A notable source of local air pollution you’ve never even heard of before.
Last spring a unique and significant source of air pollution caught my attention. At that time, I was a member of the Volkswagen Environmental Mitigation Plan Advisory Committee and at our first meeting we were given a list of types of equipment eligible for replacement with the VW funds. The Utah Division of Air Quality presented the list to us along with a graph showing the cost per ton reduction of each of the types of equipment. The third lowest cost per ton on the graph was “freight switchers.”
Freight switchers are locomotives that shuttle train cars around rail yards before they’re shipped across the country. Each unit comes with a price tag of over $1.5 million and a useful life of up to 60 years.
There are currently 60 freight switchers in Utah and they are extremely dirty. All of these switchers operate in rail yards within the state’s PM2.5 non-attainment areas, areas classified as failing to meet the National Ambient Air Quality Standards by the EPA. Forty-nine of these switchers are owned and operated by Union Pacific. Of these 49, 70% of them are “Tier 0+” and the remaining 30% are “Tier 0.” To put this into perspective, the current standard for new locomotives is Tier 4, which reduces nitrogen oxides (NOx) by 90% and direct particulate matter pollution 88.5%. Tier 0 and Tier 0+ are considerably dirtier than Tier 4.
Impact on the air shed
The 2014 emissions inventory from the Division of Air Quality shows that freight switchers accounted for over 400 tons of NOx and 8.8 tons of direct PM2.5 air pollution. On a typical winter weekday in the Salt Lake Valley the total NOx emissions coming from vehicles is about 72 tons, so these freight switchers alone emit about five and a half weekdays’ worth of vehicle pollution annually, or about 2% of the annual emissions. It’s a lot of unnecessary pollution considering they could operate much cleaner. The switchers owned and operated by Union Pacific represent 75% of these totals. Union Pacific operates three switchyards in Utah, one in Weber County and two in Salt Lake City.
Some striking evidence of just how significant a source of air pollution these freight switchers are came from data collected by the University of Utah’s Atmospheric Science Department’s TRAX air pollution monitoring study. The TRAX study collects air quality data by two air pollution sensors mounted on TRAX cars to measure PM2.5, ozone, NOx, methane and CO2 along the route. The TRAX data shows the two largest concentrations of NOx in the valley. The first spike comes when the train crosses paths with I-15. This spike is expected because it is well known that vehicles are significant sources of NOx and other pollutants.
The second spike occurs when the train is right next to the Roper switchyard, located near the I-15/I-80 “spaghetti bowl” operated by Union Pacific. This spike is directly related to the switchyard activity. Due to a number of factors, including Utah’s climate and altitude, freight switchers must remain running constantly, whether in operation or not. It is safe to assume that all 60 of the freight switchers operating in Utah are running 24 hours per day, 365 days a year, whether actually working or just idling.
What can be done to clean up these switchers? And what about VW money?
The State of Utah is eligible to receive $35 million from the VW settlement over the next 10 years (see CATALYST, December 2017). However, under the settlement, any equipment replaced with the funds must be completely destroyed. They cannot simply be moved out of the state and used somewhere else. But for a piece of equipment with a 60-year useful life that costs about $1.5 million, this isn’t reasonable. Union Pacific currently has an excess inventory of switcher locomotives of the Tier 0 or 0+ standard, which makes the purchase of new equipment unnecessary for their business. There are many other options for great projects under the VW settlement that will have significant reductions in NOx pollution.
Can Utah force Union Pacific to clean up their operations?
Unfortunately, states are preempted from establishing their own standards for locomotives under section 209 of the Clean Air Act. EPA has set the standard for locomotives, which basically only requires operators to repower or replace this equipment with a Tier 0+ designation, which is just slightly better than Tier 0. This is despite having much cleaner technology (Tier 3 or 4 engines) readily available on the market. As mentioned before, freight switchers are very expensive pieces of equipment and they have a very long useful life. So when companies like Union Pacific need to replace them, they can actually just repower the engines and keep the chassis of the switchers, rather than replace them with a brand new entire unit. Even states like California that often adopt stricter standards for air quality issues can’t get around the Clean Air Act on this one.
They can, however, use non-regulatory tools, such as incentives and “memorandums of understanding” to get the operators to replace dirty equipment with cleaner technology.
One such tool is on the table in Utah this legislative session. Representative Steve Handy’s bill, HB 211, takes an incentive-based approach, where the state can offer grant funding to Union Pacific, in conjunction with other funding sources, like the Diesel Emissions Reduction Act (DERA) funds. Handy’s bill comes with a $2 million request for appropriation which, if leveraged correctly, can be used to replace up to three of these freight switchers. This would develop a pilot project where Union Pacific can pay a portion of the costs and become comfortable with the equipment technology and the repowering of their units, and hopefully will follow as good stewards of the community and clean up their fleet of switcher locomotives.
Critics of the bill, pointing out that Union Pacific nets a multi-billion dollar profit each year, are concerned that having the taxpayers foot the bill to get these switchers cleaned up is a poor use of $2 million. They may have a good point. Union Pacific is willing to continue conversations about what will happen when the technology of the cleaner switchers is proven to work under Utah’s conditions. In the meantime, the community must keep the pressure on.
It’s worth noting that trains are less polluting than trucks. These trains haul the materials of modern urban life: coal, lumber, metals, minerals, food and beverages, wind turbines, consumer products and more.
Supporters of the bill say that incentives like this are necessary to get companies such as Union Pacific to begin implementing better practices. Take Tier 3 fuels, for example. A tax incentive was just what Chevron needed to commit to producing the lower sulfur gasoline for sale in Utah. And this will have significant impacts in reducing air pollution.
The cost-per-ton reduction associated with cleaning up freight switchers is reasonable. (The Division of Air Quality’s analysis shows that switchers come in at $3,400/ton.) Considering these switchers produce a significant amount of emissions and the cost per ton for clean up is reasonable, this could be an important piece of a large and complicated puzzle that is Utah’s air quality problem.
As industry works hard and invests in costly emissions reductions projects, the state must search for creative ways to look at other sources to get into attainment. Sources like freight switchers may have been overlooked in the past, but facing a designation of “serious non-attainment,” everything must remain on the table.
Ashley Miller, J.D., is the program and policy director for Breathe Utah. She is a member of the state’s Air Quality Policy Advisory Board and is also on the Salt Lake County Health Department Environmental Quality Advisory Commission.