Re: Request for Information (RFI) Progression to Net-Zero Emission Propulsion

Technologies for the Rail Sector

To: Office of Energy Efficiency and Renewable Energy (EERE), U.S. Department of
Energy

Date: February 6, 2024

The International Council on Clean Transportation (ICCT) welcomes the opportunity to

respond to the Request for Information (RFI) on the U.S. rail decarbonization technology.
The ICCT is an environmental research organization that supports policymakers
worldwide with technical evidence and analysis to develop effective environmental
standards for the transport sector.
This response to the RFI provides a number of technical observations that may be helpful
to EERE staff. We discuss the actions needed to promote future low- and zero-emissions
propulsion technologies, requirements on infrastructure, and coordination required for the
rail sector to meet or exceed U.S. decarbonization milestones.
Please find a summary of responses followed by the detailed responses to the RFI
questions below. If EERE staff have questions, they can feel free to reach out to
Stephanie Searle or Zhenying Shao.

Stephanie Searle, PhD

Acting Deputy Director, International Council on Clean Transportation

1
Summary of responses
The most impactful rail decarbonization pathways will be propulsion-based locomotive
technologies with zero use-phase emissions. Such a transition will bring significant local
air quality and health benefits in addition to lowering greenhouse gas (GHG) emissions
and reducing the dependence of the U.S. rail sector on fossil fuels.
We recommend prioritizing specific locomotive segments with various technology
combinations for accelerating the transition to zero-emission. The shorter-range
locomotive segments, including switchers/yard rail, industrial and local rail, and
passenger locomotives, are typically easier and more impactful to shift to zero-emission
technologies earlier, considering technology readiness, economic viability, and level of air
quality and public health impacts. Freight routes with the busiest Class I line-haul activities
should also be prioritized. Such strategic adoption of technologies and applications could
help create a market for advanced technologies to further advance and mature and
contribute to market transformation and extension for all locomotives.
For locomotives used as local, regional, and passenger trains, diesel-hybrid battery-
electric technology could be adopted in the near term as a low-emission option if the
existing battery-electric technology does not turn out to be a better alternative for these
segments. However, hybrid technology must be a temporary solution, which needs to
eventually be replaced with either overhead catenary electrification, battery-electric
technology, partial catenary electrification with batteries, or H2 fuel cells. The hybrid
approach should also ensure that the diesel locomotives comply with the latest, most
stringent (i.e., Tier 4) emissions standards.
Line-haul locomotives can adopt diesel-hybrid battery-electric in the near term, which
would gradually be phased out by adopting either the mixed approach of overhead
catenary + batteries or the H2 fuel cell technology, depending on the technology readiness
and/or economics.
Overhead catenary electrification is suitable as the immediate, prime technology for the
busiest routes, wherever feasible technically and economically. Where overhead catenary
electrification may not be a viable option as a standalone technology, e.g., for the tunnels
with height limitation, a mixed-technology approach, such as batteries or H2 fuel cells as
applicable, can apply as an alternative for shorter-range options.
Federal GHG standards for locomotives could be an important and impactful tool in
shifting the U.S. railway sector to lower-emission technologies. We recommend the Biden
Administration consider introducing such standards.
The use of biofuels will have a negligible impact on meeting long-term rail sector
decarbonization. The lifecycle GHG impacts of existing biomass-based diesel (BBD) fuels
are highly varied, while the lowest-impact feedstocks (primarily used cooking oil and
waste animal fats) are highly resource-constrained. Demand for these limited feedstocks
will primarily serve other transport sectors with limited or no other decarbonization options
(e.g., marine and aviation) for now and in the future. Creating additional demand for BBD
through a rail-specific fuel policy risks increasing demand for crop-derived biofuels further
and leading to unintended, indirect emissions attributable to land-use change that would
undermine the intended climate goals of the rail sector.

2
Responses to RFI Questions
1. What is your view of zero-emission, or net-zero emission, rail propulsion technologies
in the next 5 years? 10 years? 30 years? In your response, please include which rail
propulsion technologies for line-haul and railyard operations do you see developing most
promisingly. Please provide as many details as possible e.g., battery chemistry for
batteries, charger type for electrification, fuel cell vs combustion, feedstock source, etc.
Even though there is not yet a clear pathway to decarbonize the railway sector at the
federal level, California has committed the state-level railway decarbonization timeline.
California Air Resources Board (CARB) adopted the In-Use Locomotive Regulation
(IULR), which requires zero emissions for the newly built switcher, industrial and
passenger locomotive engines from 2030, and line haul from 2035.1 The feasibility study
supporting the regulation indicates high-confidence on zero-emission technology
readiness for all types of locomotives that operate in the United States.2
Most countries have adopted overhead catenary electrification systems to decarbonize
the locomotive sector, including line haul, passenger, regional/local, and railyard
operations. The technology has been proven mature enough to deploy at scale in the U.S.
railway sector and significantly reduce onboard locomotive emissions. 3 The U.S. has
been historically behind in electrification mainly because the U.S. freight railroads are
privately owned and revenue-driven, and the rail industry finds it financially challenging
with the massive capital cost of electrifying rail networks.
Other advanced rail technologies, such as fuel cells and battery electric locomotives, are
available, 4 though still in the development stage, and could provide air quality, public
health, and greenhouse gas (GHG) emissions reduction benefits. Hydrogen fuel cell

1
California Air Resources Board. (2022). Technical support document zero emission locomotive conversion.
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2022/locomotive22/15dayappc.pdf; California Air Resources
Board. (April 27, 20230). Locomotive fact sheets. https://ww2.arb.ca.gov/our-work/programs/reducing-rail-emissions-
california/locomotive-fact-sheets
2 California Air Resources Board. (2022). Appendix F Technology feasibility assessment for the proposed in-use

locomotive regulation. https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2022/locomotive22/appf.pdf

3 Solution Rail, Frequently Asked Questions. (no date). https://www.solutionaryrail.org/faq
4 Railway Age, Next-Gen Motive Power, by William C. Vantuono, March 2023.

https://www.railwayage.com/mechanical/next-gen-motive-power/; Federal Railroad Administration (FRA) workshop

