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Comment 2 for In-Use Locomotive Regulation (locomotive22) - 45 Day.

First NameDaniel
Last NameRice
Email Addressdrice@westernmilling.com
AffiliationWestern Milling
SubjectComments re: In-Use Locomotive Regs on behalf of Western Milling
Comment

Western Milling owns and operates three unit train receiving facilities throughout the California San Joaquin Valley in order to continually provide optimal nutrition to the largest dairy herd in the U.S.  In 2017 the company upgraded its locomotive power to highest rated Tier 4 units at all three locations and phased out diesel engines that had been in operation for over 50 years.  California is an 85% grain deficit state that relies on the continuous delivery of agricultural commodities via rail to manufacture livestock feed.  Receiving facilities have worked closely with the Class 1 railroads for decades to develop an efficient system for unloading grains in a just-in-time model.  This system generally works well however weather events, labor shortages, equipment or track failures can cause disruption to the rail network which often leads to impacts at the Receiving facility.

 

Western Milling is not at all opposed to working in earnest to improve the air quality in the San Joaquin Valley for the betterment of our employees, our communities and future generations.  Our concern with the requirement for net-zero emission by 2035 stems from the need to process hundreds of rail cars on a continuous basis.  Receiving windows can often range from 3 to 5 days but sometimes expand to 10 to 14 days when the rail network is stressed, this can lead to multiple trains arriving at the same time.  Western Milling facilities are designed and staffed to unload one unit train at a time and are heavily reliant on dependable locomotive power to process over one hundred cars efficiently.  This is currently possible with the Tier 4 locomotive units in place allowing us to process multiple trains in succession.  However, we have concerns that electric power units (either shuttles or locomotives, none of which are commercially available today) and their need for down time to charge would drastically increase our need for greater capital expenditure possibly doubling our need for horsepower.  In instances where a Receiver could not unload a unit train during established windows of time, financial penalties (demurrage) would be levied by the Class 1 railroads negatively impacting Western Milling business operations in California.


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Date and Time Comment Was Submitted 2022-10-10 13:42:09

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