International Corporation 

### Air Sciences

Draft

LADCO 2005 LOCOMOTIVE EMISSIONS

Prepared for

Michael Koerber Lake Michigan Air Director Consortium 2250 E. Devon Ave., Suite 250 Des Plaines, IL 60018

Prepared by

Christian E. Lindhjem ENVIRON International Corporation 101 Rowland Way, Suite 220 Novato, CA 94945-5010

February 2007

101 Rowland Way, Suite 220, Novato, CA 94945 415.899.0700February 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 1 LOCOMOTIVE EMISSION SOURCES

INTRODUCTION

Locomotives are usually the most important s ource of NOx, PM, and SOx emissions from offroad engines. Rail activity is especially important in the LADCO states, because Chicago and other metropolitan areas in the LADCO st ates represent import ant rail centers.

Rail activity has been typically broken into fi ve subcategories or S ource Category Codes (SCC)
shown in Table 1 from the National Emission Inve ntory (EPA, 2001). Class I railroad operations are the largest and most important railroads a nd have been split into two categories, which
ENVIRON considered to be their line-haul (SCC 2285002006) and switching (SCC 2285002010) activity. Smaller rail (Class II a nd III; SCC 2285002007) include a large number of railroads and a wide variety of operations including line-haul and switching operations. It was useful to separate switching activity from line-ha ul activity for both Class I and II/III because the emissions are usually specific to a given yard and such engines ha ve different operating profiles. Because EPA only provided one switching engine SCC, the Class I and II/III switchers were combined in the one SCC. AMTRAK operates the only continuous passenger rail system (SCC 2285002008), though there may be small (weekend) excu rsion lines operati ng sporadically and largely unidentified. The only commuter lin e (SCC 2285002009) that ope rates in the LADCO area is the METRA system in and around the Chicago metropolitan area.

Table 1. EPA NEI rail categories.

SCC EPA Description Railroad Descriptions for This Work Relative Fuel Use 2285002006 Class I line-haul Union Pacific (UP), Burlington Northern Santa Fe (BNSF), Norfolk Southern (NS), CSX, Kansas City Southern (KCS), Canadian
National 1 , Canadian Pacific (CP) 2 84.3%

2285002007 Class II/III line-haul Regional and local railroads line-haul 2.6% 2285002008 Passenger Trains AMTRAK 1.5% 2285002009 Commuter lines METRA 3 4.2% 2285002010 Yard Operations Class I yard rail and Class II/III switching railroads 7.4%

1 Illinois and Wisconsin Central also include d in Canadian National Grand Trunk (CNGT).

2 Soo Line included.
3 One other line operates an electric rail system only.



### The primary activity unit used to determine emissi ons is gallons of fuel consumed. To provide a perspective on emissions from different categories, the fuel consumption estimates for different SCC groups are shown in Table 1. The sw itching engine activity (SCC 2285002010) includes Class I (about 65% of SCC total) and Class II /III (about 35%) outlined by unique yard activity. The passenger and commuter rail systems were easily identified for this study and provided activity data specific to the system.

Emission rates used in this work were deri ved from EPA documents provided as support documentation for the 1997 locomotive emission standards (EPA, 1997). The emission rates per gallon of fuel consumed are higher with switchin g engines because the duty cycle is on averageFebruary 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 2 lower power and has a significant amount of idlin g time, so the engine does not operate as efficiently as possible. Emissi on rates are higher for smaller rail systems than Class I railroad operations because they have been expected to convert more slowly to lower emissions engines (EPA, 2004a). EPA (2004b) provided the ammonia emission rates using the latest available
data. The emission rates used in this work are s hown in Table 2. The different emission rates do not match the SCC definitions exactly. The prim ary differences are that Class II/III switching
has been treated with distinct emission factors co mpared to the Class II/III line-haul because of duty cycle differences, and commuter rail has the sa me emission factors as other passenger rail.

