Don’t Buy New Tier 4 Locomotives

By David Schonbrunn, TRAC President

Editor’s Note: These comments were sent by TRAC’s President to Metrolink, days before their Board directed staff to find grants to fund the purchase of 10-15 new Tier 4 diesel locomotives at $10.3 million a piece.

The Train Riders Association of California (“TRAC”) is a statewide rail advocacy organization that has worked since 1984 to improve passenger rail service in California. We first wish to congratulate you [Stephanie Wiggins, outgoing Executive Director of Metrolink] on your very significant promotion to leading Metro. While you are finishing up at Metrolink, we wish to offer our thoughts on the proposed procurement of new Tier 4 locomotives, to replace aging MP36s.

We have recently been in contact with CARB’s freight division and had a wide-ranging discussion about how the emissions of locomotives have not been accurately measured, for purposes of emissions inventories and most importantly, for incentives for emissions reductions programs. A copy of the notes from that meeting are appended, along with our letter that triggered the discussion.

The problem TRAC identified is high NOx emissions at idle, because the engine doesn’t have enough load to activate the [NOx] after-treatment system. Because these locomotives spend such a large number of hours idling (itself a separate and distinct problem), they emit far more criteria pollutants than is reasonable for a very expensive low-emissions locomotive. We believe this is a flaw in the EPA Tier 4 standard itself. Because it was designed for line haul freight locomotives, the certification process duty cycle does not capture the large amounts of idling typical in commuter and intercity passenger service. We suspect current Tier 4 passenger locomotives would not meet the Tier 4 standard, if evaluated with a real-world duty cycle.

For this reason, we urge your Board to not proceed with the recommended procurement. To confirm this recommendation, we urge you to produce a specification based on the real-world Metrolink duty cycle, to enable you to evaluate whether existing locomotive models can meet Metrolink’s needs. We suspect they cannot. Meanwhile, new technologies are becoming available that leap-frog over Tier 4.

While these technologies are being commercialized, we recommend you do a pilot
project to attempt to add aftertreatment to an MP36. If successful, this would create a
viable short-term alternative to getting locked into a 25-year capital investment in new
Tier 4 locomotives, with their disappointing emissions. This would leave much more
money available for the transition to zero emissions.

Using this approach, it may be possible to skip the further procurement of new diesel
locomotives altogether. In considering Metrolink’s future path to zero emissions, we
suggest you consider the direction now being explored by the Long Island Railroad for
their unelectrified routes. (See attached article.) They will outfit existing Electric Multiple
Unit cars with batteries, and install fast charging facilities at selected stations.

Another battery approach would be Stadler’s Akku Battery Electric Multiple Units, which
recently demonstrated a 115-mile range without recharging, despite heat and cold
conditions that fully stressed the HVAC system. (See attached articles.) These trainsets
are commercially available now. We think they make far more sense than proceeding
with a $20 -$30 million dollar prototype electric locomotive.

Thank you for considering these comments. We would be pleased to answer any
questions you might have, at the phone number below.

Attachments

http://www.calrailnews.org/wp-content/uploads/2021/05/TRAC-Metrolink-Comment-set.pdf

http://www.calrailnews.org/lets-have-accurate-locomotive-emissions/

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TRAC files STB response, challenging transfer of freight rights to SMART

By David Schonbrunn, President of TRAC

In response to the threats to the Northwestern Pacific Railroad (NWP, which spans over 300 miles from Larkspur Landing in Marin County to Samoa in Humboldt County), the Train Riders Association of California (TRAC) took action today based on its letter to Senator McGuire about his Great Redwood Trail Bill, SB 69.  TRAC filed comments with the Surface Transportation Board (STB), the federal regulatory agency that governs railroad legal matters. (The bookmarked comments are a 140 page, 20 Mb. download.)

