The Atlanta Eight-Hour Ozone Attainment Demonstration 

Appendix T 

Voluntary Reduction of Emissions 

from Railyards in 

Metro Atlanta Region
Voluntary Reduction of Emissions from Railyards in the Metro Atlanta Region 

Introduction: The Georgia EPD has spent a significant amount of time analyzing the 

source and impact of emissions of ozone and fine particulate matter precursors from 

railyards in the metro Atlanta area. Table 1 lists railyards located in the metro Atlanta 

area as of April 22, 2005. While the use of railroads for shipping has a lower overall 

impact on air quality when compared with moving equivalent tons of cargo by trucks, 

railroad-related emissions of NOx are an important contributor to ozone concentrations in 

many of Georgia’s nonattainment counties. Cost-effective options are available to 

significantly reduce NOx from locomotive engines, however federal regulations do not 

currently require nor allow states to require their use. In addition, recently proposed 

federal regulations for these engines would not significantly reduce their emissions to the 

level possible for many years. 

Table 1 Metro Atlanta Railyards 

County Operator Railyard Name 

Cobb Georgia Northeastern 

Railroad 

CSX Railroad 

Norfolk Southern Railroad 

GNRR Yard 

Bolton Yard 

Whitaker Yard 

Fulton CSX Railroad 

CSX Railroad 

CSX Railroad 

CSX Railroad 

CSX Railroad 

Norfolk Southern Railroad 

Norfolk Southern Railroad 

Norfolk Southern Railroad 

Norfolk Southern Railroad 

Howells Yard 

Tilford Yard 

Hulsey Yard 

Fairburn Yard 

Bellwood Yard 

Inman Yard 

Armour Yard 

South Yard 

Industry Yard 

Clayton Norfolk Southern Railroad Forest Park Yard 

DeKalb CSX Railroad Portion of Hulsey Yard 

While estimates of emissions from locomotives have a high level of uncertainty, the 

likely levels of NOx emissions from locomotives in the Georgia nonattainment counties is 

significant. For example, while stationary facilities emitting 25 or more tons of NOx per 

year in the ozone nonattainment counties are regulated under the Title V requirements of 

the Clean Air Act, eleven of the twenty-three nonattainment counties in 2002 had 
estimates of greater than 50 tons of NOx per county emitted from yard locomotives1

alone. One county (Fulton) had emissions greater than 380 tons of NOx per year from 

yard locomotives alone. Statewide, line-haul locomotives were estimated to emit 23,671 

tons of NOx per year and railyard locomotives were estimated to emit 3,062 tons, levels 

comparable with emissions from 32 million Tier 2 automobiles2

. 

The Georgia EPD has undertaken a number of activities to better understand and reduce 

railroad-related emissions, including submitting three proposals for funding assistance 

from the Georgia Department of Transportation under the Congestion Mitigation for Air 

Quality improvement program (CMAQ) to retrofit railyard locomotives with much lower 

emitting engines and to analyze emissions contributions to very high monitored ambient 

ozone and PM2.5 concentrations near large, active railyards, and working with a group of 

23 states to prepare better railroad-related emissions inventories. To initiate these 

activities, a Technical Working Group Meeting titled “Air Quality and Railroads in 

Georgia” was held in Atlanta by the Georgia EPD on March 21, 2007. The meeting 

brought together Georgia Class I and Shortline Railroad representatives with members of 

the EPD and other Georgia agencies to discuss issues related to air quality and emissions 

from railroad-related activities. The meeting was well attended and participants have 

continued to be cooperative and interested in our air quality management efforts. 

In particular, representatives from Georgia’s two Class I railroads (Norfolk-Southern and 

CSXT) have subsequently shared some engine and operations data and have discussed 

the possibility of collaborative emissions reduction projects. Representatives from the 

two Shortlines operating in nonattainment counties, the Chattooga & Chickamauga 

Railway and the Georgia Northeastern Railroad, attended the meeting have completed a 

questionnaire designed to collect engine and operations data needed for estimating 

emissions and have provided feedback on the design of the questionnaire. Shortline 

railroads, which account for approximately 27% of track route mileage in Georgia, are 

not required to submit equipment or operations data and their emissions are therefore not 

currently included in the emissions inventories. More details of this meeting and a 

general plan related to improvement of the railroad-related emissions inventory and air 

quality modeling analysis can be found on a website at http://www.georgiaair.org/, under 

“Hot Topics”, “Railroad-Related Activities”. 

