California Services in disagreement with CARBs proposed rules

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GDRRiley

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California Air Resource Board has proposed a number of changes to the environmental regulations around rail transport which the 3 Joint Power Boards which run the California services are rightfully not happy about.

There is a proven tech, Electrification but the state nor class 1 seem willing to start the projects needed. Even with an environmental regulations bypass (Current proposal trying to get support) getting the ~10,000 track miles needed under wire will not be quick

Some of the valid criticisms raised by the paper:

punishing a pax operator for adding more service shouldn't not happen. The drive should be to push more people to rail and expanding service is key to that.
the less than 10 year timeline for only passenger operations is really quite short given the lack of funding now, freights get an extra 5 years. Which is still an ambitious timeline.
carve out funds for buying new equipment is really weird for the passenger operators as well.
the 23 year useful lifespan does not align with fed funding which is 30-40 years, if the goal was reducing emissions forcing a rebuild to the latest standard at 15-20 years would work.

At this point they've got test units coming for hydrogen but making a 10-12 car hydrogen FLIRT is going to push the limits and that is before a 110mph operational speed which would allow future higher speed operations.

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MARC Rider

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I'd like to see a link to the proposal to see what's in it. I suspect this is pretty early in the rulemaking process, so there may be many opportunities to change it.

Having worked with CARB and other California agencies on greenhouse gas issues in the past, I've found that although they are trying to be serious about reducing greenhouse gas emissions, their goals are probably unrealistic without having to force policies that will be wildly unpopular even in "liberal," "left-wing" California.
 

GDRRiley

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I'd like to see a link to the proposal to see what's in it. I suspect this is pretty early in the rulemaking process, so there may be many opportunities to change it.
Reducing Rail Emissions in California | California Air Resources Board
Would have good for me to link it.
Having worked with CARB and other California agencies on greenhouse gas issues in the past, I've found that although they are trying to be serious about reducing greenhouse gas emissions, their goals are probably unrealistic without having to force policies that will be wildly unpopular even in "liberal," "left-wing" California.
While I agree they are serous I think often their method of trying to reduce emissions is flawed.
There is 0 push from them to move freight from trucks to rail and they are not trying to push people out of personal vehicles to transit. Caltrans and LA metro are still talking about large amounts of freeway expansion.

Sounds like CARB is missing the forest for the trees here. Any increase in rail service that takes cars off the road is going to be a net improvement in air quality even if it has to be done using Diesel motive power for now, until electrification and/or alternate power sources are developed and deployed.
The states basically set on a 2035 deadline for new equipment bought by the state to be 0 emmsions which means by 2050-2055 it will be EOL or at least due for a rebuild in most cases.
 

SubwayNut

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Couldn't the freight companies and Amtrak Long Distance not comply since their equipment is used in Interstate Commerce and only need to follow Federal, not state regulations?
 

GDRRiley

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Couldn't the freight companies and Amtrak Long Distance not comply since their equipment is used in Interstate Commerce and only need to follow Federal, not state regulations?
the goal is to get freight RR to make binding agreement but yes if they choose to they wouldn't need to follow it. The state will likely offer up lots of investments to get them to agree

I'm not sure what the plan is for Amtrak LD trains
 

GDRRiley

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I've read lot of the public comments from the organizations who run rail or who support it like OCTA being a member of metrolink and SMART

The pax operators are really not a happy
 

Anderson

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the goal is to get freight RR to make binding agreement but yes if they choose to they wouldn't need to follow it. The state will likely offer up lots of investments to get them to agree

I'm not sure what the plan is for Amtrak LD trains
The other issue is that if the freight operators refuse to comply, that's likely to lead to a domino effect - I wouldn't be surprised if the pax operators were able to basically turn around and say "Imposing a burden on us which we can't get compliance with will force us to end services/block establishing new services and backfire on your stated goals".
CARB may be able to exercise outsized influence on the auto market, but on this one it feels like they lack their usual leverage and don't realize it.
 

