ConservAmerica, C3 Solutions, and ACC Oppose Locomotive Rule

ConservAmerica, along with C3 Solutions and American Conservation Coalition, submitted comments this week to the Environmental Protection Agency (EPA) on whether the California Air Resources Board’s (CARB) In-Use Locomotive Regulation meets the criteria for a waiver of federal preemption under section 209 of the Clean Air Act (CAA).  Approving the waiver would allow California and other states to mandate zero emissions locomotives even though these technologies are not available to meet the nation’s rail transportation needs.

Implementing CARB’s rule would result in a shift in freight transportation from rail to truck, which would offset the intended environmental benefits of the rule. Rail is the most efficient form of on-land freight transportation and far more fuel efficient than trucking: it is roughly one-tenth the emissions intensity of trucking on a ton-per-mile basis. While long-haul trucks have also made significant progress in fuel efficiency and emissions reductions, moving more freight to roadways will result in a net increase in pollution and make America’s highways less safe.

“As a nonprofit organization dedicated to pursuing fiscally responsible solutions to our most pressing environment and energy challenges, reducing emissions is one of our top priorities.” said Todd Johnston, ConservAmerica’s Vice President of Policy. “Unfortunately, not only does CARB’s rule have the potential to increase emissions, but it would also increase transportation costs, hurting families and businesses through higher prices for the products they need daily, like food and energy.”  

To read the full text of the letter, click here.

To read our blog post about the regulation, click here.