Table 2. Emission factor estimates used in this work (in grams per gallon). (Emission reduction due to fleet turnover to engines meeting lower emission standards.) Engine Type HC CO NOx PM SOx 1 NH3 2

Precontrolled 1999 Line-haul 10 26.6 270 6.7 16.7 0.116 Precontrolled 1999 Switching 21 38.1 362 9.2 16.7 0.116 Including emission reductions expected with the EPA rulemaking (% Reduction) 2005 Class I Line-haul 9.59 (4.1%) 26.6 184.1 (31.8%) 6.43 (4.0%) 16.7 0.116

2005 Class I Switching 20.88 (0.6%) 38.1 336.7 (7.0%) 9.14 (0.7%) 16.7 0.116

2005 Class II/III Line-haul 10 26.6 265.6 (1.6%) 6.70 16.7 0.116

2005 Class II/III Switching 21 38.1 356.1 (1.6%) 9.20 16.7 0.116

2005 Passenger 9.79 (2.1%) 26.6 200.8 (25.6%) 6.57 (1.9%) 16.7 0.116

1 Reported as SO 2 and derived from an average sulfur level of 2600 ppm (EPA, 2004c).

2 EPA (2004b).



### CLASS I RAILROADS

Because the Class I railroads were expected and i ndeed had the most signifi cant rail operations in the LADCO states, every Class I railroad was petitioned for information about their rail operations.

Union Pacific (UP, 2007), Burlington Northe rn Santa Fe (BNSF, 2006), and CSX (2007) provided the most favorable re sponses providing county summarie s of line-haul and switching engine fuel consumption. Norfolk Southern provi ded county level activity for their line-haul freight movements in 2002 (NS, 2004) and State to tals for 2005 (NS, 2006), and detailed their switching rail activity for Cook County yards in the 2002 data but did not update those estimates for 2005. Canadian National (CN, 2007) and Cana dian Pacific (CP, 2006) railroads provided State-level total activity though CP could not de tail their switching engines. Kansas City Southern, which operates primarily in western Il linois and to Chicago, di d not provide activity data. Table 3 summarizes the data pr ovided by the railroads for this work.February 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 3 Table 3. Class I Railroad fuel consumption submittals.

Railroad Railroad
ID Line-Haul Activity Submittal Switching Activity Submittal Burlington Northern Santa Fe BNSF By county line-haul activity By county switching activity

Canadian National CNGT State total fuel consumption State total fuel consumption Canadian Pacific CP State total gross ton-mile No data submitted CSX (Chessie System) CSX By county line-haul activity By county switching activity

Kansas City Southern KCS No data submitted No data submitted Norfolk Southern NS By county line-haul activity in 2002 and State totals for 2005 By county switching activity for Cook Co. in 2002 only. Union Pacific UP By county line-haul ac tivity By county switching activity



### For Kansas City Southern (KCS), which did not provide estimates of relative activity in the LADCO states, an alternative method was used to estimate state fuel consumption. The US national fuel consumption for the railroad was prorated against the relative system mileage
within Illinois as a fraction of the railroad’s reported US national system (AAR, 2006).

For Canadian Pacific, switching engine activity was estimated as a fraction of line-haul fuel consumption from their line-haul activity. E NVIRON estimated this to be 7.25% of line-haul fuel consumption as derived from the CP fuel consumption submittals (AAR, 2006). Likewise, Norfolk Southern provided only the Cook Co. activity, so ENVIRON multiplied the line-haul activity by 8.95% for NS specifica lly to estimate the overall fr action of NS switching engine activity.

Class I railroad fuel consumption is presented in Tables 4 and 5; these estimates are primarily the railways’ submittals.

Table 4. Class I Railroad line-haul 2005 fuel consumption estimates.

Railroad/State Illinois Indiana Michigan Ohio Wisconsin BNSF 109,809,384 0 0 0 30,285,369 CNGT 26,370,193 4,799,739 19,491,428 187,760 20,546,552 CP 2,715,644 2,086,920 3,084,322 84,666 9,368,715 CSX 14,637,848 43,189,477 6,541,787 78,198,981 0 KCS 3,028,496 0 0 0 0 NS 22,607,541 53,609,405 3,546,979 78,884,760 0 UP 78,854,338 0 0 0 7,323,114 Total 258,023,444 103,685,542 32,664,516 157,356,168 67,523,751February 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 4 Table 5. Class I Railroad switching 2005 fuel consumption estimates.

