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To: Ron M e

Date: June 2 4

C omments:

T his memoran d
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readily2 Traditionally, control factors have not been applied to aircraft for criteria pollutant forecasts. Quantitative information on reductions has not been available, and th e reductions from these standards are beli eved to be minimal. EPA’s Office of Transportation and Air Quality has an active project that is de signed to help them better understand the impact of ICAO standards on commercial aircraft NO xemission inventories. TranSystems|Pechan contacted EPA and learned that yearspecific NO x control factors accounting for rule penetration into the do mestic aircraft fleet will be forthcoming, but are not yet available (Manning, 2011). As such, no controls were developed and applied to the aircraft engine category forecasts.

2. Commercial Marine Vessels
For the purpose of applying growth and controls for commercial marine vessels (CMVs), it was assumed that Category 1 and 2 engines typically use distillate fuels, while Category 3 engi nes primarily use residual blends. As such, Category 1 & 2 growth and control factors were applied to diesel in-port and underway SCCs (2280002100 and 2280002200), and Category 3 growth factors and reductions were applied to residual in-port and underway SCCs (2280003100 and 2280003200).
TranSystems|Pechan developed growth factors for residual CMVs using average annual growth rates by region developed by EPA for the RIA to support their Category 3 engine rulemaking (EPA, 2009a). Re gional growth rates are available for designated states in the East Coast region, as well as the Gulf Coast Region. These same growth rates were used to estimate 2007 SEMAP emissions from the available 2008 NEI emission estimates for residual CMV emission estimates (Pechan, 2010).
For diesel engine CMV emissions, TranSystems|Pechan calculated growth factors based on fuel consumption forecasts published by the EIA. Table 67 of EIA’s Annual Energy Outlook, 2010 provides national-level forecasts of distillate oil (diesel) energy consumption (in trillion Btu) by domestic and inte rnational shipping sectors for years out to 2035 (EIA, 2010).

In 2009, EPA promulgated new emission standards for certain categories of diesel engines used in CMVs. TranSystems|Pechan developed CMV control factors using informat ion from EPA’s regulatory impa ct analyses (RIA) for these emission standards (EPA, 2008; EPA, 2009a).

Control factors for Category 1 & 2 engines were developed based on emission reductions calculated from national base case and control case inve ntories developed for the years 2002 through 2040 (EPA, 2008). These control factors account for both the level of control required by the standard (i.e., control efficiency) as well as the measure of rule penetration (i.e., what fraction of the fleet is meeting the specific level of contro l). TranSystems|Pechan estimated emission reductions and control factors for the chosen forecast year relative to any reductions expected to occur in the 2007 base year. Emission reductions were modeled for NO x , SO 2 , PM-10, PM-2.5, and VOC for Category 1 & 2 engines.
Control factors for Category 3 engines were developed from EPA regional base case and contro l case inventories. EPA’s RIA for Category 3 engines includes base and control case inventories for select y ears out to 2030 (EPA, 2009a). Region-specific control factors were developed for the selected forecast year based on EPA’s inventories for the East Coast and Gulf Coast regions of the U.S. Using EPA designations, SESARM States/countie s were assigned to the East Coast or Gulf Coast region. Emission reductions were modeled for NO x , SO 2 , PM-10, and PM-2.5 for Category 3 engines.

3. Locomotives
Base year emissions for locomotives are reported for the following SCCs:

 2285002006 – Diesel Class I Line Haul

 2285002007 – Diesel Class II/III Line Haul

 2285002008 – Diesel Passenger (Amtrak)

 2285002009 – Diesel Commuter

 2285002010 – Diesel Switchyard Locomotives3 For Class I and Class II/III line haul and di esel switchyard operations, TranSystems| Pechan calculated gr owth factors based on freight rail sector fuel consumption forecasts, as published by the EIA. Table 67 of EIA’s Annual Energy Outlook, 2010 provides national-level forecasts of freight rail distillate oil (diesel) consumption (in trillion Btu) out to 2035 (EIA, 2010) . For passenger and commuter rail, growth factors were developed from national forecasts of intercity rail diesel consumption, and commuter rail diesel consumption, available from Table 46 of the Annual Energy Outlook, 2010 (EIA, 2010).

