Eastern Railroad Discussion > Emissions Credit Process - Tier 4 Credit Locomotives???

I thought I understood the process of how emissions credits enable Tier 3 locomotives to still be sold as Tier 4 Credit units, but now I'm not sure after users here vs another rail forum swear the other is totally wrong.

In particular, the recent post on the CSX Wabtec order for new/rebuilt locomotives raised some questions on who is actually banking emissions credits. Specifically, one group swears that those emissions credits are held only by the manufacturer to hand out as they see fit. However, the other group say those emissions credits are held by the railroads only to "cash-in" as they see fit.

Hoping somebody can fully explain who is actually "banking" these credits?!?!

I tried to get an answer out of EPA about a year ago concerning railroad diesel locomotive engines.  I eventually received a boilerplate answer along the lines of "we're cutting regulations, etc., etc."  Nothing specific.  I'll have to try again Real Soon Now.

Good question that has a lot of bearing on a number of situations. I had always thought the credits were held by the railroad, not the manufacturer, and were "earned" by their actions in how they ran their fleet and the emissions from that actual service. It would surprise me if the credits were like chits to be handed out by the manufacturers as they saw fit.

MC

The EPA ruling today may dial back the clock in favor of Tier 3.

GN1969 Wrote:
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> The EPA ruling today may dial back the clock in
> favor of Tier 3.

I could be misunderstanding the Trump administration rules released today, but doesn't appear they have any connection to regulation of particulate matter (PM) and nitrogen oxides (NOx) that differentiate Tier 3 and Tier 4. Instead these new rules focus on revoking EPAs ability to regulate CO2 emissions as part of Clean Air Act...which tells me Tier 4 isn't going anywhere. With this being said (and relevant to my original question), manufacturer's are still selling Tier 3 units under this credit program that apparently nobody understands and the current administration won't stop! 🤣



Edited 1 time(s). Last edit at 02/12/26 19:35 by AaronJ.

•  Seems to be railroad credits:   Regulatory Framework: These credits are used in Averaging, Banking, and Trading (ABT) programs. For instance, if a locomotive family emits less than the allowed FEL (Family Emission Limit), the owner generates positive credits that can be used to offset higher-emitting engines elsewhere.(google)
• So by buying and using low emission locos..with truck engines..the RRs could rack up lots of credits for future use.
• RB

Edited 1 time(s). Last edit at 02/12/26 23:34 by up833.

I believe there can be buying and selling of credits as well which by definition opens the door to negotiations as to whether the builder or owner of a locomotive banks them.
 

Bill Miller
Galt, ON

CCMF Wrote:
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> I believe there can be buying and selling of
> credits as well which by definition opens the door
> to negotiations as to whether the builder or owner
> of a locomotive banks them.
>  

Yeah, that muddies the water even more. I am coming to the conclusion that both entities can bank these credits...which means we will likely never know if the NS ES44AC order for 40 Tier 3 units is truly NS credits, Wabtec credits, and/or some combination. The fact we are a decade beyond Tier 4 implementation and it appears to be relatively easy to still get at least modest sized orders of Tier 3 units via emissions credits (BNSF, CSX, and NS orders) tells you nobody is that concerned about changing out of Tier 4 when Tier 3 never went away.



Edited 1 time(s). Last edit at 02/13/26 08:28 by AaronJ.