Today’s action opposes the request of the current freight operator on the NWP, which is named NWPCO, to have the transfer of its freight operating rights to SMART be exempt from a full administrative process. TRAC opposes the transfer on three principal grounds: 1). SMART has neither the financial strength nor the institutional competence or temperament to be in the freight business; 2). SMART appears to be moving to become freight operator in bad faith–it seems more likely that SMART wants to discontinue freight service than operate it; and finally, 3). exempting the transfer from a full administrative process would strand shippers located along the Cloverdale to Willits segment of the NWP.

The Cloverdale to Willits segment of the line is part of an extensive portion of the NWP that has been out of service since 1998, after damage from floods and deferred maintenance left the line in such poor repair that the Federal Railroad Administration shut it down with an Emergency Order. Senator McGuire’s SB 69 would rip out the tracks north of Cloverdale and put a trail where the tracks had been, in an effort to reduce construction costs. TRAC asserts that this approach is penny-wise and pound-foolish. A look at the Los Angeles area shows how incredibly expensive it is to restore rail service after its pre-World War II rail infrastructure was converted to highways. Building trails alongside rails is what SMART is already  doing, and what NCRA has been doing in Humboldt County. TRAC vigorously opposes SB 69’s attempt to change that approach.

The North Coast Railroad Authority (NCRA) currently owns the tracks between Healdsburg in Sonoma County and Samoa in Humboldt County. TRAC’s ally, TRANSDEF, has sent NCRA a letter demanding its Board retract its vote to file an application to railbank its tracks between Willits and Samoa. Railbanking is an alternative available to railroads that seek to legally abandon their rail infrastructure. If railbanking is approved by the STB, the rails can be removed without (arguably) affecting the easements from adjacent landowners that establish the rail right-of-way. We say arguably, because there is a large amount of litigation seeking to have these easements revert to landowners. If rails are not removed, there is absolutely no reason to railbank. Trains cannot legally be operated on railbanked lines.

Because NCRA’s railbanking application avoided dealing with the Cloverdale to Willis segment of the NWP, today’s action by TRAC specifically seeks to have the STB order NWPCO to propose the future status of that segment in the current proceeding.

TRAC recognizes that the Eel River Canyon is an entirely different issue than the restoration of rail both north and south of the Canyon, both of which TRAC views as feasible. As such, TRAC has no objection to railbanking the Canyon, although it would serve little purpose.

If TRAC is successful in blocking SMART from becoming the freight operator of the southern portion of the NWP,  it would remain possible for cost-effective extensions to Willits and Suisun City to move forward, led by a private-sector freight operator that would offer freight service, passenger service and excursion service. Passenger service could possibly be undertaken as a subsidized public-private partnership, once freight service is restored to Willits.

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Let’s Have Accurate Locomotive Emissions

By David Schonbrunn, TRAC President

Editor’s Note: These comments were sent by TRAC’s President to the California Air Resources Board, which will have a workshop on Reducing Emissions From In-Use Locomotives on March 30, 2021.

The Train Riders Association of California (“TRAC”) is a statewide rail advocacy organization that has worked since 1984 to improve passenger rail service in California. We seek to attract automobile drivers to rail, thereby reducing the emissions from motor vehicles. While the emissions from locomotives are only a small part of the motor vehicle emissions inventory, we were pleased to receive an announcement about the upcoming Reducing Emissions From In-Use Locomotives workshop.

In advance of that workshop, we wanted to offer our thoughts on the testing of passenger locomotive emissions, which have important implications for emissions inventories and emissions reduction incentive programs, such as Carl Moyer and the Prop. 1B Goods Movement Emission Reduction programs.

Our concerns about locomotive emissions began when we were informed that Caltrain idled its trains all night long in the San Francisco railyard. Besides the noise pollution to the new residential buildings that abut the railyard, the criteria and GHG emissions must be substantial–and completely unnecessary. This is the foundation for our first recommendation:

1. Passenger locomotive emission measurements must be based on a real-world duty cycle, which captures all the idling that occurs during a 24-hour day of standard operation.