GDRRiley

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CARB may be able to exercise outsized influence on the auto market, but on this one it feels like they lack their usual leverage and don't realize it.
CARB has the direct power to do that, they are pushing way outside their legal limits here. Its clear railroad emissions can only be set by the feds. (as a state you could require all purchases made with state money are X or Y but thats the limit)
 

MARC Rider

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While I agree they are serous I think often their method of trying to reduce emissions is flawed.
There is 0 push from them to move freight from trucks to rail and they are not trying to push people out of personal vehicles to transit. Caltrans and LA metro are still talking about large amounts of freeway expansion.
If they were really serious, they would be pushing policies to reduce the amount of freight transported and to not just push people out of their cars and into transit, but also to somehow reduce the amount of total passenger miles traveled. And as population increases every year, that means that each person will need to travel fewer and fewer miles every year. All of this stuff requires policies that are so draconian that I don't think they would be politically viable.
 

jis

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The State, if it is that serious, could step upto the plate and say that they will fund electrification of all major routes in the state in exchange for railroads acquiring rolling stock that uses said electrification, and after 2035 ban use of non-electric power on electrified railroads in a staged manner. I don't think they will do that if they can get good publicity in the environmental community by just making proclamations of unfunded mandates as far as they can.
 
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GDRRiley

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If they were really serious, they would be pushing policies to reduce the amount of freight transported and to not just push people out of their cars and into transit, but also to somehow reduce the amount of total passenger miles traveled. And as population increases every year, that means that each person will need to travel fewer and fewer miles every year. All of this stuff requires policies that are so draconian that I don't think they would be politically viable.
arguing for less freight transport isn't going to fly, best we can do is push for a mode shift to rail which is more effficent and with wires far more green and cheaper
To reduce how much people need to travel we need denser cities which is starting to happen but way outside CARB
The state, if it is that serious, could step upto the plate and say that they will fund electrification of all major routes in the state in exchange for railroads acquiring rolling stock that uses siad electrification, and after 2035 ban use of non-electric power on electrified railroads in a staged manner. I don;t think they will do that if they an get good publicity in the environmental community by just making proclamations of unfunded mandates as far as they can.
I wish we'd do a rolling electrification program, I'd also want it come with them adding extra tracks for more capacity so we can remove some of the major bottlenecks
Shortlines are the other group that needs help here they've got ~1000 track miles and 150 locos most of which are pre T0.

Amtraks letter was great, we support the idea but given feds regulate railroad emissions we won't listen

Submit Public Comments to CARB | California Air Resources Board
 

MARC Rider

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arguing for less freight transport isn't going to fly, best we can do is push for a mode shift to rail which is more effficent and with wires far more green and cheaper

Oh, I agree with that, but if population and/or the economy continues to grow, the emissions reductions yielded by the "efficiency" of the mode shift to rail will be overwhelmed by the increased amount of freight that will be hauled around.

To reduce how much people need to travel we need denser cities which is starting to happen but way outside CARB

It's not just "denser" cities. The last time I was in LA, I was surprised at how dense the urban development was. The problem was that you still needed cars to get around most places. They need to redesign for walkable neighborhoods, so that you can do most of the things you need to do in daily life without having the need for any form of motorized transportation. (OK, those with physical mobility impairments can ride around in scooters, but they work pretty well in a town plan optimized for pedestrians.) Oh, and forcing people to live in walkable neighborhoods also probably won't fly, either, but if it's not done, all of the increased "efficiency" won't help reduce emissions.
 

MARC Rider

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Here's a more useful link that describes what they're proposing for passenger locomotives.


They won't be requiring ZE ("Zero emissions") locomotives until 2030. And that's just for "new build" locomotives that they buy. After 2030, they can still use existing locomotives that are less than 23 years old. That means they could buy a whole bunch of diesel locomotives in 2029 and continue to avoid electrification until after 2050. That's what the truckers did in 2006 for a particularly stringent EPA on-road diesel rule that was effective in 2007. Plus, there are all sorts of exemptions.

Frankly, I think the scope of the rule is way too broad. Their real problem from criteria pollutants is in railyards, where they probably should force adoption of very low and zero emissions technologies for the switchers. There's a lot of emissions concentrated in a small area in railyards. Emissions from linehaul locomotives operating in rural areas should be less of a concern.

Also, they claim that compliance with their proposed rule will reduce PM 2.5 from passenger locomotives equivalent to PM 2.5 emissions from 90,000 cars, that is "equivalent to removing 90,000 cars from California's roads." However, in 2018, there were over 15 million cars registered in California, and I would expect that number will be higher in 2030. These emission reductions are rounding error. It seems to me very foolish to dump on the passenger rail operators an unfunded mandate that would provide insignificant benefit, especially since the state does apparently have a policy to encourage the use of passenger rail as a strategy to lower emissions.
 
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