Comment Log Display

The following is a digest of Sierra Northern Railway's comment
regarding the 15-day changes to the proposed In-Use Locomotive
Regulation.  The full comment and exhibits are attached.

The attached documents set forth Sierra Northern Railway's ("Sierra
Northern") comments concerning the California Air Resources Board's
("CARB") Proposed In-Use Locomotive Regulation as updated by the
proposed 15-day changes made available March 1, 2023 (the "Proposed
Regulation").

Regarding the Alternative Fleet Milestone Option ("AFMO") that CARB
has proposed, Sierra strongly recommends the addition of an early
adopter provision to the AFMO.  This early adopter provision would
establish an accelerated first milestone in 2025 to facilitate
emission reductions up to five years earlier than the Proposed
Regulation.   Rather than establishing only the 2030 milestone as
proposed in the 15-day change, a fleet could opt to meet either a
2025 or 2030 milestone:
•	Beginning in 2025, 100 percent of annual fleet usage in
California must be from Tier 3 (or cleaner) locomotives (the Sierra
recommended early adopter "2025 Milestone"), or,
•	Beginning in 2030, at least 50 percent of annual fleet usage in
California must be from Tier 4 (or cleaner) locomotives, (the CARB
proposed "2030 Milestone").

The three remaining AFMO milestones in the Proposed Regulation
would remain unchanged:
•	Beginning in 2035, 100 percent of annual fleet usage in
California must be from Tier 4 (or cleaner) locomotives.
•	Beginning in 2042, 50 percent of annual fleet usage in California
must be ZE.
•	Beginning in 2047, 100 percent of annual fleet usage in
California must be ZE (no exceptions).

Through the integration of the early adopter provision into the
Proposed Regulation, CARB would:
•	Deliver greater PM2.5 and NOx emission reductions to impacted
communities.
•	Deliver faster PM2.5 and NOx emission reductions to impacted
communities.
•	Catalyze a more rapid transition to 100% zero emission
locomotives.
•	Dramatically reduce the costs of the transition to zero emission
locomotives.

We appreciate the opportunity to submit these comments.  Please
contact me if there are any questions or issues with the
transmission of the comments.

Best Regards,

Graham Noyes
Noyes Law Corporation
For Sierra Northern Railway