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Comment 37 for In-Use Locomotive Regulation (locomotive22) - 45 Day.

First NameMark
Last NameTwain
Email AddressMark.Twain@Loco-Emissions-Watchdogs.com
Affiliation
SubjectImprovements to Locomotive In-Use Rule
Comment
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

Attachment www.arb.ca.gov/lists/com-attach/40-locomotive22-BWZWPwBsAD4FZgln.pdf
Original File NameComments on Proposed CARB In-Use Locomotive Rule V3.pdf
Date and Time Comment Was Submitted 2022-11-07 23:09:52

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