The EPD has been awarded funding based on three submitted railroad-related proposals 

submitted to the Georgia Department of Transportation 2007 CMAQ solicitation. All 

three of the projects proposed to retrofit switchyard locomotives (a.k.a. switchers), which 

generally utilize one powerful, old, high-emitting engine, with a set of 2 or 3 currentmodel nonroad diesel engines (e.g., those used in new construction and farm equipment) 

per locomotive. Most switcher locomotives are believed to operate 24 hours per day 365 

 

1

 Locomotives are divided into three categories, (1) yard locomotives (“switchers”) which are used to 

assemble and disassemble trains in railyards, (2) line-haul locomotives which are used to pull freight over 

long, generally intercity or interstate distances, and (3) road locomotives which are used both as switchers 

and for local hauling generally by Class III (‘Shortline’) railroads. These categories of locomotives have 

different engine types, operation patterns, and normal speed ranges. 

2

 Calculations based on the Tier 2 NOx emissions standard (0.07gNOx/mile) for highway vehicles and 

assuming 12,000 vehicle miles traveled per year. 
days per year, mostly within a designated railyard. This newly available ‘Genset’ 

technology guarantees significant emission reductions. Each project proposal submitted 

covered a different nonattainment metropolitan statistical area containing at least one 

switchyard operation: Atlanta, Macon, and Rome. The Atlanta proposal also contained a 

study, which was fully funded, to characterize emission sources in and near two major 

railyards in Atlanta located near monitors recording some of the worst ozone and PM2.5 

levels in the city. 

Table 2 provides information on the amount of funding awarded through CMAQ per 

fiscal year for each of the projects (note that FY 2009 contains the funding for the 

emissions study, which does not require a match and will not be awarded to a private 

entity): 

Table 2. CMAQ Awarded Funding for Genset Retrofits and Ambient Monitoring 

and Analysis in Georgia Nonattainment Areas. 

Project Fiscal Year Federal 

Funding 

Minimum Match 

Required 

Total Project 

2009* $200,000 $0 $200,000 

2010 $12,000,000 $3,000,000 $15,000,000 

2011 $12,000,000 $3,000,000 $15,000,000 

EPD Railroad 

Project - Atlanta 

2012 $12,000,000 $3,000,000 $15,000,000 

2010 $1,800,000 $450,000 $2,250,000 

2011 $900,000 $225,000 $1,125,000 

2012 $900,000 $225,000 $1,125,000 

EPD Railroad 

Project – Macon 

2013 $900,000 $225,000 $1,125,000 

EPD Railroad 

Project – Rome 

2010 $900,000 $225,000 $1,125,000 

*The 2009 project is the ambient monitoring and analysis, all others are genset retrofits. 

These CMAQ funding awards will allow us to provide incentive and support for railroads 

to purchase and use this new engine technology in railyards located in the GA 

nonattainment areas. The railroads must also provide training, updated testing and 

maintenance procedures, and to assume other costs and risks which are not quantified in 

the cost of retrofitting the switcher locomotives. These Gensets would not be built or 

designated to these areas without this significant financial incentive. 

After receiving internal administrative clearance to provide funding to private entities, the 

EPD plans to release a request for proposals (RFP) specifying project selection criteria 

and weighting. Any railroad operating in each nonattainment area will be eligible to 

participate and will be able to propose various retrofit options. For Atlanta, the EPD will 

select proposals for funding based on criteria including, but not limited to, their total 

emissions reduction potential and its subsequent impact on ambient pollutant 

concentrations, retrofit cost, available match, previous technology and conversion 

performance, and cooperation with data collection and emissions reporting efforts. The 

selected railroads will be responsible for conducting or subcontracting the locomotive 
retrofits. The EPD will participate in negotiations to optimize air quality benefits with 

any combination of the two Class I and/or the Shortline Railroads operating in the 

nonattainment areas specified. . 

If a voluntary program is pursued in addition to the Genset locomotive retrofits, the 

Georgia EPD will advise the railroads on which potential actions would be most effective 

in improving air quality. There are a few potential emission reduction options, which are 

described below. The most likely for implementation include ensuring the use of the 

lower emitting locomotives in sensitive areas, accelerating the use of low-sulfur diesel 

fuel, and implementing anti-idling technologies or procedures. 

Additional Emissions Reduction Options 

3⁄4 Ensuring the use of the lower emitting locomotives in sensitive airsheds.