Locomotives in commuter and intercity service constitute a supermajority of the passenger rail fleet, and need to have their own unique duty cycle, different from locomotives for long-distance passenger trains. The start-stop nature of their service, coupled with modest periods of operations during the day, cause them to sit idling in standby much more, both in stations and at termini overnight.

In checking into the emissions from Tier 4 engines at idle, using EPA data, we became concerned that the NOx emissions at idle are more than 100 times higher than those at Notch 8 maximum power. Unlike freight locomotives, passenger locomotives contribute significant emissions when idling, because they produce hundreds of horsepower to generate hotel power (which runs the lights and HVAC in the passenger cars).

This reinforces the importance of fully capturing emissions at idle when developing emissions inventories or awarding emissions reduction incentive funding. ARB’s 2017 Passenger Rail Emissions Model generates its outputs simplistically, using gallons of fuel burned, converted into bhp-hrs, and then multiplied by a factor in grams of criteria pollutant/bhp-hr. That last factor is what we are criticizing. It needs to be based on a real-world 24-hour duty cycle combined with full-system emissions testing.

We dug a bit deeper and found that the EPA testing procedures do not include the emissions from the generation of hotel power. Because hotel power is obviously in use when trains are running, accurate emissions measurements for inventories and incentive programs must include the emissions from the generation of the full electrical load for a typical consist.

2. Passenger locomotive in-use emissions measurements must be made with hotel power producing the full electrical load needed for the typical consist.

The issue here is not the compliance with the EPA regulations regarding engine certifications. EPA certification test data were never designed to provide measurements of a locomotive’s total in-use emissions. The issue is the actual total emissions of a passenger locomotive. That is the number of central importance to all of ARB’s emissions reduction activities.

Either as part of an incentive funding program or by regulation, ARB should require logs from commuter and intercity rail operators that enable accurate duty cycles and total emissions to be calculated for each operator. According to ARB’s workshop materials, Tier 4 passenger locomotives cost 2.7 times more than line haul freight locomotives. That makes the job of properly measuring the emissions from these locomotives all that more important, to make sure that incentive funds aren’t being wasted. We urge ARB to gather all the data from public operators needed to determine real-world emissions, and then recheck its incentive program funding decisions to ensure that the expected emissions reductions are actually being achieved.

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SB 69 Seeks to Rip Out NWP Rails

By David Schonbrunn

David Schonbrunn is President of the Train Riders Association of California. Contact him at President@calrailnews.org

In the greatest threat to the NWP since the SP abandonment proceedings, Senator Mike McGuire, representing the North Coast has introduced the Great Redwood Trail bill, SB 69. He seeks to create the nation’s longest trail, running from Larkspur Landing in the south to Samoa in the North. The trail would run alongside SMART’s tracks, eventually all the way to Cloverdale. North of there, however, the rails would be “railbanked”–a polite term for rail removal, with the vague promise that they could be brought back at a future date because the right-of-way would be protected.

While the Train Riders Association of California is not opposed to a trail, we do note that the $1 – $5 billion cost would benefit relatively few people. With the State in fiscal crisis because of the pandemic, this trail is hardly a fiscal priority. See our letter. Here’s what we find troubling about the proposal:

Railbanking is Problematic

•   Railbanking is legally suspect: Adjacent property owners can sue to eliminate the rail easement over their land once trains can no longer run. Trails are not guaranteed to preserve rail easements.

•   We are unaware of any railbanked rail lines that have been restored to rail service. Trail advocates don’t like to talk about this, but railbanking appears to be a one-way street.

Railbanking Blocks New Service to Mendocino

•   The North Coast Rails with Trails Coalition has identified at least 21 shippers in Mendocino County that want their businesses connected by rail to the national rail network. SB 69 calls for railbanking all the rails in Mendocino County, thereby denying them service.

•   Restoration of the currently out-of-service tracks to Willits would help climate change and highway congestion by getting trucks off the highway. Replacing rotted crossties and repairing crossing signals would enable Class 3 service (40 mph for freight, 59 mph for passenger).

