I agree. The statement about “typical locomotives” seems to me to be a statement of general information and not binding regulatory text.

I read the regulations, although I am no expert. The understanding I got from reading them is that the fuel limit applies to any locomotive of any kind of propulsion with a prime mover of 1006 horsepower or higher and that burns liquid fuel. I write “liquid fuel” because all of the regulatory limits are measured in gallons. So, if you burned coal/wood, perhaps you would not need to worry.

The regulation uses the word “engine” and not “prime mover,” so in the most literal interpretation it would seem to apply to steam locomotives with 1006 horsepower or higher at the driving wheel. They may not have meant “engine” in this sense, though.

I am left unclear about how the 10,000 gallon limit would apply to a locomotive fleet comprised of some locomotives above 1006 horsepower and some below. If a museum uses 8,000 gallons per year in its large locomotives, could it also burn 5,000 gallons more in the locomotives it has that are below 10006 horsepower?

Also, I am unsure how a museum should apply the regulations to a steam locomotive that was never rated or measured for horsepower output. Or maybe the fact that steam locomotives have no prime mover renders steam outside the scope of the new regulations?

I hope that some helpful clarifications or revisions will come.

This seems to be targeted specifically at diesel locomotives and there is an exemption for historic or interpretive locomotives. Digging a little into the CARB website, they state that they worked with historic locomotive operators in developing the rules. Doesn’t say who. They also state that there are 23 historic locos in the state. That sounds low to me but I’ve never counted. I find no evidence that they’re currently considering steam but maybe that would fall under a different section altogether other than off-road vehicles.

Something to keep in the back of your minds - where goes California in these matters, the rest of the country will eventually follow in some fashion.

There is another avenue open to them. By converting to CNG and using RNG ( renewable natural gas ) they can achieve zero emissions using that proven technology.

Probably won't happen as it would require a major Capex in new refueling infrastructure, all new loco. prime movers etc.

As goes California so goes the nation. Ross Rowland

I'm not sure if that's steam or diesel. The Trains Magazine list for 2022 comes up with 19 steam locomotives that were operated at least one day a year.

https://www.trains.com/trn/railroads/lo ... tive-list/

The second thing that pops up in my mind is that there's a State RR museum in CA, run by their park service. That should open a hole for exemptions for historic equipment that could be pushed with good legal representation to other museums in that state.
And of course, the first thing that pops to mind is the same thing that occurred to most people here in WA state when the governor declared no gas burning autos will be allowed to be sold or bought with a deadline in a few years. And this has been strongly countered with how completely unprepared the state is to support the infrastructure needed to have everyone with an electric car. I talked with a state senator about this not long ago in a chance encounter and asked how the homeless and lower economic level folks (groups who are given a great degree of latitude in this state these days) are supposed to afford electric cars and the stuff needed to charge them, neither of which have any low-cost options.
All I got in reply was a blank stare off into space for a minute, followed by a mumbled, "I doubt people have thought that part out."

Aside from CNG being an inferior technology to proven LNG in a great number of respects... it is not only not 'zero-emission' it it not even 'zero-net-carbon'.

Surely you weren't thinking of reforming CNG and sequestering the CO2 under supercritical pressure on an operating locomotive?

Might be ironic if Steam is exempt, historic diesels aren't, so operating steam becomes more economically viable and there is a sudden increase in market value for small/moderate size steam.

Expect this to be only the start. I was at a large science conference late last year and had a long chat with a pair of young researchers who had set up monitoring equipment along a class 1 ROW going though a disadvantaged neighborhood and were displaying their results on a poster paper.

They were not only monitoring NOX and other emissions, but non-emission particle levels. They measured increases of small non-emission particles during and after the passage of freight trains - in other words the debris kicked up by the passage of the train. They couldn't understand why some trains had higher levels then others. Their eyes popped out when I suggested those higher levels were likely coal drags.

I think it's fair to assume that they're referring to diesel only. Nowhere do I see any mention or hint of steam.