A potentially effective emissions reduction strategy is ensuring the use of the lower 

emitting locomotives in sensitive airsheds. A program based on this principle was 

implemented in the South Coast Air Basin (SCAB) of California through a 1998 

Memorandum of Understanding between CARB, the two California Class I railroads 

operating in the SCAB (Burlington Northern and Santa Fe Railway Company and Union 

Pacific Railroad Company) and the U.S. EPA. The MOU includes provisions for early 

introduction of clean units, with requirements for a fleet average in the SCAB equivalent 

to U.S. EPA's Tier 2 locomotive standard by 2010. 

A reduction in fleet-average locomotive emissions can be achieved by either assigning 

lower-emitting engines to use in and around the nonattainment counties, upgrading the 

Tier-level certification during re-manufacturing, a process undergone approximately 

every 5 years of the 40+ average years of service provided by a locomotive, or 

purchasing as clean-running engines as possible when expanding the fleet or replacing 

locomotives. 

A promising new locomotive design has recently become available which utilizes 

multiple (generally 2 or 3) diesel engines such as EPA Tier III off-road certified engines. 

This allows the locomotive, called a ‘genset’, to run on only one engine when additional 

power is not needed, resulting in both lower emissions and lower fuel consumption. 

According to the EPA, much of the operating time of locomotives, particularly switchers, 

is spent in the range that would only require the use of one of the engines. Additionally, 

‘stop-start’ functionality is built in to reduce unnecessary idling. Comparative emission 

factors between traditional and genset locomotives are specified in Table 3. 

Table 3. Engine Emission Factors 

Gaseous and Particulate Emissions (g/bhp-hr) 

Switch Line Haul 

HC CO NOx PM HC CO NOx PM 

Tier 0 2.1 8 14 0.72 1 5 9.5 0.6 
Tier 1 1.2 2.5 11 0.54 0.55 2.2 7.4 0.45 

Tier 2 0.6 2.4 8.1 0.24 0.3 1.5 5.5 0.2 

Genset 

(NREC) 0.04 1.51 3.37 0.05 0.02 0.93 2.88 0.02 

National Railway Equipment Co. http://www.northeastdiesel.org/pdf/low-emissions-switcher-012206.pdf

As can be seen, the use of a genset rather than the more common Tier 1 switcher can 

result in a 70% reduction in NOx. As an ideal example of potential emissions reductions 

from the use of these locomotives, if genset switchers replaced all yard switchers in the 

five heavily populated ‘urban core’ counties of Atlanta3

 (assumed to be Tier 1), NOx

would be reduced by 0.83 TPD from 2.72 TPD (based on 2002 EPD inventory data). A 

number of states, including California, Texas, and New York, have provided funding to 

assist Class I railroads in the purchase of switcher gensets, each of which costs 

approximately $1.5M. Assuming 23.54 tons NOx/year per yard locomotive (based on 

EPA national average estimates for 2002), there would have been 42.2 yard locomotives 

operating in the urban core counties. The cost of replacing this number of yard 

locomotives with genset switchers is $50.6M. 

As a result of the Workshop described above, one of Georgia’s Class 1 railroads, 

Norfolk-Southern, has indicated their intention to locate at least one new genset in their 

largest railyard in Fulton county (Inman Yard). They recently purchased other gensets, 

and if we receive funding assistance, we hope to negotiate the placement of other gensets 

at Inman or another rail yard(s), with the possibility of also accelerating the use of lowsulfur diesel fuel, as described below. In addition, or alternatively, funds may be used to 

assist a Shortline(s) with Tier level upgrades or the purchase of a genset if an improved 

emissions inventory combined with air quality modeling sensitivity analysis indicates that 

this approach would reduce peak ozone more effectively. 

3⁄4 Accelerating the use of low-sulfur diesel fuel.

Currently, most diesel fuel in the state of Georgia contains 15 ppm of sulfur (ppmS), 

while locomotives and marine engines are allowed to use diesel with 500 and greater 

ppmS. The use of 15 ppmS by locomotives will be phased in between 2012 to 2014. 

According to a study by the Southwest Research Institute for the CA Air Resources 

Board (CARB), the use of a CARB specified fuel with 50 ppmS rather than 320 ppmS 

EPA diesel fuel reduced NOx emissions from line-haul locomotives by approximately 

3.5%. 

Using the results of this study, a conservative estimate4 of potential emission reductions 

from accelerating the use of lower sulfur fuel by railroads in the five urban core counties 

 

3

 Clayton, Cobb, DeKalb, Fulton, and Gwinnett. 

