Please rethink locomotive regulation for a stronger California.

I am writing today to express my opposition to CARB’s In-Use Locomotive Regulation.

This regulation proposes unrealistic emissions standards for locomotives in California, which could lead to numerous adverse consequences affecting public well-being and the economy. Implementation of CARB’s regulation will result in job losses across the county, disruptions in the supply chain, and potentially higher harmful emissions if freight shifts from rail to trucks. Moreover, it will halt crucial rail facility projects, such as the Barstow International Gateway, that will play a significant role in reducing highway congestion and generating thousands of well-paying jobs in Southern California.

The California Air Resources Board (CARB) adopted the In-Use Locomotive Regulation, which would require the implementation of “zero-emission” locomotives in California. But here’s the kicker: “Zero-emission” tech, such as that proposed for electric locomotives, is not commercially viable, and it’s not clear when it will be. Meanwhile, there are emissions-cutting projects underway right now that will be either stalled or completely scrapped if these regulations move forward. Rather than investing in efficient freight movement, railroads will be required to spend hundreds of millions per year just in California to stay compliant with the rule.

Consequently:

  • Rail projects already in progress, such as the Barstow International Gateway, would be canceled completely as development would become cost-prohibitive

  • Thousands of promised and existing well-paying jobs would vanish

  • The cost of goods movement through California would increase to the point of being non-competitive, shifting cargo to other ports outside the state

  • Our national supply chain and West Coast port throughput would suffer without new rail projects that improve efficiency

  • Ultimately, this regulation will result in shifting freight from rail—the most efficient way to move goods over land—to trucks, increasing highway congestion

There are more practical solutions for reducing carbon emissions in California and protecting our health.

I urge you to rethink this approach to locomotive regulation and support common-sense regulations that accelerate the commercial viability of lower- and “zero-emission” locomotives while protecting California jobs, the economy, and the national supply chain.

Greg Raven, Apple Valley, CA

Sent to:
CARB Board Members