Railroad/State Illinois Indiana Michigan Ohio Wisconsin BNSF 550,000 0 0 0 500,000 CNGT 2,743,600 0 1,584,145 91,323 1,711,510 CP 196,926 151,334 223,660 6,140 679,375 CSX 2,040,000 1,440,000 1,080,000 4,440,000 0 KCS 131,360 0 0 0 0 NS 2,023,203 4,797,633 317,428 7,059,585 0 UP 2,559,434 0 0 0 971,067 Total 10,244,522 6,388,967 3,205,233 11,597,047 3,861,951



### CLASS II/III REGIONAL, SHORTLINE , AND SWITCHING RAILROADS

In order to estimate potentially important small rail activity, the national fuel consumption per railroad employee was used and associated wi th local employment information. Benson (2004) prepared the national estimates of fuel consumption and employees shown in Table 6 from annual surveys conducted by ASLRRA (1999). Na tionally, Class II/III rail is of lesser importance than the Class I rail, which consumed nearly 20 times th e fuel that these smaller rail systems consume nationwide. Table 6 provides the national summary estimates for Class II/III fuel consumption and employees; on average about 10,000 gallons of fuel are consumed per year per employee. By contrast, the Class I railroad fuel consumption per employee averages about 25,000 gallons per employee, possibly due to long er haul trips where fewer employees are required per ton-mile of operation. The ASL RRA (2007) was consulted for estimates for 2005, but ASLRRA indicated that, in th e absence of a formal survey, th ey expect that the level of employment and activity has been relatively flat for many years. Based on that assessment, ENVIRON assumed the same level of activity for 2005 as 2002.

Table 6. Class II/III national summary activity rates.

Year Employees Fuel Consumption (gallons) 1993 24,000 200,000,000 1994 25,000 225,000,000 1995 24,000 225,000,000 1996 24,000 200,000,000
1997 No data available 1998 23,000 210,000,000 1999 23,000 220,000,000 2000 22,000 220,000,000 2001 22,000 220,000,000



### The results for estimating fuel consumption in 2002 were used as identical for 2005 within the scope of this project. ENVIRON estimated 2002 fuel consumption using the fuel consumption per employee where the number of employees for each company was provided from a purchased database of Dun & Bradstreet (D&B). The number of employees multiplied by the fuel consumption per employee as calculated from 20 01 in Table 6 provided the fuel consumption of
each railroad in each state. The D&B data supplemented by AAR also indicated whether theFebruary 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 5 railroad was considered a typical (line-haul) railroad or only provided switching services to determine the appropriate emission factors for line-haul or switching operations by railroad.

PASSENGER RAIL

AMTRAK provided an estimate of 2.35 gall ons per train-mile of travel. AMTRAK (www.amtrak.com ) provides the weekly schedules for all trains in the Midwest including track mileage on their web site. ENVIRON used the AMTRAK schedules to estimate the number of trains and mileage for each train (both ways). These trains are shown in Table 7. The 2.35 gallons per train-mile fuel consumption figure was applied to the weekly mileage multiplied by
52 for an annual estimate in Table 8.

Table 7. AMTRAK Midwest operations in 2005.
Route Miles Train (number) Weekly Trains (Both Ways) Route to Terminus or Exit of LADCO IL IN MI OH WI

Chicago Zephyr (5 & 6) 14 Chicago – Burlington IA 205 0 0 0 0 Cardinal / Hoosier State (51 & 50) 6 Chicago – Cincinnati OH 9 266 0 24 0

Cardinal / Hoosier State (850 & 851) 14 Chicago – Indianapolis IN 9 187 0 0 0

City of New Orleans (58 & 59) 14 Chicago – Cairo IL 365 0 0 0 0

Empire Builder (7 & 8) 14 Chicago – La Crosse WI 18 0 0 0 263 Hiawatha (329 – 342) 96 Chicago – Milwaukee WI 18 0 0 0 68 Illinois routes (300 – 307, 311, 313. 314. 316) 56 Chicago – St. Louis 284 0 0 0 0

Illinois routes (380 – 383) Carl Sandberg 28 Chicago – Quincy IL 258 0 0 0 0

Illinois routes (390 & 393) 28 Chicago – beyond Carbondale IL 310 0 0 0 0

Lakeshore Ltd. (48 & 49) 14 Chicago – Erie PA 9 146 0 280 0 Michigan (350 – 355) 42 Chicago – Pontiac MI 9 41 252 0 0 Michigan (364 & 365) 14 Chicago – Port Huron MI 9 41 267 0 0 Southwest Chief 14 Chicago – Keokuk IA 220 0 0 0 0 Texas Eagle (21 & 22 or 421 & 422) 14 Chicago – St. Louis MO 284 0 0 0 0