(May 2023), Rail decarbonization – it’s a journey, presented by UK Department of Transport; Europe’s Rail joint
undertaking decarbonization plan, presented by Alstom Transportation, https://railroads.dot.gov/elibrary/europes-rail-
joint-undertaking-decarbonization-plan; Decarb down under – an Australian update, presented by Australasian Center
for Rail Innovation, https://railroads.dot.gov/elibrary/decarb-down-under-australian-update; The current status of the
development of carbon-neutral & energy-conserving Rolling Stock for railway systems in Japan, presented by
Railways Technical Research Institute, Japan, https://railroads.dot.gov/elibrary/current-status-development-carbon-
neutral-energy-conserving-rolling-stock-railway-systems; Progress Rail decarbonization solutions, presented by
Progress Rail, https://railroads.dot.gov/elibrary/progress-rail-decarbonization-solutions; APTA Whitepaper on Battery-
Electric and Hydrogen Passenger Rail Equipment, presented by American Public Transportation Association,
https://railroads.dot.gov/elibrary/apta-whitepaper-battery-electric-and-hydrogen-passenger-rail-equipment; Deutsche
Bahn’s Global Decarbonization Strategies, presented by Deutsche Bahn, https://railroads.dot.gov/elibrary/deutsche-
bahns-global-decarbonization-strategies; Hydrogen and Battery: How Stadler’s Alternative Propulsion Products Make
US Rail More Sustainable, presented by Stadler US Inc., https://railroads.dot.gov/elibrary/hydrogen-and-battery-how-
stadlers-alternative-propulsion-products-make-us-rail-more. Popovich, N. D., Rajagopal, D., Tasar, E., & Phadke, A.
(2021). Economic, environmental and grid-resilience benefits of converting diesel trains to battery-electric. Nature
Energy, 6(11), 1017-1025. https://www.nature.com/articles/s41560-021-00915-5; California Air Resources Board,
Public hearing to consider the proposed in-use locomotive regulation, September 2022,
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2022/locomotive22/isor.pdf; California Air Resources Board,
Transitioning to a Zero or Near-Zero Emission Line-Haul Freight Rail System in California: Operational and Economic
Considerations, prepared by RailTEC, University of Illinois at Urbana-Champaign, 2016.
https://ww2.arb.ca.gov/sites/default/files/classic/railyard/docs/uoi_rpt_06222016.pdf

3
locomotives utilize proton exchange membrane (PEM) technology, where low-voltage fuel
cells are combined in stacks.5 There have been several fuel cell demonstration projects
in California, including a project operated by Sierra Northern Railway. 6 Lithium-ion
batteries are promising battery chemistry for locomotives due to their high power and
energy density.7 As of 2022, battery electric locomotives are commercially available in
switcher applications. CARB anticipates that regional freight operations could switch to
fully battery electric, and the line-haul systems could transition to hybrid diesel-battery
electric systems in the near term as battery technology advances.8
Some rail operators have suggested adopting biomass-based diesel (BBD), including
hydrotreated vegetable oil (i.e., renewable diesel) and second-generation fuels, as a
transition plan. Biofuel use in the U.S. has historically been driven by fuel policies such
as the federal Renewable Fuel Standard (RFS) and state-level low-carbon fuel standards
(LCFS) like the California one, which function as a biofuel production mandate and fuel
carbon intensity standard, respectively. These policies already allow for BBD used in rail
to generate compliance. Shifting existing BBD consumption from the on-road sector to
the rail sector would not decrease net GHG emissions and, if pursued as a rail
decarbonization strategy, would mistakenly attribute existing fuel policy impacts to the rail
sector. Thus, a rail fuel policy would necessarily need to credit changes in fuel production
and consumption beyond the levels of existing fuel policies.
Biofuels suitable for use in the rail sector may be made from a wide variety of feedstocks
but can be consolidated into a broad category of BBD, including fatty acid methyl ester
(FAME) biodiesel, drop-in renewable diesel made via hydrotreating, and second-
generation drop-in renewable diesel made from cellulosic feedstocks, wastes, and
residues. Though BBD may be suitable for use in existing locomotives, its efficacy as a
long-term decarbonization plan or near-term transition plan may be greatly limited by the
sustainability and availability of feedstocks suitable for producing these fuels. While some
BBD fuels generate lower lifecycle GHG emissions than fossil diesel, they are not net
zero options. There is a wide range of possible emissions attributable to BBD fuels, with
some generating emissions similar to or in excess of fossil diesel.9 These impacts include
direct supply chain emissions associated with feedstock cultivation (e.g., fertilizer use)
and fuel production (e.g., process natural gas) in addition to market-mediated, indirect
emissions associated with increased demand for biomass feedstocks across global
commodity markets. For example, soy oil-derived renewable diesel, which is theoretically
the most abundant source of additional renewable diesel, generates approximately 40-
50% lifecycle GHG reductions based on the pathway life-cycle emissions certified under

5
California Air Resources Board (2022). Appendix C Technical support document: zero emission locomotive
conversion. https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2022/locomotive22/15dayappc.pdf
6 GTI Energy. (March 24, 2021). California Energy Commission awards funding to demonstrate hydrogen locomotive

for rail applications in California. https://www.gti.energy/california-energy-commission-awards-funding-to-

demonstrate-hydrogen-locomotive-for-rail-applications-in-california/
7 Alternative Fuels Data Center, Department of Energy (n.d) Batteries for electric vehicles.

https://afdc.energy.gov/vehicles/electric_batteries.html#:~:text=Lithium%2DIon%20Batteries,-
Lithium%2Dion%20batteries&text=They%20also%20have%20a%20high,a%20challenge%20for%20the%20industry
8 California Air Resources Board (September 20,2022). Public hearing to consider the proposed in-use locomotive

regulation; Staff report: initial statement of reasons.

https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2022/locomotive22/isor.pdf
9 Based on a database of approved pathways under the California Low-Carbon Fuel Standard

(https://ww2.arb.ca.gov/resources/documents/lcfs-data-dashboard) and EPA’s assessment of fuel pathways for the

Federal Renewable Fuel Standard (https://www.epa.gov/fuels-registration-reporting-and-compliance-help/lifecycle-
greenhouse-gas-results)