Passenger Service to Willits?

•    Conceivably, passengers in the low-density cities to the north of Windsor could be served by the freight operator, providing convenient service connecting Willits, Ukiah, and Cloverdale to SMART at Windsor.

•   Taking long-distance trips off the highway is important method of reducing GHG emissions.

•   While the ride quality wouldn’t equal SMART’s, passengers rode on jointed rails for over a century.

•   Lightweight European diesel multiple units have much lower operating costs than SMART’s DMUs (which would reduce the subsidy needed to make the service worthwhile for the freight operator).

•   TRAC estimates that the existing 78.6 miles of jointed rails from Windsor to Willits could be brought back into Class 3 service for roughly $150 million.

•   Compare that to SMART’s $264 million estimate to build 22.3 miles of tracks to Cloverdale, less than 1/3 of the distance to Willits. The difference is SMART’s gold-plated standard: By building everything new, it seeks to prevent unexpected–and unbudgeted–maintenance issues.

•   Because of the urgency of climate change, TRAC believes it is critical to provide rail service now–and deal with future problems in the future.

•   Building as inexpensively as possible makes it more likely to secure funding sooner.• A private-sector rail operator could potentially be motivated to invest in the capital improvements needed to restore service to Willits, as part of becoming the freight operator.

•   SMART has passed on multiple offers of a TRAC presentation on rail to Willits.

Passenger Service in the Highway 37 Corridor?

•   Partnering with a private-sector freight operator in this corridor could produce a low-cost passenger service that connects SMART to the Capitol Corridor Fairfield station in Solano County.

•   TRAC estimates a low-cost rehabilitation of the existing jointed rail to Class 3 would cost less than $100 million, while SMART’s estimate ranges between $780 million and $1.3 billion.

•   Rehabilitation would be a quick process that could provide near-term help to commuters stuck in Highway 37 congestion.

SMART as a Freight Operator?

•   SMART has no institutional competence in the freight business.

•   SMART does not have an entrepreneurial culture.

•   Senator McGuire either doesn’t understand the financial risks of SMART becoming a common carrier, or is making sure the subject gets zero visibility in his promotion of the Great Redwood Trail.

•   SMART has enough of its own serious problems without entering the freight business: the severe impact of the pandemic on its ridership, and the challenge of gaining public support for a sales tax renewal.

•   With SMART high-cost design standards, the extension of service to Willits and Solano County would be infeasible if it became the freight operator.

What About Humboldt County?

•   Because State policy on climate change means that Humboldt’s future transportation will need to rely more on rail, tearing out the rails is exactly backwards.

•   If the rails are restored to service for freight, they could be used for passenger service as well as for tourist excursion service, a boon for the local economy.

How you can help

Please contact your Assembly member and tell him you oppose SB 69’s railbanking and transfer of freight rights to SMART: Marc Levine [415-479-4920] for Marin and Sonoma Counties, or Jim Wood [(707) 576-2526] for Sonoma, Humboldt and Mendocino Counties.

If you aren’t already a member of the Train Riders Association of California, I invite you to join us. Use the donation button to the right of this page.

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Links to TRAC’s Curated Rail-Related News, June-December 2020

We have gathered links to selected news items over the last six months, listed below. Note: these are PDFs with embedded links.

Some links may not work because some publications move article around after a few months.

June-July 2020

September 2020

October 2020

November 2020

December 2020

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70 Years of “Structural” Racism – Literally (Freeways)

In the 1960’s, fighters of urban freeways often made the point that new freeways were often “…white men’s roads through black men’s bedrooms” as well as being “slum clearance” (sic). The tendency of freeway planners to plot their lines through the least expensive areas, such as black neighborhoods, still shows up in concrete 60-70 years later. And neighborhoods next to freeways often are the least desirable, and most polluted even today in 2020.

https://www.latimes.com/opinion/story/2020-06-24/bulldoze-la-freeways-racism-monument

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