4

 Using 330 to 50 ppmS rather than 500+ to 15 ppmS sulfur reduction and using the 2002 emissions 

inventory estimates of locomotive emissions in Georgia (excludes Shortline activity). Additionally, ARB 

staff believes that, for a number of reasons, these tests underestimate emissions benefits gained from the 

use of the CARB fuel. 
is 0.34 TPD NOx. The use of this fuel throughout Georgia (excluding Shortlines) would 

result in a reduction of 2.57 TPD NOx (based on 2002 emissions data). 

CARB estimates that the use of CARB diesel fuel over on-highway EPA diesel fuel 

would result in a net cost increase of 3 cents per gallon. Considering an estimate of 

123,026,000 gallons of diesel fuel used by the railroad industry in Georgia in 2005 (by 

the Dept. of Energy5), the increased cost for the amount of diesel fuel used in Georgia in 

2005 would have been $3.7M, or approximately $487k for only in the urban core 

counties. 

3⁄4 Reducing engine idling time.

The use of idle-reduction technology (eg. Automatic Engine Stop-Start (AESS), 

Auxiliary Power Units (APUs.) with controls, etc.) is becoming increasingly common 

due to its significant reduction in fuel requirements. Switchers are estimated to idle 60% 

of the time, and line-haul locomotives 40% of the time6

. Accounting for general levels of 

emissions under idling conditions, NOx is estimated to be reducible by 3-5% for linehauls, and 16-20% for switchers7

. This would result in a 0.49 TPD reduction in NOx

from switchers in the urban core, and a 0.28 TPD reduction from line-haul locomotives in 

the urban core (assuming average idle time even when operating in the urban core and in 

and around rail yards). 

The EPD will assist railroad in identifying where idle-reduction technology could be best 

implemented, and possibly assisting in its purchase and installation (which is estimated to 

cost approximately $30-35k per engine.) An alternative approach to reducing idle-related 

emissions is to encourage more stringent shutdown procedures. Technology selection or 

operation guidelines would be established in cooperation with the participating railroad to 

ensure optimal emissions control and compatibility with equipment and general operating 

needs. 

Other potential projects/activities include: 

 

1. Performing a comprehensive analysis of railroad-related emissions at yards, 

such as from loading/unloading equipment, testing/maintenance, and truck 

patterns at Intermodal facilities to identify possible measures to reduce 

emissions. 

2. Encouraging/accelerating the use in Georgia of techniques and equipment 

under testing and development by the railroads, such as LEADER (use of 

“Golden Run” guidance) and the optimization of wheel-rail interfaces. 

 

5 http://tonto.eia.doe.gov/dnav/pet/pet_cons_821dst_dcu_nus_a.htm

6

 Locomotive Emission Standards, Regulatory Support Document. United States Environmental Protection 

Agency, Office of Mobile Sources, April 1998. 

7

 Locomotive Idling Reduction, Presented to National Idling Reduction Planning Conference, Albany, NY, 

May 17-19, 2004by D. E. Brann, Emissions Compliance, Electro-Motive Division, General Motors 

Corporation. http://www1.eere.energy.gov/vehiclesandfuels/pdfs/idling_2004/brann.pdf
3. Exploring options for expanding the use of railroads for moving freight, which 

would reduce the per ton emissions compared with the use of trucks. 

4. Exploring options for moving some railroad operations outside of highly 

populated areas that are out of attainment with the NAAQS. 

This wide range of emission reduction options for locomotives, the high levels of 

railroad-related emissions, and the currently cooperative stance of the Georgia Railroads 

offers a unique opportunity to produce significant emission reductions and subsequent air 

quality benefits in the nonattainment counties of Atlanta. An additional initiative in the 

GA EPD rail program is a eastern US (or possibly nationwide) collaboration to increase 

our understanding of rail-related emissions. 

Improved Understanding of Railroad-Related Emissions 

The GA EPD is co-leading the Eastern Regional Technical Advisory Committee 

(ERTAC) Rail Subcommittee, which is made up of representatives from state and 

regional air quality protection agencies that convened to improve our understanding and 

estimates of railroad-related atmospheric emissions. A regional or national approach to 

building a railroad emissions inventory, rather than a state-by-state approach, will benefit 

both the railroad community and the respective air agencies by requiring less effort and 

resources than if acting independently. In addition, a collaboration between the air and 

railroad organizations is being pursued because cooperation will produce much more 

meaningful results due to an understanding of the uses of the emissions inventories by the 

agencies and of operations and data availability from the railroads. The ERTAC Rail 

Subcommittee, the Association of American Railroads, and representatives from all eight 

Class I railroads that operate in the US have begun communicating about the approaches 

and data needs to support this effort. The following information was provided to the 

railroad community as an overview of the Subcommittee and its objectives before our 

first web-based meeting: 

The Eastern Regional Technical Advisory Committee (ERTAC)

State air pollution control agencies must estimate emissions from sources to develop a 

state-wide air pollutant emissions inventory that is used for planning purposes. ERTAC 

was convened by a group of state agencies to identify and address significant gaps in our 

representation of air pollutant emissions. We believe that collaboration will greatly 

improve our chances of addressing what we consider to be critical requirements for 

effective air quality planning. You can learn more about ERTAC at www.ertac.us . 

