This is obviously speculation and I don't mean to start a political debate (or I would have posted this on the General Discussion forum).
It seems plausible (or inevitable) that a number of EPA regulations may change significantly with the change in administration....
Could the "Tiered" off road diesel emissions standards be effected?
And if so, what would occur in the U.S Class 1 locomotive market?
Both GE and Cat/Progress/EMD have invested a lot in developing Tier IV complaint locomotives. Could this turn out to be money and time wasted?
It seems to me that if there is a drop or end to orders for Tier IV locomotives in the near future it may signify that the railroads don't want to further gamble with the higher maintenance and other costs associated with the newer emissions control technology when regulatory changes may be just around the corner..
"I Often Dream of Trains"-From the Album of the Same Name by Robyn Hitchcock
If I have anything to say about it, the Tier 4 final NOx regulation will be edited slightly, just enough to make it practical for sanely-modified EMD 2-stroke engines to make regulation emissions without difficulty over the range of expected operation. If I remember correctly this is something like 0.3 of a percent off the nominal standard (which was essentially pulled out of some twenty-something bureaucrat's hat as a nice large reduction in 'pollution' over what Tier 3 provided).
This is similar to my opinion about the imposition of the 'double nickel' political speed limit after the first OPEC 'oil shock'. It would have made far better sense in most respects to have gone straight to 100kph, a nice round, high-sounding metric number that corresponds to an economic operating gear speed for many contemporary Class VIII trucks. (And then I wouldn't have used the expedient of tempting the state enforcement agencies into enforcing the limit as strictly as they could get away with, for their own gain...)
I don't think too many people in Muncie are going to complain that 'all their hard work in 'ginning up a Tier 4 final solution' is wasted just because they could go back to building locomotives with reasonable pollution control cost. They'll appreciate a corrected mistake, won't they?
"Double-nickle?" Don't remind me! No disrepect intended, but have you ever done 55 mph over the long, flat, endless plains of Nebraska? I did, in 1975.
And in a Volkswagen "Beetle" no less! I didn't think I'd ever get across!
I don't think either major locomotive builder would object to a standard more easily reached by the locomotives they built for Tier III.
GE are still building ES44ACi units for Australia (or at least did so very recently) and EMD built some SD70 ACe/lc for the same place units a couple of months earlier.
Quite apart from the Tier IV credit units built recently.
If money can be saved by a small adjustment to the standard, you would hope that the Trump administration and their friends in Congress would do the right thing.
M636C
Or maybe Tier III is clean enough. I run the operations for an entity that has to do a lot of snow plowing in very cold weather. The units with Tier III motors run just fine in all conditions, but the units with Tier IV motors get very temperamental in very cold weather because the fuel filter for Tier IV is so fine that if there is even a hint of viscosity in the diesel fuel they are wont to clog up.
This may only be a temporary reprieve, though, and I think that the builders will be careful to hedge their Tier IV solutions lest the regulations return...
I'd wonder if a Tier 3.5 standard would result in more reductions on emissions than the Tier IV standard. Setting tighter limits for new locomotives doesn't do much good if no one buys new locomotives.
I wonder what Tier the FEC obtains with their natural gas units? I would suspect it has to make a significant difference but at what cost of capital, fuel and maintenance compared to operating a Tier IV diesel and that cost of capital, fuel and maintenance? I guess FEC is getting the real world data on the natural gas side of the equation.
GE already has sold hundreds of their Tier IV products to several major customers. I believe several of these have returned for repeat orders as well, besides Norfolk Southern (But it has only been 5 months or so, so wait for their 2017 capital plans to be announced).
With them seemingly further ahead of the game than ever before, I wouldn't count on them wanting to see this happen or not taking advantage of their power to lobby against any attempt to backtrack on standards that could improve EMD's competitive position after GE made the investment to get it right.
And there's every chance that EMD has succeeded, albeit later than their competitor, and doesn't even need this to again attempt to compete. EMD's demos haven't rolled that many miles and could be impressing potential customers rather than turning them away like I assume we're thinking is happening.
Plus they weren't exactly lighting the world on fire before Tier IV came around so it's in their best interest to advance the state of the art if they're going to recapture lost ground. A reversion to a product that was selling well below what the competition was, combined with a lengthy absence from new locomotive orders, doesn't strike me as exactly the road to success.