4
the California LCFS or EPA’s RFS. Biofuel pathways using wastes and residues such as
used cooking oil or waste animal fats generally have the lowest lifecycle GHG emissions
of existing technologies, but these fuels are highly resource-constrained and largely used
up by the road sector in existing biofuel policies. 10 Emerging fuel pathways such as
hydrothermal liquefaction (HTL) and algae will require significant financial investment and,
like existing biomass feedstocks, are in limited supply. This level of investment would be
better spent on scaling up zero-emission technologies that can entirely displace the rail
sector’s dependence on fossil diesel.
Increased pressure for crop-derived biofuels risks generating unintended indirect
emissions that would undermine the impact of decarbonization efforts. Recent modeling
by the US EPA as well as ICAO suggests that indirect land-use change emissions
attributable to soy-derived biofuels are highly uncertain and maybe even higher than
initially modeled for the LCFS or RFS. 11 Due in part to the linkages between soy oil
demand and palm oil markets in Southeast Asia, the diversion of soy oil to biofuel
production may generate displacement effects which result in high indirect emissions from
palm oil substitution.12 In some cases, these indirect effects may increase the emissions
of soy-derived biofuels beyond those of conventional fossil fuels.
2. What efforts are you aware of to decarbonize rail transportation, including ways to
reduce diesel fuel use? Are you aware of intermediate decarbonization milestones for rail
transportation? Are you aware of longer term decarbonization goals for rail transportation?
If so, describe how those goals might be met, including whether low-carbon biofuels will
play a role.
Various jurisdictions have recognized rail decarbonization as a critical element in their net
decarbonization targets and have committed with low- and zero-emission pathways.
Countries over the world have invested in electrifying their rail sector using catenary
overhead systems. In addition, efforts are identified worldwide to apply cutting-edge
technologies, particularly for the sectors where the railway system cannot be electrified.
- California adopted the IULR in April 2023, aimed at forcing the retirement of old
diesel locomotives and introducing zero-emission locomotives starting in 2030.13
- Canada is setting a rail decarbonization pathway for 2050, looking into diesel drop-
in fuel replacement as a near-term strategy around 2030, and working for hydrogen
and battery locomotives as a long-term strategy to achieve net zero emission by
2050.14

10 O’Malley, J., Pavlenko, N., Searle, S., and Martin, J. “Setting a lipid cap under the California Low-Carbon Fuel
Standard’. (Washington, D.C.: International Council on Clean Transportation, 2022).
https://theicct.org/publication/lipids-cap-ca-lcfs-aug22/
11 U.S. EPA, “Model Comparison Exercise”. June 2023. https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1017P9B.pdf;

ICAO, “CORSIA Eligible Fuels – Life Cycle Assessment Methodology”. 2019. https://www.icao.int/environmental-
protection/CORSIA/Documents/CORSIA_Eligible_Fuels/CORSIA_Supporting_Document_CORSIA%20Eligible%20F
uels_LCA_Methodology_V5.pdf
12 Fabio Santeramo. “Cross-Price Elasticities for Oils and Fats in the US and the EU”. (Washington, D.C.:

International Council on Clean Transportation, 2017). https://theicct.org/sites/default/files/publications/Cross-price-

elasticities-for-oils-fats-US-EU_ICCT_consultant-report_06032017.pdf
13 California Air Resources Board, CARB passes a new In-Use Locomotive Regulation estimated to yield over $32

billion in health benefits, April 27, 2023, https://ww2.arb.ca.gov/news/carb-passes-new-use-locomotive-regulation-

estimated-yield-over-32-billion-health-benefits-0
14 Federal Railroad Administration (FRA) workshop, Pathways to decarbonizing the rail sector: a Canadian

perspective, presented by Transport Canada, Denver, CO, May 2023, https://railroads.dot.gov/elibrary/pathways-

decarbonizing-rail-sector-canadian-perspective.

5
 -
China has achieved over 73% railway electrification over ~96,312-mile-long network,
with a rate of almost 100% for passenger railways.15
- Europe has electrified about 60% of the ~142,000 miles of railway network, covering
about 80% of rail traffic.16 As of 2021, Luxembourg ranks the top on electrification
rate, with 96.7% of railways electrified; Germany ranks the top on the length, with
~12,881 miles of network electrified. Europe has developed a “Europe’s Rail” or “EU
Rail” program to develop a carbon-free mobility roadmap from 2022 to 2030.17 This
roadmap identifies the work for developing a credible alternative for diesel traction,
meeting technical performance requirements at acceptable costs, covering battery
electric, H2 fuel cell, and suburban catenary trains with onboard energy storage
systems and refuel/recharge infrastructure.
- India’s railway network is over 90% electrified, which is around 35,525 miles (out of
the network of 40,584 miles). 18 India Railway aims to reach net-zero carbon
emissions by 2030, but it might be able to achieve 100% electrification earlier.19
- Japan has electrified over 90% of passenger- and freight miles as of 2018.20 The
country adopted a “green transformation (GX)” policy in its transport sector, covering
railway decarbonization as well.21 In addition to the existing catenary electrification
system, Japan adopted battery-electric in passenger trains and has invested in
hydrogen (H2) fuel cell locomotives, H2 refueling infrastructure, and biodiesel fuel,
mainly for the unelectrified lines.
- Switzerland’s railway network is ~3,418 miles long and is 100% electrified.22
- The United Kingdom (UK) plans to achieve a net-zero rail network by 2050 and
remove all diesel-only passenger and freight locomotives by 2040 (Scotland has
committed to remove all diesel locomotives from the network by 2035).23 As of March
2022, 38% of the UK rail network is electrified with overhead catenary system, and
70% of the passenger rail fleet is electric.
Some jurisdictions have included the rail sector within transport fuels policies. For
example, the EU includes the rail sector in the Renewable Energy Directive, which
mandates a 14.5% emissions reduction in the average GHG intensity of transport fuels
by 2030.24 However, policy compliance in this sector is primarily provided by electricity
supplied to the rail sector rather than biofuels. In the U.S., policies such as the Federal

15 Ministry of Transportation, China, “2022 年交通运输行业发展统计公报”[2022 statistic report for transportation

industry development]. June 16, 2023. https://xxgk.mot.gov.cn/2020/jigou/zhghs/202306/t20230615_3847023.html
16 European Commission. Rail, electrification of rail infrastructure. https://alternative-fuels-

observatory.ec.europa.eu/transport-mode/rail
17 FRA workshop, Europe’s Rail joint undertaking decarbonization plan, presented by Alstom Transportation, Denver,

CO, May 2023, https://railroads.dot.gov/elibrary/europes-rail-joint-undertaking-decarbonization-plan.