The ERTAC Rail Subcommittee

Railroad-related sources were identified as a very high-priority early in ERTAC’s 

planning activities due to the extent and level of emissions throughout the US, the high 

level of uncertainty associated with their representation in current emission inventories, 

and their rapid projected growth due to increased shipping demand, better fuel-efficiency, 

and generally lower emissions compared with alternative modes of transporting freight. 

The ERTAC Rail Subcommittee was formed to improve emissions estimates from this 
sector. The subcommittee is comprised of active representatives from air quality 

protection agencies in 13 different states, as well as three regional air quality 

management groups representing additional states as shown in Table 1. 

The Importance of Rail Emissions 

Railroad activity releases a variety of emissions and occurs throughout the United States, 

often concentrated in densely populated, polluted urban areas. In particular, emissions of 

NOx and primary PM2.5 from diesel combustion contribute to ambient concentrations of 

ozone and PM2.5, pollutants for which many states have counties out of attainment of the 

National Ambient Air Quality Standards. Ozone and some components of PM2.5 are 

‘secondary’ pollutants, meaning they are formed in the atmosphere rather than directly 

emitted, making them difficult to manage. Some control strategies can be inefficient or 

even counter productive if pursued in areas with a poorly characterized chemical 

composition (i.e. a poor understanding the mix of compounds in the ambient air). Maps 

of the ozone and PM2.5 nonattainment areas in the United States are attached (Figure 1) 

and clearly illustrate why these pollutants are of interest to air quality management 

agencies. 

Current Status of Rail-related Emissions Inventories

Historically, each state has either requested voluntary data submissions individually or 

has estimated emissions using surrogates for the calculation of emissions from railroad 

activities. When additional effort is undertaken, these estimates are often found to be 

inaccurate. For example, a recent study of locomotive activity in the state of New York 

found, for the year 2002, NOx emissions to be underestimated from Class I line-haul 

locomotives by 70%, by 11522% from Class II and III locomotives, and by 4671% from 

line-haul commuter rail. Yard locomotive (switcher) NOx emissions were overestimated 

by 97%. This study estimated a total of 25,000 tons/year of NOx to be emitted by these 

railroad sources in New York State, a significant contribution to the airshed. This level 

of error can impact the effectiveness of controls applied by other sources in the airshed, 

the efficiency of selected control strategies, and can obscure valuable opportunities for 

reducing emissions. 

Previous efforts by individual states to improve their characterization of railroad 

emissions have often proven to be costly and ineffective. There are no consolidated, 

reliable sources of information regarding the location and activity of these sources. We 

hope that by unifying our efforts we can both build a more accurate, comprehensive 

inventory while reducing the burden on railroads of responding to individual state data 

requests, which often are developed with differing approaches and formats (see Appendix 

A for example questionnaires). 

 

Objectives and Approach

Our primary goal is to build a link-level, consolidated emissions inventory of railroad 

related sources for the year 2008, focusing on Class I, II, and III line-haul emissions, 

railyard locomotive and possibly other uncharacterized yard source emissions, and 

commuter and passenger locomotive emissions. We plan to spatially and temporally 

allocate these emissions as accurately as possible. Our current efforts are largely aimed 
at evaluating potential calculation methodologies based on the best available data we can 

obtain for the 2008 inventory; however, we also hope to develop a future methodology in 

cooperation with the railroad community so that future inventories will require less effort 

and will be more accurate. We intend to inform stakeholders of our activities at all stages 

of development, clearly record our efforts and techniques, and to invite collaboration so 

that we prepare an efficient mode of data collection that will not compromise 

confidentiality requirements or impose significant administrative burdens. We feel that 

this activity is critical to our respective agencies’ responsibility of protecting and 

improving air quality and hope that you will support us in these efforts. 

The following sections of the report described our current understanding/plans for 

emissions inventory calculations and potential sources of data related to the Class I 

railroad community.