1998 Locomotive NOx Fleet Average Emissions Agreement in the South Coast Air Basin
This page last reviewed November 17, 2015
In 1994, the California Air Resources Board (ARB) adopted Measure M-14 as a federally enforceable measure in California’s State Implementation Plan (SIP). Measure M-14 provides the South Coast Air Basin (SCAB) with an estimated 65 percent reduction in locomotive NOx emissions (up to 24 tons per day) between 2000 and 2010.
Measure M-14 was achieved through the combination of U.S. EPA regulations for cleaner locomotives and the 1998 Locomotive NOx Fleet Average Agreement (1998 Agreement). The 1998 Agreement, signed by ARB, Union Pacific Railroad (UP) and BNSF Railway (BNSF), significantly accelerates the introduction of cleaner locomotives into the South Coast Air Basin. The 1998 Agreement is estimated to provide about half of the total Measure M-14 NOx reductions.
Specifically, under the 1998 Agreement:
UP and BNSF agreed to operate locomotive fleets that “on average” meet a Tier 2 NOx emission standard, or 5.5 g/bhphr by 2010 (and through 2030).
UP and BNSF are allowed to use ultra-low emitting locomotive (ULEL) credit to meet the fleet average.
UP and BNSF must continue to comply with the Tier 2 locomotive fleet average from 2010 to 2030.
Additionally, U.S. EPA agreed to enforce the 1998 Agreement with “backstop” or “contingency” emission reductions, if necessary. (Source: Federal Register / Vol. 63, No. 73 / Thursday, April 16, 1998 / Rules and Regulations – p. 18979).
1998 Locomotive NOx Fleet Average Agreement (PDF - 361 KB)
Statement of Principles - 1998 Locomotive NOx Fleet Average Agreement (PDF - 589 KB)
Determining Locomotive Fleet Average Emissions for Compliance
The UP and BNSF fleet average is measured by the work that an individual locomotive performs in the South Coast Air Basin. Locomotive work is measured in megawatt-hours (MWhrs) - the electricity that a diesel-electric locomotive produces to operate. MWhrs are measured by a watt-meter located on a locomotive. The watt-meter measures the electricity used by the locomotive, and transmits that information by radio signal to UP and BNSF. The percent of work performed by each locomotive is multiplied by that locomotive’s emission level to determine the weighted emission level. The weighted emission levels are summed for all locomotives to determine the total fleet average emission level.
Ultra-Low Emitting Locomotive (ULEL) Credit
The 1998 Agreement allows UP and BNSF to help meet the NOx fleet average of 5.5 g/bhp-hr through credits generated by operating advanced technology or ultra-low emitting locomotives (ULELs). A ULEL is defined as meeting either a 4.0 g/bhp-hr NOx level or better through 2011, or a 3.0 g/bhp-hr NOx level or better through 2014. Some examples of ULELs include genset locomotives and battery electric hybrid locomotives.
ULEL credit provides an incentive for UP and BNSF to invest in and promote the development of advanced locomotive technologies while maintaining operational flexibility of their respective locomotive fleets. Both companies have elected to generate ULEL credit. UP has generated ULEL credit by operating switch locomotives with NOx levels below 3.0 g/bhp-hr. BNSF has generated ULEL credit by operating line haul locomotives with NOx levels below 4.0 g/bhp-hr. Together, these strategies have resulted in significant emission reductions and public health benefits. These benefits have occurred both locally, in and around railyards, and regionally throughout the South Coast Air Basin.
Moreover, these locomotive technologies have been obtained and operated by other railroads across the state, providing California with additional and early locomotive emission reductions. The ULEL credit can be used annually (2010-2030) by each railroad to help achieve the required 5.5 g/bhp-hr NOx fleet average.
Fleet Average Credit (FAC)
The 1998 Agreement has another option for UP and BNSF to generate NOx emissions credit (other than ULEL credit). This type of NOx emissions credit is referred to as the Fleet Average Credit (FAC).
FAC from 2005-2009:
From 2005-2009, the Fleet Average Target is designed to decline from 11.1 g/bhp-hr (2005) to 8.0 g/bhp-hr (2009). UP and BNSF can obtain FAC for locomotive fleet average NOx emissions levels below the Fleet Average Target for a given year.
FAC from 2010-2030:
From 2010-2030, the 1998 Agreement requires both UP and BNSF locomotive fleets in the South Coast Air Basin to achieve a NOx emissions level of 5.5 g/bhp-hr. To obtain FAC during this timeframe, UP and BNSF must have a locomotive NOx fleet average emissions level below 5.5 g/bhp-hr.
The figure below shows the Fleet Average Target that a participating railroad’s Fleet Average Emission level must be below, to obtain FAC.
As an example, in 2007 the 1998 Agreement Fleet Average Target for NOx was 9.6 g/bhp-hr. If a railroad had a fleet average NOx emissions level of 9.0 g/bhp-hr, that railroad would receive the NOx emissions difference in FAC. In this example (9.6 Fleet Average Target – 9.0 NOx Fleet Average Emissions Level), the railroad would receive 0.6 g/bhp-hr NOx of FAC.
