The Honorable Michael S. Regan
Administrator
Environmental Protection Agency
1200 Pennsylvania Avenue NW; 1101-A
Washington, DC 20460
Re: CARB’s Clean Air Act Authorization Request (EPA-HQ-OAR-2023-0574)
Dear Administrator Regan:
We urge you to deny the California Air Resources Board’s (CARB) application to exempt its In-Use Locomotive Regulation (Regulation) from the Clean Air Act.
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.
Ultimately, the CARB Regulation would undermine efficiency and dramatically slow commerce, thereby undermining the integrity of the integrated supply chain and the reliability of railroads to meet demand. Ironically, it would also harm ongoing efforts to reduce greenhouse gas emissions in the freight rail industry. We urge you to reject CARB’s application.
Sincerely,
U.S. Chamber of Commerce
Agricultural Retailers Association
Aiken Chamber of Commerce
Alaska Chamber
Albany Area Chamber of Commerce (OR)
Arkansas State Chamber of Commerce / Associated Industries of Arkansas
Ascension Chamber of Commerce
Associated Industries of Florida
Berkeley Chamber of Commerce
Billings Chamber of Commerce
Brea Chamber of Commerce
Buckeye Valley Chamber of Commerce
Buellton Chamber of Commerce
Burlington Chamber of Commerce
Cadillac Area Chamber of Commerce
California Business Roundtable
California Farm Bureau
Campbell County Chamber of Commerce
Canby Area Chamber of Commerce
Carlsbad Chamber of Commerce
Central Fairfax Chamber of Commerce
Chamber Southwest Louisiana
Chandler Chamber of Commerce
Chicagoland Chamber of Commerce
Chino Valley Chamber of Commerce
Columbia Montour Chamber of Commerce
Colusa County Chamber of Commerce
Corsicana & Navarro County Chamber of Commerce
Davis Chamber of Commerce
Decatur Chamber of Commerce
Detroit Regional Chamber
Duchesne County Chamber of Commerce
Eden Prairie Chamber
Edwardsville/Glen Carbon Chamber of Commerce
Fort Worth Chamber of Commerce
Fountain Hills Chamber of Commerce
Gateway Chambers Alliance
Georgia Chamber of Commerce
Glendora Chamber of Commerce
Green Oaks, Libertyville, Mundelein, Vernon Hills Chamber of Commerce
Grant County Chamber of Commerce
Greater Binghamton Chamber of Commerce
Greater Cheyenne Chamber of Commerce
Greater Coachella Valley Chamber of Commerce
Greater Flagstaff Chamber of Commerce
Greater Grass Valley Chamber of Commerce
Greater High Desert Chamber
Greater Lafayette Commerce
Greater Lawrence Chamber of Commerce
Greater Mankato Growth
Greater North Dakota Chamber
Greater Omaha Chamber
Greater Phoenix Chamber
Greater Rochester Chamber of Commerce
Greater Shreveport Chamber
Greater Spokane Valley Chamber of Commerce
Greater Topeka Chamber
Habersham County Chamber of Commerce
Harbor Association of Industry and Commerce
Huber Heights Chamber of Commerce
Illinois Chamber of Commerce
Indiana Chamber of Commerce
Inland Empire Economic Partnership
Iowa Association of Business and Industry
Joliet Region Chamber of Commerce & Industry
Kalispell Chamber of Commerce
Kentucky Chamber of Commerce
Kingman Area Chamber Of Commerce
Louisiana Association of Business and Industry (LABI)
Laguna Hills Chamber of Commerce
Laguna Niguel Chamber of Commerce
Lewistown Area Chamber of Commerce
Long Beach Area Chamber of Commerce
Longview TX Chamber of Commerce
Los Angeles Area Chamber of Commerce
Los Angeles County Business Federation (BizFed)
Loudoun County Chamber of Commerce
Maryland Chamber of Commerce
Minneapolis Regional Chamber
Minnesota Chamber of Commerce
Missouri Chamber of Commerce and Industry
Modesto Chamber of Commerce
Montana Chamber of Commerce
Moses Lake Chamber of Commerce
Murrieta/Wildomar Chamber of Commerce
Nebraska Chamber of Commerce & Industry
Nevada Farm Bureau Federation
New Jersey State Chamber of Commerce
Newark Regional Business Partnership
Newport Beach Chamber of Commerce
North Carolina Chamber of Commerce
North Country Chamber of Commerce
North San Diego Business Chamber
Norwalk Chamber of Commerce
Orange County Business Council
Oregon Business & Industry
Palm Desert Area Chamber of Commerce
Palos Verdes Peninsula Chamber of Commerce
Payson Santaquin Area Chamber of Commerce
Pennsylvania Chamber of Business and Industry
Pocatello-Chubbuck Chamber of Commerce, Inc.
Port Hueneme Chamber of Commerce
Prattville Area Chamber of Commerce
Queen Creek Chamber of Commerce
Queens Chamber of Commerce
Rancho Mirage Chamber of Commerce
Rio Rancho Chamber of Commerce
Roseburg Area Chamber of Commerce
San Angelo Chamber of Commerce
San Gabriel Valley Economic Partnership
San Marcos Chamber of Commerce
Santa Barbara South Coast Chamber of Commerce
Santa Paula Chamber of Commerce
Santee Chamber of Commerce
Schuylkill Chamber of Commerce
Simi Valley Chamber of Commerce
South Bend Regional Chamber
South Dakota Chamber of Commerce & Industry
South Valley Chamber of Commerce
St. Paul Area Chamber
Streetsboro Area Chamber of Commerce
The Chamber of Grand Forks / East Grand Forks
The Greater Houston Partnership
The Greater Springfield Chamber of Commerce
The Mansfield Area Chamber of Commerce
Tulare Chamber of Commerce
Union County KY Chamber of Commerce
Utah Valley Chamber of Commerce
Vegas Chamber
Washington County (MD) Chamber of Commerce
West Ventura County Business Alliance
White Pine Chamber of Commerce
Will County Center for Economic Development
Willits Chamber of Commerce
Yorba Linda Chamber of Commerce
