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From: Jack Stewart, President
California Manufacturers & Technology Association
	

Thank you for accepting this testimony into the record of this
proceeding.

CMTA supports the Memorandum of Understanding entered into between
ARB and the railroads with regard to locomotive emissions. As a
result of a voluntary and collaborative process, the MOU achieves
20% reduction in locomotive PM emissions statewide. Because of
federal preemption over control of these emissions, the reductions
are larger and sooner than could have been required by any
California regulatory or legislative body. 

In addition, CMTA supports the process ARB adopted to develop this
MOU. By using a cooperative approach, California has avoided
implementation delays due to disagreements over the State’s legal
authority over the affected companies. As a result, in the first 6
months of MOU implementation, the railroads have already made
significant investments to reduce locomotive idling and smoking
and increase the use of low sulfur fuel in California. The MOU has
also stimulated plans to invest in new, cleaner technology,
represented by the announcement to purchase 70 new switch engines
for use in LA over the next two years.

CMTA advocates for both economic growth and a healthy environment.
These goals require that government and industry work together to
find solutions to environmental challenges.  The railroad MOU
represents such a solution and I urge you to keep the MOU in
effect.