Comment Log Display

Dear Chair Randolph,

The attached letter and accompanying exhibits set forth Sierra
Northern Railway's and Sierra Railroad Company's comments in
support of the California Air Resources Board's Proposed Repeal of
the In-Use Locomotive Regulation. Sierra Northern and Sierra
Railroad appreciate the opportunity to provide these comments to
CARB.

For more than a decade, Sierra Northern has directly engaged with
CARB staff and leadership to collaboratively develop and implement
an industry-informed, cost-effective, and feasible strategy for
reducing greenhouse gas and criteria pollutant emissions in the
short line railroad industry.  In a landmark achievement in March
of this year, Sierra successfully completed testing of the first
four-axle hydrogen-fueled, zero emission switching locomotive in
the U.S. at Sierra's railyard in West Sacramento as further
described and illustrated in Exhibit A  of this Comment. 

Sierra Northern and Sierra Railroad support CARB's Proposed Repeal
for multiple reasons. As stated in the Initial Statement of
Reasons, the Proposed Repeal provides more certainty to California
locomotive operators.  In addition, the Proposed Repeal avoids
protracted and expensive litigation. Most importantly, the Proposed
Repeal enables the more rapid implementation of voluntary and
commercially viable strategies to achieve criteria and GHG
pollutant reductions in the short line rail industry.

Please see the attached comment and exhibits for Sierra Northern's
and Sierra Energy's full comment.

Best Regards,

Graham Noyes
Noyes Law Corporation
419 Broad Street, Suite E
Nevada City, CA  95959
www.fuelandcarbonlaw.com