18
Central Organization for Railway Electrification, India. https://core.indianrailways.gov.in/
19 Narayan, Subhash. Railways on track to meet target of 100% electrification by Dec. July 28, 2023.

https://www.livemint.com/news/india/railways-on-track-to-meet-target-of-100-electrification-by-dec-
11690543908598.html
20 Climate Chance. The progressive electrification of land and maritime transport. 2019. https://www.climate-

chance.org/wp-content/uploads/2019/12/cp5-2019-japan-transport_en_20191014.pdf
21 FRA workshop, The current status of the development of carbon-neutral & energy-conserving Rolling Stock for

railway systems in Japan, presented by Railways Technical Research Institute, Denver, CO, May 2023,
https://railroads.dot.gov/elibrary/current-status-development-carbon-neutral-energy-conserving-rolling-stock-railway-
systems
22 “Electrifying rail for sustainable transport”. October 31, 2022. https://new.abb.com/news/detail/96454/electrifying-

rail-for-sustainable-transport
23 FRA workshop, Rail decarbonization – it’s a journey, presented by UK Department of Transport, Denver, CO, May

2023, https://railroads.dot.gov/elibrary/rail-decarbonization-its-journey.
24 https://theicct.org/publication/fuels-fit-for-55-red-iii-jul23/

6
Renewable Fuels Standard (RFS) and California’s LCFS obligate fossil fuel refiners and
importers to blend an increasing share of alternative fuels. These policies do not have
mechanisms to ensure the allocation of any of these biofuels to the rail sector.
3. What are the benefits and challenges of the various rail propulsion technologies as
compared to the other alternatives? If possible, please provide a ranking of the alternative
technologies starting with the most viable/promising option.
In the near term, we recommend prioritizing the following technologies:
- Catenary system for passenger locomotives and the busiest freight corridors, with
battery-electric technology for the short-range locomotive segments such as yard
rail/switchers, industrial, local/regional, and passenger locomotives, and a substitute
connecting partially electrified routes.
- Diesel-hybrid battery-electric locomotives as a temporary, near-term approach for
freight locomotives while transitioning to zero-emission technologies. However, the
hybrid approach should ensure that the diesel locomotives comply with the latest,
most stringent (i.e., Tier 4) emissions standards.
For the full transition to zero-emission in the longer term, we recommend the following:
- The catenary system should be the prime technology, wherever technically and
economically feasible, as it is one with the highest apparent grid-to-rails energy
conversion efficiency (~ 90%), followed by battery-electric locomotives (~ 80%),
followed by H2 fuel cell locomotives (~ 40%).25
- Where catenary is not a viable option, a mixed-technology approach should apply
for various zero-emission pathways, such as partial catenary system combined with
either batteries or H2 fuel cells, as applicable.26 This combined technology approach
could overcome the technical and economic constraints of individual technologies
and trade off the unique technology challenges.
The catenary system has been by far the most popular and technologically mature
approach to zero-emission pathway for rail outside of the U.S., widely adopted for
passenger rail (including very high-power demand such as high-speed rail) and for heavy-
haul freight rail (applications seen in China, Sweden, Australia, South Africa, and India).27
A major bottleneck of this approach is the underlying capital cost of infrastructure. A range
of cost estimates between $5.1 million to $31 million per km was reported for overhead
catenary construction in the U.S. for passenger rail, not including the cost of double-stack
locomotives. Compared to the rest of the world, the cost issue for electrification is more
severe in the U.S. For example, Lawrence Berkeley National Lab (2021) reported that
electrification is about twice as expensive in the U.S. as in Europe. 28 This might be
because U.S. freight locomotives could have ten times larger payloads than in Europe,
significantly increasing the average electricity infrastructure requirements and costs.29

25 Railway Age, Follow the Megawatt-Hours: Hydrogen Fuel Cells, Batteries and Electric Propulsion, by Michael
Eden, March 2023, https://www.railwayage.com/mechanical/locomotives/follow-the-megawatt-hours-hydrogen-fuel-
cells-batteries-and-electric-propulsion/
26 Under the status quo for EU's alternative powertrains, as of May 2023, range in unelectrified section varies

between 40 to 150 km for battery-electric locomotives, 400 to > 1000 km for H2 fuel cell locomotives, and > 1000 km
for diesel hybrid battery-electric locomotives. (https://railroads.dot.gov/elibrary/europes-rail-joint-undertaking-
decarbonization-plan.)
27 Popovich, N. D., Rajagopal, D., Tasar, E., & Phadke, A. (2021). Economic, environmental and grid-resilience

benefits of converting diesel trains to battery-electric. Nature Energy, 6(11), 1017-1025.

https://www.nature.com/articles/s41560-021-00915-5
28 ibid
29 ibid

7
“Discontinuous” or “partial” catenary approach is considered as an alternative solution for
the non-electrified parts of the network. Europe, Japan, and the UK have already adopted
battery-electric propulsion for the non-electrified part of the passenger railway, where
batteries could be charged during the electrified part. 30 The battery-electric propulsion
substitute the power and enables low- or zero-emission operation for the non-electrified
parts of the network. 31 The combination could also adopt H2 fuel cells.
Battery-electric technology is by far best suited for relatively short-range segments,
including passenger rail, yard rail or switchers, industrial, and local/regional rail, and it
complements non-electrified sections. Brazil, Europe, and the UK have battery-electric
locomotives in operation, while Australia, Scotland, and the U.S. are beginning trials and
operations over the next few years.32 The major challenges with battery-electric
technology include the high cost of batteries, short battery range, heavy reliance on
charging infrastructure leading to large capital costs of infrastructure, slow charging
rate, and thermal challenges related to safety. The practical operating range on batteries
has been reported as 20 to 60 miles, followed by over 45-minute charging periods.33
Although there is scope for battery charging from regenerative braking, the amount of
energy that could be captured is highly variable as railroads often limit the amount of
dynamic braking for train handling safety. 34 However, with ongoing research and
development, improvements are expected in battery energy density (both gravimetric
and volumetric), charging speed, and battery cost reduction, which could extend the
opportunity for the application up to line-haul locomotives.35
H2 fuel cell technology has the potential to overcome the range limitation and need for
extensive charging infrastructure, as seen in battery-electric locomotives. H2 locomotives
require fewer fueling stops, and refueling time is typically similar to diesel, e.g., roughly
15 minutes for a regional train.36 This technology has been argued as a viable alternative

30 FRA workshop (May 2023), Europe’s Rail joint undertaking decarbonization plan, presented by Alstom
Transportation; The current status of the development of carbon-neutral & energy-conserving Rolling Stock for
railway systems in Japan, presented by Railways Technical Research Institute, Japan; APTA Whitepaper on Battery-
Electric and Hydrogen Passenger Rail Equipment, presented by American Public Transportation Association,
https://railroads.dot.gov/elibrary/apta-whitepaper-battery-electric-and-hydrogen-passenger-rail-equipment; Rail
decarbonization – it’s a journey, presented by UK Department of Transport.
31 Ibid
32 Railway Age, Next-Gen Motive Power, by William C. Vantuono, March 2023.

