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Cleaner Air for America

THE CASE FOR A NATIONAL PROGRAM TO CUTPOLLUTION FROM TODAY’S DIESEL ENGINES

Cleaner Air for AmericaTHE CASE FOR A NATIONAL PROGRAM TO CUTPOLLUTION FROM TODAY’S DIESEL ENGINES

AUTHORSYewlin Chee

Cindy Copeland

Mark MacLeod

Jana Milford

Vickie Patton

Janea Scott

Nancy Spencer

Cover images: Left: Trucks “plugged in” to the IdleAire system (Photo courtesyof IdleAire). Center: Children’s baseball team (Doug Menuez/Photodisc Green).Right: Construction equipment retrofit with a diesel particulate filter (Photo cour-tesy of Johnson Matthey).

Our missionEnvironmental Defense is dedicated to protecting the environmental rights of allpeople, including the right to clean air, clean water, healthy food and flourishingecosystems. Guided by science, we work to create practical solutions that win last-ing political, economic and social support because they are nonpartisan, cost-effective and fair.

©2005 Environmental Defense

The complete report is available online at www.environmentaldefense.org.

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Acknowledgments iv

Executive summary v

Introduction 1

CHAPTER 1Principles for a national retrofit program 3

CHAPTER 2The dangers of diesel pollution 8

CHAPTER 3The pollution reduction gap 12

CHAPTER 4Cleaning up existing engines is a cost-effective way to protect 14Americans from the health risks of diesel exhaust

CHAPTER 5Diesel cleanup programs that 20are working now

Conclusion 33

APPENDIX AThe national pollution burden from diesel engines 34

APPENDIX BMethodology used to estimate the benefits and costs of pollution 38reduction scenarios for existing diesel engines

Notes 42

Contents

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The authors of this report are: YewlinChee, Cindy Copeland, Mark MacLeod,Jana Milford, Vickie Patton, Janea Scott,and Nancy Spencer. We would like tothank Dr. John Balbus for his consulta-tion on the health effects section of thereport. We would also like to thanktechnical consultant Sandra Goodman,from E3 Ventures, for her detailedanalysis of the costs and benefits ofretrofitting various diesel fleets. Wevery much appreciate the help ofStephanie Tatham for completing

Acknowledgments

quickly and successfully numerous tasksinvolved in writing and producing thereport. And last, but certainly not least,we extend our sincere appreciation to themany people who lent their knowledge,ideas, wisdom and insight to reviewingseveral iterations of this report.

Environmental Defense does notendorse any particular air pollutioncontrol technology or method. Thisreport factually describes air pollutioncontrol technologies and methods basedon published reports.

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The U.S. Environmental ProtectionAgency (EPA) estimates that by 2030, itsrevolutionary programs to reduce air pol-lution from new diesel buses and freighttrucks and new nonroad diesel equipmentwill slash diesel emissions by more than80% from 2000 levels. Collectively, thesefederal standards are projected to preventmore than 20,000 premature deaths,15,900 hospital admissions, and overhalf a million asthma attacks each year.

But because these federal standardsapply only to new diesel engines andbecause diesel engines are so durable,the high levels of pollution from exist-ing diesel sources will persist through-out the long lives of the engines inservice today. The practical effect ofthis lengthy transition to cleaner dieselengines is that the children sufferingthe effects of diesel exhaust today will beraising their own children before thenew federal emission standards delivertheir full health benefits in 2030.

Executive summary

A national program to cut pollutionfrom today’s diesel engines would speedthe transition to cleaner diesel enginesand achieve healthier air for today’s chil-dren. To assess the health benefits andcosts of a comprehensive diesel emissionreduction program for existing engines,as well as to evaluate potential fundinglevels, Environmental Defense examinedtwo scenarios in which different emissioncontrol measures were applied to dieselconstruction equipment, school busesand transit buses in the core countiesof the 50 largest metropolitan areasin the U.S. These 88 counties, alongwith the District of Columbia, contain94.6 million people, or one-third ofthe U.S. population.

We examined construction equipmentbecause these engines have high pollu-tion levels and typically operate for longhours. We included diesel school busesand transit buses because they exposesensitive populations to diesel pollution.

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$600 million–$1.6 billion

$10.6 billion–$19.2 billion

FIGURE 1Investments in a national diesel control program yield healthy returnsAn investment in diesel engine retrofits ranging from $600 million to $1.6 billion yieldsa multi-year stream of health benefits with a net present value ranging from $10.6 to$19.2 billion.

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Our two scenarios assumed installationof two widely available emission controlmeasures on construction equipment andbuses within the studied counties: dieselparticulate filters and diesel oxidationcatalysts. Diesel particulate filters canreduce particulate pollution by 80% to95% per engine, but can only be appliedto a limited set of engines. Diesel oxida-tion catalysts reduce particulate pollutionby 20% to 35% per engine, but are sig-nificantly lower in price and can beapplied broadly across fleets. Thus, thesetwo scenarios illustrate the range ofcosts to achieve steep reductions from alimited set of engines and more modestreductions over many more engines. Thescenarios are illustrative. The appropri-ate mix of pollution reduction strategieswill vary widely across communities.

Using EPA’s valuation methodologies,we found that investment in a nationaldiesel pollution control program willyield healthy returns. Figure 1 shows thelump sum costs of applying the two tech-nology scenarios to school buses, transitbuses and construction equipment inthe 50 most populated cities rangedfrom $600 million to $1.6 billion.The net present value of the resultinghealth benefits far exceeded these costs,

and ranged from $10.6 billion to $19.2billion (see Figure 1).

Our analysis provides a benchmarkfor the level of funding necessary tomake a real impact in reducing danger-ous emissions from the existing dieselfleet. Over the course of seven years, theemission controls examined in our studywould range in cost from approximately$83 million annually to $296 millionannually (see Figure 2). EnvironmentalDefense recommends federal funding for anational program of $296 million annu-ally for seven years. Federal funding inthe higher part of the cost range wouldincrease the ability of a national pro-gram to address types of diesel enginesand control technologies excluded fromour analysis such as locomotive andmarine engines and idle reduction strate-gies. Importantly, it would also provideresources to better accommodate con-trols for additional pollutants, to supportadditional communities, large and small,across America that are committed towell-run clean diesel programs, and toaddress the administrative costs inherentin a program of this scope. The nation’s50 most populated areas, which wereexamined in our pollution reductionscenarios, are listed in Table 1.

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$83 million–$296 million$129 million–$287 million

FIGURE 2Diesel pollution reduction scenarios: range of annual costs wheninvestments spread over seven years

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Diesel exhaust is one of the mostdangerous forms of air pollutionDiesel exhaust is as ubiquitous as dieselequipment, which is used throughout oureconomy, in transportation, construction,agriculture and industry, on our highwaysand streets, in our waters and on our rails.The need for a major national programto reduce diesel pollution is based on theextraordinary level of harm diesel exhaustcauses to the people who breathe it. Dieselexhaust and many of its components areconsidered probable human carcinogens.EPA national air toxics data shows thatup to 80% of the total cancer risk Amer-icans face from air pollution can beattributed to diesel exhaust.

Diesel exhaust is made up primarilyof microscopic particles that lodge deepin our lungs and deliver toxic pollutantsto our bloodstreams along with a varietyof hazardous gases like sulfur dioxideand oxides of nitrogen. It is associatedwith a wide range of health effectsbeyond cancer, including neurologicaleffects, a weakened immune system,respiratory disease and cardiovasculardisease. Diesel exhaust contributes toall the adverse health effects associatedwith particulate pollution, and also tothe formation of ground-level ozone,which is a powerful respiratory irritantassociated with asthma attacks, hospital-izations and premature death.

26. Milwaukee27. Orlando28. Indianapolis29. San Antonio30. Norfolk-Virginia Beach-Newport News31. Las Vegas32. Columbus, OH33. Charlotte, NC34. New Orleans35. Salt Lake City36. Greensboro, NC37. Austin38. Nashville39. Providence-Fall River40. Raleigh-Durham-Chapel Hill41. Hartford42. Buffalo, NY43. Memphis44. Jacksonville, FL45. Rochester, NY46. Grand Rapids, MI47. Oklahoma City48. Louisville, KY49. Richmond, VA50. Greenville-Spartanburg, SC

1. New York City2. Los Angeles3. Chicago4. Washington-Baltimore5. San Francisco-Oakland6. Philadelphia7. Boston8. Detroit9. Dallas-Fort Worth10. Houston11. Atlanta12. Miami, FL13. Seattle-Tacoma14. Phoenix15. Minneapolis-St. Paul16. Cleveland17. San Diego18. St. Louis19. Denver20. Tampa-St. Petersburg21. Pittsburgh22. Portland, OR 23. Cincinnati24. Sacramento25. Kansas City

Source: U.S. Census Bureau, 2000

TABLE 150 most populated metropolitan areas in the U.S., examined in dieselpollution reduction program scenarios

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The pollution reduction gapNow is the time for national action to cutpollution from today’s diesel engines. Theserious health effects of diesel pollution areexpressed by EPA’s projected benefits of itsemission standards for new diesel trucksand buses and nonroad equipment. Oncethose programs are fully phased in by2030, EPA estimates 20,000 prematuredeaths will be prevented each year. Thesame health effects that will be avoided in2030 are occurring now, and will continueuntil today’s high-polluting diesel equip-ment is replaced or cleaned up. Becausediesel engines are so durable, newer,cleaner engines will be slow to penetratethe market, and EPA projects that only50 percent of the ultimate annual level ofhealth benefits resulting from the newnonroad engine standards will be achievedby 2020. Figure 3 shows the full particulatepollution reductions under EPA’s emissionstandards for diesel trucks, buses andmachinery will not be realized until 2030.

Diesel cleanup programs areworking todayGrant, loan and incentive programsto reduce diesel pollution are already

being administered by local, stateand federal government agencies.On a limited scale, these programsare delivering the promise of lowerdiesel emissions and speeding thetransition to cleaner diesel fleets. Thegeographic and technological rangeof these programs demonstrates boththe nationwide scope of the dieselpollution problem and the opportunityfor an expanded federal effort todeliver cleaner, healthier air to com-munities across the country. Theseprograms are the proving groundsfor a more complete national program.Figure 4 summarizes some of thediesel pollution reduction programscommunities across the nation arecarrying out today.

A national diesel pollutionreduction program: Cleaner Airfor AmericaA well-funded, well-designed nationalprogram would accelerate the transitionto cleaner diesel technology and closethe gap between the clean diesel tech-nology of tomorrow and today’s highlevels of dangerous diesel pollution.

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FIGURE 3Particulate pollution under phase-in of federal standards for diesel trucks,buses, and machinery

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Environmental Defense strongly sup-ports creation of a new federal grant andloan program organized on the follow-ing principles:

1. A diesel pollution reduction programshould maximize health and environ-mental benefits. Projects competingfor federal grant and loan funds shouldbe ranked by the health and environ-mental benefits they will produce,with priority given to projects that offerthe greatest protection, especially thosethat target susceptible subpopulationsincluding children.

2. A diesel pollution reduction programshould promote cost-effective solutions.A competitive grant process should mini-mize costs by encouraging competitionamong cleaner diesel solutions.

3. Including all industry sectors servesmany populations. A national programshould serve the broad range of peopleexposed to diesel exhaust, includingschoolchildren and the people who livenear and work at railroads, ports, road-ways, farms, mines, construction sitesand industrial facilities where dieselequipment is used.

4. A program should advance a broadrange of solutions. Successful solutionswill include pollution control retrofits,replacement of old engines withnewer, cleaner models, operationalchanges such as idle-reduction, andalternative power sources such as truckstop electrification and shore powerfor marine vessels. All of these solutionsshould compete for federal funds onthe basis of their costs and the benefitsthey offer.

5. Incentives should be tailored to thespecific application. Some sectors willbe better suited for grant programs,while for others, loans will providesufficient incentive for fleet owners to

accelerate diesel emission reductions. Anational program should be flexible inresponding to these differences.

6. A federal grant and loan programshould reward state and local efforts.State and local support for emissionreduction measures can be rewardedthrough federal matching funds.

7. A federal program should capitalizeon and support community action.The burden of air pollution fallsheavily on local governments. Com-munities are banding together in public-private partnerships to reduce pollutionsuch as the Cleveland Air Toxics pilotproject. Projects associated with suchcollaborative local efforts should begiven priority in a federal grant andloan program.

8. Information on program performanceshould be accessible. EPA should estab-lish standardized metrics to report theprogress of grant and loan recipient pro-grams, and should make this informa-tion widely accessible.

A well-designed federal grant andloan program to reduce diesel pollutioncould help foster a variety of clean airprograms including: 1) local, state andfederal agency leadership in cleaning upgovernment diesel fleets through pro-curement policies, 2) federal recognitionof diesel pollution reduction programsin state air quality management plans,and 3) local collaborative efforts to lowerexposure to hazardous air pollutionthrough comprehensive community-based strategies.

The human health and economiccase to lower pollution from today’sdiesel engines is compelling. Withsustained federal support, the nationcan speed the transition to cleanerdiesel engines and achieve cleaner airfor America today.

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FIGURE 4Cleaner air for America success stories

Seattle and Juneau cruise ship docks. TheWest Coast Diesel Emissions Reduction Collaborativefacilitated Princess Cruise’s project to provide shore-based electric power to its cruise ship docks. Shorepower will eliminate 13 tons per year of smog-forming oxides of nitrogen (NOx) and 2 tons per year ofparticulate pollution emissions in Seattle.

Los Angeles: Alternative marine power eliminatesship pollution at berth. The new China Shippingterminal at the Port of Los Angeles will eliminate1 ton of NOx and particulate pollution each day it isin use.

Denver: Hybrid buses serve downtownpassengers. Hybrid electric and compressed naturalgas-fueled buses deliver passengers to a downtownpedestrian mall that links offices, shopping andregional transit.

Houston locomotive retrofit and repowerprojects: The Texas Emissions Reduction Project isfunding replacement of old switching engines withnewer, cleaner models, and repowering engines withhybrid technology. TERP expects to reduce locomotiveNOx emissions by 3300 tons.

Chicago Anti-Idling Study. A cooperative public-private demonstration project estimates that available5

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1 anti-idle technology would eliminate 12.5 tons of NOx

per year at an average-sized rail switching yard.

New York: Construction contracts requirecleaner diesel equipment. State law requires bestavailable retrofits and ultra low sulfur diesel (ULSD)fuel in all state-controlled construction projects inLower Manhattan, including at the World TradeCenter site. Local Law 77 makes ULSD and bestavailable emission control technology a requirementof all city contracts.