The 710 despite all its qualities, is perhaps best left to the ECO repowering line, upgrade programs like the SD70ACu program, export orders, etc. The core of it is still ultimately a 30 year old design, so surely La Grange can design something even better today.
Leo_Ames The 710 despite all its qualities, is perhaps best left to the ECO repowering line, upgrade programs like the SD70ACu program, export orders, etc. The core of it is still ultimately a 30 year old design, so surely La Grange can design something even better today.
There is nothing to prevent EMD from developing a Tier III version of the 1010J engine. It would probably be cheaper to build and might have better fuel economy and is likely to cost less to buy and to maintain.
On the other hand, I supect NS and some other customers would not mind buying some new units with a 710 engine but including any improvements in the Tier IV locomotives.
Equally GE could probably offer a locomotive that took advantage of their Tier IV developments with fewer of the disadvantages.
The 710 has a line of development dating back to 1939, so more than 77 years, although the 567B of the late 1940s and the 567C of the early 1950s were the engines where most of the details were introduced.
The EMD two stroke engines have an established reputation for longevity far exceeding that of the GE FDL series. It remains to be seen if the GEVO or the 1010 can come close to that record. It always costs less if you don't have to replace something large and expensive.
So the consensus that the regulations may be rolled back to Tier III but not completely eliminated?
If and when that happens what becomes of the already delivered GE Tier IV locomotives? Would there be a rush to rebuild them (I imagine that changing the emissions control system would be a major undertaking)? I'm sure General Electric would not be the ones paying for that.
Also, some posters point out that Progress EMD could go back to using the 710 engine which would probably leave the 1010 as an expensive orphan? Could that mean that a roll-back would have negative financial consequences for EMD?
I am talking from my bosses persepective here if the OTR side was rolled back to 2006 but with the cavet we have to keep DPF with SCR onboard. For us that would be the best of both worlds in a way we could get rid of EGR and that is were close to 70-80% of all our issues are coming from. You can not make a turbocharged diesel engine eat it own exhaust and expect it to like it. That is what we have heard may happen from our sources in the ATA and OOIDA as what they think is going to happen. Between that and dumping the Stupid CAFE regulation of 15 MPG for all OTR trucks that was due to be impossed by 2020. If we get the removal of EGR alone we stand to gain close to 50% more reliablity and close to 40% more MPG out of what we are getting for a 2% increase in current emissions. Think about that for a second we will burn 40% less fuel more reliable trucks and have 2% more emissions over the current standards.
Why are we hoping for these changes simple the CBA for what the EPA wants to do are going to be so high and all regulations imposed in the last 20 years are going to be reviewed for accuracy of cost according to ATA and OOIDA sources and when they see the actual costs of what this has cost in Real Money to the economy look for massive changes in how the EPA can mandate stuff. The Era of the EPA coming in and saying do this or your fined I think is going to be OVER forever.
carnej1So the consensus that the regulations may be rolled back to Tier III but not completely eliminated?
Not what I was saying! I'm looking at rolling the Tier 4 final NOx standard back from its current, Tier 4, very low value by about 1/3 of a percent, in order to make it rigorous but something that EMD can meet without great amounts of hardware and careful control (and by extension, other builders, too). The other Tier 4 final components, probably including PM, can stay where they are if (as I understand) no locomotive builder has a problem achieving them with anything more complicated than software that does not take down the life expectancy of engine components (I'm thinking of the 'buzz of death' flash for the Power Cerebrovascular Accident as a cautionary tale here.)
The problems being described for EGR are interesting, because I'd have thought that some of the optimizations to engine control for Tier 4 would reduce the gunk in the recirculated exhaust rather than increase it, and better methods of cooling the exhaust enough to get reasonable charge density without cooling it too much and killing thermodynamic efficiency would have been standardized by now.
The actual idea of recycling the "free" CO2 and reducing atmosphere of exhaust to control the temperature peak during engine combustion (and, perhaps, to promote carbon oxidation over nitrogen oxidation) is not a bad one. When done as FGR it is definitely a good idea. The problem is doing it in the environment of a working truck engine, and by extension a truck engine in random service with as low an expensively-bought control sophistication as possible, and no energy storage either in the engine or transmission. It's a salutary experience to look at what happens to real-world engines that have run EGR for a substantial time, and compare that with the theory used to design them in the first place.
