Comment Log Display

Michael Mitsuda
33210 Lake Oneida Street
Fremont, CA 94555-1285


June 22, 2010

CARB board members
 


Dear CARB board members:

Re:   Agenda Item 10-6-5 (June 24, 2010) Public Meeting to
Consider Staff Recommendations for Commitments between ARB and UP
and BNSF Railroads to Accelerate Further Diesel PM Emission
Reductions at Four High Priority Railyards in the South Coast Air
Basin

Dear CARB Board Members:

Thank you for directing your staff to dedicate time and resources
to reduce toxic emissions and health risk at railyards in
California.  I am very appreciative of the attention and
direction
the board members have given to staff regarding this issue.
However, I am concerned that the product that staff will present
to
the board on June 24, 2010, falls short of what the community
needs
and what the board directed.  

The current proposed agreement (commitment letters) between the
railyards and the California Air Resources Board (CARB) achieves
only an additional 9-12 percent emissions reduction (depending on
the yard)—over a 10-year span—at the four high-risk railyards
identified by CARB. Due to the extremely high cancer risk for
people living in close proximity to the 
railyards, more efforts are necessary to further reduce the
risks.
These should include air monitors around the railyards, and if
monitoring shows non-compliance to the stronger regulations,
fines
and penalties should ensue.

Additionally, measures to reduce oxides of nitrogen and
particulate matter at California's railyards should be crafted to
maximize greenhouse gas (GHG) reductions, while achieving the
greatest public health benefits as quickly as possible. For
example, electrification or alternate fuel use of yard hostlers,
rather than repowering them with diesel engines, can 
eliminate diesel emissions and provide GHG emission reductions as
well. These measures support and have the potential to further
contribute to the 
GHG reduction goals of AB32.

While the board directed staff to pursue site-specific measures
to
reduce cancer risk and emissions from the highest risk railyards,
because it would give a relief to communities around the yards
faster, we believe that many of the provisions in the agreement
could be implemented by railyards across the state. We urge you
to
adopt statewide measures to reduce pollution from these sources. 

Lastly, I am concerned that communities do not benefit from
emissions reductions from this new Memorandum of Understanding
(MOU) until after 2015. Due to the current elevated health risks,
operational efficiencies can and need to be implemented now to
begin protecting these communities today.  There are 14 other
major
railyard communities across the state. If we do not protect them
now, these communities could end up receiving the 
dirtier locomotives as the cleaner locomotives come to the four
high-risk yards. All these communities will benefit from a
statewide regulation for all non-preempted locomotives, cargo
handling, operational measures and risk reduction audit plan.  

Thank you for considering these comments and for your continued
diligence on this issue. 

Sincerely,


Michael Mitsuda