https://www.railwayage.com/mechanical/next-gen-motive-power/; FRA workshop (May 2023), Progress Rail

decarbonization solutions, presented by Progress Rail, https://railroads.dot.gov/elibrary/progress-rail-decarbonization-
solutions; Europe’s Rail joint undertaking decarbonization plan, presented by Alstom Transportation; Hydrogen and
Battery: How Stadler’s Alternative Propulsion Products Make US Rail More Sustainable, presented by Stadler US
Inc., https://railroads.dot.gov/elibrary/hydrogen-and-battery-how-stadlers-alternative-propulsion-products-make-us-
rail-more; Rail decarbonization – it’s a journey, presented by UK Department of Transport; APTA Whitepaper on
Battery-Electric and Hydrogen Passenger Rail Equipment, presented by American Public Transportation Association;
Deutsche Bahn’s Global Decarbonization Strategies, presented by Deutsche Bahn.
33 FRA workshop (May 2023), Overview of low- and zero-emission technology options for railway motive power,

presented by DB E.C.O. North America, https://railroads.dot.gov/elibrary/overview-low-and-zero-emission-technology-

options-railway-motive-power
34 California Air Resources Board, Transitioning to a Zero or Near-Zero Emission Line-Haul Freight Rail System in

California: Operational and Economic Considerations, prepared by RailTEC, University of Illinois at Urbana-
Champaign, 2016. https://ww2.arb.ca.gov/sites/default/files/classic/railyard/docs/uoi_rpt_06222016.pdf; Railway Age,
Follow the Megawatt-Hours: Hydrogen Fuel Cells, Batteries and Electric Propulsion, by Michael Eden, March 2023,
https://www.railwayage.com/mechanical/locomotives/follow-the-megawatt-hours-hydrogen-fuel-cells-batteries-and-
electric-propulsion/.
35 FRA workshop (May 2023), Overview of low- and zero-emission technology options for railway motive power,

presented by DB E.C.O. North America.

36 ibid

8
to overhead catenary electrification and battery-electric technologies for routes longer
than 20 miles.37 Several H2 fuel cell passenger locomotives are in full operation in Europe,
with the most recent additions in China in mid-2023.38 Canada, U.S., Japan, the UK,
Scotland, and India have launched or plan to launch field trials, demonstrations, and
service operations for H2 technology in the next few years.39 Decarbonizing the rail sector
through the use of H2 would require parallel efforts to replace locomotives and fueling
infrastructure along with replacing present-day H2 production—which is overwhelmingly
produced from fossil natural gas—with renewable or lower-GHG sources. Otherwise,
combusting conventional H2 made from natural gas may not meaningfully reduce the life-
cycle emissions associated with diesel locomotives. Renewable H2 produced via
electrolysis from renewable electricity could have cost reductions over time as renewable
electricity costs decline, though there would also be additional costs associated with
hydrogen distribution and fueling infrastructure.40 The major limitations of H2 fuel cells
include lower grid-to-rail energy conversion efficiency (roughly 40%) and poor
performance with load fluctuation compared to battery-electric locomotives.
Diesel-hybrid locomotives couple the conventional diesel-electric propulsion with either
onboard batteries or battery tenders (as railcars filled with batteries), where the batteries
can substitute power for a share of the trip. It is a low-emission propulsion technology
with a relatively lower capital cost. Battery tenders can be attached or de-attached to the
existing diesel locomotives. This technology offers instant fuel cost savings, local air
quality and public health benefits, and environmental justice for disadvantaged
communities in or around rail yards. California’s demonstration in 2021 indicated that a
diesel-hybrid locomotive with 2.4 MWh battery tenders could reduce fuel consumption by
12% (6,200 gallons of diesel and 69 tons of CO 2 emissions), NOX emissions by 8%, and
CO, THC, and PM emissions by 3%, compared to diesel-only operation.41 With a larger

37 ibid
38 FRA workshop (May 2023), APTA Whitepaper on Battery-Electric and Hydrogen Passenger Rail Equipment,
presented by American Public Transportation Association; Lessons Learned and Best Practices from 4+ Years of
Safe Operation of iLint Hydrogen Fueled Train in Germany, presented by Evb,
https://railroads.dot.gov/elibrary/lessons-learned-and-best-practices-4-years-safe-operation-ilint-hydrogen-fueled-
train; Railway Technology, CRRC unveils “world’s most powerful” hydrogen train, June 19, 2023, https://www.railway-
technology.com/news/crrc-unveils-worlds-most-powerful-hydrogen-train/?cf-view; Hydrogen Fuel News, First
hydrogen passenger train launched in China is also a world first for urban transit, January 31, 2023,
https://www.hydrogenfuelnews.com/hydrogen-passenger-train-china/.
39 FRA workshop (May 2023), Progress Rail decarbonization solutions, presented by Progress Rail; Hydrogen and

Battery: How Stadler’s Alternative Propulsion Products Make US Rail More Sustainable, presented by Stadler US
Inc.; Hydrogen Hybrid Switcher Locomotive for Freight Movement in Canada, presented by Canadian Pacific,
https://railroads.dot.gov/elibrary/hydrogen-hybrid-switcher-locomotive-freight-movement-canada; Pathways to
decarbonizing the rail sector: a Canadian perspective, presented by Transport Canada; Efforts Towards
Decarbonization in Japan, presented by Ministry of Infrastructure, Transport and Torism,
https://railroads.dot.gov/elibrary/efforts-towards-decarbonization-japan; APTA Whitepaper on Battery-Electric and
Hydrogen Passenger Rail Equipment, presented by American Public Transportation Association; Rail decarbonization
– it’s a journey, presented by UK Department of Transport; Railway Age, Next-Gen Motive Power; Railtech.com,
Scotland’s hydrogen train project looks back to the future, November 21, 2011,
https://www.railtech.com/all/2022/11/21/scotlands-hydrogen-train-project-looks-back-to-the-future/?gdpr=accept; The
Times of India, India’s first hydrogen train likely to run from Haryana’s Jind by 2024, June 26, 2023,
https://timesofindia.indiatimes.com/travel/travel-news/indias-first-hydrogen-train-likely-to-run-from-haryanas-jind-by-
2024/articleshow/101281042.cms.
40
Adam Christensen. (2020). Assessment of Hydrogen Production Costs from Electrolysis: United States and
Europe. https://theicct.org/publication/assessment-of-hydrogen-production-costs-from-electrolysis-united-states-and-
europe/
41 The demonstration used Wabtec’s early generation diesel-hybrid model FLXdrive 1.0, in partnership with BNSF,

piloted in California in 2021 for a line-haul locomotive for a 3 month field trial; BNSF Railway, BNSF zero-and near

