january 11 2007 n.
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Clean Air Panel

Clean Air Panel

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Clean Air Panel

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  1. January 11, 2007 Clean Air Panel

  2. Recent Bond MeasuresApproved November, 2006 • Proposition 1B • $19.9 billion Transportation Bond • Makes $1 billion available to CARB for emission reductions, not otherwise required by law or regulation, for activities related to the movement of freight along California’s trade corridors. • Makes $2 billion available for improvement of the movement of goods – through the ports, on the state highways and rail systems, and between California and Mexico. • Goods Movement Action Plan recommendation from BTH & CARB to CTC by December, 2006. • Final decision-making by CTC.

  3. CARB’s Emission Reduction PlanStatewide Trucks • Plan seeks to apply the best available control technology to the entire truck fleet in private ownership, with a targeted program to modernize the subset of trucks serving ports • Plan targets an 88% reduction in diesel PM, and about a 60% reduction for NOx and ROG by 2020

  4. CARB’s Emission Reduction PlanStatewide • Locomotives: • Plan seeks upgrades for engines in switcher locomotives • Plan calls for retrofit diesel PM controls on existing engines • Plan recommends federal standards that would achieve 90% controlof diesel PM andNOx for new engines

  5. Clean Air Action PlanPOLA - POLB Trucks • CAAP calls for replacement or upgrade of all frequent and semi-frequent caller trucks, and all older (model year 1993 and older) trucks that call at both Ports by the end of 2011 • Development of alternative fuel infrastructure to provide additional options for cleaner trucks

  6. Clean Air Action PlanPOLA - POLB • Locomotives • CAAP seeks upgrades of all existing PHL switch engines to Tier II engine standards by end of 2007 • Use of idle restrictions, Tier III equivalent locomotives, cleaner fuels, and retrofit controls on all Class I switcher, helper, and long haul locomotives operating on Port property • Stringent standards for new or modified railyards, implemented via the CEQA process, to ensure significant reductions fromlocomotives, CHE, and truck operations • Implementation via contract or memoranda of understanding • On-going legal and cost-effectiveness analyses prior to adoption of port-wide tariff’s or ordinances

  7. Industry Efforts:Railroad

  8. US Railroad Intermodal Flows (car loads) for 2002

  9. AdoptedSCAQMD NOx Inventories Tons NOx/Day Data Sources: SCAQMD AQMPs & Other Materials

  10. 25 1987 1997 20 2005 2010 15 10 5 0 Adopted SCAQMD PM 2.5 Inventories Tons PM2.5/Day Data Sources: SCAQMD AQMPs & Other Materials

  11. Inherent Efficiencies of Rail vs. Capacity 1 double stack train equals up to 280 trucks Trains are 2-4 times more fuel efficient than trucks on a ton-mile basis Fuel Efficiency Trains are 2-3 times cleaner than trucks on a ton-mile basis NOx Emissions

  12. Comparison of Mobile Source Requirements(South Coast Inventory 2010)

  13. Freight Railroads’ California Environmental Improvement Program • 1994 -- Supported the US EPA’s standards for new and re-manufactured locomotives • 1998 -- Developed enforceable MOU with ARB and US EPA to achieve accelerated reductions in Southern California • 2000 -- Created an end-user research & development program for new technologies

  14. Additional Railroad Emission Reduction Program Components • 2001 -- $5 million in funding by the railroads for particulate trap research at Southwest Research Institute • 2005 -- Concluded an MOU with the Air Resources Board to accelerate PM reductions in and around rail yards • Ongoing -- Funding & demonstrating new locomotive technologies: • Spark ignited LNG technologies • Idle reduction devices • New switch engines using truck engine technologies • Hybrid locomotives

  15. SouthCoast Fleet Average from 1998 MOU Reductions from EPA Loco. Tiers 1 and 2 only … continental US Reductions when Loco. Tier 0 added to Tiers 1 and 2 … continental US % Reduction in loco. NOx 67% NOx reduction from South Coast Fleet Average Program in Southern California! 2000 2005 2010 Southern California commitment from the Railroads

  16. How the ARB Described the 1998 MOU “ This compliance requirement would be met by the use of only the cleanest engines within the SCAB non-attainment area by an aggressive phase-in of these engines over five years. In essence, this fleet average requirement represents the most aggressive scrappage and replacement program of any transportation source in the SCAB (in effect, 100 percent scrappage/replacement with the latest, low-emitting locomotives over 5 years from 2005-2010). It would lead to an overall emission reduction of 67 percent by 2010.” [Emphasis Added] The California State Implementation Plan for Ozone, Vol. II: The Air Resources Board's Mobile Source and Consumer Products Elements, Appendix B, at B-20 (Nov. 15, 1994).

