22 April 2024

David Dickinson
Office of Transportation and Air Quality
Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Reference: Docket ID No. EPA–HQ–OAR–2023–0574

Dear Mr. Dickinson,

The ICCT supports EPA authorization of the California Air Resources Board’s (CARB) In-Use
Locomotive Regulation pursuant to section 209(e) of the Clean Air Act. We put forward these
comments on the basis of our work as an international research organization supporting the
development and implementation of advanced vehicle regulations in the world’s largest markets.

The proposed rule sets standards based on a review of technically feasible and cost-effective
strategies to reduce in-use locomotive emissions, and the rule will address a compelling interest
to comply with national ambient air quality standards in the state. These comments provide
some technical observations that inform our views.

Exhaust from diesel locomotive engines is a known human carcinogen. Exposure to diesel
exhaust contributes to lung cancer, ischemic heart disease, cerebrovascular disease, chronic
obstructive pulmonary disease, and asthma exacerbation among other health outcomes.
Exposure is greatest within several hundred meters of a major traffic corridor. Seaports and
railyards can produce relatively high exposure to diesel exhaust in and around low-income and
minority communities owing to extensive engine idling and low speed operations, especially in
urban areas.

California’s standards will reduce in-use locomotive pollutants at levels that exceed federal
requirements. According to CARB, the in-use locomotive regulation is expected to avoid about
90% of locomotive particulate matter (PM) and oxides of nitrogen (NOx) emissions by 2050.
These reductions are equivalent to the avoidance of nearly 7,000 tons of PM and 386,000 tons
of NOx. CARB also projects the regulation will reduce 21 million tons of greenhouse gas
emissions (GHG) over this period. 1 Communities, particularly those near rail operations, as well
as train operators and railyard workers, will benefit the most from improved air quality and
contribute to the Biden Administration’s Justice40 Initiative.

California has introduced an in-use age limit, which will accelerate the uptake of cleaner and
more efficient locomotive engine technology. The long service life of locomotives, up to fifty
years or more, is a barrier to cleaner locomotives. The impact is evidenced by the sluggish
adoption of Tier 4 engines, which account for less than 5% of California’s fleet nearly a decade

1
California Air Resources Board. (2023). The In-use Locomotive Regulation was approved by the Board
on April 27, 2023. Retrieved from https://ww2.arb.ca.gov/our-work/programs/reducing-rail-emissions-
california/locomotive-fact-sheets#:~:text=Locomotive%20Emissions,tons%20per%20year%20of%20NOx
after Tier 4 standards went into effect. An in-use age limit will achieve greater emission
reductions by accelerating investments to a pace faster than is occurring under business-as-
usual.

California’s innovative approach is poised to accelerate the use of zero-emission technology.

Zero-emission engines are more energy efficient, produce zero tailpipe criteria pollutants, and
produce far fewer greenhouse gas emissions than conventional fossil diesel engine technology.
While the locomotive fleet in California relies heavily on diesel engines today, most countries
have already committed to electrifying their railway networks. The spending account provision
included in California’s regulation secures dedicated funding to support investments in zero-
emission rail technology.

In summary, ICCT supports EPA authorization of California’s In-Use Locomotive Regulation.

This action will effectively clean up the in-use emissions of locomotives and invest in more
efficient zero-emission solutions. EPA will find ample justification for a waiver in light of the
stringent rules California has set forward and the compelling interest of the state. If EPA staff
have any questions, they can feel free to contact to Zhenying Shao.

Sincerely,

Stephanie Searle, PhD

Chief Program Officer
The International Council on Clean Transportation