9
battery capacity (7.3 MWh), fuel consumption reduction can reach nearly 30%.42 Europe
has already adopted the hybrid technology for switchers and passenger locomotives;
some are either already in operation or have been ordered.43 Australia and Canada are
adopting the 7.3 MWh battery diesel hybrid for long-haul freight locomotives.44
H2-ICE involves H2 combustion in the internal combustion engine (ICE). Converting diesel
locomotives to run on H2 can be cost-effective and still substantially reduce emissions
while maintaining diesel-like efficiency and performance levels.45 China converted the
first diesel-engine locomotive to run purely on hydrogen-powered fuel cells in June 2023,
which can operate continuously for up to 190 hours with 270kg H2 onboard. 46 Other
countries, including the Irish and the U.S., have trial projects kicked off testing retrofitting
diesel train engines to hydrogen internal combustion engines.47
The other approach is to blend H2 into diesel with the hypothesis that partial H2 use could
support emission reduction.48 The Government of Canada and the National Research
Council shared in their preliminary findings that GHG emissions reduction could be up to
50%, with the maximum H2 fraction (50%) being blended with diesel based on lab testing.
However, they also reported various challenges in managing high combustion
temperature for H2 in a diesel engine at high load, managing high pressure, using high
H2 share requiring significant engine modification, and optimizing injection timing having
tradeoffs in emission benefits between GHG and NOX emissions.
5. For direct electrification of rail, how do you foresee the infrastructure (such as overhead
catenary) being built? Who should own and operate the infrastructure?
Innovative approaches can share the roles and responsibilities among the government,
industry, technology and/or utility providers, and other private entities on financing,
managing, and operating the infrastructure. For example, a commission can perform as
a joint power authority – Alameda Corridor Transportation Authority (ACTA) – to plan,
fund, and execute infrastructure-building projects. This type of joint effort has built and

zero-emission freight facilities project (zanzeff) data acquisition support, May 2021,
https://ww2.arb.ca.gov/sites/default/files/2022-11/zanzeff-bnsf-belreport.pdf
42 Railway Age, FLXdrive ‘electrifies’ Pittsburg, by William C. Vantuono, September 14, 2023,

https://www.railwayage.com/freight/flxdrive-electrifies-pittsburgh/
43 FRA workshop (May 2023), APTA Whitepaper on Battery-Electric and Hydrogen Passenger Rail Equipment,

presented by American Public Transportation Association; Deutsche Bahn’s Global Decarbonization Strategies,
presented by Deutsche Bahn, https://railroads.dot.gov/elibrary/deutsche-bahns-global-decarbonization-strategies;
Progress Rail decarbonization solutions, presented by Progress Rail; Railway Age, Next-Gen Motive Power.
44
Railway Age, Next-Gen Motive Power; Canadian National Railway Company, CN Advances Sustainability Efforts
With Wabtec’s Battery-Electric Locomotive, November 4, 2021, https://www.cn.ca/en/news/2021/11/cn-advances-
sustainability-efforts-with-wabtecs-battery-electric/.
45 FRA workshop (May 2023), Pathways to decarbonizing the rail sector: a Canadian perspective, presented by

Transport Canada. https://railroads.dot.gov/elibrary/pathways-decarbonizing-rail-sector-canadian-perspective;

46 Collins, L. (June 16, 2023). World first as Chinese company converts diesel locomotive to run on hydrogen fuel

cells. https://www.hydrogeninsight.com/transport/world-first-as-chinese-company-converts-diesel-locomotive-to-run-
on-hydrogen-fuel-cells/2-1-1468903
47 Martin, P. (September 19, 2023). Irish rail operator to trail hydrogen combustion in retrofitted diesel train engine.

https://www.hydrogeninsight.com/transport/world-first-irish-rail-operator-to-trial-hydrogen-combustion-in-retrofitted-
diesel-train-engine/2-1-1520833; Railtech.com (November 16, 2022). US research project to develop hydrogen
combustion engine for rail. https://www.railtech.com/rolling-stock/2022/11/16/us-research-project-to-develop-
hydrogen-combustion-engine-for-rail/
48 FRA workshop (May 2023), Pathways to decarbonizing the rail sector: a Canadian perspective, presented by

Transport Canada. https://railroads.dot.gov/elibrary/pathways-decarbonizing-rail-sector-canadian-perspective;

10
run the Alameda (Rail) Corridor successfully since the 1980s.49 The ACTA utilized various
funding sources, including Federal loans, port contributions, Federal, state, and local
funds, railroads contributions, and a revenue bond, to achieve the total $2.4 billion budget
of building the infrastructure and further operating the corridors with roles and
responsibilities covering dispatching trains, infrastructure maintenance and security,
collecting fees and finance.50
Similarly, Federal, state, regional, and local funding opportunities can apply to the
infrastructure of direct electrification. The recent Infrastructure Investment and Jobs Act
(Act) allocated $102 billion in federal infrastructure funding, with sustainability as one of
the dedicated focus areas in rail network improvement.51 Funding allocated to Amtrak can
enhance infrastructure, given the network overlaps. The Act allocated $22 billion for
Amtrak to repair and replace old, obsolete assets in its network, with an additional $44
billion allocated to the Federal Railroad Administration to support railroad improvements.
Additional grants and loans are available from other federal agencies, including the
Department of Transportation (FTA, FHWA), Department of Energy (LPO), and
Environmental Protection Agency, to promote the infrastructure building to support the
zero-emission transition. Tax revenues can also support, as well as bond financing and
private sector debt financing.
7. What are the most critical gaps (e.g., with respect to standards, regulations, supply
chain, labor) that need to be filled to support acceptance of and markets for alternative
rail propulsion technologies?
Stringent standards for new locomotives from the federal level would be very helpful in
promoting the adoption of advanced propulsion technologies that are low- and zero-
emission. The Tier 4 tailpipe standards implemented in 2015 have been in place for
almost a decade, which are no longer stringent enough to promote the adoption of state-
of-the-art technology. There are not yet GHG emissions standards for locomotives.
Transition to zero-emission technologies will be challenging and delayed without
implementing stringent requirements for both criteria and CO2 emissions.
Tightened requirements for refurbished and remanufactured engines are essential to
remove/replace/repower/retire old, diesel locomotives. Although Tier 4 was adopted from
2015, nearly half of fleet are still Tier 0 and Tier 1 certified, and only 7% are subject to
Tier 4 standards as today. 52 This has been largely due to the regulatory flexibility for
remanufactured/refurbished locomotives to remain compliant with the original old
standards after the end-of-useful life, leading to very slow turnover rate and delayed
phase-in of engines meeting more stringent standards and adopting advanced technology.
State efforts that promote zero-emission technology can magnify federal efforts.
California’s IULR sets a great example for other states to follow. The IULR requires