I suspect that one approach to doing the modification in a 'politically optimized' manner would involve keeping the current Tier 4 final NOx in the "standard" somewhere, making the slightly increased version the 'norm' but providing enhanced benefit of some kind for new power that meets Tier 4 final as written.
I think there are benefits for the 1010 as well as the C175/QSK families in this framework, even if the 'carrot' provided isn't enough to sway the railroads in the same way the mandated stick did.
RME the thing is with even the ULSD which is 15PPM of sulphar in it your still creating sulphric acid as a by proudct of combustion and that stuff has a PH of 1 regardless of what you do with it. Then you have it heated and in areosol form and you pass it thru a water or air cooler to get the exhaust your making the engine rebreathe cool enough for it to choke on it. Sulphric acid eats things like aluminum brass copper loves to corrode steel and there are particulates in the exhaust since this is before they are sent thru the exhaust filter to be further processed. So regardless of what acid resistant coating you put into those coolers your going to get corrison sooner than later. Right now we are seeing about 500-600K miles before EGR coolers on our engines fail spectaculary and blow the engine higher than the moon when 10 gallons of coolant mixes with 12 gallons of oil and turns the engine into a 1 ton boat anchor. Then throw in to even get the fuel to burn at the reduced O2 levels as the EPA has mandated up to 30% EGR on OTR engines we have to run at such extreme Injection Pressures our 2016's have a Injector opening pressure of over 45K Psi before the injector even will pop open. We suffer what is called Injector Cup failures where the cup aka the part of the cylinder head the Injector mounts into is literally being cut into 2 parts from the extreme pressure of the fuel being injected into the motor.
These engines are not fun to work on for our mechanics. Heck our head Mechanic right now is in VA trying to learn how to repair our latest batch from Volvo due to they put in a different design on the EGR cooler that they hope will last 750K miles before failing. However we have had 3 fail already on trucks with less than 20K miles. The Theroy of EGR is a good one however trying to make an engine that is turbocharged relies on Compression for its source of Lighting off and oh runs over 100K miles a year is not a good idea.
carnej1 So the consensus that the regulations may be rolled back to Tier III but not completely eliminated? If and when that happens what becomes of the already delivered GE Tier IV locomotives? Would there be a rush to rebuild them (I imagine that changing the emissions control system would be a major undertaking)? I'm sure General Electric would not be the ones paying for that. Also, some posters point out that Progress EMD could go back to using the 710 engine which would probably leave the 1010 as an expensive orphan? Could that mean that a roll-back would have negative financial consequences for EMD?
This is an excellent, excellent thread! Thank you all for an incredibly informative discussion. The enormous amount of experience and intellectual horsepower is evident. It is a most enjoyable read - practically a Trains article created on the fly!
And if Tier 4 is rolled back - how much R&D investment will GE and EMD have made for compliance with Tier 4? Will there be a way for the roll back legislation to rebate that investment to them? Will the Mexican's pay for it?
Never too old to have a happy childhood!
Chances are the next president from the other side will roll the regulations back out if they are rolled back by the Trump Administration. Both builders know this. I expect if they do end up being reversed the builders will simply restart their Tier III lines until they need to return to Tier IV production.
But it could just be modified, not rolled-back completely, to the sensible cost-effective, overall pollution reducing (considering what alternative forms of transportaion pollute) compromise, which should be permanent.
daveklepperBut it could just be modified, not rolled-back completely, to the sensible cost-effective, overall pollution reducing (considering what alternative forms of transportation pollute) compromise, which should be permanent.
I don't think they're listening on this forum.
The point would be to 'rightsize' Tier 4 (and beyond), not abolish it. As noted, the latter would likely result in a string of forward-and-backward tinkering by administration, and no little further effective abuse of the mandate power.
At least we will be spared the horrors of the carbon-credit scam for a few years more.
You guys all realize that the Tier 3 and 4 locomotive emission regs were adopted by EPA during George W. Bush's adminstration in 2008, right? This is one EPA regulation that you can't pin on the Obama administration.
