Locomotive Emissions Monitoring Program - Railway Association of ...

1.1
Audit of the LEM Reporting Process:
As required under Section 5.3 of the 2006-2010 MOU, an audit was conducted in 2009 of the 2007 LEM reporting
process. The purpose of the audit was to support transparency with respect to the MOU and to demonstrate credibility
of the data contained in the 2007 LEM Report as well as the reported progress towards meeting the reduced
greenhouse gas (GHG) emissions targets outlined in the MOU. This objective was achieved through validation of data
collection processes and reviewing documentation pertaining to selected data included in the report.
The scope of the audit included the processes and methodology for data collection, normalization and analysis
used to develop the report. In particular, the objectives of the audit were to:
• Provide assessment and verification of locomotive inventory data pertaining to Section 3.0 of the MOU to verify
that commitments under Section 3.2 of the MOU have been met;
• Provide assessment and verification of GHG data pertaining to Section 4.0 of the MOU to verify that commitments
under Section 4.1 of the MOU have been met;
• Provide assessment and verification of NOx, SOx and fuel consumption data pertaining to Section 5.0 of the MOU
to verify that commitments under Section 5.2.2 of the MOU have been met; and
• Verify data for fuel used by the different categories of railways, as outlined in Section 5.2.2 of the MOU.
The auditor collected audit evidence and limited assurance for GHG data from document reviews, interviews and
physical observation of activities, including:
• Enquiry/interviews;
• Data systems evaluation; and
• Application of a small set of analytical procedures such as re-calculation of emissions data, obser vation of information
management system controls, confirmation of delivery of product, data inspection and data analysis.
1.2
Findings of the Audit
Audit findings were presented in terms of nonconformities (NCs) with the audit criteria, that is, where a stated
requirement of the MOU was not met as well as opportunities for improvement (OFIs), that is, suggestions on
strengthening the data reporting methodology and processes).
1.2.1.
Nonconformities
During the Audit, one nonconformity was identified vis-à-vis Section 3.2 of the MOU.
Description of finding: The number of new EPA Tier 2 locomotives acquired in 2007 was listed in the 2007 LEM Report
as 85. Evidence identified during the audit indicated that the number of EPA Tier 2 locomotives that should have
been reported was 105, a misstatement of approximately 24%. The overall reporting of locomotive CAC emissions
was not materially impacted by this misstatement.
The reported number of high-horsepower units upgraded to EPA Tier 0 in 2007 was 92. Evidence identified during
the audit indicated that the number of high-horsepower locomotives upgraded to EPA Tier 0 reported was 78, a
misstatement of approximately 15%. Through secondary information requests made to verify CAC commitments,
there were two findings:
• All 72 of the high-horsepower locomotives reported by one of the Class I railways already met the EPA Tier 0
standard and as a result were recertified, not upgraded, when remanufactured in 2007, i.e., these were not
reported in a consistent manner; and
• AMEC was unable to obtain sufficient appropriate evidence through the secondary information request to confirm
that the 6 units reported by another Class I railway had been upgraded to Tier 0.
2 LEM 2008