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.