,583
$3,332
$1,783
$49,698
$1,491
($52)
$51,137
$40,910
$1,111
$1,783
$47,477
$1 ,424
($52)
$48,849
$39,080
$31,264
                                            5-39

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Draft Locomotive and Marine RIA
       DPF Volume

       During development of this proposal, engine manufacturers have suggested
that DPF volumes could be up to three times engine displacement. The size of the
DPF is based largely on the maximum allowable flow restriction for the engine.
Generically, the filter size is inversely proportional to its resistance to flow (a larger
filter is less restrictive than a similar smaller filter). In the 2007 highway and NRT4
rules, we estimated that the DPF would be sized to be 1.5 times the engine
displacement based on the responses received from EMA and on-going research
aimed at improving filter porosity control to give a better trade-off between flow
restrictions and filtering efficiency.  As explained in Chapter 4 of this draft RIA, here
we have estimated a ratio of 1.7:1.

       DPF Substrate

       The DPF can be made from a wide range of filter materials including wire
mesh, sintered metals, fibrous media, or ceramic extrusions.  The most common
material used for DPFs  for heavy-duty diesel engines is  cordierite.  Here we have
based our cost estimates on the use of silicon carbide (SiC) even though it is more
expensive than other filter materials. In the 2007 highway rule, we estimated that
DPFs would consist of a cordierite filter costing $30 per liter. To remain
conservative in our cost estimates for nonroad applications, we assumed  the use of
silicon carbide filters  costing double that amount, or $60 per liter, because silicon
carbide filters are more  durable. As discussed in Chapter 4 of this draft RIA, we
believe that metal substrates may be choice for locomotive and marine DPFs, which
would cost less than a silicon carbide substrate. Nonetheless, to be conservative in
our cost estimates, we have assumed use of silicon carbide filters for locomotive and
marine applications, so  have based costs on the $60 per  liter cost estimate. This cost
is directly proportional to filter volume, which is proportional to engine displacement.
We have converted the  $60 value to $2005 using the Producer Price Index (PPI) for
manufacturing industries; the end result being a cost of $62 per liter.19

       DPF Washcoating and Canning

       These costs are based on costs developed under contract for our 2007 highway
rule.20  We converted those costs to  $2005 using the PPI for manufacturing industries.
We then calculated a linear "best fit" to express the washcoating and canning costs as
$8(x) + $91, where x  is the DPF volume in liters.

       DPF Precious Metals

       The total precious metal content for DFPs is estimated to be 60 g/ft3 with
platinum as the only precious metal  used in the filter.  In our NRT4 rule, we used a
price of $542 per troy ounce for platinum. Here we have used the 2005 average
monthly price of $899 per troy ounce for platinum.21
                                     5-40

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                                        Chapter 5: Engineering Cost Estimates
       DPF Can Housing

       The material cost for the can housing is estimated based on the DPF volume
plus 20 percent for transition (inlet/outlet) cones, plus 20 percent for scrappage
(material purchased but unused in the final product) and a price of $1 per pound for
18 gauge stainless steel as estimated in a contractor report to EPA and converted into
$2005.

       DPF Differential Pressure Sensor

       We believe that the DPF system will require the use of a differential pressure
sensor to provide a diagnostic monitoring function of the filter. A contractor report to
EPA estimated the cost for such a sensor at $45.22 A PPI adjusted cost of $52  per
sensor has been used in this analysis.

       DPF Direct Labor

       Consistent with the approach for SCR systems, the direct labor costs for the
DPF are estimated based on an estimate of the number of hours required for assembly
and established labor rates. Additional overhead for labor was estimated as 40
percent of the labor costs.

       DPF Warranty

       Consistent with the approach taken for SCR system costs, we have estimated
both near-term and long-term warranty costs. Near-term warranty costs are based on
a three percent claim rate  and an estimate of parts and labor costs per incident, while
long-term warranty costs are based on a one percent claim rate and an estimate of
parts and labor costs per incident. The labor rate is estimated to be $50 per hour with
two hours required per claim, and parts cost are estimated to be 2.5 times the original
manufacturing cost for the component.