My guess is that both GE and EMD have too much skin in the game right now to want to back out. Also, Canada is moving forward with their own locomotive emission regs, which will likely mirror the US regs. Lastly, advanced emission controls will be needed to sell new locos to EU countries. The EU loco emission regs are what finally killed off the hugely successful EMD Class 66 design in the UK. Even with Brexit, I don't see the UK backpedaling on environmental policy.
I understand the frustration about EMD and the 710-series engine. But, really, it was all EMD's fault. They should have continued development of the 265 engine, if for nothing else to achieve higher horsepower ratings. GE knew that they had to change the base technology of their diesel engines close to 15 years ago with the development of the Tier 2-compliant GEVO's and, thus, were able to make a relatively smooth transition to Tier 3 and then Tier 4. GE has been much more aggressive than EMD and has reaped the rewards of their efforts. It pains me to say this because, as a fan, I am a die-hard EMD man. I sure hope EMD comes up with a winner with the SD70ACe-T4.
Leo_Ames EMD's demos haven't rolled that many miles and could be impressing potential customers rather than turning them away like I assume we're thinking is happening.
EMD's demos haven't rolled that many miles and could be impressing potential customers rather than turning them away like I assume we're thinking is happening.
Did I miss something? Why would we think these units are not demoing successfully? Has a railroad cut their orders? I know UP didn't go for their option to buy more, but they also didn't put in a further order for GE units unless I missed something.
I'd be hard pressed to attribute soft orders to anything other than the current market conditions.
YoHo1975 Leo_Ames EMD's demos haven't rolled that many miles and could be impressing potential customers rather than turning them away like I assume we're thinking is happening. Did I miss something? Why would we think these units are not demoing successfully? Has a railroad cut their orders? I know UP didn't go for their option to buy more, but they also didn't put in a further order for GE units unless I missed something. I'd be hard pressed to attribute soft orders to anything other than the current market conditions.
UP stated in one of their quarterly conference calls this year that they didn't plan on ordering any more new locos (beyond what was already on order) in either 2017 or 2018, barring some radical increase in traffic levels. I think they said that they had close to 1500 loco's in storage at the time.
ns145They should have continued development of the 265 engine, if for nothing else to achieve higher horsepower ratings.
The cavitation situation was hopeless, even in somewhat derated form. And, reading between the lines of some of M636C's comments, a relatively thin-wall complex cast block is woeful trouble a few years down the line when it starts cracking... and with all the complex vibration and ultrasonically-assisted wear and corrosion issues, I'd expect the cracking to commence 'early and often' on a 265 making significant hp.
The evolution of the design into the 1010 (which if I remember correctly is a metric equivalent of 265 displacement) has had, I believe, the same kind of intensive modern design attention that characterized the C175 development at Cat. I for one am interested to see how well the 1010 holds up in service once the maintenance becomes less than perfect.
RME ns145 They should have continued development of the 265 engine, if for nothing else to achieve higher horsepower ratings. The cavitation situation was hopeless, even in somewhat derated form. And, reading between the lines of some of M636C's comments, a relatively thin-wall complex cast block is woeful trouble a few years down the line when it starts cracking... and with all the complex vibration and ultrasonically-assisted wear and corrosion issues, I'd expect the cracking to commence 'early and often' on a 265 making significant hp. The evolution of the design into the 1010 (which if I remember correctly is a metric equivalent of 265 displacement) has had, I believe, the same kind of intensive modern design attention that characterized the C175 development at Cat. I for one am interested to see how well the 1010 holds up in service once the maintenance becomes less than perfect.
ns145 They should have continued development of the 265 engine, if for nothing else to achieve higher horsepower ratings.
But the 1010 is the fruit of continued development of the 265 engine. It is where EMD ended up out of necessity anyway. To be fair, EMD did tweak the 265 engine for the Chinese as part of a 300-unit order for JT56ACe 6,000 HP locos in the mid 2000's. I haven't heard any reports, good or bad, about these locos.
