Idle thoughts for the interested student…..

“Idle hands are the devils playground,” many of us heard from our parents and grandparents a long, long time ago.

A modern paraphrase might be “idle locomotives are the devil in the diesel’s details.”

Our purpose this morning is to pass along some information that may be useful to you in understanding the issues associated with LD 439, a proposed bill before the Maine Legislature, that would limit excessive idling by passenger trains.  The information is in the form of summary notes provided to the Legislature’s Transportation Committee as they considered the bill.

The first part of these notes were provided following public testimony at a hearing on the bill, and before the work session was held.  (APU stands for Auxiliary Power Unit; IST stands for Idle Stop Technology.)

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Summary Notes on APU's and IST's as Related to LD 439

Operational Background:

• NNEPRA is a state agency, and operates scheduled Downeaster passenger rail service between Boston and Brunswick.

• Three train-sets, each with locomotives and coach/cafe cars, are employed to provide the service.

• Train-sets are in actual operation approximately 40% of the time; 60% of their daily duty cycles are 'standby mode.'

• Current protocols dictate that standby mode requires locomotive idling, regardless of location or ambient temperature. (Throttle settings vary during idling periods. Existing on-board automatic engine start-stop systems (AESS) facilitate idling operations.)

Economic Consequences of Current Idling Protocols:

• Downeaster service has been in operation for 13 plus years, or nearly 5,000 days. Idling for an aggregate of 40 hours per day means 200,000 idling hours to date. At an average fuel cost of $55 per hour, this amounts to a total of $11 million in non-productive operating expenses since inception. (Figures assume Standby throttle setting, fuel consumed at 22 gph, and average cost of $2.50 per gallon.)

• In view of these figures, suggestions that the Downeaster is a benefit to the environment and improves Maine's Air Quality are without merit. To the contrary, they suggest that NNEPRA's management skills and commitment to the public trust are questionable.

Technologies Relevant to Passenger Train Idling:

• Downeaster train-sets have two operational requirements while on standby:

  • Coach cars require electrical power to keep HVAC, lighting, and food refrigeration active, and air pressure to keep brakes working.

  • Locomotives require running engines to keep air pressure up, batteries charged, and operating fluids at normal temperatures.

• These requirements are met by idling the locomotive to keep power and braking applied to the coach cars, and to keep locomotives in warmed up, ready-to-go status. (Automated controls vary throttle settings as required.)

• Alternatives to such lengthy idling periods include:

  • Auxiliary Power Units (APU's); these are fixed, site-specific assets that make AC 'plug-in' power available to coach cars and locomotives, delivering 480Volt commercial supply from utility provider.

  • Idle Stop Technology (IST); this is a heating unit installed aboard a locomotive to eliminate the need to idle the diesel engine. Units can either be powered by plug in power from APU's, or self-powered by auxiliary engines using fuel from the locomotives. IST can be integrated with existing on-board AESS systems.

• APU's have been in use for decades, are affordable and reliable, and already exist in Maine and numerous locations elsewhere throughout the US.

  • Rockland, Portland, Rensselaer NY, and MBTA in Massachusetts.

  • Costs per unit depend on the number of train-sets served (reportedly less than $200,000.)

  • Example: MBTA installation at Bradford Station in Haverhill serves four train-sets simultaneously.

• IST units also are available in a variety of types:

  • Units are available from three US manufacturers and at least one German company serving North America (examples: Hotstart, AST.)

  • Costs per unit are in the $20,000 to $40,000 range depending on options selected.

Affected Engine/Train-set Population and Status:

• NNEPRA draws from a subset of nominally 20 locomotives in the Amtrak Northeast fleet to meet its operating needs.

• These engines are 'home-roomed' at the Rensselaer, New York operating base, and some may already be equipped with IST units powered by on-site APU's.

• Claims that any and all Amtrak engines nation-wide would be affected are false. Concerns about open flames are similarly without merit.

Statutory Issues:

• Opponents claim Federal authority related to Amtrak operations would render this legislation null and void. NNEPRA, the state agency at which this legislation is directed, is not protected or otherwise exempted by federal authority in these operational specifics.

• Prior challenges and legal interaction confirm the Surface Transportation Board (STB) does not regulate Amtrak. Amtrak is regulated under separate federal legislation and authority. Amtrak legislation relating to municipal and state regulation applies pre-emption only to siting location specifics; Maine AG has affirmed this conclusion.

Possible Amendments for Clarification:

• Bill should apply only to regularly scheduled passenger rail service.