Pere Marquette (370, 371) 14 Chicago – Grand Rapids MI 9 41 126 0 0

Table 8. AMTRAK state 2005 fuel consumption estimates. Fuel Consumption (gallons per year) Train (number) IL IN MI OH WI Chicago Zephyr (5 & 6) 350,714 0 0 0 0 Cardinal / Hoosier State (51 & 50) 6,599 195,031 0 17,597 0
Cardinal / Hoosier State (850 & 851) 8,798 182,811 0 0 0 City of New Orleans (58 & 59) 624,442 0 0 0 0 Empire Builder (7 & 8) 30,794 0 0 0 449,940 Hiawatha (329 – 342) 383,219 0 0 0 646,682 Illinois routes (300 – 307, 311, 1,943,469 0 0 0 0February 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 6 Fuel Consumption (gallons per year) Train (number) IL IN MI OH WI
313. 314. 316) Illinois routes (380 – 383) Carl Sandberg 882,773 0 0 0 0 Illinois routes (390 & 393) 1,060,696 0 0 0 0 Lakeshore Ltd. (48 & 49) 15,397 249,777 0 479,024 0 Michigan (350 – 355) 46,192 210,428 1,293,365 0 0 Michigan (364 & 365) 15,397 70,143 456,784 0 0 Southwest Chief (3 & 4) 376,376 0 0 0 0 Texas Eagle (21 & 22 or 421 & 422) 485,867 0 0 0 0 Pere Marquette (370, 371) 15,397 70,143 215,561 0 0 Total 6,246,131 978,333 1, 965,709 496,621 1,096,623



### To allocate AMTRAK activity by county, an approximate estimate of the relative mileage in each county was used to apportion the fuel consum ption for each of the specific trains shown in Table 8. One adjustment was made to the track mileage method to more properly estimate Cook County, Illinois because all trains are either destined to or or iginate from Chicago. ENVRION estimated the fuel consumption in Cook Co. assumi ng all trains travel 25 miles within Cook Co.
The calculation for Cook Co. increased the C ook Co. activity by about 50% over the track mileage method. The remaining activity for counties other than Cook County was then
reallocated to other counties using relative track mileage.

COMMUTER RAIL

The largest and only diesel powered commuter line in the LADCO area is the METRA rail system. METRA (2007) provided fuel consumpti on information by rail line as shown in Table 9 and track mileage along each line by county in Table 10. A sample of the schedule for the UP-N line is provided to show that all trains do not r un to the end of each line, and also to show the relative weekday and weekend activity. Fi gure 1 shows the rail lines including county
boundaries.

Table 9. 2005 fuel consumption for METRA rail.
Fuel (gallons) Lines Comments 10,346,670 UP (W, N, and NW) N – M through F; From Kenosha 9 trains N – M through F; From Waukegan 16 trains N – M through F; From Winnetka 3 trains N – M through F; From Highland Park 3 trains N – Saturday; Kenosha 5, Waukegan 6 N – Sunday; Kenosha 3, Waukegan 5 M-F; 31 per day, Sat = 11, Sun = 8 4,445,430 BNSF Several trains predominately in Cook Co. 4,636,460 MD (W and N) Line splits into two 2,929,984 RI

642,397 NCS 552,171 SWFebruary 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 7 Fuel (gallons) Lines Comments 306,248 HC 0 ME All electric rail line merging with the South Shore Line 23,859,360 TOTAL

Table 10. METRA rail line mileage by county.

