Comment Log Display

1.  It is common practice for the major railroads to lease the
locomotives from third party leasing companies.  There may be more
than 200 leased locomotives that are operated by BN and UP in
California that do not bear their name on the locomotives.  It is
not clear if they are covered by this agreement

2. All the efforts that are part of the agreement bring only 20%
reduction in PM.  Even this 20% reduction is not a real number as
most of the locomotives have already been equipped with idle
reduction technology, or were already committed to installing them
prior to the agreement.  This agreement therefore creates not much
new effort other than a huge regulatory system of monitoring,
paper work, training, more administrative work. A lot of money it
seems like will be spent on government personnel monitoring this
porogram

3.  The program as outlined is too weak and delivers very little
public benefit at great adminstrative cost to both private and
government.  

4.  Why not adopt South Coast AQMD's MOU Statewide and force all
locomotives to comply with Tier II with early banking and credits
as incentives. This will give 50% PM benefits, 60% NOx benefits. 
There are already technological developments in place to provide
Tier II retrofit kits

In light of the above, we urge the Board to reject the agreement
on the basis that it provides very little public benefits at great
adminstrative burden.  It is also based on misguided science, i.e.
smoke and particulates are equivalent.  I can understnad a lay man
saying this, but I have trouble seeing this inference in a
regulatory document.  Let me simply say that smoke and particulate
matter are not equivalent.  

In closing, we simply state that this agreement is based on too
lenient measures, provides very little public benefit, is too
beauracratic in nature, and most of it is based on what the
railroads are doing anyway.  CARB has not presented what it is
going to cost in CARB staff time and expense to implement and
montor this program.  We must have the whole financial picture.