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 Post subject: EPA emission regulations for historic diesels?
PostPosted: Fri Nov 01, 2019 9:28 pm 

Joined: Fri Feb 26, 2010 11:46 pm
Posts: 71
Can anyone provide some insight into the way EPA regulations for diesel emissions apply to historic diesel locomotives? A pointer to the appropriate chapter and verse of the regs would be greatly appreciated.

I'm asking because I was corresponding recently with someone who is exploring what it would take to get an historic diesel operating for an excursion service. He was told that there is an EPA mandate that all serviceable locomotives must meet a certain minimal clean emission standard by 2021. This will preclude a variety of older locomotives from ever running again unless they undergo extensive, expensive overhaul.

It seems like this would be a big deal for the heritage railroad industry, but I haven't seen any discussion of this topic. I searched the forum for past posts on this topic, but came up empty handed. Maybe I just missed it?

Thanks,
Paul


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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Fri Nov 01, 2019 9:44 pm 

Joined: Sat Jan 21, 2017 11:43 am
Posts: 15
Depending on when that "historic" locomotive was manufactured, EPA locomotive emission rules may not apply. See:

https://www.epa.gov/regulations-emissio ... locomotive

Note the January 1, 1973 date.


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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Fri Nov 01, 2019 11:39 pm 

Joined: Fri Mar 26, 2010 11:43 am
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Will the new emissions requirements only be met by retrofitting equipment, or are we talking a scaled standard based on age?

It may simply be that your 1975 locomotive simply needs to be in good running condition to meet the standards. No more dirty air filters, low compression, and dribbling injectors allowed...

Maybe.


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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Sat Nov 02, 2019 9:59 am 

Joined: Mon Apr 30, 2007 12:45 am
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Location: Illinois
Pegasuspinto wrote:
Will the new emissions requirements only be met by retrofitting equipment, or are we talking a scaled standard based on age?

It may simply be that your 1975 locomotive simply needs to be in good running condition to meet the standards. No more dirty air filters, low compression, and dribbling injectors allowed...

Maybe.


The document explaining the applicability of the standards has an exclusion for "small businesses (on page 3)":

Quote:
The regulations do not apply to existing locomotives owned by railroads that are classified as small businesses, as defined below, because these locomotives are not considered to be new locomotives when remanufactured


And a definition of "small railroad" for the above exemption (page 4):

Quote:
Definition of Small Railroads Line-haul railroads with fewer than 1500 employees and switch railroads with fewer than 500 employees are classified as small railroads. For railroads owned by parent companies, the number of employees used to determine small business status is the combined number of employees of the railroad and any parent companies.


So, unless your organization has more than 500 employees, the regulations do not apply.

Link to the "technical highlights" document, explaining applicability: https://nepis.epa.gov/Exe/ZyPDF.cgi/P1001Z9L.PDF?Dockey=P1001Z9L.PDF

Jeff

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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Sat Nov 02, 2019 10:51 am 

Joined: Fri Feb 26, 2010 11:46 pm
Posts: 71
Thank you all for the information. Very helpful.

Paul


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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Sat Nov 02, 2019 10:56 am 

Joined: Wed Jun 29, 2016 11:58 am
Posts: 62
Pegasuspinto wrote:
The document explaining the applicability of the standards has an exclusion for "small businesses (on page 3)":

Quote:
The regulations do not apply to existing locomotives owned by railroads that are classified as small businesses, as defined below, because these locomotives are not considered to be new locomotives when remanufactured


And a definition of "small railroad" for the above exemption (page 4):

Quote:
Definition of Small Railroads Line-haul railroads with fewer than 1500 employees and switch railroads with fewer than 500 employees are classified as small railroads. For railroads owned by parent companies, the number of employees used to determine small business status is the combined number of employees of the railroad and any parent companies.


So, unless your organization has more than 500 employees, the regulations do not apply.