Hunts Point Truckstop electrification. Electrifiedtruck stop facilities are reducing idling emissions atthis massive meat and produce market located in aNew York City neighborhood where one-third of thechildren suffer from asthma.

I-85 Truckstops reduce diesel emissionsin Georgia, South Carolina and North Carolina.Electrified stations eliminate idling emissions and save263,000 gallons of diesel fuel per year at each of threetruck stops. Truckers turning off their engines willeliminate 35 tons per year of NOx and 1 ton per yearof PM emissions at each electrified truck stop.

Various locations: EPA’s Clean Schoolbus USAProgram is making the ride to school healthier forkids in 47 communities scattered across the country.

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Diesel exhaust is one of the mostdangerous and pervasive forms of airpollution. In 2004, the U.S. Environ-mental Protection Agency (EPA)finalized a program to dramaticallyreduce pollution from nonroad dieselengines used in construction, agri-culture, manufacturing and mining.This program complements the cleanair standards for nonroad diesel enginesand fuel adopted in 2001 for onroaddiesel engines used in trucks andbuses. EPA estimates that by 2030,the nonroad and onroad diesel programstogether will slash emissions from thesefleets by more than 80% from 2000levels and annually prevent more than20,000 premature deaths.

EPA’s actions to reduce diesel pol-lution are truly revolutionary. But theemission standards apply only to newengines, and diesel engines are so dur-able that they are typically used formany years, sometimes for decades.Therefore, the diesel revolution will takeyears to be fully realized, and its benefitswill be delayed as dirty old enginescontinue to run and pollute for yearsto come. EPA estimates that by 2020,only half of the annual pulic healthbenefits of the nonroad diesel rule willbe achieved. The children suffering theeffects of diesel exhaust today will beraising their own children before thenew emission standards deliver theirfull health benefits in 2030. To realizemore immediate health protectionsfor today’s children, it is essential tocut pollution from diesel engines thatare on the road today.

A program that will reduce dieselpollution today can relieve the burdenimposed on the millions of peopleexposed to the dangerous exhaust fromdiesel engines now in use. Policymakers

Introduction

can maximize the human health benefitsof clean air investments by acting swiftlyto close the divide between today’s high-polluting engines and the cleaner fleetsdue years from now.

The technical foundation for clean-ing up today’s diesel engines is at hand.Cleaner low sulfur diesel fuel is alreadyavailable in some large markets and willbe required for onroad vehicles in 2006.The broad availability of cleaner dieselfuel creates the opportunity to deploya range of cost-effective emission con-trols, such as diesel particulate filters,to reduce pollution from existing dieselengines. Similarly, strategies to controlengine idling are available to cut emis-sions from idling trucks, buses, loco-motives, and marine engines.

EPA’s diesel retrofit program, alongwith leading state programs like Cali-fornia’s Carl Moyer Program andTexas’ Emission Reduction Plan, haveshown that diesel retrofits are a feasibleand cost-effective means to reducepollution from existing engines. Thisincludes dangerous diesel particulatematter, nitrogen oxides that lead toozone pollution and the many toxicand carcinogenic chemicals found indiesel exhaust. Federal leadership toexpand these programs will deliverthe promise of EPA’s diesel emissionreduction programs to Americans with-out waiting decades for old engines towear out.

We review the serious healthand environmental threats causedby diesel exhaust, and the strikingamount of diesel pollution that willbe emitted between now and the fullrealization of the emission reductionsEPA’s new diesel standards aredesigned to achieve. We evaluate theinvestments necessary to achieve more

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immediate clean air benefits acrossAmerica, and the extraordinary divi-dends in human health protectionsthat will result. Finally, we highlightsome of the promising and successfulemission reduction programs alreadyin place across the spectrum of

existing diesel engines: constructionequipment, onroad heavy-dutytrucks, school and transit buses,commercial marine engines, andlocomotives. These programs arethe proving grounds for more far-reaching national action.

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The case for reducing pollution fromexisting diesel engines is compelling.Accelerated retrofit and replacement ofexisting engines, combined with changesin the way these engines are operated,will yield immediate public health bene-fits. Chapter 5 examines a variety ofsuccessful programs in place now to cutdiesel pollution. These programs showthat diesel retrofits and other emissionreduction strategies for existing dieselengines are both practical and cost-effective. Indeed, the experience gainedfrom the programs in place provides thetechnical and policy foundation for amore comprehensive national strategy.

This section describes the principlesfor designing a more comprehensivefederal grant and loan program as wellas non-financial incentives to cut pollu-tion from today’s diesel engines. Suchinitiatives could have multi-facetedbenefits for state and local governments.States could draw on expanded supportfor diesel pollution abatement programsto lower particulate pollution and ozone,and to cut haze in national parks andwilderness areas. State pollution abate-ment strategies to address these airquality problems are due in 2007 forozone and haze, and 2008 for particu-late pollution. Enhanced programsto cut pollution from existing dieselengines could also benefit urban andrural communities hard hit by dieselpollution or otherwise seeking federalsupport for ways to lower the public’sexposure to hazardous diesel exhaust.

Design principles for a grantand loan programCongress should establish a federalgrant and loan program that wouldmake funds available to diesel emission

CHAPTER 1Principles for a national diesel retrofit program

reduction projects that deliver publichealth and environmental benefits in acost-effective manner. Because of thewide variety of populations affected bydiesel emissions and the range ofemission reduction strategies available,EPA will need a sufficient degree offlexibility to assess and rank competingprojects. By adopting the followingdesign principles, Congress wouldmaximize the benefits of a federal grantand loan program while giving theAgency an appropriate degree ofguidance and discretion on the selectionof individual projects:

1. A diesel pollution reductionprogram should maximize healthand environmental benefits

The primary consideration in rankingproposed diesel emission reductionprojects should be the health and envi-ronmental benefits produced by theproject. Projects expected to producethe greatest health and environmentalbenefits include those that: serve areasthat fail to meet the health-basednational ambient air quality standards,serve areas with high population densi-ties, target susceptible subpopulationsincluding children and the elderly,reduce more than one pollutant and/orair toxic, and assist areas that receive adisproportionate amount of air pollutionfrom diesel equipment.

While assisting communities inachieving the national heath-based airquality standards is an important goal ofany national diesel retrofit program, aprogram should not overlook the healthand environmental benefits of projectsin areas meeting the national standards.For example, truck stops—where rowsof tractor-trailers run their dieselengines constantly to provide heat and

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electricity for the cab—create local hotspots of poor air quality where truckstop employees, truckers, other travelers,and surrounding neighbors endure highexposure levels. Idle reduction programscan provide important public healthbenefits to those exposed even if thetruck stop is located in an area meetingthe health standards.

The contaminants in diesel exhaustalso degrade the environment andcontribute to haze in national parks.Diesel pollution reduction projects tohelp protect forests, aquatic ecosystemsor scenic vistas can be important in theirown right while also lowering harmfulhuman exposure to particulate pollution.

2. A diesel emission reduction programshould promote cost-effective solutions

A competitive grants process wouldminimize costs by creating competitionbetween diesel retrofit solutions. Suchcompetition promotes efficiency acrossthe program design chain includingthe emission control manufacturers,equipment suppliers, and fleets. As ageneral guiding principle, those appli-cations that provide greater publichealth or environmental benefits perdollar should be selected over thosewith higher unit costs.

The implementing agency willneed some flexibility to evaluate cost-effectiveness. Some measures thatappear cost-effective in the short runmay be less so over time. Even withinfleets, some portions of the fleet havemore potential for cleanup thanothers—which also impacts cost-effectiveness. The agency administeringthe program should also be given flex-ibility to award some funds to inno-vative approaches that are not as faralong in research, development anddeployment but that are neverthelesspromising in achieving cost-effectivepollution reductions.

3. A program should include all industrysectors and serve many populations

A diesel emission reduction programshould not be limited to certain sectors.Instead, a program should promotetechnology in all sectors includingconstruction, locomotive, school andtransit buses, short-haul freight andgarbage trucks, marine and ports, andagriculture. Each of these industrysectors is also comprised of a sub-population of Americans includingfarmers, dockworkers, railway workers,children, laborers, tourists on ferryboats, construction workers, and manyothers. A national program shouldattempt to serve all of these populationsby supporting pilot projects that willspur development and broader deploy-ment of emission reduction applicationssuited to each sector.

4. A program should advance a broadrange of diesel emission reductiontechnologies

The goal of a diesel emission reductionprogram is, of course, to provide publichealth and environment benefits byreducing diesel pollution. But thetechnology to provide diesel emissionreductions can take many forms. The listof possible applications is expansive andincludes: switching to ultra-low sulfurdiesel fuel; repowering with moreefficient and cleaner engines; installingafter-market emission control tech-nology; and idle reduction programsincluding use of auxiliary power units,and truck stop or port electrification.

A competitive grants program opento all possible technologies will releasethe power of the market to spur inno-vation. American entrepreneurs, whetherworking on after-market emissions con-trol equipment, auxiliary power units,or any other diesel emission reductionsolution should be eligible for appropri-ate incentives. Pre-selecting a subset of

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technology applications for supportwould inhibit innovation.

5. Incentives should be tailored to thesector and specific applications

Incentives should be tailored to theeconomic characteristics of theindustry sector and the specificapplication. The scope of possiblediesel emission reduction measuresand variety of applications necessitatesaligning the economic incentive pro-vided from a grant and loan programwith the economic and businesscharacteristics of individual applications.For instance, there may be limitedopportunity to recover the capitalinvestment made to retrofit constructionequipment. Therefore, a grant for thefull capital cost of the equipment maybe required to induce retrofit invest-ment. But for truck stop electrification,the story may be quite different. In thiscase, fuel savings that accrue to truckowners by turning off their engines andutilizing the electric power source atthe terminal can be used to pay forthe electrification equipment. Ratherthan a full grant, truck stop electrifica-tion proposals may only need a low costloan program to overcome the “firstcost” barrier.

6. A federal grant program shouldencourage state and local efforts

To provide the greatest amount of pub-lic health and environmental benefits, afederal grant program should leveragestate and local resources. An exampleis a provision for matching funds wherestate and local governments devotesome of their own resources to access alarger amount of federal dollars. Sucha provision would increase the totalsupply of funds—and concomitantbenefits—and would help demonstratea community's commitment to thesuccess of the program.

Another form of leverage is non-financial. States and local governmentscould establish specifications requiringretrofit equipment as part of the con-tract competition for public worksprojects. States could also establishteams of diesel emission reductionexperts that could assist communitieswith developing diesel emission reduc-tion project proposals, preparing grantsapplications, designing monitoringand verification programs and otheractivities. States could also develop theirown leadership program by committingto retrofit a portion of the state vehiclefleet. A federal grant program could giveadditional weight to applications fromstates that undertake one or more ofthese practices.

7. A federal program should capitalizeon and support community action

EPA has recently established acommunity-based air toxics programknown as Community Action for aRenewed Environment. The programutilizes a multi-stakeholder local col-laborative approach to identify com-munity air toxics risks and carry outspecific measures to reduce thoserisks. The proposed measures for thepilot initiative in Cleveland, Ohioincluded diesel retrofit and idlereduction projects. Communityinvolvement can help ensure dieselemission reduction projects are rigor-ously implemented and evaluated.Further, communities developing acomprehensive strategy to lower airtoxics exposure demonstrate a strongcommitment to air quality improve-ments. To reward this level of com-munity effort and leverage the benefitsof federal support, diesel pollutionabatement projects that are proposed aspart of a broader community-based airtoxics initiative should receive somehigher funding priority.

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8. A program should make informationaccessible

Expanding the scope of diesel emissionreduction efforts requires stakeholderconfidence. Equipment owners andoperators need to know how dieselpollution control technologies performin real world conditions. State and localofficials relying on diesel emissionreduction strategies as part of air qualityplanning need to know that reductionstrategies actually deliver the promisedbenefits. The public requires similarassurance if taxpayer funds help pay forthe projects. To bolster confidence, EPAand the California Air Resources Boardmust establish a system for prompt,accurate and reliable verification ofdiesel emission reduction technologies.Further, projects funded under a federalgrant and loan program should be sub-ject to appropriate monitoring andverification protocols. EPA shouldthen publicize information on the per-formance of projects including theircost-effectiveness. By reporting onsuccessful and unsuccessful projects,participants can replicate the successesand avoid potential failures.

Placing a national dieselemission reduction grant andloan program in contextThese design principles apply to avoluntary grant and loan program.Such a program can spur the deploy-ment of retrofits and other dieselemission reduction solutions. Retrofitprojects funded by the program canserve as platforms for testing and veri-fication of additional equipment con-figurations—which is necessary forwider deployment. These same projectsprovide valuable experience for equip-ment owners and operators, mechanicsand maintenance personnel, and engineand emissions control manufacturers.

Similarly, local, state and federal airquality managers can better understandthe role of diesel emission reductionstechnologies as part of an overalleffort to improve air quality. A federalprogram that encourages cooperationand the transfer of information betweenEPA, states, and local stakeholderscan accelerate the development ofclean air solutions.

While a federal grant and loanprogram can “seed” solutions that havebroader benefits, it is unlikely there willbe enough resources in any single retro-fit program to address the millions ofexisting diesel engines. Other policiesand programs including non-financialincentives will be required to comple-ment a national voluntary grant andloan program.

STATE AND FEDERAL AGENCYLEADERSHIPPublic agencies should be leaders inincorporating public values into oper-ating decisions and should be the firstto avail themselves of diesel emissionreduction solutions. The federal gov-ernment has a series of laws, executiveorders, and presidential directivesgoverning its own energy and watermanagement. State governors haveissued executive orders specifying goalsfor renewable energy purchases by stateagencies. The President and Congress,along with their state counterparts,could establish similar programs toreduce diesel pollution from existingfederal and state fleets.

SPECIFICATIONS IN PUBLICWORKS CONTRACTSAnother way of promoting the use ofcleaner diesel fleets is for local, state andfederal governments to include dieselemission reduction practices as a require-ment in contracts for public worksprojects such as highway construction

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and the building of public facilities.Contracts can include specificationsfor the use of ultra-low sulfur dieselfuel, installation of emission controls onequipment, and idle reduction practices.Once construction fleets upgrade theirequipment and practices for governmentcontracts, the public would continue toreceive benefits if the equipment is usedin private contracts. This approach hasbeen adopted in several state and localprojects already.1 Establishing suchrequirements for all federal highwayprojects would be a dramatic incentiveto further deployment of emissionreduction strategies.

