Getting Real about Metrolink Tier 4 Engine Emissions
/Since I first started paying attention to air quality in Elysian Valley, I’ve been endlessly frustrated by Metrolink’s idling engines at the Central Maintenance Facility on San Fernando Road. In response to community activists efforts in 2012, Metrolink promised a number of improvements to protect public health, improvements that our community worked hard to help fund. Included in this are electric power hookups that should have reigned in avoidable emissions. At the February 20, 2020 Metrolink community meeting, Metrolink’s own internal audit showed what the community had known just from observation: the electric plug-ins were not being used. So, in the face of a climate crisis, this agency burns through fossil fuel instead of connecting to electric ground power whenever possible. Another promised improvement was a new, cleaner train. Five years late due to a host of production problems, Metrolink’s Tier 4 has been assessed at “up to 85% cleaner”. At community meetings and AQMD railyard emissions meetings, I asked a simple question that no one ever answered: WHEN is it 85% cleaner? I was shocked to learn that emissions data from commuter trains such these are not captured in real time, so no one could tell us how it behaved during idle. Turns out, we were right to wonder. A recent letter from the Train Riders Association of California talks about this very issue!
Given how often we encounter idling engines, we wrote to the AQMD and California Air Resources Board to please hold off buying any more of these trains until we know just how they perform during the many hours of idling we observe at Metrolink facilities. It’s a bit technical, and incredibly important, so get your coffee, get comfortable, and read on…
A Metrolink engine waiting to enter the CMF for servicing, idles next to Albion Park while children play.
April 21, 2021
Dr. William Burke, Chair
South Coast AQMD
Re: Metrolink Tier 4s Real World Emissions at All Idle Settings Must Be Addressed
Dear Dr. Burke,
In Elysian Valley and Cypress Park, many people live in close proximity to the Metrolink Central Maintenance Facility (CMF). In these fast-growing neighborhoods, a large number of people are subjected to diesel exhaust from over 25 locomotives being serviced 16 hours a day on weekdays as well as weekend servicing. A mere 400 feet or fewer from homes and the LA River greenway shared path, locomotives are observed idling for many hours, including hours before and after each is serviced (refueling, cleaning of cabins, engine checks, staging etc.).
Our communities’ environmental health concerns led to the formation of the Metrolink Community Workgroup in 2012, under the guidance of Congressman Adam Schiff. At meetings with Metrolink CEOs, their staff, and many of our elected officials, we've brought much-needed attention to the dire public health impacts of this situation, namely that these low-income communities are being poisoned by the CMF. Community pressure on this issue is so strong that we held standing-room-only meetings with 250 people in attendance.
In 2012 Metrolink responded by presenting a solution: replace the older legacy locomotives with cleaner-burning Tier 4 locomotives. However, funding for new locomotives needed to be found. Community leaders, many local nonprofit organizations, and local elected representatives wrote over 30 endorsement letters in support of the SCAQMD receiving Carl Moyer funding so that Metrolink could begin purchasing Tier 4 locomotives. They were proclaimed to be 85% cleaner in both Particulate Matter (PM) and Nitrogen Oxides (N0x): https://metrolinktrains.com/globalassets/about/tier-4-factsheet.pdf
With the support of many community leaders who offered their endorsements, Metrolink was able to procure funding for these new locomotives. Then, our efforts as a community were in a holding pattern as we awaited the Tier 4s, believing that these trains would right decades of environmental wrongs and lessen public health damages inflicted on our neighborhoods. To our dismay, these Tier 4 trains - the first of their kind to be built - ended up being five years late due to numerous manufacturing problems. The costs exceeded $280,000,000. But finally, by early 2021, nearly all 40 Tier 4 engines were in operation.
However, it now appears that your agency should have been doing more to protect our community. It recently came to our attention through a letter posted by David Schonbrunn, President of Train Riders Association of California (TRAC), Let’s Have Accurate Locomotive Emissions, that Tier 4 locomotives have much higher N0x emissions at idle than we would expect in a low-emissions engine. It is not clear to us that these engines are performing as well as they should, given the promises made to the community and the price that was paid. Based on this new information, these new engines are a big disappointment. If remedial actions are not taken, the residents of Elysian Valley and Cypress Park will continue to be subjected to concerning N0x levels for years to come – emissions that shouldn't exist in a "clean" engine.
Our communities are not expendable. As recipients of harmful, unwanted emissions from the CMF, Los Angeles River Communities for Environmental Equity (LARCEE) in partnership with the Metrolink Community Working Group must insist that SCAQMD investigate and determine the real-world emissions of Metrolink's Tier 4 locomotives at all idle settings employed at the CMF. These measurements need to be made with the three following separate settings for hotel power: turned off; turned on at power levels typical for operations; turned on at power levels typical for maintenance at the CMF. The emissions generated in the production of hotel power must be included in the emissions for each engine notch setting when calculating total emissions through the application of the duty cycle.
There is also the issue of upholding idling regulations. The TRAC letter referenced above addresses locomotives idling all night in San Francisco. Members of our community have observed individual Metrolink locomotives continuously idling up to six hours. At outlying stations, engines have been observed idling continuously overnight and during long mid-day layovers. We see locomotives that are often left unattended, and that don’t automatically shut down after 30 minutes. Why is that able to happen, when federal rules call for an automatic shut-off? This appears to be a violation of both federal and state anti-idling regulations. Please see rule 40 CFR Part 1033.115 (g). Link for your convenience: https://www.ecfr.gov/cgi-bin/text-idx?SID=71e6b124de14cc8fc6be790b99d2d17e&mc=true&node=pt40.36.1033&rgn=div5#se40.36.1033_1115
Therefore, Los Angeles River Communities for Environmental Equity, in partnership with the Metrolink Community Working Group also insist that SCAQMD investigate the idling practices at the CMF and other Metrolink facilities, report its findings, and enforce current regulations. Additionally, SCAQMD should ensure that rail agencies are using the trackside power plug-in systems at all times at the CMF and outlying stations. Metrolink’s own internal audit admitted that these plug-ins were not being used.
Furthermore, LARCEE and the Metrolink Community Working Group urge SCAQMD to collect the operations logs and onboard data from commuter and intercity passenger rail agencies needed to compute a real-world duty cycle specific to this segment of the national locomotive fleet, so that it may then employ this duty cycle in emissions inventories and emissions reductions incentive programs.
To make sure the emissions reductions incentive programs are working properly, we seek an analysis of the difference between the emissions expected from current locomotive incentive programs and the real-world emissions determined as a result of these requests. Please note that this issue has been one of great concern since these engines were first approved; questions about how the Tier 4s were evaluated and the lack of real-time measurements of idling emissions, were raised during community comment at CARB & SCAQMD Railyard emissions working group meetings at SCAQMD headquarters in 2017.
While these reviews are pending, we assert the following:
SCAQMD and CARB have an ethical responsibility to halt the purchase of more Tier 4 locomotives.
No approval should be provided Metrolink by any funding, governmental or environmental agency until the investigation and research of pollution caused by the Tier 4's is complete, published, and the improper testing is rectified.
We also respectfully suggest that your agencies put out a request for proposals to cost-effectively retrofit the Tier 4 locomotive fleet to reduce emissions at idle.