Link to the "technical highlights" document, explaining applicability: https://nepis.epa.gov/Exe/ZyPDF.cgi/P1001Z9L.PDF?Dockey=P1001Z9L.PDF

Jeff


I agree that the pollution standards are not going to apply to museums because of the small business exemptions, but even if they did, that locomotive in question would only have to meet Tier 0 standards. Look on page 3:

https://nepis.epa.gov/Exe/ZyPDF.cgi/700 ... 0004EQ.PDF

I have no idea how hard that would be for a well maintained 1975 diesel locomotive to meet those standards.

Perhaps one would like to meet or beat at least the smoke opacity standards in order to give your customers a good experience?

Brian


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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Sat Nov 02, 2019 11:33 am 

Joined: Fri Aug 27, 2004 4:02 pm
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Location: Back in NE Ohio
Trying to appeal to younger visitors to museums and tourist railroads with their more enlightened views on the environment might, or probably, mean that your 60 year-old Alco that smokes like "Old 97" every time the engineer gooses the throttle is not the sought-after attraction it was for their parents and grandparents. Those of us who are knowledgeable steam or Diesel fans know that a truly representative operation minimizes wasteful heavy-smoking exhaust as the sign of either bad firing, bad coal or oil, or a locomotive with significant problems that it is.


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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Sun Nov 03, 2019 11:32 am 
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I believe that you need to look beyond EPA rules, to local Air Quality boards. The San Francisco Bay area, the Los Angeles Area, and Clark County (Las Vegas NV) among others have local regulations that may apply. All three of the examples above now regulate when wood burning home fireplaces can be used. In CA they have tax rebate and other programs to replace older diesel equipment (railroad locomotives, heavy trucks, and maritime) with low emissions equipment.

Two cycle diesels generally cannot meet the higher standard, so EMD 567, 645 and 710 engines are targets as are FMs. So far, this has not affected museums, but may in the future by reducing the supply of spare parts for these engines as they fall out of favor...

At the same time we are seeing the value of some older locomotives, even hulks rise as they are used as candidates for rebuilding as "green" locomotives... preserving trucks and frames, with most everything else being discarded.

Randy

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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Sun Nov 03, 2019 12:11 pm 

Joined: Thu Feb 03, 2005 9:32 pm
Posts: 284
Judging by the blue cloud following this Arkansas & Missouri C420 going through Rogers AR last month emission regs do not apply here.


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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Mon Nov 04, 2019 8:30 am 

Joined: Thu May 24, 2012 1:37 pm
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As I recall, this was going to be a priority for the EPA sometime in one of the Obama administrations, and I think we discussed it here then.

I suspect to the extent anything 'draconian' for older diesel locomotives actually got under way then, it was deprioritized after 2016. That doesn't mean it won't re-emerge in any future potentially very doctrinaire era...

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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Mon Nov 04, 2019 9:34 am 

Joined: Sun Aug 22, 2004 11:26 am
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Location: Maine
Is there a comparative for emission gases from steam locomotives versus Diesel locomotives? Perhaps that's dependent on the grade of solid fuel or oil being combusted before emissions are tested. I think it's inevitable, somebody is going to contest our operating locomotives, both steam and Diesel, as the world climate crisis deepens.
Also, there seems to be a belief floating around that burning used fryolator oil is a universal "fix".

Can anyone comment on this?

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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Mon Nov 04, 2019 7:39 pm 

Joined: Fri Feb 13, 2015 2:48 pm
Posts: 108
Here's the specifics of the CARB (California Air Resources Board) concerning diesel locomotives https://ww2.arb.ca.gov/our-work/program ... ation-road


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 Post subject: Re: EPA emission regulations for historic diesels?
PostPosted: Wed Nov 06, 2019 9:42 am 

Joined: Thu May 24, 2012 1:37 pm
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A CARB link from the above more specific to locomotives:
https://ww3.arb.ca.gov/msprog/offroad/loco/loco.htm

(Thanks, Jennie!)

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