  17. 2005 CARB/Rail MOU – What It Does • Phase I: Brings about a 20% reduction in PM emissions from rail yards in California over the next three years • Phase II: Invites all local air districts and community groups to discuss longer-term locomotive emission control strategies • The reductions achieved by the MOU are larger and sooner than could have been required by any California regulatory or legislative body • The only way the State could get reductions from preempted sources was through a voluntary agreement • By using a cooperative approach, California has also avoided implementation delaysdue to disagreements over the State’s legal authority

  18. 2005 CARB/Rail MOU – Outcomes • ~425 locomotives will be equipped with automatic shutdown devices with 15 minute triggers • At least 80% of California fueling will be low-sulfur – six years earlier than required by federal regulation • At least 99% of all locomotives will comply with stringent smoke regulations– a much higher rate than any other mobile source • Health risk assessments will be carried out at the 16 major rail yards throughout California

  19. Sources EMISSIONS (tpy) & Reductions 2005 (Base) 2010 % Reduction Strategy Through Trains 10 5 50% ‘98 MOU Switcher Locomotives 7 0.7 90% ‘98, ‘05 MOU, CARB Diesel Loco Refueling 2 0.5 75% ‘98, ‘05 MOU Cargo Equipment 34 13.6 60% ARB Rule Container Truck 7 0.7 90% Bond (or Moyer) Funding Total 60 20 65% Reductions in Rail Yard Diesel PM Based on information the California Air Resources Board staff presented in 1/27/06 ARB Meeting

  20. NOx Emissions per ton Mile of Freight South Coast Air Basin

  21. PM Emissions per ton Mile of Freight South Coast Air Basin

  22. Technology Developments

  23. Comparative Markets: Locomotives & Trucks • Diesel engine technology is driven by the US over-the-road truck market • 211 Class 8 trucks have been sold for every locomotive since 1972 • Engine technologies “cascade down” through normal marketplace forces • Automotive Truck Locomotive, Stationary, and Marine • Example: Electronic Fuel Injection • Introduced into the auto market in early 1980’s • Entered truck market in late 1980’s • Entered locomotive market in 1994 • Engine technologies cannot be quickly and simply “scaled up”

  24. Liquefied Natural Gas Switcher Locomotive 1200 sustainable horsepower, spark ignited

  25. New Switch Locomotive Technology: Hybrids 2000 peak horsepower from batteries “Hybrid” light-medium duty switcher Batteries recharged by 290 HP EPA off-road Tier 2 diesel gen set Significantly exceeds EPA locomotive Tier 2 requirements

  26. New Switch Locomotive Technology: Gen Set (2) 700 sustainable horsepower diesel gen sets “Gen Set” heavy-duty switcher Powered by (2) EPA off-road Tier 3 diesel gen setsProjected to exceed EPA locomotive Tier 2 requirements

  27. Diesel Particulate Filter (DPF) R&D • Two UP 1500 horsepower switchers will be equipped with DPF technology in 4Q ‘05 • Units will be tested for maintainability, durability and performance in California • Railroads have been co-funding 5-year R&D project investigating performance, durability and applicability of DPF to older switching locomotives • R&D work being performed by Southwest Research Institute (“SwRI”) through Association of American Railroads • There is no technicalprecedent for this work

  28. Evaluate Emissions Reduction Possibilities from a Systems Perspective • Must balance the needs of shippers, transporters, commuters, adjacent communities, regulators, and many other stakeholders • Altering one part of the system can cause disruption to the entire goods movement system (ships, rail, and truck operations) • International port calls, labor opportunities, freeway traffic patterns, and even commuter rail operations • Unintended economic and environmental consequences of various public policy choices must be squarely addressed • This issue needs a statewide focus and management team (per the Governor’s recommendation)

  29. Industry Efforts:Trucks

  30. Recent Litigation • PMSA v. CARB • Complaint filed in December, 2006 • PMSA Litigation Challenges • CARB Auxiliary Engine Rule • Multiple grounds for preemption

  31. Recent Litigation • BNSF, UP & AAR v. SCAQMD • Trial took place over three days, Nov. 28-30, in Federal District Court • Railroads challenged recently enacted SCAQMD rules regarding locomotives • Ruling expected at anytime

  32. Recent Litigation • RR Litigation Challenges SCAQMD Rules • Rule 3501 requires the Railroads to record and report data for locomotive idling events longer than 30 minutes • Rule 3502 imposes a penalty for certain locomotive idling events longer than 30 minutes • Retrofit with anti-idling technology

  33. Recent Litigation • RR Litigation Challenges SCAQMD Rules: • Rule 3503 requires the Railroads to gather information, develop an air emissions inventory, calculate the cancer and non-cancer health risks posed by their operations at rail yards, and to annually notify the affected public if risks exceed the public notification levels.

  34. Recent Litigation • Causes of Action • Preemption under ICCTA • Preemption under Clean Air Act • Preemption under Boiler Act • Violation of Commerce Clause • Lack of authority under state law