Carrier/Line Additional Description Mile post Co. Mile post Co. Mile post Co. Mile post Co. Mile post Rock Island District Main Line 0.0 Cook 25.8 Will 40.2 Rock Island District Beverly Branch 9.9 Cook 16.5

Rock Island District LaSalle - Beverly 0.0 Cook 16.5
SouthWest Service 0.0 Cook 28.9 Heritage Corridor 0.0 Cook 26.7 Will 37.2 Burlington Northern Santa Fe 0.0 Cook 16.2 DuPage 34.6 Kane 37.5 Union Pacific West 0.0 Cook 14.7 DuPage 33.0 Kane 35.5
Milwaukee District West 0.0 Co ok 16.2 DuPage 26.2 Cook 34.0 Kane 39.8
Union Pacific Northwest 0.0 Co ok 31.7 Lake 35.7 McHenry 63.1

Union Pacific McHenry Branch 43.2 McHenry 50.6

Union Pacific OTC to McHenry 0.0 Cook 31.7 Lake 35.7 McHenry 50.6
Milwaukee District North 0.0 Cook 23.0 Lake 49.5
North Central Service 0.0 Cook 31.1 Lake 52.8

Union Pacific North 0.0 Cook 20.5 Lake 45.2 Kenosha, WI 51.6February 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 8 Figure 1. METRA rail system.February 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 9 It was beyond the scope of this study to de termine absolutely the emissions and fuel consumption by county for the METRA system given the large number of routes and train types. There are many issues that could affect relative fuel consumpti on including number of starts, weight of each train (number of cars and passenger load), idle time, empty train runs (used for scheduling purposes), and range of each train (for instance, not all trains start/run to the end of line). This is demonstrated in Table 9 for th e sample of trains along the UP-N line where the number of trains varies widely by the route and last station north.

However, it was necessary to pr ovide a best estimate of relativ e activity by county to reflect greater activity in Cook County, ra ther than using only the prorat ed track mileage because all
trains do not run to the end of the line. Because the number of trains running to the end of each
line is a fraction of all trains along that line, in this work the commuter emissions were distributed to each county using the full mileage within Cook County, half the track mileage in adjoining counties, and one quarter the mileage for outlying counties. The one-quarter estimate was applied to Kenosha (WI) along the UP-N, McHenry (IL) along the UP-NW, and Lake (IL) along the MD-N and NCS lines shown above. This approximately reflects the relative activity in
terms of number of trains on the outer reaches of each line based on the train schedules provided for the UP-North line where approximately one quart er of trains run to Kenosha and many trains stop at Waukegan, only halfway through Lake Count y. The modified mileage for each county was used to apportion the fuel c onsumption as shown in Table 11.

Table 11. METRA rail 2005 annual fuel consumption estimate (gallons) by county.
Illinois Wisconsin Line Cook DuPage Kane Lake McHenry Will Kenosha UP (all) 6,784,402 932,576 125,393 1,458,007 883,840 0 162,452 BNSF 2,682,159 1,519,062 244,209 0 0 0 0 MD (all) 3,541,871 374,911 220,425 499,253 0 0 0 NCS 546,728 0 0 95,669 0 0 0 HC 255,926 0 0 0 0 50,322 0 RI 2,397,260 0 0 0 0 532,724 0 SWS 552,171 0 0 0 0 0 0 Total 16,760,517 2,826,549 590,027 2,052,929 883,840 583,047 162,452



### For a specific metropolitan Chicago study, it may be warranted to further investigate this allocation scheme if a specific lo cal emission inventory is required, but it shoul d also be realized that all freight traffic (well defined data were available for BNSF, UP, and NS-freight railways) is not as well understood as this commuter syst em. Therefore, any errors in the allocation
method for the METRA commuter rail added consid erably less uncertainty to all locomotive emissions allocations than might be expected with such an approximate method. Also, a
misallocation will not affect the overall emi ssions estimates, only to which county those emissions were allocated. Lastly, the allo cation method used here is more accurate in apportioning METRA’s activity than using track mileage alone.

The only other commuter rail line, the Northern Indiana Commuter Transit District (formerly the South Shore line) commuter rail, runs only an elec tric rail line. This operation operates only two small diesel locomotives and only to pick-up non functioning electric trai ns during rare power problems.February 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 10 SUMMARY

The 2005 summary emissions (annual metric tonn es) for locomotive in the LADCO states are shown in Tables 12 through 16.