Similar to CMVs, diesel locomotive engines are subject to revised Federal Tier 0, Tier 1, and Tier 2 standards, as well as new Tier 3 and 4 standards. TranSystems|Pechan developed control factors for diesel-powered locomotive engine emissions based on EPA’s locomo tive engine RIA and associat ed emission factor guidan ce (EPA, 2008; EPA, 2009b). TranSystems|Pechan compiled fleet-average emission factors published by EPA for 2007 and the chosen forecast year, and calculated the incremental reductions expected over this time period. Future year emission factors are available for Large Class I Line Haul, Small Class II/III Line Ha ul, Switchyard, and Passenger/Commuter operations . Reductions were modeled for NO x , PM-10, PM-2.5, VOC, as well as SO 2
.
4. File Formats
To transmit the relevant nonroad growth and control information, we prepared the following Excel files. Descriptions of their content are also included.
Nonroad Growth Factor Summary.xlsx – This file contains growth factors by state and source category code (SCC) for each forecast year relative to 2007 (Columns K through S – highlighted in green). A growth factor code and growth factor code description are also provided to indicate which set of data were used to develop each growth factor. County-level growth factors were developed for some counties for residual CMV (to reflect available regional growth rates), and for aircraft where airports and their associated LTOs from the TAF could be matched to counties. The geographic resolution of the growth factors is indicated in Column J, “Geography.” The state or co unty to which the growth factor applies is listed under Column A, “FIPS.” State or local agencies should first match nonroad catego ry growth factors by SCC and FIPS county, and where there is no match at the county level, the state-level GF should be used.

SEMAP Rail and CMV Control Factors.xlsx – This file contains two sheets - “Locomotive Controls,” and “CMV Controls.” In both sheets, control factors (CF) by state or county and SCC are provided for each forecast year relative to 2007 (highlighted in yellow and labeled as 2017 CF, 2018 CF, etc.) Values for control efficiency (CE), rule penetration (RP), and rule effectiveness (RE), that comprise the overall control factor, are also included. Control efficiency for each SCC was determined by compiling the control efficiency of the most string ent Tier associated with a standard, relative to the baseline control. Rule effectiveness was always assumed to be 100% . Rule penetration was then estimated based on the CE, RE, and final CF value. All values are expressed as a percent. In a few cases, county-level control factors were developed (e.g., for residual CMV to reflect regional growth rates in Florida). The state or county to which the control factor applies is list ed under Column A, “FIPS.” Similar to the growth factors, State or local agencies should first match nonroad control factors by SCC and county, and where there is no match at the county level, the state-level GF should be applied.

5. References
EIA, 2010. Energy Information Administration, Department of Energy, “Annual Energy Outlook, 2010, with Projections through 2035 ,”

DOE/EIA-0383(2010), Energy Information Administration, O ffice of Integrated Analysis and Forecasting, Washington, DC. May 11, 2010.
EPA 2008. U.S. Environmental Protection Ag ency, “Regulatory Impact Analysis: Cont rol of Emissions of Air Pollution from Locomotive Engines and Marine Compression Ignition Engines Less than 30 Liters Per Cylinder,” Office of Transportation and Air Quality, EPA-420-R-08-001. March 2008.

EPA, 2009a. U.S. Environmental Protection Agency, “Regulatory Impact Analysis: Co ntrol of Emissions of Air Pollution from Category 3 Marine Diesel Engines,” Office of Transport ation and Air Quality, EPA420- R-09-019. December 2009.4 EPA, 2009b. U.S. Environmental Protecti on Agency, “Emission Factors for Locomoti ves,” Office of Transportation and Air Quality, EPA-420-F09-025. April 2009.

FAA, 2010. Federal Aviation Administration, “Ter minal Area Forecasts, 2009-2030,” available from http://aspm.faa. gov/main/taf.asp . 2010.
Manning, 2011. Personal Communi cation, Bryan Manning, EPA with K. Thesing, TranSystems|Pechan. March 24, 2011.

Pechan, 2010. E.H. Pechan & Associates, Inc., “Area and Nonroad 2007 Base Year Inventories, Final Report,” prepared for Southeastern States Air Resource Managers, Inc. June 2010.