STATE IMPLEMENTATION PLANSA strong non-financial incentive for dieselemission reduction programs is theirpotential eligibility to qualify as emissionreduction measures in state and tribal airquality management plans required torestore healthy air or cut haze in nationalparks. EPA already has prepared guidancefor local governments relying on truckidling and switchyard locomotive idlingemission reductions in air quality man-agement strategies. EPA should finalizerigorous guidance to assist state, tribaland local air quality managers in deter-mining the amount of emission reduc-tions that can be obtained from variousdiesel pollution control programs.

LOCAL COLLABORATIVE EFFORTSMuch of the current progress reducingpollution from existing diesel engineshas originated from local initiativessuch as those in Puget Sound andSacramento. As noted, Cleveland ispursuing diesel emission reductionsas part of a community-based, multi-stakeholder collaborative process tolower air toxics. Recently, regionaldiesel collaboratives, such as theMidwest Diesel Initiative and theWest Coast Diesel Emissions Reduc-tion Collaborative, have broughttogether affected citizens, industryand public officials to examine dieselemission reduction measures.

A ROLE FOR REGULATIONWhile this discussion has focusedon voluntary programs, in some caseslocal, state, or federal agencies maydetermine that some form of regula-tion is the appropriate solution. Forinstance, the California Air ResourcesBoard has established a requirementthat locomotive and marine enginesoperating predominately within thestate use ultra-low sulfur diesel fuel in2007, several years before federal lawwould require. State and local officialsmust preserve their authority to tailordiesel emission reduction policies tolocal conditions.

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Diesel exhaust is the mix of gas,liquid and solid components that isproduced when an engine burns dieselfuel. Its composition depends on thetype of engine, the operating condi-tions, fuel characteristics and thepresence of a control system, but italways contains both particulatematter and a complex mixture ofhundreds of gases. The small size ofthe particles in diesel exhaust and thelarge number of toxic chemicals itcontains make diesel exhaust a par-ticularly potent threat to the humanbody. In addition, oxides of nitrogen(NOx) and volatile organic compounds(VOCs) in diesel exhaust combinein the presence of sunlight to formground-level ozone, which poses furtherserious danger to human health and tothe environment.

More than 40 constituents ofdiesel exhaust are listed by eitherEPA or the California Air ResourcesBoard (CARB) as hazardous air pol-lutants or toxic air contaminants. Atleast 21 of these substances are listedby the State of California as knowncarcinogens or reproductive toxicants.Numerous governmental agencies andscientific bodies including EPA, theWorld Health Organization, CARB,and the Health Effects Institute haveconcluded that diesel exhaust is aprobable human carcinogen.

According to the Multiple AirToxics Exposure Study (MATES-II)conducted by California’s SouthCoast Air Quality ManagementDistrict, about 70 percent of the totalinhalation cancer risk from air pollu-tion for the average Los Angelesresident is due to diesel exhaust.1

California’s Office of EnvironmentalHealth Hazard Assessment concluded

CHAPTER 2The dangers of diesel pollution

that “long-term exposure to dieselexhaust particles poses the highestcancer risk of any toxic air contaminantevaluated ....”2 A separate assessmentsuggested that the result for theUnited States as a whole is even worse:80 percent of the total cancer riskfrom hazardous air pollutants nation-wide is associated with the inhalationof diesel exhaust.3

Last year, CARB sponsored a riskassessment of diesel exhaust at the J.R.Davis Yard, a busy hub for railcarswitching located in Roseville, nearSacramento. It is the busiest rail yardwest of the Rocky Mountains, and railcars are switched there around the clock.Once a rural area, Roseville has boomedin population, and families in newhomes live close to this large sourceof diesel pollution.

The Roseville study concluded thatdangerous concentrations of ultra-fineparticulates from the rail yard extendout over a now-crowded landscapeand affect residents for miles around.4

Specifically, diesel exhaust from therail yard contributes an estimatedadditional cancer risk at a rate between100 and 500 cases per million peopleover an area in which between 14,000and 26,000 people live, and at a ratebetween 10 and 100 cases per millionpeople over a larger area in which140,000 to 155,000 people now live.Cancer risks posed to workers in theimmediate area of the switching yardwere even higher. The study concludedthat the cancer risk associated withdiesel emissions at the rail yard weresubstantially higher than the riskposed by diesel emissions on theadjacent interstate highway, I-80,which is itself a major east-westtrucking route, and an additional

9

source of dangerous diesel emissionsthat threatens this growing community.

Diesel exhaust’s small particlesare a big problemThe small size of the particles indiesel exhaust makes it an efficientmeans of delivering chemicals intoour bodies. Diesel exhaust is easilyinhaled deep into the lungs, whereits clearance is slow compared to largerparticles that are primarily depositedin larger airways.5 Up to 85% of fineparticles remain in the lungs 24 hoursafter initial exposure.6 This meansthat diesel exhaust has easy, long lastingaccess to the most sensitive parts ofthe lungs.

Exposure to diesel exhaust has beenassociated with a wide range of healtheffects including cancer, neurologicaleffects, a weakened immune system,respiratory disease and cardiovasculardisease. A recent evaluation of lung cancermortality in approximately 55,000 rail-road workers between 1959 and 1996revealed that those regularly exposed todiesel exhaust had a higher risk of dyingfrom lung cancer than workers withlimited exposure. The risk of lung cancermortality for workers who operateddiesel-powered trains was 40% greaterthan that for workers like ticket agentsand clerks who were less exposed.7

Even short-term exposure to diesel ex-haust can have immediate effects like diz-ziness, headaches, light-headedness, andnausea.8 People who inhale diesel exhaustcan experience nasal irritation, breathingdifficulties, cough and chest tightness.9

Animal studies suggest that exposure todiesel exhaust particulates decreases thebody’s ability to fight bacterial infections.10

In both animals and humans, short-termexposure to diesel exhaust causes inflam-mation in the bloodstream and thick-ening of the blood, symptoms which areassociated with cardiovascular diseaseand heart attacks and offer a potentialexplanation for the increase in cardio-vascular morbidity from air pollution.11

Long term exposure to diesel exhausthas been associated with other respira-tory effects including chronic inflamma-tion of lung tissue.12 Several studies havealso linked diesel exhaust particles toasthma, suggesting that these particlescan increase the severity of respiratorysymptoms in individuals with pre-existing conditions like asthma.13

Health effects of fine particulatepollutionBecause it is so laden with fine particles,diesel exhaust is implicated in all of the

The J.R. Davis Yard in Roseville, California.

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NOx pollution from diesel enginesWhile this report addresses mostly particulate mat-ter, diesel exhaust also contains both oxides of nitro-gen (NOX) and volatile organic compounds (VOCs),which combine in the atmosphere to form ground-level ozone, the primary component of smog. Ozonesmog can have serious effects on respiratory healthincluding shortness of breath, chest pains andcoughing that can lead to asthma attacks, hospitaladmissions and emergency room visits, decreasedlung function, possible long-term lung damage, andpremature death.17 These consequences are moresevere if ozone exposure occurs during physicalactivity, for example working or exercising outdoors.NOX also contributes to several other types ofpollution including nitrate particulate pollution,regional haze in national parks, nitrogen pollutionin our coastal waterbodies and forests, and acidrain in forests, soils and aquatic ecosystems.

Diesel exhaust is a special concern for areasthat do not meet the federal air quality standardsfor ozone due to its major contribution to ozone-forming NOx. In 2004, EPA found that 474 counties,home to 159 million Americans, do not comply withthe federal health-based eight-hour ozonestandard.18 Overall, diesel engines, includinghighway vehicles (onroad), nonroad engines, marinevessels and locomotives released almost 6.9 millionshort tons of NOX in 2002, or 32% of NOX from allanthropogenic sources. In places like the SanJoaquin Valley and Houston, the NOx levels fromdiesel engines can be even higher.

Similar to particulate pollution, EPA’s revolution-ary new emission standards for onroad and nonroaddiesel engines will achieve dramatic reductionsfrom current NOx emission levels by 2030, but mostof these reductions will not be achieved for morethan a decade.

There are several technologies currentlyavailable or in development to accelerate the paceof NOx reductions from diesel engines, including:

• Selective Catalytic Reduction (SCR), which canachieve a 75–90% reduction in NOx

19,• Lean NOx catalysts, which can achieve a 10–40%

reduction in NOx20,

• Exhaust gas recirculation, which can achieve a40% or more reduction in NOx

21, and• Fuel emulsifiers, which can achieve a 16–20%

reduction in NOx.

Like any retrofit option, these technologiesare not proper for all engines in all locations.Fleet operators and equipment manufacturerswill know which technology is appropriate.CARB has determined that NOx removal is cost-effective at a cost of up to $13,600 per ton of NOxreduced.22 The Texas Emissions Reduction Programfollows a similar standard of $13,000 per ton ofNOx reduced.23

Communities working to restore and maintainhealthy ozone concentrations or otherwise impactedby NOx pollution will need a variety of tools to cutNOx pollution from today’s diesel engines.

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FIGURE 5Current NOx emissions from diesel engines and reductions under new EPA rules

Reductions show the effect of the 2001 onroad diesel rule and the 2004 nonroad diesel rule. Percent reductionsare relative to emissions from all major onroad and nonroad diesel engines categories in the year 2000 exceptlocomotives and commercial shipping. Source: Estimated from EPA, 2000 and EPA, 2004a

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dangers that led EPA in 1997 to adoptmore protective health-based nationalambient air quality standards for fineparticles. Last year, EPA released acomprehensive review of recent scien-tific evidence on the harmful effects ofparticulate pollution in a report titledAir Quality Criteria for ParticulateMatter, commonly known as thePM Criteria Document.14 The PMCriteria Document detailed a wealthof studies that built upon previouslyestablished health impacts of particulatepollution including increased hospitaland emergency room visits for respira-tory and cardiovascular illness andincreased mortality. Respiratory effects

from exposure to fine particles includeasthma attacks and decreased lungfunction.15 The effects on cardiovascularhealth are just as severe; numerousstudies have linked elevated particulatepollution with incidence of irregularheartbeat and increased heart attack risk.16

The weight of evidence on thesignificant morbidity and mortalityassociated with fine particles is sostrong that EPA and the Clean AirScience Advisory Committee haverecommended significantly tighteningthe national air quality standards forfine particles to reduce the immenseburden that fine particle pollutionplaces on public health.

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Children, the elderly and the chronically ill bear special risksfrom diesel exhaust Children, the elderly, individuals with asthma, cardiopulmonary disease andother lung diseases, and individuals with chronic heart diseases are particu-larly susceptible to the effects of dieselexhaust.24 Evidence continues to mount thatchildren, especially those with asthma, areexceptionally sensitive to the effects of fineparticle pollution.25

Air pollution affects children more thanadults because they inhale more pollutants perpound of body weight and have a more rapidrate of respiration, narrower airways, and aless mature ability to metabolize, detoxify, andexcrete toxins. Children also spend more timeoutdoors engaged in vigorous activities. Ath-letes are similarly susceptible for this reason.Exposures that occur in childhood are ofspecial concern because children’s develop-mental processes can easily be disrupted andthe resulting dysfunctions may be irreversible.In addition, exposures that occur early in life appear more likely to lead to diseasethan do exposures later in life.26

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EPA has estimated that by 2030, thediesel rule for onroad trucks and buseswill prevent 8,300 premature deaths eachyear which otherwise would have beencaused by exposure to particulate pollutionfrom diesel emissions.1 EPA projects thatthe onroad diesel rule will also annuallyprevent more than 7,000 hospitaladmissions, 360,000 asthma attacks andmore than 1.5 million lost workdays in2030.2 The nonroad rule similarlypromises tremendous health benefits in2030, including avoidance of 12,000premature deaths and 8,900 hospitaladmissions each year from particulatepollution exposure.3 The nonroad rule isprojected to annually prevent 200,000cases of exacerbated asthma in childrenin 2030.4 Notably, EPA’s estimates ofthe benefits of reduced diesel emissionsdo not even consider any reduced cancerrisk associated with the new rules.

The same health effects that will beavoided in 2030 when implementationof these federal rules matures are occur-ring today and will continue to occuruntil high-polluting diesel equipment

CHAPTER 3The pollution reduction gap

now in use is replaced or cleaned up.Figure 6 shows the pace at which EPAprojects the health benefits from its non-road diesel rule will be achieved, begin-ning in 2007, when the first phase of thelow-sulfur diesel fuel requirements takeeffect for nonroad engines. Only about30% of the ultimate level of annualbenefits will be realized by 2015, andjust over 50% will be realized by 2020.These numbers suggest that thousandsof premature deaths could be preventedeach year by speeding the cleanup of non-road diesel engines in the current fleet.

The slow progress toward the healthbenefits promised by the new federaldiesel rules is mirrored by the rate ofdiesel emission reductions. Most of thereductions in particulate pollution (PM2.5)emissions resulting from the rules willnot be achieved for more than a decade.Figure 7 shows projected trends in PM2.5

emissions from onroad and nonroad dieselengines. By 2030, the national inventoriesof PM2.5 emissions from diesel enginesare projected to be about 80% lower thanemission levels in 2000. However, more

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FIGURE 6Pace of achieving health benefits from EPA’s non-road diesel rule

EPA’s report shows monetized benefits, including improved visibility and human health.Health benefits account for 98% of the total.) Source: Adapted from EPA, 2004a, Table 9-16.

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than half of the reductions in annualemissions levels will be postponed untilafter 2015.

Two factors drive the delay in reduc-ing diesel pollution. The first factor isthe lapse in time before the emissionsstandards take effect for new engines.The standards finalized in 2001 foronroad engines will be phased in from2007–2010, while the phase-in of newstandards for nonroad diesel engines isbased on engine size, and begins in 2008with engines smaller than 75 horse-power (hp). Final standards for nonroadengines greater than 750 hp will not beeffective until 2015. The second factor is

the long lifespan of diesel engines,especially those used in heavy agricul-tural and construction equipment. Asshown in Table 2, under typical operat-ing loads and levels of use, EPA esti-mates that heavy equipment engines canlast for two decades or more, dependingon how they are used.

These two factors combine to extendthe current high diesel pollution levelsfor years into the future. At the sametime, the long life of diesel enginesmeans that applying available pollutioncontrol technologies and practices toexisting engines can have immediateand lasting human health benefits.

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FIGURE 7Current PM2.5 emissions from diesel engines and reductions under newEPA rules

Reductions show the effect of EPA’s 2001 onroad diesel rule and 2004 nonroad diesel rule.Percent reductions are relative to emissions from onroad and nonroad diesel engines in theyear 2000. Source: Estimated from EPA, 2000 and EPA, 2004a.)