       DPF Manufacturer and Dealer Carrying Costs

       Consistent with the approach for SCR systems, the manufacturer's carrying
cost was estimated at four percent of the direct costs.  This reflects primarily the costs
of capital tied up in extra inventory, and secondarily the incremental costs of
insurance, handling and storage. The dealer's carrying cost was estimated at three
percent of the incremental cost, again reflecting primarily the cost of capital tied up in
extra inventory.

       Savings Associated with Silencer Removal

       DPF retrofits are often incorporated in,  or are simply replacements for, the
silencer (muffler) for diesel-powered vehicles and equipment.  We believe that the
DPF could be mounted in place of the silencer, although it may have slightly larger
dimensions. We have estimated that applying  a DPF allows for the removal of the
silencer due to the noise attenuation characteristics of the DPF. We have accounted
                                     5-41

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Draft Locomotive and Marine RIA
for this savings and have estimated a silencer costs at $52. The $52 estimate is an
average for all engines; the actual savings will be higher for some and lower for
others.

      DPF System Cost Estimation Function

      Using the example DPF costs shown in Table 5-22, we calculated a linear
regression to determine the DPF system cost as a function of engine displacement.
This way, the function can be applied to the wide array of engines in the locomotive
line haul and/or marine fleets to determine the total or per engine costs for DPF
system hardware.  The functions calculated for DPF system costs for locomotive line-
haul and marine applications are shown in Table 5-23.

      For locomotive switcher applications, we have used the costs developed for
our NRT4 rulemaking because locomotive switchers tend to be powered by land
based nonroad engines making it appropriate to use the same costs developed for that
rule. These costs are also shown in Table 5-23.
       Table 5-23 DPF System Costs as a function of Engine Displacement, x, in Liters

Line-haul locomotive; marine
Switcher locomotive

Near-term cost function
Long-term cost function
Near-term cost function
Long-term cost function
Linear Regression
$217(x) + $199
$166(x) + $153
$146(x) + $75
$112(x) + $57
R2
0.999
0.999
0.999
0.999
Note: Near term costs include a 3 percent warranty claim rate while long term costs include a 1
percent warranty claim rate and the learning effect.
       The near-term and long-term costs shown in Table 5-23 change due to the
different warranty claim rates and the application of a 20 percent learning curve
effect.
5.2.2.3 Aftertreatment Marinization Costs

       For marine engines, the Tier 4 requirements will entail increased costs
associated with marinizing the engines for the marine environment. Marine Cl and
C2 engines are typically land based nonroad engines that are marinized for the marine
environment. This marinization can take many forms, but is generally a matter of
altering the cooling system to make use of sea or lake water rather than relying on
ambient air since marine engines tend to be enclosed within vessels where ambient air
radiators like those used in land based engines cannot operate efficiently.  Such
marinization efforts have been done for years and will continue but do not represent
                                     5-42

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                                        Chapter 5: Engineering Cost Estimates
incremental costs associated with the new standards. Marinization costs associated
with the new aftertreatment devices that would be added to comply with the Tier 4
standards—to control the surface temperatures in the typically tight space constraints
onboard a vessel—do represent incremental costs associated with the proposed
program and, thus, they must be considered.

       Under contract to EPA, ICF International conducted a study that considered
the costs associated with marinizing aftertreatment devices.23  In their study, ICF
looked at the costs associated with two methods of marinization: triple wall stainless
steel; and, insulating blankets.  Both methods could be used to control the surface
temperature of the aftertreatment device such that accidental touching would not
cause burns or otherwise compromise safely. The triple wall insulation method
proved more cost efficient.  Using this method, the device would, essentially, have
three layers of stainless steel surrounding the substrate rather than the single layer
normally used on land based engines. These layers would be  separated by a few
millimeters to provide an insulating air gap.