• Passenger trains operated as seasonal, historical, or museum related attractions could be exempted. (Though IST could save $ in the long run, they may not be able to afford APU's and necessary mods to locomotives. Federal funds may be available for these purposes.)

Takeaway:

• Existing NNEPRA idling protocols for Downeaster train-sets are inefficient, outdated, unnecessary, environmentally detrimental, and dangerously unhealthy for effected neighborhoods. They can be mitigated by applying well-known, proven, and cost effective technologies. As a state agency, NNEPRA should be statutorily mandated to comply with such widely-accepted and up-to-date remedial operating procedures, and minimize burden on taxpayers.

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The second part of the notes followed up on questions and responses made at the Work Session.  The Sponsor of the bill is Senator Stan Gerzofsky.

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Summary Notes Following Transportation Committee Work Session for LD 439 Held Thursday, April 9, 2015

Sponsor Note: The following comments are submitted as an addendum to Summary Notes provided prior to the LD 439 Work Session; those notes are attached. All points made there remain wholly relevant and unchallenged.

Location Relevance – State vis-a-vis Brunswick:

• LD 439 was initiated in response to years of suffering by Brunswick residents from excessive Downeaster idling year round during standby periods. This has created a perception that excessive idling is a Brunswick only issue. This is false and misguided.

  • As described in the prior summary notes, the three Downeaster train-sets idle an aggregate of 43 hours a day. Of that, since inception of service to Brunswick more than two years ago, approximately 5 hours per day of that idling has taken place at Brunswick in-town neighborhoods.

  • The remainder of the 43 hours of idling takes place at other standby locations; primarily in Portland. The reduction in Brunswick idling hours due to recent rescheduling simply shifted those idling hours to other locations.

  • The carbon footprint associated with 43 hours a day of standby idling, and the burden of its detrimental impacts on the environment, affects all of us in Maine, and those beyond our borders as well.

  • The estimated consumption of diesel fuel in non-productive idling approaches $1 million per year, and this wasted expense falls upon all taxpayers, not just those of Brunswick.

The Myth of Idling Necessity:

• Claims have repeatedly been made that there is no alternative to idling the engines all year round because of various technical issues. As has been reported to you, train-sets in other states are operating successfully without such excessive idling, and this is enabled with common, affordable technology solutions.

• Previous notes describe how the combination of Auxiliary Power Units (APUs) and Idle Stop Technology (ISTs) provide for all the operational needs of the coach cars and the locomotives.

• More has been learned about the Amtrak locomotive population. In addition to the GE P42s NNEPRA draws from in Rensselaer, there are 18 GE P32 diesel electric locomotives there, all of which came from the factory with IST on board. 17 of those are fitted with wiring harnesses for APU connection.

• Fears that four hours without air pressure necessitates a complete brake system re-certification process are groundless. Use of plug-in power from an APU coupled with an air compressor and battery charger will maintain brake system pressure at specified levels, avoiding any need for retesting and will maintain batteries at full charge to facilitate locomotive startup.

Legalities/Pre-emption:

• As described in the earlier notes, the assertion that the proposed legislation would be rendered useless because of pre-emption is false. Pre-emption applicability on Downeaster operations has already been thoroughly analyzed, and the Maine AG's office confirms that the legislation would not be neutralized by federal law. Further, NNEPRA has not been recognized as a 'railroad,' and as such is not covered by federal pre-emption.

• The two relevant correspondence items are attached.

Analyst Comments of Note:

• “I'm not an attorney.”

• “OPLA would probably say it's probably pre-empted.”

• “Not cut and dried; STB doesn't feel comfortable making final determination.”

• “Massachusetts and Rhode Island have rules in their SIP (State Implementation Plan?)”

Amtrak Representative Comments:

• The following answers to Committee questions were provided by the Amtrak representative present at the work session. Name not clearly heard, but is “Superintendent of Mechanical Department. (Q & A wording is approximate as heard on video.)

  • Q: Where would 'power-plug' be located? A: “I don't know.”

  • Q: What would 'power-plug' do? A: “Help you reduce RPMs and emissions.”

  • Q: How does cold weather impact ability to idle down even with power-plug? A: “Very sensitive to cold; potentially be able to shut down at times.”

  • Q: Are there reasons you don't shut down in warmer weather? A: “We can do it, but the more times you cycle the engine, the more wear and impact on reliability; and there are issues with brakes being shut down too long.”

  • Q: Time frame for installing? A: “10 – 12 weeks for Amtrak to procure. Probably 6 months overall at best.

  • Q: Power-plug would reduce emissions by how much? A: “Don't know what the percentage would be.”

