The Illinois Chamber of Commerce alongside chambers from across the country joined the US Chamber in urging the EPA to deny the California Air Resources Board's (CARB) application to exempt its In-Use Locomotive Regulation (Regulation) from the Clean Air Act. Provided below is an excerpt from the letter.

The overreach of the CARB Regulation is stunning. It would mandate zero-emissions locomotives in some cases by 2030 and across-the-board by 2035, even though the technologies necessary to achieve these reductions do not exist. 

Despite moving 40% of the nation’s long-distance freight by ton-mile, the sector accounts for only 0.6% of U.S. GHG emissions. Moreover, railroads are an essential freight transportation option for American businesses — including those in manufacturing, agriculture, retail, and energy production — in which scale of operations is critical to competing in the global market.

Allowing the Regulation to move forward would cause enormous and destructive impacts to America’s supply chains and economy, and likely increase greenhouse gas emissions.

  • California Regulation Would Be National Regulation. A very large portion of the locomotive fleet moves through the state of California each year, so railroads operating as far away as Montana, Pennsylvania, North Carolina, and even Maine and Florida would be forced to comply with California’s standard.
  • The CARB Regulation Threatens the U.S. Supply Chain. Railroads are developing new technologies to reduce emissions, but there are no viable, zero-emission locomotives that could be deployed at scale to meet the demands of the CARB Regulation. Without proven technology in place, the logistical challenges of complying with this Regulation would be enormous and complicate critical supply chains for energy products, food, intermodal deliveries, and service to America’s ports.
  • Freight Would Be Forced from Rail to Roads. It is hard to envision a scenario whereby trains would stop at the California border to change locomotives without significant impact on national supply chains, making diversion of freight off the rail network the most likely outcome.
  • The CARB Regulation Would Drive Short Line Railroads Out of Business. In California alone, short lines handle more than 260,000 carloads per year. Nationally, short line railroads handle 20 percent of rail cars at origin and destination, serving virtually every industry. Short lines do not have the capacity to replace their entire locomotive fleets to comply with the deadlines.
  • The CARB Regulation Would Harm the Largest Railroads and their Customers. Estimates suggest that Class I railroads would be required to deposit as much as $800 million per year, per railroad, for compliance with spending account provisions of the proposal. This capital drain could force major infrastructure improvements to be shelved, including those designed to reduce operations emissions and improve safety. Moreover, Union Pacific recently estimated that a fleet renewal as stipulated by the CARB Regulation would lead to more than $14 billion in cost increases passed on to consumers.

View the full letter, and the list of signees: HERE

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Western DuPage Chamber of Commerce
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