49 The Alameda Corridor Transportation Authority (ACTA) was created with members covering local elected officials,
as well as representatives of the ports of Los Angeles and Long Beach, the U.S. Navy, the Army Corps of Engineers,
affected railroads, trucking industry, and the Los Angeles County Transportation Commission. Alameda Corridor
Transportation Authority. https://www.acta.org/
50 Department of Transportation. October 22, 1999. Review of the Alameda Corridor project.

https://www.oig.dot.gov/sites/default/files/tr2000004.pdf
51 Federal Railroad Administration. December 11, 2023, Bipartisan Infrastructure Law Information from FRA.

https://railroads.dot.gov/BIL
52 U.S. Environmental Protection Agency (EPA), 2020 National Emissions Inventory locomotive methodology,

prepared by Eastern Research Group, Inc., May 2022, https://www.epa.gov/system/files/documents/2023-

01/2020_NEI_Rail_062722.pdf

11
banning of diesel locomotives from existing fleets that are older than 23 years and
requires that all new switchers and passenger locomotives must be operating in zero-
emission configuration while in California starting from 2030 and the requirement extends
to all new line-haul locomotives starting from 2035.53 Other states could adopt California’s
approach, accelerating the retirement of old, dirty diesel engines and requiring the usage
of zero-emission technology in the fleet.
Transition to zero-emission technologies could be strategic and prioritized for specific
locomotive segments. Switchers/yard rail, industrial, local/regional and passenger
locomotives are typically easier to transition to zero-emission technologies considering
technology readiness, economic viability, and level of air quality and public health impact.
Such strategic adoption could help create a market for advanced technologies to further
advance and mature and contribute to market transformation and expansion for
technologies for line-haul freight locomotives.
8. What infrastructure is required to support promising alternative rail propulsion
technology? Are there specific routes, railyards, or network segments that would be a
good candidate for alternative propulsion technologies (e.g., catenary, hydrogen fuel cells,
or batteries)?
Infrastructure requirements will vary through the route network depending on the overall
transition approach to rail decarbonization and the target locomotive segment.
For overhead catenary system, major infrastructure requirements would include
construction of overhead catenaries, construction and/or modification of existing road
infrastructure or terrains to allow for the vertical clearance needed for the double-stack
locomotives and overhead wiring, and ensuring grid readiness through the network or,
more specifically, through parts of the electrified network (assuming there would be un-
electrified portions of the network).
For battery-electric locomotives, the prime requirement would be the source of external
charging for the batteries. This source of charging could be in one or more of the forms
of charging stations (en-route or trip-end depending on battery range and trip length),
overhead catenaries (in case of discontinuous or partial electrification approach), or a
third rail (also known as a live rail, electric rail or conductor rail) which is a method of
providing electric power to locomotives through a semi-continuous rigid conductor placed
alongside or between the rails of a railway track. The battery-electric locomotives can
take advantage of the existing catenaries if there are any. The benefits would then include
no additional infrastructure for en-route charging stations plus no additional time lost for
charging (since batteries would be charged from the catenaries) en-route.
For H2 fuel cell locomotives, the major requirement would be the H2 refueling centers to
refill the tender cars for H2 along with the building of tender cars that meet the potential
safety and design requirements.
The investment can be prioritized to the areas where the largest benefits of emission
reduction and air quality and public health improvement can be identified. Railyards

53 CARB defines zero-emission configuration as a locomotive that operates in zero-emission capacity in California,
which can be either a zero-emission capable locomotive (e.g., a diesel hybrid battery-electric locomotive) or a zero-
emission locomotive (e.g., a full battery-electric or H2 fuel cell locomotive). California Air Resources Board, CARB
passes a new In-Use Locomotive Regulation estimated to yield over $32 billion in health benefits, April 27, 2023,
https://ww2.arb.ca.gov/news/carb-passes-new-use-locomotive-regulation-estimated-yield-over-32-billion-health-
benefits-0

12
located close to the community, passenger railway routes, and freight corridors with the
most frequent railway traffic are top candidates for introducing promising zero-emission
rail technology with focused funding investment. Short-distance regional switchers and
industrial locomotives should be considered low-hanging fruits for the transition by
adopting battery-electric technology with minimal need for charging infrastructure. 54
Meanwhile, diesel-hybrid battery-electric technology should be adopted immediately once
those prove viable based on field trials or pilots, but only as a temporary solution, which
would eventually be replaced with electrification, battery-electric technology, a mix of the
two (i.e., partial electrification + batteries), or H 2 fuel cell.
10. What government actions do you think are necessary to help move the rail sector
towards net-zero emissions? Responses were added under Question 2 and 7.
11. Other than tax credits, what opportunities are there to incentivize transition to clean
fuels, recognizing that costs are likely to be higher in the near to mid-term? (For example,
vehicle consumer incentives in the on-road sector include the use of high occupancy
vehicle (HOV) lanes, free workplace charging, etc.).
Governments can assist in closing the cost gap between fossil diesel and alternative fuels
by using numerous policy levers. Market-based programs such as the California’s LCFS
incentivize eligible parties based on their fuel’s lifecycle GHG emission reductions relative
to a declining carbon intensity (CI) target. In effect, the program incentivizes fuel
producers to decrease emissions along their fuel supply chain rewarded them for
producing fuel compatible with more efficient powertrain technologies using an energy
efficiency ratio (EER) multiplier. In heavy-rail applications, electricity-based pathways
have an EER of 4.6 relative to fossil diesel; thus, electricity is 4.6x more valuable than
BBD per energy equivalent unit of fuel. Electrified light rail and trolley cars that operate
using “fixed guideway systems” have an EER of 3.3 and 3.1, respectively.55 Alternative
fuel pathways such as electricity, liquid biofuels, and renewable natural gas have all
exhibited significant growth since the start of the LCFS program in 2011. For example,
electricity-based pathways made up 0.6% of credits at the start of the program in 2011
and now make up 24% of annual credits.56
In addition to crediting fuel producers, the LCFS has specific provisions that credit eligible
parties for infrastructure and technology investments. Infrastructure credits have scaled
up investment in alternative fueling infrastructure and meet growing energy demand from
alternative powertrain technologies. 57 A similar infrastructure crediting provision could
apply to upgrade Class I-III locomotives' fueling systems. While the capacity crediting
formula for FCIs is amenable to hydrogen refueling stations for tender cars and en-route
charging of batteries, the formula could be revised to support building overhead catenary
and third rail infrastructure. For example, the FCI crediting formula could be updated