  • Q: Would it be significant? A: “I don't think it will be too significant.”

NNEPRA Executive Director Comments:

• The following answers to Committee questions were provided at the work session by Patricia Quinn, NNEPRA Executive Director. (Again, Q & A wording is approximate as heard on video.)

  • Q: Time line for power-plug? A: “10-12 weeks for order, 3-4 months to install.”

  • Q: Location? A: “Haven't 100% determined location; Brunswick West, or in the wye area before Cedar Street; do it where easiest and most cost effective.”

  • Q: Is location best decided by you or us? A: “We scratched our head on this last summer with the Brunswick Town Manager, and there is no perfect location. We'll go back to the town; go with place of least resistance.” “ we can live with any option agreeable to the Town”

  • Other: “We modified our schedule.” “Power-plug previously at Cedar Street (DOT) – NNEPRA has different requirements. Two tracks, different kinds of plugs.”

Letter from NNEPRA Board Chair:

• The committee is in receipt of a letter from Martin Eisenstein, Chairman of the Board of Directors of NNEPRA. The letter is dated April 6, 2015.

• Many such promises have been made before; none have been fulfilled.

• The assertion that an enclosed layover facility will eliminate the problem is abjectly false and disingenuous.

  • Notice the words “eliminate the need for train engines to run outdoors between runs and reduce the number of trains which run outdoors in Portland as well.” That is, the train engines will run indoors in Brunswick. There will be no less running of engines on an aggregate basis, and substantive likelihood there will be more.

  • Under current protocols, an average of one train-set idles for about 5 hours in Brunswick every day. The need for substantial track repairs may affect the location, but not the total idling period.

  • Under the proposed layover facility operating scenario, three train-sets will layover in Brunswick, and be maintained at the facility. There has been talk as well of keeping a fourth locomotive at the facility as a 'warm-spare.'

  • Even worse, MBTA documents suggest other Amtrak equipment will be routed to Brunswick for maintenance at the facility.

  • Under these conditions, locomotive idling in Brunswick can be expected to grow from current levels to approx. 40 hours a day, and likely much more. Note that NNEPRA and Amtrak have insisted that locomotives cannot be shut-down. Parking them under a tin roof will not change that.

  • Idling the engines under a roof will serve only to collect and concentrate the diesel fumes and particulate matter before exhausting them from roof openings via unfiltered ventilation fans. The roof in effect serves as a collection funnel. This may change the dispersion pattern for the emissions compared to open site idling, but all emissions will be exhausted into the nearby neighborhood, and total amounts will be ten times current emissions.

  • Furthermore, workers inside the building will be exposed to concentrated levels of these fumes and diesel dust.

  • In short, the building will not mitigate anything; it will simply change the specifics of how the diesel exhaust reaches the nearby environment, while increasing the daily amounts by an order of magnitude.

  • The technology to be located inside the building to eventually allow complete shutdown could be located outside Maine Street Station as well.

• References to 'additional capital expense' are specious, in that the cost of fuel wasted on idling (~$1 million per year) is completely ignored, as is the wear and tear on the engines from the additional running time.

Sponsor's Takeaways:

• As delineated above, the significance of this operating problem, and the relevance of the proposed LD 439 legislation to address it, are of local, statewide, and broader implication.

• As stated earlier, existing NNEPRA idling protocols for Downeaster train-sets are inefficient, outdated, unnecessary, environmentally detrimental, and dangerously unhealthy.

• Recent offers by NNEPRA to half-heartedly and only partially address the problem have been promised before but never implemented. There is no reason to believe things will be any different this time, and even if they were, the actions proposed do not resolve the offensive circumstances.

• The systemic operating anomalies can be mitigated by applying well-known, proven, and cost effective technologies. As a state agency, NNEPRA should be statutorily mandated to comply with such widely-accepted and up-to-date remedial operating procedures, and to minimize the burden on taxpayers and the environment.

Sponsor's Summary Comments:

• Based on this follow-up to work session discussions, and the attached earlier notes, it is my conviction that nothing of substance has changed, and nothing new has been learned since the public hearing on LD 439. Conversely, the discussions bring to light additional rationale for passage of the bill.

• I therefore respectfully reaffirm my request that you vote out the bill with a unanimous Ought to Pass finding.

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We trust you find these notes and factoids mesmerizing.  At the very least, they should make you a more informed listener in related discussions between the Executive Director of NNEPRA, the operator of the Downeaster passenger rail service, and town officials.  You can count on others to assume you are completely uninformed on the issues as they attempt to sway deliberations with ‘romance of the rails’ arguments.

  

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