       The ICF study looked at aftertreatment marinizing costs for a range of engine
sizes in a manner similar to that discussed above for SCR and DPF systems. The
details of these estimates are contained in the final  report.24 In the report, ICF
calculated costs using a 1:1  or a 1.5:1 device volume to engine displacement ratio.
However,  as noted earlier, our analysis leads us to believe that a 2.5:1 ratio (SCR) and
1.7:1 ratio (DPF) are more applicable.  As a result, we have adjusted the ICF results
somewhat higher to reflect a larger sized device being insulated; these adjustments
are reflected in Table 5-24 for marinization of SCR systems and in Table 5-25 for
marinization of DPF systems.  The resultant linear regression  best fit curves for
marinization costs as a function of engine displacement are shown in Table 5-26.
                                     5-43

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Draft Locomotive and Marine RIA
                                            Table 5-24 SCR System Marinization Costs
Typical Engine Power (kW)
Typical Engine Displacement (L)
SCR Catalyst Marinization Hardware C
Assembly
Labor @ $28/hr
Overhead @ 40%
Total Assembly Cost
Markup on Hardware and Assembly @
Total SCR Catalyst Marinization Costs
Total SCR Catalyst Marinization Costs


ost




29%
- Near term
- Long term
64
4.2 :
$23 1
$0 :
$3
$1 :
$4 !
$8 i
$34
$27 !
93
7
$28 i
$0 :
$3
$1
$4
$9
$42
$33 |
183
10.5 !
$29 i
$0 :
$3
$1
$4 •
$9
$42
$34 |
620
27 :
$65 I
$0 :
$3
$1 '
$4
$20 :
$90
$72 !
968
34.5
$77
$0
$3
$1 '
$4
$24 -
$105
$84 !
1425
51.8 !
$91 :
$0
$3
$1
$4 :
$28
$123
$98 ;
1902
111 :
$173 :
$0
$3
$1
$4 ,
$51
$228
$182 ;
3805
222
$292 ;
$0
$3
$1
$4 ,
$86
$382
$305 ;
5968
296
$350
$0
$3
$1
$4
$103
$456
$365
                                            Table 5-25 DPF System Marinization Costs
Typical Engine Power (kW)
Typical Engine Displacement (L)
DPF Marinization Hardware Cost
Assembly
Labor @ $28/hr
Overhead @ 40%
Total Assembly Cost
Markup on Hardware and Assembly @ 29%
Total DPF Marinization Costs - Near term
Total DPF Marinization Costs - Long term
64 ;
4.2
$15 :
$0 -
$3
$1
$4
$6 .
$25
$20 :
93 :
7 :
$22 :
$0 I
$3 ~
$1 T
$4 :
$8 :
$34 :
$27 I
183 :
10T5""
$29 :
$0
$3
$1 "
$4 !
$9 :
$42 ~
$34 ]
620 ;
27 :
$52 :
$0
$3
$1
$4
$16 ;
$72
$58
968
34.5
$61 :
$0
$3
$1
$4
$19 '
$84
$67
1425 :
51.8
$75 :
$0
$3
$1
$4 :
$23
$102
$81
1902 ;
111 :
$112 :
$0
$3
$1
$4 .
$34 .
$150
$120
3805
222
$218 '
$0
$3
$1
$4
$64 .
$286
$229 "
5968
296
$262
$0
$3
$1
$4
$77
$343
$274
                                                           5-44

-------
                                         Chapter 5: Engineering Cost Estimates
       Table 5-26 Marinization Costs as a function of Engine Displacement, x, in Liters

SCR System Marinization
DPF System Marinization

Near-term cost function
Long-term cost function
Near-term cost function
Long-term cost function
Linear Regression
$l(x) + $42
$l(x) + $34
$l(x) + $35
$l(x) + $28
R2
0.990
0.990
0.991
0.991
Note: Near term costs include a 3 percent warranty claim rate while long term costs include a 1
percent warranty claim rate and the learning effect.
5.2.2.4 Summary of Engine Variable Cost Equations