TABLE 2Median lifetimes for diesel engines used in various types of constructionand agricultural equipment

Equipment type Engine size (hp) Activity (hrs/yr) Median engine life (yr)

Row Crop Tractor 300 475 17Row Crop Tractor 500 475 25Crawler/Dozer 90 900 9Backhoe 100 1135 20Hydraulic excavator 430 1100 11Grader 220 960 8.2

Estimated using EPA’s default emissions modeling assumptions (EPA, 2004b)

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The health effects of diesel exhaustdescribed earlier are not abstract. Theyare a regular part of life for millionsof people who are exposed to dieselexhaust. Diesel exhaust is a specialconcern for areas that do not meet thefederal air quality standards for ozoneand particulate matter. In 2004, EPAfound 474 counties, home to 159 millionAmericans, do not comply with thehealth-based eight-hour ozone standard.1

EPA also has found that 208 countiesdo not comply with the health-basedfine particulate pollution standard.2 Airquality managers need to take aggressiveaction to meet the ozone and particulateair quality standards, protect their popu-lation’s health, and meet the compliancedeadlines they face over the coming years.Immediate retrofit programs can helpcommunities bridge the gap betweenthe statutory deadlines they face toreduce particulate pollution and ozone

CHAPTER 4Cleaning up existing engines is a cost-effective way toprotect Americans from the health risks of diesel exhaust

in the short term and the phase-in of newdiesel engine emission reductions over theperiod from 2007 through 2030. Untilexisting, high-polluting diesel engineshave been replaced with new technology,retrofits are an important means toreduce diesel pollution and achieve theemission reductions these areas need toprotect public health and comply withtheir Clean Air Act obligations.

Reducing pollution from existingdiesel engines can also lower harmfulexposure to diesel exhaust in areas thatmeet the federal air quality standards.For existing diesel equipment, the com-bination of retrofit control technologywith ultra-low sulfur fuel can reduceemissions of hazardous diesel particulatematter (PM), dramatically improvingboth environmental conditions andpublic health. Catalyzed diesel particu-late filters (DPFs) are the most effectiveretrofits that are widely available now.

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Construction equipment retrofit with a diesel oxidation catalyst.

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Diesel particulate filters can reduce PMemissions by 80-95%, with simultaneousreductions in hydrocarbon and carbonmonoxide emissions.3 Current equip-ment costs for DPF retrofits for schoolbuses and construction equipment rangefrom $4500 to $10,000.4 Even at theupper end of this range, these costs areonly a fraction of the typical new equip-ment price for construction equipmentin the 175–300 horsepower size range.5

Moreover, costs are expected to comedown significantly due to economiesof scale and as experience with DPFretrofits increases. DPFs must be usedin conjunction with ultra-low sulfurdiesel fuel and are not appropriate forall applications.

Diesel oxidation catalysts are awell established and cheaper but lesseffective alternative to DPFs for retrofitapplications. They can reduce dieselPM emissions by 20–50%, althoughthere is some concern that DOCsmay not reduce ultra-fine particles.DOCs also cut hydrocarbon and carbonmonoxide emissions by about 60–90%.6

Current costs for DOC retrofits toschool bus engines and constructionequipment range from $700 to $2,500.7

These retrofit costs are only about1% of the new equipment price formedium-sized construction equip-ment.8 DOCs do not require ultra-lowsulfur diesel fuel for operation and can beused in many different applications.

To assess the health benefits andcosts of a comprehensive diesel emissionreduction program for existing engines,as well as to evaluate potential fundinglevels, Environmental Defense examinedtwo scenarios in which different emissioncontrol measures were applied to dieselconstruction equipment, school busesand transit buses in the core countiesmaking up the 50 largest metropolitanareas in the U.S. These 88 counties,along with the District of Columbia,contain 94.6 million people, or one-third of the U.S. population.

We examined construction equipmentbecause these engines have high pollu-tion levels and typically operate for longhours. We included diesel school buses

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and transit buses because they exposesensitive populations to diesel pollution.

Our two scenarios assumed installa-tion of DPFs and DOCs within thestudied counties. Because these twotechnologies vary significantly in appli-cability and pollutant removal efficiencies,these two scenarios illustrate the rangeof costs to achieve steep reductions froma limited set of engines and more modestreductions over many more engines. Thescenarios are illustrative. The appropri-ate mix of pollution reduction strategieswill vary widely across communities.

Using EPA’s valuation methodologies,we found that investments in a nationaldiesel pollution control program willyield healthy returns. Figure 8 shows the

lump sum costs of applying the twotechnology scenarios to school buses,transit buses and construction equip-ment in the 50 most populated citiesranged from $600 million to $1.6 bil-lion. The net present value of the result-ing health benefits far exceeded thesecosts, and ranged from $10.6 billionto $19.2 billion.

Our analysis reaches results consistentwith the analyses EPA performed for itsonroad and nonroad diesel rules, whichshowed that the societal benefits of eachof these rules would vastly outweigh theircosts. In the case of the onroad dieselrule for trucks and buses, EPA esti-mated that, in 2030, the value of thehealth and welfare improvements it





17

could quantify would outweigh the costsof the rule by more than 15:1.9 Theagency similarly estimated that, in 2030,the benefits of the nonroad diesel equip-ment rule would outweigh its costs by aratio of 40:1.10

The analysis of diesel retrofit scenariosprovides a benchmark for the level offunding necessary to make a real impactin reducing dangerous emissions from

the existing diesel fleet. Over the courseof seven years, the emission controlsexamined in our study would range incost from approximately $83 millionannually to $296 million annually (seeFigure 9).

Environmental Defense recommendsfederal funding for a national program of$292 million or more annually for sevenyears. Funding at the higher part of the

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FIGURE 8Investments in a national diesel control program yield healthy returnsAn investment in diesel engine retrofits ranging from $600 million to $1.6 billion yieldsa multi-year stream of health benefits with a net present value ranging from $10.6 to$19.2 billion.

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$83 million–$296 million$129 million–$287 million

FIGURE 9Diesel pollution reduction scenarios: range of annual costs wheninvestments spread over seven years

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cost range would allow a national pro-gram to address types of diesel enginesand control technologies excludedfrom our analysis such as locomotiveand marine engines and idle reductionstrategies. Importantly, it would alsoprovide resources to better accommo-date controls for additional pollutants,to support communities, large and small,across America that are committed towell-run cleaner diesel programs, and toaddress the administrative costs inherentin a program of this scope.

The health benefits associated withreduced particulate pollution were esti-mated based on EPA’s benefits analysisfor the 2004 nonroad diesel rule. Thebenefits quantified include reduced riskof premature death, non-fatal heartattacks, chronic and acute bronchitis,exacerbated asthma, upper and lowerrespiratory symptoms, work loss days,and minor restricted activity days. Animportant limitation of our reliance onEPA’s benefits estimates for the nonroadrule is that the benefits of reduced

cancer risk from reduced exposure todiesel exhaust are not considered.Furthermore, only the benefits of directparticulate matter reductions wereconsidered in our analysis; the analysisdid not account for the co-benefits ofhydrocarbon and carbon monoxidereductions from use of DPFs andDOCs or of sulfur oxides reductionsfrom using ultra-low sulfur diesel.

To estimate benefits from retrofitapplications, the particulate pollutionbenefits from the nonroad rule werescaled down by the ratio of particulateemissions reductions from retrofits tothe particulate emissions reductions inthe nonroad rule. The benefits were alsoscaled down by the ratio of the currentpopulation to the projected 2030 pop-ulation that was used in the nonroadrule analysis. Other than the populationadjustment, our benefits analysisassumes that exposure patterns asso-ciated with retrofits will be the sameas those associated with new nonroadengine control requirements.

A delivery of ultra low sulfur diesel fuel to New York's World Trade Center site. In late 2006,ULSD will be widely available across the United States

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This assumption may lead to under-estimation of the health benefits fromretrofit programs that target urban areaswith relatively high exposure to particulatepollution. The analysis does not accountfor enhanced benefits to individuals likeconstruction workers who are highlyexposed to diesel exhaust at constructionsites and school children who are highlyexposed while riding on school buses. Arecent study conducted in the Los Angeles

area found that children riding on diesel-fueled school buses inhale roughly amillion times more school bus exhaust(by mass) than non-riders in the generalpopulation.11 Consequently, cleaningup diesel exhaust from school buses isa particularly cost-effective means ofreducing such children’s exposure.12 Theassumptions and methodologies reliedin our retrofit scenario analysis aredescribed in more detail in Appendix B.

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A variety of programs at the federal,state and local levels have already begunto close the gap between today’s highdiesel pollution levels and the reduceddiesel emissions of the future. Thissection describes a sampling of pro-grams across the country that arereducing diesel emissions through solu-tions that include retrofit and repowerprojects, accelerated low sulfur fueluse, idle reduction technologies andchanges in the way diesel engines areoperated.1 For additional examples ofpollution control technologies, pleasesee Environmental Defense’s CleanerDiesel Handbook.2

Start spreadin’ the news:New York is providing cleanerair todayRetrofit programs will be a critical com-ponent to any New York State cleanupplan because 30 counties in New York

CHAPTER 5Diesel cleanup programs that are working now

State currently fail to meet the federalhealth-based air quality standard forozone (“smog”) including the entireNew York metropolitan area, Albanyand Rochester.3 Nearly 90% of NewYork residents live in one of thesecounties. Similarly, EPA recently foundthat the following 10 counties in NewYork State are out of compliance withthe federal health-based standard forparticulate pollution: Bronx, Kings,Nassau, New York, Orange, Queens,Richmond, Rockland, Suffolk andWestchester.4 Diesel pollution is oneof New York’s most pressing environ-mental health problems, especiallybecause diesel equipment is being usedin areas with very high concentrationsof people.

Lower Manhattan is a thriving mixof apartments, art galleries, shops andrestaurants, where more than 4,000children live in neighborhoods asdiverse as Tribeca, Chinatown and

Reconstruction at the World Trade Center site in New York City.

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Battery Park City. During the recon-struction of the World Trade Centersite, lower Manhattan will also be one ofthe nation’s largest construction sites,teeming with diesel engines operatingjust steps from schools, playgrounds,parks, homes and offices.

The close proximity between thismassive construction project and adense population called out for airquality protections. New York’s leadershave responded to that call and arerequiring best available retrofits andultra-low sulfur diesel fuel in state-controlled lower Manhattan con-struction projects, including the WorldTrade Center site.5 Contractors andsubcontractors using diesel-powerednonroad vehicles with an engine horse-power rating of 60 hp and above arenow required to use ultra-low sulfurdiesel fuel and to retrofit, where prac-ticable, their equipment with oxidationcatalysts, particulate filters, or tech-nology with “comparable or bettereffectiveness.”6 At World TradeCenter 7, retrofits and other pollutioncontrol measures are already in place.Several pieces of construction equip-ment have been retrofitted, and oneelectric crane is being used in lieu of atypical diesel engine crane because itdoes not create any on-site emissions.

New York City also recently extendedcleaner diesel requirements to city-funded construction projects. New YorkCity Local Law 77 adds specificationsto city contracts requiring the use ofultra-low sulfur diesel fuel and bestavailable emissions-control technologiesin all city construction. Local Law 77also calls for PM and NOx pollution con-trol technologies, requiring agencies touse technologies that “shall be primarilybased on the reduction in emissions ofparticulate matter and secondarily basedupon the reduction in emissions ofnitrogen oxides.”7

Delivering diesel emissionreductions where they areneeded mostHUNTS POINT ELECTRIFICATIONPROJECT, NEW YORK CITYAt the southern tip of the Bronx, justabove Manhattan, the extremely poorand mostly minority Hunts Pointcommunity has one of the highestasthma rates in the nation. Approxi-mately one out of every three childrenhas asthma in Hunts Point.8 Given theconnection between diesel exhaust andrespiratory disease, it is not surprisingthat Hunts Point is also a hotspot ofdiesel pollution.

The Hunts Point CooperativeMarket includes one of the largest meatmarkets in the world, as well as theHunts Point Produce Market, throughwhich 80% of fresh produce in the NewYork area moves. The market drawshundreds of diesel trucks each day,which are a major source of the 20,000diesel truck trips through the neighbor-hood each week. On average, a long-haultruck operator can have an 8–12 hourlayover at the Hunts Point market whilewaiting to load or unload, or to complywith the federal rest period require-ments. When trucks idle through thislayover, the resulting diesel emissionsplace a serious burden on the peoplewho live and work in Hunts Point.

Hunts Point, then, was an ideal placefor the nation’s first operational advancedtruck stop electrification project. Sus-tainable South Bronx, the New YorkPower Authority and IdleAire Tech-nologies Corporation received a grantfrom Clean Air Communities to con-struct a system that can accommodate28 trucks. At full operation, the projectis expected to eliminate 2,000 tons ofpollution each year.9 The Hunts Pointproject is delivering diesel emissionreductions in a community where theyare urgently needed.

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Cleaner school buses forprecious passengersThe pollution that comes from thediesel engines that power school busescan cause respiratory disease andexacerbate long-term conditions likeasthma. There are about 450,000 publicschool buses in the United States andabout 390,000 of those run on dieselfuel. About two-thirds of the dieselschool buses on the road today weremanufactured between 1990 and 2002.These buses can be made much cleanerby upgrading or retrofitting their exist-ing emission control systems. Aboutone-third of all diesel school buses arepre-1990 buses.10 Because these busesare so dirty and often cannot use dieselpollution controls, the best solution forthem is replacement.