CARB that lovely regulatory agency that literally thinks things through like this. This is the same agency that decreed that a human being trying to sleep in a metal box has zero rights to air conditioning in the desert in a truck that can reach 160+ degrees inside. Yeah California basically says OTR drivers have to cook inside their trucks yet a dog is allowed to have air conditioning or the owner is guilty of animal cruelty and given more time than a murderer in California. Or how they want to same time as this regulation want to ban all diesel powered refrigeration units used to cool fresh meat and produce that are shipped all over the USA and into California along with things like ice cream and frozen foods. This same state also is being sued for several other things in Federal Court that violated the Commerce Clause one of which was Prop 12 their animal welfare act that literally made 80% of all pork farms illegal to run in the USA when there isn't one slaughterhouse in California for pork. Those of us in the Logistics industry call California the land of Fruitcakes and NUTS running the place and the place where you go to get the fruit and nuts for the nation.

LNG might be superior to CNG in many applications but NOT as a railroad locomotive fuel.

CNG is far easier to handle, FAR less dangerous in an accident, ( Google LNG truck accidents and watch the video of the Chinese 18 wheeler that wrecked, punctured its 5,000 gal. LNG tank and when the vapor cloud from the escaping LNG found a guy smoking a cigarette it exploded and vaporized everything within 200 yards), and by using the currently available emissions credits using RNG can achieve zero emissions.

Far, far superior to LNG.

Ross Rowland

The explosion haxards of CNG are well established, and far more than those of LNG.

The risk in LNG release is not gaseous concentration, but the intensity of a developed pool fire. If you look at some of the LNG spill testing, you will see manual ignition, by someone who walks away (!) after the fire starts. Critical-mixture detonation is not the thing that it is with CNG, and any ignition over the pool will not progress to detonation, let alone initiate the rest of the fuel volume.

Fuel density for CNG is relatively pathetic by comparison, and transferring fuel at CNG pressure is fraught with peril in a typical railroad setting -- probably more so as the equipment ages and is mismaintained.

Part of the current advantage for LNG is the advances that have been made in nanoinsulation. With some care in detail design, the boilover losses, for example in buff/draft slosh, can be minimal. Conversely, there is or should be ample waste heat to regasify the LNG for induction at the required mass flow.

I do understand that you made a considerable effort to commercialize CNG locomotives a few years ago, but it really is an inferior solution on locomotives. In my opinion.

It's a pity that neither approach has any hope of traction (pun intended) as we progress to zero-carbon research priority. But I suggest that you look at some of the interesting possibility of conducting reforming in blue-hydrogen generation from natural gas entirely at typical CNG pressure... much of the 'work product' would apply nicely to certain forms of sequestration.

Sorry but I'm not sold. Just watch that Chinese 18 wheeler's vapor cloud devour everything within 200/300 yards and you'll know all you need to about the dangers of LNG in a derailment.

Just imagine the nightmare it would be if a unit train of LNG were to experience a bad wreck and the resulting fires consumed all 100 tank cars each carrying 25,000 gals. of LNG.

When you witness what chaos and damage the 5,000 gals. of LNG caused in the Chinese video and then extrapolate that to 2.5 million gals. on a railroad unit train it's truly hard to imagine the destruction that would result especially if the wreck happened in an East Palestine type setting.

LNG is far to dangerous to ever be moved in quantity on the railroad.

IMHO-Ross Rowland

Anyone who actually bothers to click on the "Historic" locomotive image/link will see the following:

"There are currently 23 operational diesel‑powered historic locomotives in California."

and also:

"Exemptions could apply for demonstration museums, education, tourist railways and historic preservation purposes or any special one-time movements not used to haul freight for hire."

So that answers some questions.

Bio or renewable fuel does NOT make you zero emission, it makes you carbon neutral. You will have the same, or worse, emissions. Particulates, unburned hydrocarbons, nitrous oxides, and many other nasties will all be the same, and require all the mitigation devices we all love. Catalyst, EGR, DPF, DEF, DPF, etc.

Although this isn't the place to be conducting a fuel debate -- I think you're mistaking LNG for LPG. They are very, very different things. That's not to say that you can't get an explosion from an accident that creates a pool fire without venting a single-walled tank with inadequate insulation... but see this reference:

https://www.gti.energy/wp-content/uploads/2018/12/Safety-4-Juan_M_Bonilla-LNG17-Poster.pdf

Remember that we aren't discussing tank cars transporting LNG, but locomotives using it in proper double-wall tanks. The accident in Hamilton, scaled up appropriately, would have occurred in far less time and been proportionately as dangerous.

Something I think ought to be knowingly preserved is some of the railroad motive power converted to run on natural gas, and the support equipment such as 'fuel tankcars' used with them. That's at least as important as the various railroad attempts to burn coal competitively (which of course is something else that deserves more historical attention than it's gotten...)