Comment Log Display

1.  Examining different technologies as in this Draft Assessment is
an important step in setting new regulations or funding criteria. 
However, those regulations and criteria should always regulate only
the desired end result (emission levels), rather than specifying a
required technology to achieve those results.  In this way,
creative enterprises may develop unforeseen solutions that meet the
desired end results, while avoiding or reducing harmful
side-effects such as costs or operational impacts.

2.  Table II-2’s comparison (page II-2, PDF page 40) of existing
standards for line haul locomotives with those of 750 hp off-road
engines is not the most accurate comparison.  A more relevant
comparison would be between locomotives and off-road engines above
750 hp, including engines by builders such as MTU, Cummins and
Caterpillar that are used in both locomotives and in off-road (e.g.
surface mining) equipment.  The relevant emission standards for
these off-road engines are:
 • NOx:  3.5 g/kW-hr, or 2.6 g/bhp-hr
 • PM:   0.04 g/kW-hr, or 0.03 g/bhp-hr
 • HC:   0.19 g/kW-hr, or 0.14 g/bhp-hr

3.  The metrics on page III-1 (PDF page 45), to evaluate and guide
development of advanced technologies, also need to include
reliability and maintainability under all anticipated operating
conditions.  Even the cleanest locomotive does little to improve
air quality, if it is so unreliable or difficult to maintain and
repair that a railroad can’t use it.