Children’s exposure to diesel pollu-tion on school buses is of particularconcern for several reasons:

1. Across the country millions of chil-dren ride the school bus every day;

2. Air pollution affects children morethan adults because children inhale

more pollutants per pound of bodyweight, have a more rapid rate ofrespiration and narrower airways, areless able to metabolize and rid theirbodies of certain toxins, and are exposedduring developmental stages when theimpacts can be lasting; and

3. Some studies indicate that childrenin school buses are exposed to airborneparticulate pollution concentrations5–15 times higher than backgroundlevels.11

The EPA created the Clean SchoolBus USA program to help lower chil-dren’s exposure to diesel exhaust. In2003, this program allocated $5 millionto 17 demonstration projects involvingabout 4,000 school buses. EPA expectsthese projects to remove more than200,000 pounds of diesel particulatepollution from the air over the next tenyears. In 2004, EPA awarded another$5 million for 20 retrofit and replace-ment projects, and this year, will award$7.5 million in a cost-shared grantprogram that will assist school districtsin upgrading their diesel fleets.12

2004 demonstration projects2003 demonstration projects

FIGURE 10EPA’s Clean School Bus USA program has supported demonstrationprojects across the country

Source: http://www.epa.gov/otaq/schoolbus/demo_projects.htm

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Clean School Bus USA has reduced chil-dren’s exposure to diesel exhaust in com-munities across the country, including:

• Michigan. In the greater Lansing area,the Okemos Public Schools will equip40 to 50 buses with diesel oxidationcatalysts and crankcase filtrationsystems.13 The Okemos SchoolDistrict serves approximately 4,000children who attend five elementaryschools, two middle schools and onehigh school.14

• New Mexico. Working in partnershipwith the State Department of Edu-cation, state officials will replace threeolder diesel school buses with newcompressed natural gas (CNG) buses.15

The CNG-fueled school buses willachieve substantial emissions reduc-tions relative to the conventionaldiesel-fueled buses they replaced.16

• Oregon. Sharon Banks of the LaneRegional Air Pollution Authoritysuccessfully created a market for ultralow sulfur diesel (ULSD) fuel in LaneCounty, Oregon. The objective was tobring ULSD fuel to Lane County atan affordable price ahead of EPA’s2006 mandate. To bring the price ofULSD fuel down to a competitivelevel, Ms. Banks built broad-baseddemand. City managers, countyadministrators, school districts, transitauthorities, municipal waste haulers,large private fleets, fuel distributorsand public utilities were all involved inthe endeavor. The program has been atremendous success. In the shortperiod from October 1, 2004 to Feb-ruary 1, 2005, the Lane Clean DieselProject received commitments from itspartners to purchase over 2 milliongallons of ULSD. Additionally, theLane Regional Air Pollution Authorityhas received a grant from EPA’s CleanSchool Bus Program to help make

ultra-low sulfur diesel available to15 fleets across Oregon and to retrofit42 school buses with particulatematter filters.17

• Tennessee. Of the approximately 8,000school buses in Tennessee, 95% arepowered by diesel engines.18 Tennessee’sClean School Bus program is a jointeffort between the Tennessee Depart-ment of Education and the Departmentof Environment and Conservation, inpartnership with local governments,school systems and local communities.

In-cabin exposure andcrankcase emissionsRecent studies have shown that achild riding inside of a diesel schoolbus may be exposed to considerablymore diesel particulate pollutionthan car commuters. Pollutioninside the bus comes from boththe tailpipe and from the crank-case. Crankcase emissions, onaverage, make up between 10–25%of total engine emissions over aprescribed test cycle but becomevery high (50–80%) on a relativebasis when idling.20

The Clean Air Task Forcerecently completed a study thatsheds light on technologies thatprovide cleaner air inside the schoolbus. 21 Emissions control technolo-gies that focus solely on the tailpipedo not clean up all of the pollutioninside the bus, although they areeffective at lowering pollution forsomeone who is standing near thebus.22 Similarly, emissions controltechnologies that focus solely onthe crankcase will not clean up allof the pollution inside the schoolbus. The study found that a dieselparticulate filter-crankcase emis-sion control technology combina-tion used with ultra low sulfurdiesel fuel virtually eliminated thepollution inside the bus.

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With the support of a grant fromEPA’s Clean School Bus program,83 school buses will be equipped withdiesel oxidation catalysts through apublic/private partnership betweenthe Chattanooga-Hamilton CountyAir Pollution Control Bureau andFirst Student Inc., a local privatebus contractor.19

One straightforward way to lowerpollution from school buses is to turnthem off when they are not in use. Aschool bus that is idling pollutes the air,wastes fuel, and imposes unnecessarycosts for school districts facing tightbudget constraints. A typical schoolbus burns about half a gallon of fuel perhour of idling.23 If 100 buses reducedidling time by just 10 minutes each day,they would realize a fuel savings of some1500 gallons per year. This translatesinto more than $2250 annual savings infuel costs.24 School districts that estab-lish idle-free zones can lower harmfuldiesel pollution while saving money forother educational priorities.25

Denver and San Francisco findalternative routes for cleanertransit Many transit districts have fleets withhigh-polluting diesel buses. Localgovernments are considering a varietyof solutions to reduce harmful dieselexhaust in urban areas while meetingtransit needs.

For the last five years, Denver’sRegional Transportation District hasoperated 36 “EcoMark” buses on adowntown pedestrian mall, connectingsome 50,000 passengers per day toshopping, business, and regional busand light rail routes along the mile-longmall. These hybrid buses run on a com-bination electric/compressed natural gasengine. Electric power is provided bybatteries that are charged by an alter-nator and regenerative braking (thebuses also have a small compressednatural gas engine that recharges thebank of batteries). Instead of a dieselengine, the buses have a 2.5-liter Fordindustrial engine fueled by the com-pressed natural gas tanks. The Regional

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Hybrid compressed natural gas RTD Shuttle.

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Transportation District has found thatthe hybrid buses produce lower emis-sions and have lower operating coststhan the diesel buses previously usedon the route.26

Last year, San Francisco votersapproved the “Healthy Air Enforce-ment Act,” which requires the city’sMunicipal Railway to replace all of itspre-1991 diesel buses with cleaner tech-nology by 2007. The Municipal Railway’sgoal is to eliminate all bus emissions by2020, when it hopes to operate a fleetpowered exclusively by hybrid engines,batteries, and fuel cells. San Franciscohas placed its first order for diesel-electric hybrid buses that are already inuse in Seattle, Boston and New York.

Reducing the high cost of idle time Idling occurs when an engine runs butthe vehicle is not moving. There areseveral reasons why engines idle: to keepfuel and engines warm and avoid prob-lems restarting in cold weather, for thecomfort of drivers and passengers ona hot summer days and cold winternights, or simply to be ready to movethe vehicle on short notice. But idlingwastes fuel and pollutes the air. Further,new technologies provide alternatives tothe functions served by idling.

As part of EPA’s SmartWay TransportPartnership, EPA estimates that truckand locomotive idling consumes over1 billion gallons of diesel fuel annually.The average truck uses 0.8 gallons offuel an hour while idling.27 An idlinglocomotive switching engine consumes3–4 gallons of fuel per hour in normalweather and in extremely cold weather(below 15ºF) it can use up to 8–11 gal-lons per hour at idle.28 Marine vessels andnon-road vehicles also idle their engines.

EPA estimates that long-durationidling by freight trucks annually emits11 million tons of carbon dioxide,

180,000 tons of nitrogen oxides, and5,000 tons of particulate matter. EPAalso projects that locomotive switcherlong-duration idling emits 12,000 tonsof nitrogen oxides and 500 tons ofparticulate matter annually.29

An individual long-haul truck idlesabout six hours a day, 310 days a year orabout 1,860 hours per year.30 The truck-ing industry has analyzed the impactof idling on engines; both in terms ofmaintenance and engine wear costs.Excessive idling creates the need formore oil and filter changes. Similarly,the longer the idling time, the soonerthe engine needs to be rebuilt. Enginewear is a function of fuel consumed, andlong- duration idling consumes signifi-cant fuel. The trucking industry esti-mates that, due to the need for more oilchanges and earlier overhaul costs, long-duration idling costs the average truckowner $1.13 per day.31

One solution to the problem of idlingis simply to turn the engine off, whichsaves fuel and money and virtuallyeliminates pollution. When this is not aviable solution, there are several otheroptions available. Though this discus-sion focuses on truck idling, many ofthese solutions can be used on any dieselengine. These solutions include:

• Auxiliary power generators. Auxiliarypower generators are powered by 1-,2-, 3- or 4-cylinder diesel enginesand produce 110- to 220-volt elec-tricity to run AC-powered devices,from heaters and air conditionersto microwaves.32

• Auxiliary power units (integrated).Auxiliary power units typically includean internal combustion engine, com-pressor and alternator and are fully in-tegrated into the truck’s own heating,ventilating and air conditioning (HVAC)system to provide climate control, bat-tery charging and engine heating.33

26

• Electrical Power on and off board.Truck Stop Electrification allowstruckers to “plug in” vehicles to oper-ate necessary systems without idlingthe engine. Options for truck stopelectrification include stand-alonesystems that are owned and operatedby the truck stop and can provideheating, ventilation, and air condi-tioning directly to the sleeper com-partment as well as combined systemsthat require both on-board and off-board equipment.34

• Engine idle management technology.An automatic engine shut down/start up system controls the engine(start and stop) based on a set timeperiod or on ambient temperature,and other parameters (e.g., batterycharge).35

• Fuel-fired and other no-idle heatand/or HVAC systems. These systemsinclude air conditioners that operateon battery power or heaters that use asmall fraction of the diesel fuel that isburned by an idling engine.36

I-85: North Carolina, SouthCarolina and Georgia aretrucking toward cleaner airWith the support of a $1.5 milliongrant from the National Associationof State Energy Offices, energy andenvironmental agencies in NorthCarolina, South Carolina and Georgiahave sponsored a project to electrify150 parking spaces at three truck stopsalong the busy interstate highway cor-ridor (I-85) that connects Atlanta withCharlotte and Raleigh-Durham.37 Eachelectrified truck stop is expected to save263,000 gallons of fuel annually, andprevent 2,700 tons of carbon dioxide,35 tons of nitrogen oxides, 15 tons ofcarbon monoxide, 1.8 tons of hydro-carbons and 1 ton of particulate emis-sions each year.38

All three of these truck stops usethe IdleAire system, which providesan external heating, ventilation and airconditioning unit installed above eachtruck parking space. Heat and air aredelivered to the truck cab through aservice delivery console and return air

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Trucks “plugged in” to the IdleAire system.

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supply that is connected through thepassenger window of the truck’s cab orthrough a built-in access point availablein newer trucks.39 Drivers can alsoaccess the internet and cable television.

Independent truck owners and fleetshave signed agreements with IdleAire topay $1.40 to $1.6540 per hour to use itsstandard services. An idling truck wastesabout 0.8 gallons of fuel per hour, whichtranslates into about $1.75 wasted everyhour (May 2005, the retail cost of high-way diesel fuel was about $2.1841 a gallon).Combined with the trucking industry’sestimate that maintenance for long-duration idling costs about $1.13 perday, truck idling is an expensive practice.When the significant health benefits ofreduced pollution are considered, truckstop electrification is a solution makesboth economic and environmental sense.

Ship to shore: reducingcommercial marine pollutionCommercial marine vessels contributeto air pollution along our coasts, in and

around ports, and along inland water-ways hundreds of miles from the opensea. Control of this overlooked pollutionsource has only recently become a pri-ority for EPA and state and local officials.Emission control programs for ships lagfar behind land-based sources. Andforeign-flagged marine vessels presentunique jurisdictional issues that do notapply to land-based sources.

Despite these challenges, commercialmarine pollution can be reduced in thenear-term by retrofitting and repower-ing ships. The following programs arealready in place and delivering cleanerair in and around domestic ports.

Shore power: reducing emissionsfrom ships at berth in LosAngeles, Juneau and SeattleLarge ships generally turn off theirprimary propulsion engines when theyare parked at berths loading and un-loading cargo or passengers, activitiescollectively called “hotelling.” But theycontinue to run smaller auxiliary engines

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to provide electricity, heating and cooling.On oceangoing vessels, these enginesoften run on the same extremely high-sulfur bunker fuel that they burn at sea.Because the overwhelming majorityof these huge vessels are subject to nointernational air pollution regulations oronly weak restrictions applicable to thenewest engines, this dirty bunker fuel isburned in crowded port areas withoutany emission controls whatsoever.

This practice of powering a ship atberth with the ship’s own engines createsthe paradoxical situation in which elec-tricity is produced by the uncontrolledburning of one of the dirtiest fuels inthe world within sight and breathingdistance of land-based vehicles andstationary sources subject to rigorousstandards designed to protect publichealth from the very same pollutants.West Coast ports have begun to addressthe problem of ship emissions at berthby providing shore power facilities thatallow ships to plug into land-based elec-tricity and turn off their engines. The

U.S. Navy has provided shore power atnaval bases for many years, but it is onlyin the last few years that shore powerfacilities have been built for large com-mercial ships.

The Los Angeles area has boththe worst ozone (smog) in the countryand two of the busiest ports. The boom-ing international cargo business atthe ports of Los Angeles and LongBeach is expected to triple by 2020,which means that ship emissions willincrease dramatically over the next15 years as well.

Last summer, the world’s firstshore power facility for containerships opened at the Port of LosAngeles. As a result of a settlementof lawsuits brought by the NaturalResources Defense Council, Coalitionfor Clean Air and local citizens’ groups,the City of Los Angeles equipped theChina Shipping Terminal at Berth 100with alternative marine power capableof providing electrical service to twolarge container ships simultaneously.

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A terminal at the Port of Los Angeles is designed to accommodate and simultaneouslycharge two Alternative Marine Power vessels.

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Container ships dominate both theshipping traffic and the pollutant emis-sions inventory at Los Angeles. Accordingto the Port of Los Angeles, a containership on a typical port call using its ownengines produces emissions equivalentto 69,000 diesel truck miles. By con-trast, a container ship using the shore-based alternative marine power systemis expected to eliminate an estimatedone ton of NOx and particulate pollu-tion per day in port.

Shore power projects require signifi-cant capital investments in electricalinfrastructure and modifications toexisting ships. The Port of Long Beachrecently commissioned a detailed studyof the feasibility and cost-effectivenessof shore power facilities for oceangoingcargo ships.42 That study concluded thatfor ships that frequently call at the sameport and have high power needs at berth,investment in shore power facilities is acost-effective way of reducing hotellingemissions. It also concluded that othermeasures including alternative fuels,alternative engines, and emission con-

trols such as diesel oxidation catalystsare feasible means of reducing emissionsfrom oceangoing ships at berth.

Princess Cruises, part of the world’slargest cruise line, Carnival Corpora-tion, has begun providing shore powerfor passenger cruise vessels. In 2001, itbecame the first cruise line to use shorepower when it provided electrical serviceto its passenger terminal in Juneau,Alaska. By 2004, seven Princess cruiseships were equipped to use shore powerin port.

The Juneau shore power facility wascompleted through an innovative part-nership between Princess, the City ofJuneau and Alaska Electric Power &Light Company. Princess bore the costof retrofitting its ships—at $500,000each—to accept shore power.43 TheCity and Borough of Juneau set aside$300,000 from cruise passenger fees asa contribution to the cost of the land-based expenditures related to the project,and Princess paid the remainder of the$2.5 million in capital costs to provideshore power. Alaska Electric Light and

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A full ship “plug in” of Alternative Maritime Pier.

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Power Company agreed to segregate theamount Princess pays for shore powerin a fund to defray the cost of winter-time power generation and therebyreduce local consumers’ power bills.

