RS.0Ceqel Sale ws JPMartios Tepe: (2 583-2086 ihe Vee Chnlemen Fos om 58 07 Che Aoi Seceary Karl Simon Director. Transportation Climate Division, Office of Transpartacion and Abr Quality Environmental Protection Agesey 11200 Pennsylvania Avene, WOW, Washington, DC 20460, Re: Docket ID No, EPA-HQ: OAR-2023- 0574 Dear me. Stian, (On behalf wf 60-017, | am writing today to commenton the abore-referercuel Docket We represent 1800 members chraughout California, (We strongly oppose CARB's efforts to im plenent its [nese Locomotive Regulation ‘This regulation ignores the complex. interconnected nature of rallnoad operations, as well asthe realty of where {technology stands today. Hy seeking to enforce zero-emisslons lacamotive standards that will not be ‘commerrialty available anytire in the foreceeahle future, these regulations would advercely affect not ‘only California but the rest of the county. An atthe most fundamental level. this regulation Is preempted by federal law, which ensures that interstate commerce will not’be burdened or hindered bya patchwork of ‘competing state ar local-fevel stand res We strongly believe that this regulation will createa negative chain reaction if allowed to-go into effect, with significant impacts on: LuLCalfornia and nations jabs [Te national supply chai “ithe rational sate and lacaleeonamy, inereasing costs farahigpers and consumers “the abiity of teat std nation Loeftectively arti to lowers ions Incomocives oP diversion, wath ship traveling ta Sautha and Fastera poms, ane mace cargo being tanaterr to true 1 fact, highly likely thatthe regulatton’s oa of redueingemissions an Improving alr quality would have the opposite result (CARB's regulation would make freight transportation uneconomical in California, detving up the ost of rail ‘service causing, rel ta shlf from rll to truck, less fuel-eficlent mode, This wil ead to more enngestion an California's already overburdaned highway system while adding mareair pollution, with che most significantlrmpaees to the San Pedro Bay port complex and the Inland Empire inthe formofa congested supply chain and increased truck trafic “This wrould be indirect confMice with the DOT, DOE and EPA's US. National Blueprine for Transportation Decarbonization which prioritizes the movement of freight by ral, im stating," Hosad freight velicles such as trucks. .are the largest contrioutor to freight emissions. Using mice elicient roudle..s essential Laredice overall transportation emissions and energy use. Using more efficient modes covld also reduce the mumiser of vehicles om the road and reduce congestion, improving travel time and traific flow, thereay reducing GHG emissions and other harmful air pollutants” Inaddition, the regulation would be caunter-productive by increasing greennouse gas (GHG) ‘emigslons thraugh the diversion of eargo to more distanf, less environmmentally-canicious North American trade srateways. The Pert of Los Angeles estimates that 1 in 12 jabs in Les Angeles and Long, Wench, as well as 1 in jobs In the counties ef Los Angeles, Orange, Riverside, San Rernardina and Ventura are connected io the Parts, ssn 24 many as three nilon jobs nationwide'The shifting of supply chains will have numerous unintended cunsequences (One of these would be the inability of railrnads tp invest in their operations, due to tue extremely high ‘campliance casts far the raliroads te operate in California. The CARB regulation’: spenching account provision would require Class | railroads to deposit as much se $H00 million per year per railroad, whieh, repmesants approximately 20-25% af che total annual nationwide capital expenditures for rach ofthese railcoads, And iF EPA approves CARE's request, other states could implement similar regulations However if theClass 1 ralroads have to set aside $800'million gach pcr-year in California under this regulation, they will pot be ale todnvest in major nfrastruesure in che stare ‘And short-line railroads could ga out of business antiraly, «fact that CARB has even aelmowledgad, ‘We urge EPA to reject CARB's approach to locomotive regulation an! support a wore collaborative approach to-accelerate the commercial viability nf lower- and zero-em issn locomotives, while ranting Jots, the econemy and the national supply thal Sineg R.S.0'Connell General Chairman