SOUTHERN PACIFIC TRANSPORTATION COMPANY

Problem
The Southern Pacific Transportation Company (Southern Pacific) faced increased enforcement action from the South Coast Air Quality Management District (SCAQMD) in Southern California over visible emissions from locomotives operating in the region. Southern Pacific was interested in developing a strategy to decrease dramatically the likelihood of locomotives operating in potential violation of local visible emission standards.

Solution
CEA worked with Southern Pacific and SCAQMD regulators to develop a strategy that would significantly reduce, if not eliminate, future violations. Specifically CEA:

• Worked with Southern Pacific to establish a multi-departmental team to address the regulatory challenge and develop a comprehensive voluntary compliance strategy.
• Negotiated a creative settlement agreement with the SCAQMD for Southern Pacific to conduct a voluntary compliance program with field monitoring and preventative maintenance activities.
• Guided implementation efforts of the compliance program, including designing a data reporting system, developing a training module for technicians, and helping to conduct internal field audits to measure progress.
• Facilitated internal communications between technicians and upper management during implementation of the program.
• Represented the client before the SCAQMD to report progress of the program and renew the agreement after the initial expiration date.

Results

• Through CEA’S leadership, Southern Pacific was successful in establishing a voluntary compliance program with the SCAQMD, thereby avoiding litigation and costly fines.
• The compliance program has decreased the number of locomotives operating outside of the local compliance guidelines by over 90%.
• Locomotive performance has improved due to early identification of problems through the preventative maintenance program.