California is once again trying to set policy that will significantly impact (read: hurt) the rest of the nation. Through their narrow climate emergency lens, the California Air Resources Board (CARB) wants to restrict the types of locomotives used on the state’s rail system and needs permission from the Environmental Protection Agency (EPA) to be granted a waiver in order to do so.
If the Golden State gets its way, trains that are more than 23 years old will not be allowed to operate within its borders starting in 2030. By 2047, 100 percent of the fleet must be zero emissions.
Approximately 72 percent of line haul Class I locomotives in the country enter California each year. Placing such strict constraints on trains coming and going from the state would have ripple effects across the continent. Because rail operations are interstate, Congress has passed numerous statutes declaring that regulation of the rail industry must occur at the federal level. One state should not have the ability to alter the nation’s rail transportation system and frustrate supply chains throughout the U.S., as well as with our neighbors to the north and south.
Considering freight railroads contribute only 0.5 percent to total U.S. greenhouse gas (ghg) emissions and 1.7 percent to transportation-related ghg emissions, such heavy-handed regulation is rather pointless, and yet, will have devastating consequences.
Freight trains ship approximately 1.6 billion tons of raw materials and finished goods per year, amounting to 61 tons of goods per American and accounting for roughly 40 percent of long-distance freight volume. Everything from food, chemicals, coal, crude oil, construction products, paper, and every stage of an automobile.
Imagine the supply chains of these items coming to a halt because railcar requirements couldn’t be met. Businesses would suffer, the economy would be hurt financially, and consumers would ultimately pay the price through scarcity and/or increased costs.
Rail shipping will no longer be an option for those who cannot comply with the mandate. The smaller outfits in the industry will be forced to close their doors; others will need to shift to heavy-duty trucking.
If no railroads were used at all, over 83 million additional trucks would need to be added to public roadways and about four times more fuel to handle the freight. More trucks on roads obviously increases ghg emissions, proving to be counterproductive to CARB’s intentions of decreasing pollution.
If decarbonization is the goal, we should be shifting to more freight trains and less semi-truck use due to the significant difference in ghg emissions. Even transferring just 10 percent of freight from truck to rail, ghg emissions would fall by more than 20 million tons annually; that is the equivalent of removing four million cars from our highways. Policies that make it harder to use rail are not the answer.
According to the Association of American Railroads (AAR), the technology for a zero emissions locomotive is not currently available because it has “not been sufficiently tested in prototype or operational service,” despite billions in investments. President and CEO Ian Jeffries correctly points out that those advancements “cannot simply be willed into immediate existence by policymakers.” It makes zero sense to mandate nonexistent technology.
Railroads continue to invest billions to reduce their environmental impact, which is why their footprint is already so low. This mode of transportation is the most fuel-efficient way to haul goods over land.
Multiple railway organizations and labor unions, shipping groups, trade associations, state and local chamber groups, and government entities, as well as a number of Senators and Congressman are deeply concerned about the CARB waiver. Often at odds regarding various regulations, they are all united in opposition to this rule.
AAR and the American Short Line and Regional Railroad Association (ASLRRA) filed suit against CARB last summer, arguing that the federal government has exclusive authority to regulate rail operations. Other legal action is likely to occur, especially from states who have already sued against California’s Advanced Clean Trucks rule and Advanced Clean Fleets rule.
Elected officials are once again penalizing anything carbon-related without considering the ramifications. Most importantly, they are putting the American consumer last by jeopardizing supply chains for countless goods utilized by businesses and families.
The EPA should not grant California a waiver allowing them to place such rigid requirements on locomotives.