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EPA classified three types of locomotives with in the beginning different emission limits- Freshly manufactured: new builds or remanufactured using less than 25% used parts by value. Refurbished: A remanufactured locomotive using 25-50% used or reconditioned parts by value with a new regulated engine (more new than old) Remanufactured: EPA’s definition of remanufacturingis“To replace each and every power assembly of a locomotive or locomotive engine, whether during a single maintenance event or cumulatively within a five-year period.” Replacement power assemblies can be new or reconditioned. By value it isn't allowed to fall into the refurbishing category. Freshly manufactured and refurbished locomotives have to comply to the Tier 4 new locomotive emission limits since 2015. Only remanufactured locomotives don't have to follow Tier 4 limits depending on year of original manufacture. Only Tier 0 locomotives have stricter NOx and PM limits after remanufacture, Tier 0+ = Tier 1. Though the Tiers after remanufacture are called 1+, 2+ they are the same as 1, 2 regarding NOx and PM limits. So there are regulations for rebuilding locomotives. How the NS rebuilds fit into the remanufacture category cost wise I don't know especially all remanufactured locomotives have to comply to the FRA Crashworthiness rule in 49 CFR 229 Subpart D. Regards, Volker
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