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Comment 4 for FY 21-22 Funding Plan for Clean Transportation Incentives, et al (fundingplan2021) - Non-Reg.

First NameDave
Last NameCook
Email Addressdave.cook@railpropulsion.com
AffiliationRail Propulsion Systems
SubjectRevise 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 NameCarl Moyer Lease Notes.docx
Date and Time Comment Was Submitted 2021-10-21 10:19:57

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