Comment Log Display

Evelyn R. Nackman						
Associate General Counsel
ASSOCIATION OF AMERICAN RAILROADS
425 3rd Street, SW, Suite 1000
Washington, D.C.  20024
								      June 15, 2016

Elizabeth Yura, Chief
Emissions Assessment Branch
California Air Resources Board 
Transportation and Toxic Division
P.O. Box 2815 
Sacramento, CA 95812
(916) 322-8277

SUBMITTED VIA
http://www.arb.ca.gov/msprog/tech/techreport/comments.htm

RE:	CARB’s Draft Technology Assessment--Freight Locomotives 

Dear Ms. Yura:

The Association of American Railroads (AAR) and its member
companies appreciate the opportunity to comment on the California
Air Resources Board’s (CARB) Draft Technology Assessment:  Freight
Locomotives, released on April 26, 2016 (“Draft Assessment”).   AAR
has several members that operate in California; however, all AAR
members have an interest in discussions that involve technological
advances to locomotives.  

AAR and its members remain committed to working with regulators to
reach meaningful and carefully considered resolutions to
environmental concerns in California and nationally.  As you are
aware, over the last two decades, AAR and its members made
significant investments in California and voluntarily agreed to
enforceable measures that were effective in significantly reducing
diesel particulate matter and NOx emissions from locomotives and
other rail operations in the state.  With that context in mind, AAR
provides the input below on the Draft Assessment. 

The Association of American Railroads (“AAR”) is a national,
non-profit trade association that represents the Nation’s major
freight railroads.  AAR’s membership includes freight railroads
that operate 83 percent of the line-haul mileage, employ 95 percent
of the workers, and account for 97 percent of the freight revenues
of all railroads in the United States.  AAR’s membership also
includes passenger railroads that operate intercity passenger
trains and provide commuter rail service.  AAR is the Nation’s
leading railroad policy, research, standard setting, and technology
organization.  AAR and its members are committed to operating the
safest, most efficient, cost-effective, and environmentally sound
rail transportation system in the world.

First, AAR agrees with CARB that any discussion about changes to
the emission limits for the next generation of new and retrofit
locomotive emissions standards should be, if at all, convened by
the U.S. Environmental Protection Agency (EPA).  Changing
locomotive technology in one state does not simply impact one
state.  Railroads operate across state lines.  Any changes to the
technology will require a uniform approach by regulators.  As such,
all stakeholders should be given the opportunity to be involved and
provide input.  

Second, any consideration of future standards must be predicated on
a detailed analysis of cost effectiveness as well as energy
efficiency.  In addition, CARB’s discussion of the challenges that
EPA and other stakeholders may need to consider in developing new
locomotive standards is helpful, but the discussion should also be
framed by the safety implications of any proposed solutions as well
as the environmental benefits. 

In conclusion, emission standards should encourage the most
environmentally beneficial form of transportation, rather than
unreasonably burdening it.  Creating costly, technologically
infeasible, or unsafe mandates will not benefit the environment,
protect the public, and could potentially harm the U.S. economy. 
Every effort should be made in future discussions to clearly
acknowledge significant technological obstacles and to devise
practical, cost effective, and safe environmental solutions.  

Sincerely,
 
Evelyn R. Nackman