In 2004, Princess expanded its shorepower program to Washington State,with the installation of shore powerfacilities in Seattle to serve the sameships that dock at Juneau and ply theInside Passage route between the PacificNorthwest and Alaska. The Puget SoundClean Air Agency, Port of Seattle andEPA all participated in this project. Theproject was facilitated through the WestCoast Diesel Emissions Reduction Col-laborative, an international partnershipof federal government agencies fromthe U.S., Canada and Mexico, as wellas state and local governments and non-profit and private sector partners fromCalifornia, Oregon, Washington, Alaskaand British Columbia.44

Princess paid $1.8 million in capitalcosts to construct shore power facilitiesand EPA made a $50,000 grant to fundSeattle City Light’s extension of highcapacity electrical service to the terminal.The Puget Sound Clean Air Agencypredicts that this shore power projectwill reduce NOx emissions by 14.5 tonsand particulate pollution by 2.5 tonsduring the 2005 cruise season.45

Reducing emissions from smallharbor craft in New York andLos Angeles Oceangoing vessels calling in U.S. portsare major polluters, but each large shiponly stays a few days in a given port.Smaller harbor craft that remain in portyear-round pollute much less on a per-ship basis, but because they operate con-tinuously in a relatively small area, theiremissions can add up to a major con-tribution to local pollution. For instance,in New York Harbor, the small towboats

that push and pull large vessels throughport are the second largest source of shipemissions, behind only oceangoing ships.

Ferryboats are also a major sourceof NOx pollution in New York. BeforeSeptember 2001, ferries carried 85,000commuters a day into and out of Man-hattan.46 After the September 11 terroristattacks, private ferry service doubled to1,000 trips a day. More than 40 boatsply these routes, and ferry traffic isexpected to increase as the redevelop-ment of Lower Manhattan movesforward. At present, these boats are notrequired to have pollution controls. Sowhile passengers are enjoying a scenictrip to work, the diesel engines that powertheir ride discharge almost 20% of thetotal NOx emissions from all ships ofany size in the New York Harbor.

In response to the growing problemof ferry pollution, a coalition of state,city, federal, educational and environ-mental organizations, including Environ-mental Defense, is working with ferryoperators to cut ferry pollution. ThePrivate Ferry Emissions Reduction Initia-tive will use $6.8 million from New YorkCity’s Department of Transportation,the New York State Energy Researchand Development Authority, and theFederal Transit Administration to evalu-ate, demonstrate and then deploy emissionreduction technologies on virtually allprivate ferries now serving New YorkCity. By the time it is complete, thePrivate Ferry Project aims to achieve a75-95% reduction in ferry pollution.

California’s Carl Moyer Programfunds the incremental cost of repower-ing harbor craft such as tugboats withnew, cleaner engines rather than replace-ments that would produce the same levelof emissions as the existing engines.Through 2002, 130 small vessels inthe Los Angeles area were repoweredwith the assistance of $19.5 millionin incentive program funds. As a result,

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almost 1,400 tons of NOX emissions and55 tons of particulate pollution have beeneliminated each year.47

Locomotive emissions: movingto the front of the train inCalifornia, Illinois and TexasLike commercial marine ships, loco-motive engines are among the lastsources of diesel pollution that EPA hasleft to address through rigorous emis-sion controls. Yet just like any otherdiesel engines, locomotives produce thesame dangerous blend of chemicals andparticulate matter that endangers thepeople who breathe their emissions.EPA is currently reviewing its emissionstandards for new and remanufacturedlocomotive engines.

Long-haul rail service delivers cargoacross the country. The business of switch-ing rail cars and assembling cars intotrains for this service takes place at switch-ing yards where rail lines meet. As shownin the study of Union Pacific’s Roseville,California switching yard, discussed

earlier, the concentration of pollutantsfrom locomotives gathered at switchingyards can make these facilities danger-ous hotspots of toxic pollution. To makematters worse, these yards are oftenlocated in dense urban population centers,where residents and workers are alreadyexposed to pollution from many othersources. The huge growth of importsarriving by container ships has led to railcongestion at port facilities, which alsotend to be located near large populations.

Railroads and the communities inwhich they operate have begun to recog-nize that locomotives must be a part ofcomprehensive plans to reduce dieselpollution. The Port of Los Angeles lastyear adopted its first rail policy, whichcalls for the development of facilities tohandle an expected quadrupling of cargovolumes by 2025 and aims to reducetraffic congestion by speeding cargoloading and shifting truck traffic to rail.48

Union Pacific, the nation’s largestrail carrier, has just put in service itsfirst hybrid switching locomotive, usedto switch cars at Los Angeles area ports.

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The hybrid locomotive operates onan electric battery and a diesel enginethat recharges the battery. UnionPacific projects that the hybrid enginewill emit 80-90% less NOx, and use40–70% less diesel fuel than a standarddiesel-powered switching engine.49

Expansion of this technology couldhave a dramatic impact on locomotiveemissions at ports and switching yardsacross the country.

The Texas Emissions ReductionProject (TERP) focuses on reducingNOx emissions in areas violating thefederal health-based ozone standard.TERP has committed almost $20 millionto reduce locomotive emissions in theHouston-Galveston area, which suffersthe highest ozone levels in the state. TheHouston locomotive projects includereplacement of old switching enginesand repowering locomotives with cleanerhybrid technology. TERP officials expectthese projects to reduce NOx emissions

by more than 3,300 tons, at an averagecost of about $5900 per ton.

Chicago is another major hub of railtraffic, situated at the point where severaleast-west rail lines dip around thesouthern end of the Great Lakes. One-third of all long-haul rail traffic in thecountry passes through Chicago, andthe largest U.S. rail yard, the Belt RailYard, is located there. EPA and the Cityof Chicago sponsored a locomotive idlereduction demonstration project in 2002and 2003. The governments recruitedBurlington Northern Santa Fe RailwayCompany, the Wisconsin Southern Rail-road Company, and Kim Hotstart Com-pany, a manufacturer of idle reductionsystems, as partners in the project. Basedon the successful performance of idlereduction systems in Chicago, EPA esti-mated that anti-idle retrofits at a typicallysized rail yard with five switching engineswould eliminate 12.5 tons of NOx at acost of $1,420 per ton of NOx reduced.50

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Cleaner air for America is at handEPA has adopted bold national emissionstandards that are transitioning thenation to cleaner new diesel freighttrucks, buses and diesel equipment.Because diesel engines are long-livedand fleet turnover is slow, this transitionwill occur incrementally over the nexttwenty to thirty years. Innovative actionin a variety of local communities hasdemonstrated that programs to lowerthe pollution from today’s diesel enginesare not only viable but highly beneficial.Our detailed analysis quantifying the

Conclusion

benefits and costs, using EPA method-ologies, shows that the human healthbenefits of broadly expanding theseprograms to additional communitiesacross America exceed the costs by atleast a 12 to 1 ratio. A well-designedprogram to lower pollution from exist-ing diesel engines operating todaywill accelerate the nation’s transitionto cleaner, new engines and achievemomentous human health benefits.With expanded federal support andcommunity leadership, cleaner air forAmerica is at hand.

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Diesel engines are used throughout theU.S economy in onroad vehicles, non-road equipment and vehicles, marinevessels and locomotives, and in station-ary applications to power equipmentsuch as pumps and loading equipmentand to generate electricity. Diesel exhaustis a particularly potent collection ofdangerous chemicals, and a significantcontributor to national inventories of

APPENDIX AThe national pollution burden from diesel engines

several key pollutants, including nitro-gen oxides, volatile organic compounds,fine particulates, sulfur dioxide, andcarbon dioxide, a critical greenhouse gas.

Diesel and smog: nitrogen oxidesand volatile organic compounds Diesel exhaust contains both NOX andVOCs, which combine in the atmo-

Fuel combustion39%

Highway gasoline19%

Highway diesel16%

Non-roaddiesel/ships/trains

17%

Other9%

FIGURE 11National NOx emissions by source category, 2002 (21.1 million short tons)

Source: U.S. EPA National Emission Trends

Highway diesel48%

Construction equipment11%

Marine15%

Railroads13%

Other5%Farm equipment

8%

FIGURE 12National NOx emissions from all diesel sources, 2002 (6.9 million short tons)


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sphere to form ground-level ozone, theprimary component of smog. NOX alsocontributes to several other types ofpollution including nitrate particulatepollution, nitrogen deposition and aciddeposition. Diesel engines are responsi-ble for about one-third of all NOx pollu-tion from anthropogenic sources, seeFigure 11. The highway sector and non-road sector are each responsible for abouthalf of the NOx emissions from all dieselsources, see Figure 12.

Fine particulate matter Diesel engines produce far more par-ticulate pollution than gasoline engines.Depending on operating conditions, fuelquality and emission controls, light-dutydiesel engines can emit 50-80 times andheavy-duty diesel engines can emit 100to 200 times more particle mass thantypical catalytically equipped gasoline-powered engines.1 Diesel particulatematter is typically fine (< 2.5 microns)or ultrafine (< 1 micron) in size. Virtu-ally all of the diesel exhaust particle masshas a diameter of less than 10 microns,94% is less than 2.5 microns, and 92%is less than 1.0 microns. 2 The small size

of diesel particulate matter makes it aparticularly efficient and dangerousmeans of delivering harmful chemicalsinto our bodies.

Diesel engines are a major source offine particle pollution. In 2002, dieselengines released approximately 314,000short tons of PM2.5 and accounted foralmost 5% of total fine particle pollutionin 2002. 3 Nonroad diesel vehicles createdabout two-thirds of those emissions.

Sulfur dioxideSulfur dioxide emissions contributeto the formation of secondary finesulfate particles that threaten healthand impair visibility as well as aciddeposition that harms ecosystems.Diesel engines discharged 510,000 tonsof sulfur dioxide in 2002, or 3% of thesulfur dioxide released from all anthro-pogenic sources. Nonroad engines andmarine equipment released most of theSO2 from diesel sources, largely becausethey have operated on diesel fuel withhigh sulfur content. 4

As new restrictions on highway dieselfuel sulfur content take effect in 2006for onroad vehicles and in 2010 and

Highway diesel32%

Construction equipment21%

Marine13%

Railroads6%

Other9%

Farm equipment19%

FIGURE 13National PM2.5 emissions from all diesel sources, 2002 (314,00 short tons)


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2012 for nonroad equipment, the levelsof sulfur dioxide emissions from thosediesel engines will fall dramatically.However, the dirtiest of the diesel fuels,the residual fuel burned in oceangoingvessels, is not subject to any current orproposed restriction on sulfur. Sulfurcontent in marine residual fuel canrange as high as 45,000 ppm, or astaggering 4.5% sulfur. EPA reportsthat, worldwide, residual fuel averages27,000 ppm sulfur. This is nearly 2,000times the 15 ppm level soon to be

required for onroad diesel fuels. 5 Theextraordinarily high sulfur content inresidual fuel makes shipping one of thebiggest sources of SO2 emissions on theplanet, despite the relatively smallnumber of large ships in existence.

Carbon dioxide—a globalwarming pollutantHuman-induced increases in atmo-spheric carbon dioxide (CO2) and othergreenhouse gases are shrouding the

On-road diesel21%

Marine31%

Railroads9%Non-road

39%

FIGURE 14National SO2 emissions from all diesel sources, 2002 (510,00 short tons)


Jet fuel12%

Marine fuel3%

Other3%

Diesel fuel22%

Gasoline60%

FIGURE 15National CO2 emissions from transportation, 2003 (1,874.7 million metric tons)

Source: U.S. DOE Energy Information Administration

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Earth, pushing temperatures toextremes, melting glaciers anddisrupting natural systems. Much of theCO2 emitted domestically is a result ofburning fossil fuels. Total emissions ofCO2 in the U.S. reached 5.9 billion

metric tons in 2003. Transportationplayed a large role in this pollution,emitting 1.9 billion metric tons of CO2.In 2003, the combustion of diesel fuelcontributed 22% of the CO2 releasedfrom transportation sources.6

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This appendix describes the method-ology used to analyze the benefits andcosts of two scenarios to reduce pollutionfrom existing diesel engines. E3 Ventures,a technical consultant retained byEnvironmental Defense, performed thisanalysis. The two scenarios reducedemissions of fine particulate pollution(PM2.5) by retrofitting diesel construc-tion equipment, school buses, andtransit buses with (1) diesel particulatefilters (DPFs) or (2) diesel oxidizationcatalysts (DOCs). The scenarios applied

APPENDIX BMethodology used to estimate the benefits and costs ofpollution reduction scenarios for existing diesel engines

two pollution reduction technologies todiesel equipment in the core countiesof the following 50 largest metropolitanareas in the United States.

The scenarios covered some 88counties and Washington, D.C. with94.6 million people or one-third of the2001 total U.S. population.

The monetary benefits analysis usedmethods and assumptions similar tothose used by the U.S. EnvironmentalProtection Agency in its regulatoryanalysis of the nonroad diesel rule.1





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Because many of the assumptions usedin the analysis are based on national-scaleinformation, the results are similar acrossall cities and average values were used toestimate the retrofit costs and benefits.

The analysis assumes retrofit equip-ment costs range from $4,500 to $10,000for DPFs, and from $700 to $2,500 forDOCs.2 Particulate pollution removalefficiencies (for direct particulate matter)are assumed to range from 80% to 95%for DPFs, and from 20% to 35% forDOCs.3 The analysis also assumes that40% of on-road engines (i.e., transit andschool buses) manufactured after 1994and 20% of all non-road engines (i.e.,construction equipment) can be retrofitwith a DPF, and that 80% of all on- andnon-road diesel engines can be retrofitwith a DOC. To compare the annualbenefits of PM2.5 emission reductionsfrom engine retrofits with annualizedcosts, the analysis assumes that retrofitsoccur midway through a 15-year depreci-ating engine life, and amortizes equip-ment costs over seven years.

PM2.5 emission rates for existingvehicles were obtained for each of thecounties included in this analysis fromEPA’s National Emissions Inventory(NEI) for 2001.4 NEI emissions forschool and transit buses are includedin the Heavy Duty Diesel Vehicle-Bus(Transport and School Bus) vehiclecategory, which includes emissionsfrom brakes, tires and exhaust. Exhaustemissions were separated out and usedexclusively in this analysis. NEI emissionsfor construction equipment are includedin the Construction & Mining Equip-ment vehicle category. This category in-cludes pavers, plate compactors, rollers,scrapers, paving equipment, surfacingequipment, signal boards/light plants,trenchers, bore/drill rigs, excavators,concrete/industrial saws, cement andmortar mixers, cranes, graders, off-highway trucks, crushing/processing

equipment, rough terrain forklifts, rubbertire loaders, tractors/loaders/backhoes,crawler tractor/dozer, skid steer loaders,off-highway tractors, dumpers/tenders,and other construction equipment.

