1/12/95 MEMORANDUM SUBJECT: Future Nonroad Emission Reduction Credits for Locomotives FROM: Philip A. Lorang, Director Emission Planning and Strategies Division TO: Director, Air, Pesticides, and Toxics Management Division, Regions 1 and 4 Director, Air and Waste Management Division, Region 2 Director, Air, Radiation, and Toxics Division, Region 3 Director, Air and Radiation Division, Region 5 Director, Air, Pesticides, and Toxics Division, Region 6 Director, Air and Toxics Division, Regions 7, 8, 9, and 10 This memorandum provides guidance for the calculation of emission reductions resulting from future federal emission standards for locomotives. EPA has previously released guidance for the calculation of emission reductions resulting from the court- ordered standards for nonroad equipment, exclusive of locomotive States may use the credits described herein for actions such as State Implementation Plan (SIP) submittals. The purpose of this memorandum is to provide our current estimate of the magnitude of these reductions. Section 213(a)(5) of the Clean Air Act Amendments of 1990 requires EPA to promulgate final standards for locomotive emissions by November 15, 1995. These standards will constitute the first national regulation of emissions from locomotives. EPA expects to propose locomotive standards in the Spring of 1995. The emission reduction estimates presented in this guidance are based on the latest draft of the proposed rule. As with the other proposed standards, States should understand that if the final standards result in less emission reduction than anticipated, they will be faced with the need to apply additional control measures to make up the difference. At this time, EPA intends to propose two tiers of emission standards for locomotives that are freshly manufactured after January 1, 2000. The first tier standards will apply to locomotives manufactured from January 1, 2000 through Dec. 31, 2004. The second tier standards will apply to locomotives manufactured after January 1, 2005. EPA also expects to propose standards for locomotive engines originally manufactured between January 1, 1973 and December 31, 1999 when they are remanufactured after January 1, 2000. Tier I standards are expected to reduce NOx emissions from newly manufactured locomotives by 50 percent from uncontrolled levels. NOx standards for pre-2000 remanufactured locomotives are expected to reduce these emissions by approximately one-third from uncontrolled levels. EPA also expects to set standards for hydrocarbon (HC), carbon monoxide (CO), particulate matter (PM), and smoke emissions as part of both the Tier I standards and the standards for pre-2000 remanufactured locomotives. These standards are anticipated to approximately equal present emission levels, thereby constraining any increase in emissions of these pollutants that could otherwise occur as a result of the NOx standards. The second set of standards is expected to become effective on January 1, 2005. EPA anticipates that Tier II standards will reduce NOx emissions from freshly manufactured locomotives by two thirds and PM emissions by approximately one half from uncontrolled levels. Since locomotive engines typically are rebuilt several times, EPA expects to regulate emissions from locomotives remanufactured after January 1, 2000. Rebuilds occur on a five to seven year schedule, stretching the total life of a locomotive to 35 or 40 years. Rebuild standards for engines originally built after January 1, 2000 will be the same as those that apply when the locomotive is originally manufactured and will ensure that these locomotives continue to meet the emission levels they were designed to meet throughout their total lives. EPA also expects to propose rebuild standards for locomotives and locomotive engines originally manufactured after January 1, 1973 when remanufactured after January 2000. Since the cost of controlling emissions from pre-1973 locomotives is high and since few of these locomotives will be in operation in the year 2000, the benefit-cost ratio of any controls on pre-1973 engines would be low. Consequently, EPA is not currently planning to regulate emissions from pre-1973 locomotives. According to EPA calculations, the anticipated remanufactured standards for current engines will reduce NOx emissions from the current, in-use fleet by one third. The following table provides the estimated annual NOx emission reductions that are expected to occur in the in-use locomotive fleet as a result of the anticipated new and remanufactured locomotive engine standards. Reductions are provided for years 1990 through 2010. Because it takes forty or more years for the locomotive fleet to turn over, NOx emissions will continue to decline well beyond 2010. Table 1 Annual NOx Reductions from Anticipated Locomotive Standards Locomotives Calendar Year NOx 1990 0.0% 1991 0.0% 1992 0.0% 1993 0.0% 1994 0.0% 1995 0.0% 1996 0.0% 1997 0.0% 1998 0.0% 1999 0.0% 2000 -7.9% 2001 -15.9% 2002 -23.9% 2003 -32.0% 2004 -40.2% 2005 -41.8% 2006 -42.5% 2007 -43.2% 2008 -43.9% 2009 -44.6% 2010 -45.3% These numbers are based on a draft of the proposed locomotive standards. States are permitted to take credit for them in their SIP submittals before actual promulgation, as they are able to do for nonroad standards that are currently court ordered. However, States may want to include a safety margi in their estimates to allow for the possibility that the final regulations do not result in these estimated NOx reductions. EPA expects to propose locomotive standards in Spring 1995 and to meet the statutory deadline for finalizing the standards in November 1995. The proposed and final locomotive standards will be placed on the Office of Mobile Sources (OMS) section of EPA's Technology Transfer Network (TTN) bulletin board as they become available. cc: Alan Eckert, OGC Chet France, OMS Joanne Goldhand, OMS Charles Gray, Jr., OMS Greg Janssen, OMS Larry Jones, ORD Peter Hutchins, OMS Robert Maxwell, OMS Gay McGregor, OMS David Mobley, OAQPS Margo Oge, OMS Norm Possiel, OAQPS John Silvasi, OAQPS Joe Somers, OMS Richard Wilson, OAR Mark Wolcott, OMS Howard Hoffman, OGC Mike Horowitz, OGC Susmita Dubey, OGC