FAC can be used to offset locomotive Fleet Average (FA) emissions above the Fleet Average Target. For example, if UP had an FA of 6.1 g/bhp-hr, the 0.6 g/bhp-hr of FAC could be used to meet the Final FA of 5.5 g/bhp-hr.
Finally, if a railroad submits a Fleet Average prior to 2010, including the requisite locomotive activity information, to ARB staff for FAC, that submittal is reviewed in the same manner as discussed below.
Review of Fleet Average Information
The 1998 Agreement requires UP and BNSF to submit this locomotive information to ARB staff through 2030. Beginning April 1, 2011, each railroad is required to annually demonstrate its final fleet average for the preceding year by providing operational information, such as MWhrs, for all locomotives operating within the South Coast Air Basin along with a demonstration of ULEL credits. ARB does an initial review and ensures that all necessary information was provided before issuing a Letter of Completion. ARB evaluates the submitted ULEL credit data, including individual locomotive emission and activity levels, and provides an Approval Letter for ULEL Credit for any acceptable credits. Finally, ARB analyzes the locomotive work data and the fleet average calculations and provides an Approval Letter if the information demonstrates compliance with the 1998 Agreement.
ARB validates the levels of UP and BNSF locomotive activity and locomotive fleet composition (i.e. tier levels) reported for the South Coast Air Basin through the use of data from semi-annual railyard inspections, quarterly field surveys, and extensive photographic tracking of UP and BNSF locomotives operating in California.
Summary for 2014 Calendar Year
The tables below summarize each railroad’s compliance data for the 2014 calendar year. For clarity, the information is categorized by tier or ULEL levels. However, many locomotives are certified to emission levels cleaner than the locomotive emission standards. For the purposes of determining compliance, actual certification or ULEL levels were used.
Information that provides the emissions (tier level) associated with every locomotive that visited the South Coast Air Basin in 2014 is pending and will be available in the near future (e.g. Compliance Reports and Locomotive Summaries). Note that this data is a “snap shot” for calendar year 2014 operations, and those locomotives may or may not be operating in the South Coast Air Basin at this point in time. Additionally, certified emission levels are subject to change as locomotives are remanufactured to lower emission levels. The tables below provide the aggregated number of locomotives, MWhrs by each tier levela, and the average and weighted NOx emission levels.
1998 Agreement Locomotive Compliance Summary Information
|%MWhrs by Tier Level||Weighted Average
NOx Emission Level3
to Fleet Average4
|* Either foreign power locomotives or BNSF locomotives that were non-regularly operating in California. None of the individual units are identified as intrastate locomotives. During 2014, 45 of the 78 were identified as pre-Tier 0 units and were replaced with new Tier 3 locomotives. However, BNSF was unable to confirm what portion of the 220 MWhrs was performed by the new locomotives; therefore, to conservatively calculate the fleet average, pre-Tier 0 emission levels were used. The total pre-Tier 0 locomotives account for about 0.1% of MWhrs in the South Coast Air Basin.|
|Union Pacific Railroad|
|Tier1||Number of Locomotives2||Megawatt-Hours
NOx Emission Level3
to Fleet Average4
|ULEL Credit Used||0.5
|* Either foreign power locomotives or UP locomotives that were non-regularly operating in California. None of the individual units are identified as intrastate locomotives. The pre-Tier 0 locomotives account for 0.3% of total MWhrs in the South Coast Air Basin.|
1. For more information on the U.S. EPA locomotive emission standards please visit. http://www.epa.gov/oms/locomotives.htm.
2. Number of locomotives is the sum of all individual locomotives that visited or operated within the South Coast Air Basin at any time during 2014.
3. Many locomotives are certified to emission levels cleaner than the U.S. EPA emission standards or tiers. For the purposes of this table, a locomotive’s actual certified emission level is grouped with the required tier level. Within each tier, the Weighted Average NOx Emission Level is calculated by multiplying each indivual locomotive's actual certification level by its megawatt-hours of operation.
4. The Tier Contribution is calculated by multiplying the %MWhrs by Tier Level by the Weighted Average NOx Emission Level.
For 2014, both UP and BNSF have demonstrated compliance with the Tier 2 (5.5 g/bhp-hr) locomotive NOx fleet average required by the 1998 Agreement. The links below provide formal correspondence for 2014 compliance between the ARB and UP or BNSF.
- UP Approval Letter for 2014 (PDF - 84 KB)
- UP Approval Letter for ULEL Credit for 2014 (PDF - 74 KB)
- UP Compliance Report (PDF - 727 KB)
- UP ULEL Report for Calendar Year 2014 (PDF - 64 KB)
- UP Locomotive Summary (PDF - 270 KB)
- BNSF Approval Letter for 2014 (PDF - 81 KB)
- BNSF Compliance Report (PDF - 260 KB)
- BNSF Locomotive Summary (PDF - 63 KB)
To view or download a previous year Fleet Average Compliance Report and Approval letter please click on the link above.
a. BNSF and UP requested that ARB treat the activity (MWhrs) of the individual locomotives as business confidential information. Upon review, ARB staff determined that the information meets the criteria for Trade Secrets as defined in California Government Code 6254.7, therefore, aggregate information is presented.