54 Details can be seen from the global examples as discussed in the earlier response to Question 3.
55 California Air Resources Board. (2020). Unofficial electronic version of the low carbon fuel standard regulation.
https://ww2.arb.ca.gov/sites/default/files/2020-07/2020_lcfs_fro_oal-approved_unofficial_06302020.pdf
56 California Air Resources Board. (n.d.) Low carbon fuel standard reporting tool quarterly summaries.

https://ww2.arb.ca.gov/resources/documents/low-carbon-fuel-standard-reporting-tool-quarterly-summaries
57 California Air Resources Board. (2021). Zero-emission vehicle (ZEV) infrastructure crediting within the LCFS: how

does it work. https://ww2.arb.ca.gov/sites/default/files/classic/fuels/lcfs/guidance/zev_infra_crediting_overview.pdf;

Since 2018, electric vehicle supply equipment (EVSE) operators have been awarded LCFS credits for installing
hydrogen refueling and direct current fast charging (DCFC) infrastructure (i.e., fast charging infrastructure (FCI)), in
addition to credits for the quantity of fuel dispensed. California Air Resources Board. (2018). Final regulation order.
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2018/lcfs18/frolcfs.pdf

13
based on the quantity of electricity dispensed relative to tonne-kilometers of delivered
freight to support direct rail electrification.
Continuous investment in the alternative fuels from the federal and state government
send out a clear signal particularly at early stage. For example, hydrogen’s development
got a huge increase with the 2021 Infrastructure Investment and Jobs Act, which attracted
major corporations and research organizations to collaborate and invest.58
Upfront research and grant funding are also essential to reduce the cost of new
technologies. CARB offers grant funding to locomotive operators to meet requirements
set forth under the newly adopted IULR.59 Most of these funds are administered via air
quality improvement programs. At the federal level, the Department of Transportation
(DOT) allocated $1.4 billion in funding in FY 2022 to support rail infrastructure and safety
improvements.60 This includes funding to support research and development to facilitate
innovative rail projects. The federal government could also capitalize on funding pools
allocated under the 2021 Infrastructure Investment and Jobs Act (IIJA), such as regional
Surface Transportation Block Grants.61
13. Are you aware of any goals for Total Cost of Ownership (TCO) willingness to pay for
advanced technologies? Recognizing that DOE and industry are driving to cost parity with
diesel in the long term, what do you think the goals should be regarding reasonable extra
costs over the diesel baseline in the near term?
There is a knowledge gap in the literature regarding the comprehensive evaluation of
cost-effectiveness and total cost of ownership estimates for advanced locomotive
technologies. Few studies reported such estimates for limited cost-benefit items and/or
limited types of technologies. The Lawrence Berkeley National Lab (2021) estimated net
present value total cost of ownership over 20 years for converting diesel-electric line-haul
locomotives to battery-electric locomotives (assuming batteries of 9.1 MWh capacity and
241 km range).62 The study found that over 20 years, the capital and operating costs from
the conversion would be $15 billion, while the benefits from battery-electric locomotive
operation would be savings of $44 billion based on emissions reduction of criteria air
pollutants only and $94 billion accounting for emissions reduction for both criteria air
pollutants and CO2.
A U.S. DOE-sponsored ARPA-e project led by NC State University, V-Tech, Oregon State
University, and DB reported that compared to conventional diesel, electrification and
battery-electric locomotives had the largest annual fuel savings of nearly $9 billion,
followed by the H2 fuel cell at more than $2 billion, and diesel-hybrid battery-electric at
$0.7 billion across the U.S.63

58 Graab, D. (July 11, 2023). Hydrogen: hope or hype? https://www.railwayage.com/freight/hydrogen-hope-or-hype/

59 California Air Resources Board (n.d.). Incentives for locomotives. https://ww2.arb.ca.gov/our-
work/programs/reducing-rail-emissions-california/incentives-locomotives
60 Federal Railroad Administration. (January 17, 2024). Consolidated rail infrastructure and safety improvements

(CRISI) program. https://railroads.dot.gov/grants-loans/competitive-discretionary-grant-programs/consolidated-rail-

infrastructure-and-safety-2
61 117th Congress (November 15, 2021). Public law 117-58. 135 STAT. 429

https://www.congress.gov/117/plaws/publ58/PLAW-117publ58.pdf
62 Popovich, N. D., Rajagopal, D., Tasar, E., & Phadke, A. (2021). Economic, environmental and grid-resilience

benefits of converting diesel trains to battery-electric. Nature Energy, 6(11), 1017-1025.

https://www.nature.com/articles/s41560-021-00915-5
63 FRA workshop (May 2023), Multi-decadal decarbonization pathways for U.S. freight rail, presented by DB E.C.O.

North America Inc., https://railroads.dot.gov/elibrary/multi-decadal-decarbonization-pathways-us-freight-rail.

14
Transport Canada (2020) conducted a feasibility study on adopting an H2 fuel cell by
retrofitting an existing diesel switcher. 64 The operating costs of the technology were
roughly twice that of diesel, but the difference could narrow over time with net savings
shown in a decade. The estimated cost of this conversion could range from roughly $5
million to $8 million, along with an added capital cost of nearly $300,000 per locomotive
for H2 fuel delivery and storage. Transport Canada further estimated that the overall
capital cost for adopting H2 fuel cells for Canada’s rail industry would be $32 billion, and
embracing H2 fuel cells could avert 78 Mt of GHG emissions from 2030 to 2050.
As part of the regulatory assessment, CARB (2022) estimated that the IULR regulation
transitioning to zero-emission locomotives would lead to statewide health benefits of $32
billion between 2024 and 2050, while the total net cost of the regulation would be $13.8
billion in the same timeframe.65 Locomotive operators are less likely to pay a high-cost
premium for alternative fuel technologies on a purely voluntary basis, though policy
incentives could bridge at least a portion of the cost gap.
15. In your opinion, how do certain technologies (e.g. battery) compare for different use
cases (e.g. line haul, switching)? Responses added under Questions 3 and 8.
17. What do you think should be the estimated global market size for net-zero emission
locomotives or retrofitting technologies? Responses added under Question 2.

64 Transport Canada, Assessment of the Design, Deployment Characteristics and Requirements of a Hydrogen Fuel
Cell Powered Switcher Locomotive, June 2020, https://tc.canada.ca/en/innovation-centre/priority-reports/assessment-
design-deployment-characteristics-requirements-hydrogen-fuel-cell-powered-switcher-locomotive
65 California Air Resources Board, Public hearing to consider the proposed in-use locomotive regulation, September

2022, https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2022/locomotive22/isor.pdf

15