First Name | Dave |
---|---|
Last Name | Cook |
Email Address | dave.cook@railpropulsion.com |
Affiliation | Rail Propulsion Systems |
Subject | Revise Carl Moyer for Locomotives to allow leasing of advanced technology locomotives |
Comment | Rail vehicles are the off-road application that ARB and local air agencies have the least ability to coerce into using cleaner technology; they have a solid federal pre-emption. Locomotives built in the 1960's are simple, reliable and economical to rebuild. Modern replacement gensets purchased at government expense have been a failure due to poor performance and high maintenance costs when compared to older locomotives. Recent NOx inventories of Rail Equipment in the SCAQMD air basin indicate that rail NOx emissions are going up, not down due to the railroads retiring most of the gensets and bringing older locomotives back into the area. Seeing that 'no change' is the preferred alternative to the rail industry, incremental change has been painful and resistance is incredibly strong. Non-optimal application of public policy and tax payer funds has further entrenched the 'no change' alternative. The bright side is that this industry that was dragging its feet on embracing change is now ripe for a leap frogging technology that will come from a pool of smaller more flexible companies under small pilot programs that are willing to take more risk. This requires smarter public policy and application of incentive funding that leads to private investment covering some of the risk. Leasing equipment for 5 years based on annual cost effectiveness is one promising approach. The uploaded document has more details an suggestions on this topic |
Attachment | www.arb.ca.gov/lists/com-attach/4-fundingplan2021-VDdRNgBzUm0AWVU4.docx |
Original File Name | Carl Moyer Lease Notes.docx |
Date and Time Comment Was Submitted | 2021-10-21 10:19:57 |
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