Table 12. Class I line-haul rail, SCC 2285002006 for 2005.
State HC CO NOx PM SO2 NH3 Gallons
Illinois 2,474 6,863 47,491 1,659 4,309 30 258,023,444
Indiana 994 2,758 19,084 667 1,732 12 103,685,542 Michigan 313 869 6,012 210 545 4 32,664,516
Ohio 1,509 4,186 28,963 1,012 2,628 18 157,356,168
Wisconsin 647 1,796 12,428 434 1,128 8 67,523,751

Table 13. Class I/II/III switching rail, SCC 2285002010 for 2005.
State HC CO NOx PM SO2 NH3 Gallons
Illinois 400 727 6,597 175 319 2 19,084,503
Indiana 266 483 4,392 116 212 1 12,682,467 Michigan 114 208 1,880 50 91 1 5,455,233
Ohio 282 514 4,578 123 225 2 13,487,047
Wisconsin 81 147 1,300 35 64 0 3,861,951

Table 14. Class II/III line-haul rail, SCC 2285002007 for 2005.
State HC CO NOx PM SO2 NH3 Gallons
Illinois 62 164 1,641 41 103 1 6,180,000
Indiana 23 62 619 16 39 0 2,330,000 Michigan 44 117 1,169 29 73 1 4,400,000
Ohio 64 170 1,693 43 106 1 6,376,500
Wisconsin 12 33 329 8 21 0 1,2400,00

Table 15. Passenger (AMTRAK) rail, SCC 2285002008 for 2005.
State HC CO NOx PM SO2 NH3 Gallons
Illinois 61 166 1,254 41 104 1 6,246,131
Indiana 10 26 196 6 16 0 978,333 Michigan 19 52 395 13 33 0 1,965,709
Ohio 5 13 100 3 8 0 496,621
Wisconsin 11 29 220 7 18 0 1,096,623

Table 16. Commuter (METRA) rail, SCC 2285002009 for 2005.
State HC CO NOx PM SO2 NH3 Gallons
Illinois 232 630 4,758 156 396 3 23,696,908
Indiana 0 0 0 0 0 0 0 Michigan 0 0 0 0 0 0 0
Ohio 0 0 0 0 0 0 0
Wisconsin 2 4 33 1 3 0 162,452February 2007

G:\LADCO 2005 EI\Locomotive\LADCO 2005 Locomotive Emissions.021406.doc 

### 11 REFERENCES

AAR. 2006. “Analysis of Class I Railroads, 2005,” a nd RR Industry Info: Railroad and States, http://www.aar.org/pubstores/ displayitem.aspx?id=13

, http://www.aar.org/AboutTheI ndustry/StateInformation.asp , Association of American Railroads, 2006.

ASLRRA. 2007. Phone conversation with Step hen M. Sullivan, Vice President & Executive Director ASLRRA, January.

ASLRRA. 1999. “1999 Annual Data Profile of th e American Short Line & Regional Railroad Industry.” Developed by the American Short Line & Regional Rail road Association and the Upper Great Plains Transportation In stitute North Dakota State University. (Available online at: http://www.shor tlinedata.com/ )

Benson, Doug. 2004. Personal communication, Fe bruary 19, 2004. See also ASLRRA 1999.

BNSF. 2006. Personal communicati on with Lyle Staley, December 21.

Canadian National. 2007. Personal communi cation with Erika Akkerman, January 8.

Canadian Pacific. 2006. Personal communica tion with Ken Roberge, December 11 and 12.

CSX. 2007. Personal communicati on with Rick Nath, January 15.

EPA. 2004a. Personal communicati on with Charles Moulis, March 4.

EPA. 2004b. Personal communicati on with Craig Harvey, March 10.

EPA. 2004c. Personal communicati on with Lester Wyborny, March 11.

EPA. 2001. Procedures Document For Nationa l Emission Inventory, Criteria Air Pollutants 1985-1999.” EPA-454/R-01-006, March.

EPA. 1997. “Locomotive Emission Standards.” Regulatory Support Document, United States Environmental Protection Agency, Office of Mobile Sources, April. And EPA 1997, Emission Factors for Locomotives,” Envi ronmental Protection Agency, EPA420-F-97- 051, December.

METRA. 2007. Personal communication with METRA staff, Mary McDonnell, 312-322-6939, January 2. http://metrarail.com/schedule.html

Norfolk Southern. 2006. Personal communi cation from D.M. Johnson, December 18.

Norfolk Southern. 2004. Personal comm unication from Gibson Barbee, March 8.

Union Pacific. 2007. Personal communication from Jon Germer. January 31.