       Engine variable costs are discussed in detail in sections 5.2.2.1 through
5.2.2.3. As described in those sections, we have generated cost estimation equations
for SCR systems, DPF systems, and aftertreatment marinization as a function of
engine displacement.  These equations are summarized in Table 5-27. Note that not
all equations were used for all engines and all market segments; equations were used
in the manner shown in the table. We have calculated the aggregate engine variable
costs and present them later in this chapter.
                                      5-45

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Draft Locomotive and Marine RIA
 Table 5-27 Summary of Cost Equations for Engine Variable Costs (x represents the dependent
                                   variable)
Engine Technology
SCR System Costs
SCR System Costs
DPF System Costs
DPF System Costs
SCR Marinization Costs
DPF Marinization Costs
Time Frame
Near term
Long term
Near term
Long term
Near term
Long term
Near term
Long term
Near term
Long term
Near term
Long term
Cost Equation
$185(x) + $1,323
$142(x) + $1,012
$103(x) + $183
$83(x) + $160
$217(x) + $199
$166(x) + $153
$146(x) + $75
$112(x) + $57
$l(x) + $42
$l(x) + $34
$l(x) + $35
$l(x) + $28
Dependent
Variable
Engine
Displacement
(Liters)
Engine
Displacement
(Liters)
Engine
Displacement
(Liters)
Engine
Displacement
(Liters)
Engine
Displacement
(Liters)
Engine
Displacement
(Liters)
How Used
Tier 4
Locomotive
Line-haul and
Marine Engines
Tier 4
Locomotive
Switcher
Engines
Tier 4
Locomotive
Line-haul and
Marine Engines
Tier 4
Locomotive
Switcher
Engines
Tier 4 Marine
Engines
Tier 4 Marine
Engines
       Using these equations, we can calculate the variable costs associated with the
Tier 4 standards for any engine provided we know its displacement, power, and
intended application. We could do this for every compliant engine expected to be sold
in the years following implementation of the new standards, total the results, and we
would have the total annual variable costs associated with the rule. We can achieve
essentially the same thing by calculating a sales weighted variable cost. This  could
be done for a single engine that could represent the entire fleet provided we sales
weighted the critical characteristics of that engine. Doing this for one engine  would
not provide a particularly good look at the impact of the new standards on costs since
the sizes of engines, their power, and use varies so much. Therefore, we have broken
the fleet first into the market segments according to our regulatory definitions (i.e.,
marine Cl, marine C2, locomotive, etc.).  We have further broken each market
segment into several power ranges, some of which are arbitrary and meant only to
provide more stratification of the results, and some of which are chosen to align
properly with the structure of the new standards (e.g., marine Cl has a power  cutpoint
at 600 kW since the Tier 4 standards  apply to marine engines above 600 kW).

       The necessary engine characteristics for sales weighting are engine
displacement, power, and  application. We have used the PSR database and sales
figures from 2002. The resultant sales weighted engines within given market
                                     5-46

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                                        Chapter 5: Engineering Cost Estimates
segments and power ranges are shown in Table 5-28.'  For example, the sales
weighted engine in the marine Cl segment, power range 800 to 2000 hp, has an
engine displacement of 33.4 liters and is 1266 hp (944 kW).  Empty cells in the table
mean that there are no engines in that power range and market segment.
   Table 5-28 Sales Weighted Engine Characteristics by Market Segment and Power Range
Power Range

0
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Draft Locomotive and Marine RIA
segment, those for "<600 kW" or ">600 kW"—for our total cost calculations
presented in section 5.6.
                                   5-48

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                                  Chapter 5: Engineering Cost Estimates
Table 5-29 Piece Costs for Engine Hardware by Market Segment and Power Range
Power Range
0800 hp only
0800 hp only
6800 hp only
6800 hp only
Line- i Q,,,i^h=Ko \ Marine ! Marine
Haul 1 Swltchers ] C1 1 C2
SCR System Cost