County-level counts of school andtransit buses were estimated using NEIemissions and vehicle miles traveled(VMT) data. Based on the MOBILE6model, school buses are assumed totravel 9,939 miles annually and transitbuses are assumed to travel 35,113 milesannually. School and transit bus VMTdata were divided by these annual aver-ages, respectively, to estimate the num-ber of school and transit buses in eachcounty. The resulting bus number esti-mates were compared with other data-bases such as the Department ofTransportation’s National Transit data-base. Because the NEI-VMT derivedbus estimates for some of the areasexamined in this analysis appeared lowerthan suggested in other databases, theestimated number of buses for all countieswas doubled. County-level counts ofconstruction vehicles were obtainedfrom EPA’s Office of Transportationand Air Quality.

Because DPFs are effective onvehicles manufactured after 1994, thisanalysis estimates the age distributionof state school bus fleets using datareported in the Union of ConcernedScientists’ 2002 report: Pollution ReportCard: Grading America’s School Bus Fleets.Age distributions for transit bus fleetsare based on MOBILE6 Fleet Char-acterization Data.

The estimate of the health benefitsassociated with PM2.5 emission reduc-tions from diesel engine retrofits and theassociated monetization of those bene-fits was based on direct scaling with thePM2.5 emission reductions and associ-ated health benefits and monetary bene-fits under the EPA Nonroad DieselEngine Rule as reported in Chapter 9

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of the Final Regulatory Analysis: Controlof Emissions from Nonroad Diesel Engines(hereinafter “Regulatory Analysis”). Theestimated benefits in the RegulatoryAnalysis are based on 2030 data, whichassume full implementation of the non-road diesel rule.5 The correspondingbenefits associated with the two retrofitscenarios (i.e., DPFs and DOCs) wereestimated by applying the ratio of PM2.5

emissions reductions from the retrofitscenarios to the PM2.5 emission reduc-tions assumed in the Regulatory Analy-sis. The benefits of the retrofit scenarioswere further scaled back to account forthe difference between projected 2030U.S. population and 2001 U.S. popula-tion levels.

Although the health benefits associ-ated with diesel engine retrofits con-tinue over several years, the retrofitanalysis estimates annual PM-relatedhealth benefits, and does not discountfuture benefits that occur in later years.Furthermore, although there is a recog-nized time lag between reductions inPM exposure and decreases in theoccurrence of adverse health effects, theretrofit analysis applies the simplifyingassumption of full realization of reduc-tions in PM exposure and reductions inadverse health impacts (i.e. the analysisdoes not apply a distributed lag struc-ture to the benefits estimation).

The retrofit analysis estimates themonetary value of the health benefitsassociated with diesel engine retrofitsby applying the unit values used foreconomic valuation of the PM-related

health endpoints reported in the non-road diesel Regulatory Analysis to the(health) incidence reductions associatedwith each retrofit scenario. All monetaryvalues are expressed in 2000 dollars.PM-related health endpoints includepremature mortality, chronic bronchitis,non-fatal heart attacks, respiratoryhospital admissions, acute bronchitis,asthma exacerbations, upper and lowerrespiratory symptoms, work loss days,and minor restricted activity days.

With the exception of non-fatal heartattacks, the nonroad diesel RegulatoryAnalysis expresses the monetary valuesof health-related benefits associatedwith reduced PM exposure as point esti-mates. However, the monetary benefitsof reduced non-fatal heart attacks assumeillness costs and lost earnings in lateryears and are discounted at rates of threeand seven percent. The economic valueof reduced work loss days is estimatedby applying 2001 average metropolitan-area wage data from the Bureau ofLabor Statistics.

Estimating the benefits of dieselpollution reduction scenariosThe range of capital costs associatedwith retrofitting construction equip-ment, and school and transit buses inthe 88 counties and Washington, D.C.included in this analysis is shown in theTable 5. Although diesel oxidizationcatalysts are less expensive than dieselparticulate filters, the aggregate costs ofDOC retrofits are higher than those of

TABLE 5Range of estimated capital costs and benefits

DPF DOC Value used in analysis

Low capital cost estimate $731.0 million $470.0 million $600.5 millionHigh capital cost estimate $1.62 billion $1.68 billion $1.65 billionLow value of benefits estimate $10.6 billion $18.1 billion $10.6 billionHigh value of benefits estimate $10.9 billion $19.2 billion $19.2 billion

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DPF retrofits because more engines canbe retrofit with a DOC.

Table 5 also shows the range of bene-fits associated with the diesel engineretrofit scenarios. These benefits accrueover the remaining life of a retrofittedengine, which this analysis assumes tobe seven years. The monetary values ofthe health benefits are related to PM2.5

emission reductions, which are in turnrelated to the PM2.5 reduction efficien-cies of the retrofit technology and thenumber of engines that are retrofitted.

The net present value (NPV) of thebenefits associated with diesel engineretrofits was analyzed (1) consideringthe lowest benefit stream within thefour scenarios analyzed which was DPFretrofits with a relatively low PM removalrate of 80 percent, and (2) consideringthe highest benefit stream which wasDOC retrofits with a relatively highPM removal rate of 35 percent.

The benefits of diesel engine retro-fits—the avoided instances of adversehealth effects—span the remaininguseful life of the retrofitted engine,which this analysis assumes to be sevenyears. The monetary value of healthbenefits increases over time. The in-creasing value of some benefits, such asavoided premature deaths and avoidedwork loss and minor restricted activitydays, are related to wage and pricelevels, while the monetary value of otherbenefits, such as chronic and acutebronchitis, non-fatal heart attacks,respiratory hospital admissions, asthmaexacerbations, and upper and lowerrespiratory symptoms, are related to

health care costs, which are increasingmuch more rapidly than the overall pricelevel. Total national health expendituresin the U.S. increased by 7.7% in 2003over 2002—four times the rate of infla-tion in 2003.6 Over the next severalyears, health care expenditures are fore-cast to increase by 7.1% annually7, ascompared to the long-range consumerprice index forecast of 2.4 percent.8

The two retrofit scenarios (i.e., DPFsand DOCs) were selected because theyreflect widely available technology andtwo substantially different approachesto diesel pollution reduction strategies.The DPF scenario reflects the appli-cation of technology that can achievea very high degree of particulate pollu-tion removal for the engines affectedbut can only be applied to a limited setof engines. Conversely, the DOCscenario reflects lower price technologythat achieves significantly less particu-late pollution removal on a per enginebasis but can be more widely appliedacross fleets thereby reaching a greaterset of engines. The DOC scenarioestimated 605,000 diesel engines wouldbe fitted with pollution control devices.The DPF scenario estimated 148,500engines would be fitted with DPFpollution controls. In actual practice inany single community, the solutions toreduce diesel pollution from existingengines would vary widely depending ontechnological and policy considerations.Further, the options available wouldinclude a suite of technological solu-tions, operational practices such as idlereduction, and engine replacement.

42

Chapter 11 See Environmental Defense, Cleaner Diesel

Handbook at http://www.environmentaldefense.org/go/dieselhandbook for several examples.

Chapter 21 South Coast Air Quality Management

District, Multiple Air Toxics ExposureStudy (MATES-II) in the South CoastAir Basin, March 2000. See http://www.aqmd.gov/matesiidf/es.pdf. Last accessedMay 3, 2005.

2 California Office of Environmental HealthHazard Assessment and American LungAssociation, Factsheet “Health Effects ofDiesel Exhaust,” 2001. See http://www.oehha.ca.gov/public_info/facts/dieselfacts.html. Last accessed May 3, 2005.

3 Environmental Defense, Scorecard, 2002,calculated from 1999 EPA National-scaleAssessment of Air Toxics data. See http://www.environmentaldefense.org/pressrelease.cfm?ContentID=75. Last accessed May 3,2005.

4 California Air Resources Board “RosevilleRail Yard Study,” Oct. 14, 2004. See http://www.arb.ca.gov/diesel/documents/rrstudy/rcexecsum.pdf. Last accessed May 3, 2005.

5 Schwartz, J.; Dockery, D.; Neas, L. (1996)“Is Daily Mortality Associated Specificallywith Fine Particles?” Journal of the Airand Waste Management Association46: 927–39.

6 Brown, J. S.; Zeman, K.L.; Bennett, W.D.(2002) “Ultrafine particle deposition andclearance in the healthy and obstructedlung.” Am. J. Respir. Crit. Care Med. 166:1240–1247.

7 Garshick, E.; Laden, F.; Hart, J.E.; Rosner,B.; Smith, T.J.; Dockery, D.W.; Speizer, F.E.(2004) “Lung Cancer in Railroad WorkersExposed to Diesel Exhaust.” EnvironmentalHealth Perspectives 112: 1539–1543.

8 California Office of Environmental HealthHazard Assessment and American LungAssociation, Factsheet “Health Effects ofDiesel Exhaust,” 2001. See http://www.oehha.ca.gov/public_info/facts/dieselfacts.html. Last accessed May 3, 2005.

Notes

9 South Coast Air Quality ManagementDistrict, Multiple Air Toxics ExposureStudy (MATES-II) in the South CoastAir Basin, March 2000. See http://www.aqmd.gov/matesiidf/es.pdf. Last accessedMay 3, 2005.

10 California Office of Environmental HealthHazard Assessment, “Health RiskAssessment for Diesel Exhaust” (May1998).

11 Nemmar, A.; Hoet, P.H.M.; Dinsdale, D.;Vermylen, J.; Hoylaerts, M.F.; Nemery, B.(2003) “Diesel Exhaust Particles in LungAcutely Enhance Experimental PeripheralThrombosis.” Circulation. 107:1202–1208.Salvi, S.; Blomber, A.; Rudell, B.; Kelly, F.;Sandstrom, T; Holgate, S.T.; Frew, A. (1999)“Acute Inflammatory Responses in theAirways and Peripheral Blood AfterShort-Term Exposure to Diesel Exhaustin Healthy Human Volunteers.” Am. J.Respir. Crit. Care Med. 159:702–709.

12 California Office of Environmental HealthHazard Assessment and American LungAssociation, Factsheet “Health Effects ofDiesel Exhaust,” 2001. Available online athttp://www.oehha.ca.gov/public_info/facts/dieselfacts.html.

13 Nel, A.E.; Diaz-Sanchez, D.; Ng, G.; Hiura,T.; Saxon, A. (1998) “Enhancement ofallergic inflammation by the interactionbetween diesel exhaust particles and theimmune system.” J. Allergy Clin. Immunol.102(4 pt 1):539–554.McConnell, R.; Berhane, K.; Gilliland, F.;London, S.J.; Vora, H.; Avol, E.;Gauderman, W.J.; Margolis, H.G.;Lurmann, F.; Thomas, D.C.; et al. “Airpollution and bronchitic symptoms insouthern California children with asthma.”Environ. Health Perspect. 107(9):1–9(1999).

14 EPA, National Center for EnvironmentalAssessment, Air Quality Criteria for Par-ticulate Matter (October 2004). Availableonline at http://cfpub2.epa.gov/ncea/cfm/recordisplay.cfm?deid=87903.

15 Delfino, R.J.; Quintana, P.J.; Floro, J.;Gastanaga, V.M.; Samimi, B.S.; Kleinman,M.T.; Liu, L.J.;Bufalino, C.; Wu, C.F.;McLaren, C.E. (2004) “Association of

43

FEV1 in asthmatic children with personaland microenvironmental exposure toairborne particulate matter.” Environ.Health. Perspect. 112: 932–941.Penttinen, P.; Timonen, K.L.; Tuttanen, P.;Mirme, A.; Ruuskanen, J.; Pekkanen, J.(2001) “Ultrafine particles in urban air andrespiratory health among adult asthmatics.”Eur. Respir. J. 17: 428–435.H. Desqueroux et al. (2002) “Short-TermEffects of Low-Level Air Pollution onRespiratory Health of Adults SufferingFrom Moderate to Severe Asthma,”Environmental Research Vol. 89(Section A):29–37.

16 Devlin, R.B.; Ghio, A.J.; Kehrl, H., et al.(2003) “Elderly humans exposed to con-centrated air pollution particles havedecreased heart rate variability.” Eur. Respir.J. 21(suppl 40):76–80.Gold, D.R.; Litonjua, A.; Schwartz, J.;Lovett, E.; Larson, A.; Nearing, B.; Allen,G.; Verrier, M.; Cherry, R.; Verrier, R.(2000) “Ambient Pollution and Heart RateVariability.” Circulation 101: 1267–1273.Magari, S.R.; Hauser, R.; Schwartz, J.; et al.(2001) “Association of heart rate variabilitywith occupational and environmentalexposure to particulate air pollution.”Circulation. 104:986–991.Pekkanen, J.; Peters, A.; Hoek, G., et al.(2002) “Particulate air pollution and risk ofST-segment depression during repeated sub-maximal exercise tests among subjects withcoronary heart disease: the Exposure andRisk Assessment for Fine and UltrafineParticles in Ambient Air (ULTRA) study.”Circulation. 106:933–938.Peters, A.; Liu, E.; Verrier, R. L.; Schwartz,J.; Gold, D. R.; Mittleman, M.; Baliff, J.;Oh, J. A.; Allen, G.; Monahan, K.; Dockery,D. W. (2000) “Air pollution and incidence ofcardiac arrhythmia.” Epidemiology 11: 11–17.Peters, A.; von Klot, S.; Heier, M.;Trentinaglia, I.; Hormann, A.; Wichmann,E.; Lowel, H. (2004) “Exposure to Trafficand the Onset of Myocardial Infarction.”New England J. of Medicine 351: 1721–1730.Peters, A.; Dockery, D.W.; Muller, J.E.; etal. (2001) Increased particulate air pollutionand the triggering of myocardial infarction.Circulation. 103:2810–2815.

17 62 Fed. Reg. 38,856 ( July 18, 1997); Bell,M.L.: McDermott, A.; Zeger, S.L.; Samet,

J.M.; Dominici, F. (2004) “Ozone andShort-term Mortality in 95 US UrbanCommunities, 1987–2000.” Journal of theAmerican Medical Association292:2372–2378.

18 See http://www.epa.gov/ozonedesignations/.Last accessed April 5, 2005.

19 See http://www.meca.org/jahia/Jahia/engineName/filemanager/pid/229/retrofitfact.PDF?actionreq=actionFileDownload&fileItem=214. Lastaccessed April 28, 2005.

20 Paul W. Park, “Correlation BetweenCatalyst Surface Structure and CatalystBehavior: Selective Catalytic Reduction withHydrocarbon.” May 21, 2002. EMSL 2002.Richland, Washington. See http://www.emsl.pnl.gov/new/emsl2002/abstracts/park.doc.Last accessed April 28, 2005. The CaliforniaAir Resources Board has verified a Lean NOx

catalyst at a 25% reduction in NOx. The veri-fied Lean NOx catalyst is used in combina-tion with a Diesel Particulate Filter. Seehttp://www.arb.ca.gov/diesel/verdev/level3/level3.htm. Last Accessed April 28, 2005.

