| Comment | The CMP Guidelines currently state that locomotives must be in
operation for two years prior to applying for funding.
Unfortunately, this requirement excludes many opportunities to
upgrade locomotives from unregulated to Tier 4 or better. Owners of
locomotives and railroad operators, in the face of this
requirement, will place unregulated equipment in-use before
considering Tier 4 simply because of the cost differential. IE An
unregulated locomotive costs around $250,000 whereas a new Tier 4
locomotive costs upwards of $2,000,000.
CMP should consider the future emissions benefits of reducing or
eliminating this requirement for locomotive projects.
|
|---|