BTW - the 265 was so named based on the cylinder bore size in millimeters. The 1010 is the new name for the 265 engine based on the cylinder displacement in cubic inches, just like the 567, 645, and 710 engines. Plus the 1010 designation discretely directs attention away from its tainted 265 origins.
ns145 ... The evolution of the design into the 1010 (which if I remember correctly is a metric equivalent of 265 displacement)... BTW - the 265 was so named based on the cylinder bore size in millimeters. The 1010 is the new name for the 265 engine based on the cylinder displacement in cubic inches, just like the 567, 645, and 710 engines.
... The evolution of the design into the 1010 (which if I remember correctly is a metric equivalent of 265 displacement)...
BTW - the 265 was so named based on the cylinder bore size in millimeters. The 1010 is the new name for the 265 engine based on the cylinder displacement in cubic inches, just like the 567, 645, and 710 engines.
I'd go back and edit the original post except that it's better to have the correction clearly in this form. Goes to show what happens when people like me don't think while posting. Yes, the 265 is the bore in mm, and I did in fact know that, and in further fact anyone in the least familiar with engines would realize that even with modern technology an engine with "265 displacement" (whether metric or inch) developing high horsepower from the same number of cylinders as, say, a 645 would either need fiendish amounts of boost or ... be a mistake.
I do think, however, that the work done on the 1010 engine has rectified many, perhaps most, of the apparent shortcomings in the '90s engine design. I agree that the new designation has a significant 'market component' in avoiding the dreaded H-engine number.
To be fair, EMD did tweak the 265 engine for the Chinese as part of a 300-unit order for JT56ACe 6,000 HP locos in the mid 2000's. I haven't heard any reports, good or bad, about these locos.
I think that, by itself, may answer the question. If they were bad in any of the 'historical' ways, we'd have heard something about it; if even a fair percentage of the engines remain in service to date, it would seem to me that the operational historical problems with the 265s were remediated.
I'd think M636C would have distinctive competence to answer that.
I'll answer it with a question for you.
Explain to me if there aren't issues here or issues that are at least assumed to be present with GE's offering and EMD's still in development models, why are we even having this conversation for?
Presumably, many posters here don't think that Tier IV is all it's cracked out to be and thus quite possibly isn't the best thing for railroading, locomotive manufacturers, and the environment itself at this point in time.
Heck, it doesn't even have to be a product flaw or an issue with the regulations themselves. It could simply be the cost premium that Class 1's aren't comfortable with compared to the already excellent performance of cheaper Tier III models.
To question what I said is to question the entire point of this thread. There have to be some perceived issues here or this thread would not of received all the activity that it has from some of this forum's most knowledgeable posters where diesel locomotives are concerned.
So I really don't think I was making the giant leap you appear to be thinking I did.
Someones vision of clean air
Shadow the Cats owner RME the thing is with even the ULSD which is 15PPM of sulphar in it your still creating sulphric acid as a by proudct of combustion and that stuff has a PH of 1 regardless of what you do with it. Then you have it heated and in areosol form and you pass it thru a water or air cooler to get the exhaust your making the engine rebreathe cool enough for it to choke on it. Sulphric acid eats things like aluminum brass copper loves to corrode steel and there are particulates in the exhaust since this is before they are sent thru the exhaust filter to be further processed. So regardless of what acid resistant coating you put into those coolers your going to get corrison sooner than later. Right now we are seeing about 500-600K miles before EGR coolers on our engines fail spectaculary and blow the engine higher than the moon when 10 gallons of coolant mixes with 12 gallons of oil and turns the engine into a 1 ton boat anchor. Then throw in to even get the fuel to burn at the reduced O2 levels as the EPA has mandated up to 30% EGR on OTR engines we have to run at such extreme Injection Pressures our 2016's have a Injector opening pressure of over 45K Psi before the injector even will pop open. We suffer what is called Injector Cup failures where the cup aka the part of the cylinder head the Injector mounts into is literally being cut into 2 parts from the extreme pressure of the fuel being injected into the motor. These engines are not fun to work on for our mechanics. Heck our head Mechanic right now is in VA trying to learn how to repair our latest batch from Volvo due to they put in a different design on the EGR cooler that they hope will last 750K miles before failing. However we have had 3 fail already on trucks with less than 20K miles. The Theroy of EGR is a good one however trying to make an engine that is turbocharged relies on Compression for its source of Lighting off and oh runs over 100K miles a year is not a good idea.
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