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Comment 8 for Volkswagen Environmental Mitigation Trust for California (vw-mititrust-pl-ws) - 1st Workshop.


First Name: John
Last Name: McGowan
Email Address: richard.mcgowan@ge.com
Affiliation:

Subject: Freight Switcher Funding Requirements
Comment:
Dear Ms. Lisa Williams,
Two questions regarding the Volkswagen Environmental Mitigation
Trust for California available for freight switcher locomotives.

1. Existing switcher locomotives produce high levels of emission
pollutants at EPA Tier 0+ or non-emission tier levels also
operating at low efficiency rates, which produce high greenhouse
gas output.  The older switcher configurations are relatively
inexpensive to overhaul and maintain, thus difficult to justify EPA
Tier-4 conversions without funding near 80% reimbursement rates. 
Therefore, can the 40% Volkswagen funding for switchers be utilized
in conjunction with other California state or DERA funding?     

2. The funding applies to freight switcher applications while some
re-power applications will continue to serve freight yards but will
have gross power ratings above the 2300 ghp EPA line haul
classification threshold.  Please clarify if re-power solutions
rated between 2,300 to 4,100 ghp that continue to serve California
switch yard applications, qualify for the VW funding
reimbursement.

Best regards,

John McGowan      

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Date and Time Comment Was Submitted: 2017-10-09 09:29:36



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