Please see attached white paper outlining suggestions to improve
the regulation by:
Utilizing combined NOx and PM values
when defining 'Cleanest available locomotives'
Add hybrid locomotives and
after-treatment retrofits to allowed purchases with spending
accounts
Utilize more appropriate duty cycles
to calculate in-use emissions for locomotives in switching service
and passenger service
Base fees on actual in-use emissions
especially for Tier 4 passenger locomotives
Investigate single engine passenger
locomotive engine shut off system defeats