21 See http://www.meca.org/jahia/Jahia/engineName/filemanager/pid/229/retrofitFAQ%20%28revised%29.pdf?actionreq=actionFileDownload&fileItem=712. Last accessed April 28, 2005.

22 California Air Resources Board. “The CarlMoyer Memorial Air Quality StandardsAttainment Program Guidelines: ApprovedRevision 2003.” September 30, 2003. Seehttp://www.arb.ca.gov/msprog/moyer/2003moyerguide.pdf Last accessed May 3, 2005

23 Texas State House of Representatives.“House Bill 1365.” §8(a) Effective June 22,2003. See http://www.capitol.state.tx.us/cgi-bin/tlo/textframe.cmd?LEG=78&SESS=R&CHAMBER=H&BILLTYPE=B&BILLSUFFIX=01365&VERSION=5&TYPE=B Last accessed May 3, 2005.

24 U.S.EPA Health Assessment Documentfor Diesel Engine Exhaust, May 2002,EPA/600/8-90/057F.

25 See, e.g., Norris, G., et al. (1999) “AnAssociation Between Fine Particles andAsthma in Emergency Department Visitsfor Children in Seattle,” Environ. HealthPerspect. 107: 489–493.Tolbert, P.E., et al. (2000) “Air Quality andPediatric Emergency Room Visits for

44

Asthma in Atlanta, Georgia,” Am. J.Epidemiol. 151:798–810.Gauderman, J.W., et al. (2000) “AssociationBetween Air Pollution and Lung FunctionGrowth in Southern California Children,”American Journal of Respiratory andCritical Care Medicine 162:1383–1390.

26 American Academy of Pediatrics, “AmbientAir Pollution: Respiratory Hazards to Chil-dren,” American Association of PediatricsNews, 1993. See also Landrigan, P., et al.(1998) “Children’s Health and the Environ-ment: A New Agenda for PreventionResearch,” Environmental Health Per-spectives 106 (suppl. 3): 787–94

Chapter 31 EPA (2000) Regulatory Impact Analysis:

Heavy Duty Engine and Vehicle Stan-dards and Highway Diesel Fuel SulfurControl Requirements, Table VII-19,EPA420-R-00-026, December 2000.

2 Ibid.3 EPA (2004a) Final Regulatory Analysis:

Control of Emissions from Nonroad DieselEngines, Table 9-11, EPA420-R-04-007,May 2004.

4 Ibid.

Chapter 41 See http://www.epa.gov/ozonedesignations/.

Last accessed April 5, 20052 See http://www.epa.gov/pmdesignations/

documents/Apr05/factsheet.htm. Lastaccessed April 27, 2005. Also, see generally,http://www.epa.gov/pmdesignations/. Lastaccessed April 5, 2005

3 See http://www.meca.org/jahia/Jahia/engineName/filemanager/pid/229/retrofitfact.PDF?actionreq=actionFileDownload&fileItem=214 Last accessed on April 4, 2005

4 Summary of Products That Are Reported toReduce Particulate Emissions From Diesel-Fueled Engines. Report Appendix IX,California Air Resources Board; 10/2000.See http://www.epa.gov/otaq/retrofit/documents/meca1.pdf Last Accessed onApril 5, 2005

5 EPA (2004) Final Regulatory Analysis:Control of Emissions from Nonroad Diesel

Engines, Table 6.5-3, EPA420-R-04-007,May 2004

6 See http://www.meca.org/jahia/Jahia/engineName/filemanager/pid/229/retrofitfact.PDF?actionreq=actionFileDownload&fileItem=214. Lastaccessed on April 4, 2005

7 Summary of Products That Are Reported toReduce Particulate Emissions From Diesel-Fueled Engines. Report Appendix IX, Cali-fornia Air Resources Board; 10/2000. Seehttp://www.epa.gov/otaq/retrofit/documents/meca1.pdf Last Accessed on April 5, 2005.

8 EPA, 2004, Table 6.5-39 EPA (2000) Regulatory Impact Analysis:

Heavy Duty Engine and Vehicle Standardsand Highway Diesel Fuel Sulfur ControlRequirements, EPA420-R-00-026,December, Table ES-5.

10 EPA (2004a) Final Regulatory Analysis:Control of Emissions from Nonroad DieselEngines, EPA420-R-04-007, May 2004,Table 9-17.

11 Marshall, Julian D. and Eduardo Behrentz,“Vehicle Self-Pollution Intake Fraction:Children’s Exposure to School BusEmissions,” Environ. Sci. Technol. 39,2559–2563 (2005).

12 Id.

Chapter 51 The diversity of programs described here

reflects the varying needs of individualprojects with respect to equipment, location,fuel availability, and other related factors.This is not a comprehensive list of successfulretrofit projects across the country andEnvironmental Defense does not endorseany particular retrofit technology or retrofittechnology manufacturer.

2 Environmental Defense’s CleanerDiesel Handbook may be found athttp://www.environmentaldefense.org/go/dieselhandbook

3 See http://www.epa.gov/ozonedesignations/regions/region2desig.htm. Last accessedApril 18, 2005.

4 See http://www.epa.gov/pmdesignations/finaltable.htm. Last accessed April 18, 2005.

5 New York State Assembly. N.Y. ALSChapter 259, Assembly Bill 11700 (2004).New York State Governor’s Office. “PressRelease: Governor Signs Bill Creating the

45

Coordinated Construction Act for LowerManhattan.” August 10, 2004. See http://www.state.ny.us/governor/press/year04/aug10_1_04.htm Last accessed May 3, 2005.

6 Ibid.7 New York, NY, Local Law 77, §2(f )(1)

(2003). See http://www.nyccouncil.info/pdf_files/bills/law03077.pdf. Last accessedMay 2, 2005

8 See http://www.cleanaircommunities.org/projects/huntspoint.html. Last accessedMay 3, 2005.

9 Ibid.10 See http://www.epa.gov/cleanschoolbus/

basicinfo.htm. Last accessed on April 13,2005.

11 See Children’s Exposure to Diesel Exhaust onSchool Buses, http://www.ehhi.org/reports/diesel, last accessed on April 13, 2005. Seealso Marshall, J.D.; Behrentz, E. (2005)“Vehicle Self-Pollution Intake Fraction: Chil-dren’s Exposure to School Bus Emissions,”Environ. Science Technol. 39, 2559–2563.The Natural Resources Defense Council andthe Coalition for Clean Air issued a reportexamining children’s exposure to diesel ex-haust on school buses called, No Breathing inthe Aisles. This report found that a child rid-ing inside a diesel school bus may be exposedto as much as four times the level of dieselexhaust as someone riding in the car immedi-ately in front of that same bus. See http://www.nrdc.org/air/transportation/schoolbus/schoolbus.pdf. Last accessed April 13, 2005.

12 See http://www.epa.gov/cleanschoolbus/funding.htm. Last accessed April 13, 2005

13 See http://www.epa.gov/otaq/schoolbus/demo_projects.htm. Last accessed April 13,2005.

14 See http://okemos.k12.mi.us/users/admin/about.htm. Last accessed April 16, 2005.


16 See http://www.cleanairfleets.org/altfuels.html. Last accessed April 16, 2005.


18 See http://cleanairtn.org/tnschoolbus.php.Last accessed April 16, 2005.


20 Information based on Donaldson letter toEnvironmental Defense dated March 25,2004.

21 See http://www.catf.us/publications/view/82. Last accessed April 13, 2005.

22 The CATF study found that a bus equippedwith a diesel oxidation catalyst (DOC)showed cabin levels of ultrafine particles,black carbon and PAH that were similar inmagnitude to those observed in conventionalbuses. Thus, the CATF found it difficult toascertain whether a DOC provided anyin-cabin benefit. See http://www.catf.us/publications/view/82. Last accessedApril 27, 2005

23 See http://www.epa.gov/cleanschoolbus/antiidling.htm. Last accessed April 27, 2005.

24 See http://www.epa.gov/cleanschoolbus/idle_fuel_calc.htm. Last accessed April 27,2005. EPA uses a fuel cost of $1.50 pergallon to make this calculation although theEnergy Information Administration showscurrent highway diesel retail prices at about$2.18 per gallon.

25 EPA’s website offers guidance about settingup anti-idling programs. See http://www.epa.gov/cleanschoolbus/antiidling.htm. Lastaccessed April 27, 2005.

26 Regional Transportation District, “State-of-the-art FREE MallRide facts.” See http://www.rtd-denver.com. Last accessed May 2,2005.

27 See http://www.epa.gov/smartway/idlingimpacts.htm. Last accessed May 2,2005

28 Ibid.29 Ibid.30 See http://www.ctre.iastate.edu/pubs/truck

_idling/gaines.pdf, slide 6. Last accessedMay 3, 2005.

31 See http://www.epa.gov/smartway/idlingimpacts.htm. Last accessed May 2,2005.

32 See http://fleetowner.com/equipment/whatsnewin/fleet_whats_new_auxiliary/.Last accessed May 2, 2005.

33 Ibid.34 See

http://www.eere.energy.gov/cleancities/idle/truck_elec.html. Last accessed May 2, 2005.

35 See http://www.epa.gov/smartway/idlingalternatives.htm. Last accessed May 2,2005.

46

36 See http://www.nitesystem.com/index.cfm/news?id=4. Last accessed May 2, 2005.

37 See http://www.eere.energy.gov/state_energy_program/project_brief_detail.cfm/pb_id=727. Last accessed May 2, 2005.

38 See http://daq.state.nc.us/news/pr/2004/diesel_10252004.shtml. Last accessedMay 2, 2005.

39 See http://www.idleaire.com/technology.Last accessed May 2, 2005.

40 See http://www.idleaire.com/products_and_services/fleets/. Last accessed June 10,2005.

41 See http://tonto.eia.doe.gov/oog/info/gdu/gasdiesel.asp. Last accessed May 30, 2005.

42 ENVIRON, Cold Ironing Cost EffectivenessStudy, prepared for the Port of Long Beach,March 30, 2004. See http://www.polb.com/pdfs/4_environment/Cold-Ironing-Report.pdf. Last accessed May 3, 2005.

43 Princess Cruise Lines, Press release,“Princess Ships to Connect to Shore Powerin Seattle for 2005 Summer Season,” Sep-tember 30, 2004. See http://www.princess.com/news/article.jsp?newsArticleId=na703.Last accessed May 3, 2005.

44 For a description of the West Coast DieselEmissions Reduction Collaborative, seehttp://www.westcoastdiesel.org/. Lastaccessed May 2, 2005.

45 Correspondence with Tom Hudson, PugetSound Clean Air Agency, December 22,2004.

46 The New York, Northern New Jersey, LongIsland Nonattainment Area CommercialMarineVessel Emissions Inventory (prepared forthe Port Authority of New York and NewJersey, USACE, New York District, StarcrestConsulting Group, LLC, April 2003),page 88.

47 Overview of State and Local Air QualityNeeds and Requirements to Reduce Emis-sions at Marine Ports,” presentation of HenryHogo, South Coast air Quality ManagementDistrict, at the U.S. Maritime AdministrationWorkshop on Maritime Energy and CleanEmissions, January 2002, http://www.marad.dot.gov/NMREC/conferences_workshops/jan%2029-30%202002/hogo.pdf. Last ac-cessed May 8, 2005. Carl Moyer Program2004 Guidelines, available online at http://www.ncuaqmd.org/marine_vessel2004guidelines.pdf. Last accessed May 2, 2005

48 Port of Los Angeles, News Release, “Boardof Harbor Commissioners Approve First-Ever Port of Los Angeles Rail Policy,”August 13, 2004. Seehttp://www.ewire.com/display.cfm/Wire_ID/2261. Last accessed May 3, 2005

49 Los Angeles Times, “New Hybrid Loco-motive’s Emissions Are Clean As AWhistle,” March 25, 2005.

50 EPA, “Case Study: Chicago LocomotiveIdle Reduction Project,” March, 2004,EPA420-R-04-003. See http://www.epa.gov/smartway/documents/420r04003.pdf.Last accessed May 3, 2005.

Appendix A1 U.S. Department of Health and Human

Services, “Tenth Report on Carcinogens,”National Toxicology Program, ResearchTriangle Park, NC, 2002. See http://ehp.niehs.nih.gov/roc/tenth/profiles/s069dies.pdf. Last accessed May 2, 2005

2 California Air Resources Board, EmissionsInventory 1995, Technical Support Division,October 1997.

3 U.S. Environmental Protection Agency,“1970 - 2002 Average annual emissions, allcriteria pollutants,” 2005. See http://www.epa.gov/ttn/chief/trends/trends02/trendsreportallpollutants010505.xls. Lastaccessed June 10, 2005.

4 Ibid.5 68 Fed. Reg. 9,745 at 9,768. (February 28,

2003).6 U.S. DOE Energy Information Admin-

istration, “Emissions of GreenhouseGases in the United States 2003,”DOE/EIA-0573(2003), December 2004.See http://www.eia.doe.gov/oiaf/1605/ggrpt/index.html. Last accessed May 2,2005

Appendix B1 EPA (2004a), Final Regulatory Analysis:

Control of Emissions from Nonroad DieselEngines, EPA420-R-04-007 (May 2004).

2 California Air Resources Board, Summary ofProducts That Are Reported to Reduce Particu-late Emissions From Diesel-Fueled Engines.Report Appendix IX, Oct. 2000. See http://www.epa.gov/otaq/retrofit/documents/meca1.pdf. Last accessed on April 5, 2005.

47

3 Manufacturers of Emission ControlsAssociation, http://www.meca.org/jahia/Jahia/engineName/filemanager/pid/229/retrofitfact.PDF?actionreq=actionFileDownload&fileItem=214. Lastaccessed on April 4, 2005.

4 U.S. EPA, National Emission Inventory(NEI), Emission Factor and InventoryGroup, Office of Air Quality Planning andStandards, January 2005.

5 This analysis is based on the EPA Regu-latory Analysis for proposed nonroad dieselrule (preliminary scenario), in order to avoid

the scaling adjustments EPA applied to thefinal nonroad diesel rule.

6 Smith, Cowan, Sensenig, and Catlin.“Health Spending Growth Slows in 2003.”Health Affairs, 24:1 (2005).

7 Heffler, Smith, Keehan, Borger, Clemeus,and Truffer. “U.S. Health Spending Pro-jections for 2004-201,” Health Affairs,February 23, 2005.

8 Blue Chip consensus projection of annualconsumer price index for 2007–2011.Blue Chip Economic Indicators, March 10,2005.

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