Comment Log Display

Electrification via overhead catenary wires (OCS) is the proven
zero emissions way to power freight and passenger trains. Over 1/3
of rail worldwide is powered this way, including America's most
used passenger trains in the Northeast Corridor and elsewhere, and
freight railroads in the past such as the Milwaukee Road. In
contrast, hydrogen trains are a new technology, with no line haul
freight operating commercially, and hydrogen passenger trains in
Germany and China have been abandoned due to high costs and poor
performance in real world operations. Additionally, over 95% of the
hydrogen currently available is produced through steam methane
reformation, with production-associated CO2 and NOx emissions,
while green hydrogen uses 3x as much electricity as overhead
electrification while consuming precious fresh water. Hydrogen is
also more flammable and leak prone than natural gas, posing
additional hazards for transport and refueling, and is an indirect
greenhouse gas.

Despite the numerous downsides to hydrogen fuel cell trains, CARB's
research and other policy is unfairly biased towards hydrogen and
full of inaccuracies that paint a distorted picture of the
landscape of zero emissions rail. CARB's 2016 Zero Emissions Rail
Reports contain many inaccuracies about the cost, power demand, and
other basic facts of OCS and have been cited by the American
Association of Railroads in their opposition to CARB's In-Use
Locomotive Rule. CARB's Zero Emissions Rail Project Dashboard omits
many successful, decades long electric rail projects as well as
unsuccessful, canceled hydrogen rail projects (like Germany's
LNGV), implying that both are prototype technologies on equal
footing. And the April 2024 Feasibility Analysis: Zero Emission
Train from the Port of Los Angeles to Barstow fails to fully
analyze the feasibility of OCS, biasing the results towards
hydrogen and battery locomotives. More information on the failings
of CARB's rail research are included in the attached letter. CARB
also provided funding for SBCTA's first in North America hydrogen
train, which has suffered numerous cost overruns and now a delayed
release schedule. The Low Carbon Fuel Standard has also
historically undercredited electric transit and subsidized hydrogen
in transportation.

The implementation and siting of hydrogen passenger trains also
perpetuates environmental injustice. Hydrogen trains in California
are so far planned for San Bernardino and the northern Central
Valley, areas that are in the top 20% of the DOT's Disadvantaged
Communities Index and suffer from high rates of poverty and some of
the country's worst air quality. These communities also experience
high transportation cost burdens and long car commutes, coupled
with low transit usage. Cars are the top source of CO2 and second
largest source of NOx in the state. Car-free access to jobs is
important to both alleviate air pollution and reduce poverty.
Unfortunately, investments in hydrogen trains hinder these goals.
Hydrogen trains have higher operating costs than electric trains
and are considered most optimal for low frequency routes.
Investment in hydrogen trains, with long rolling stock lifespans,
locks in slow, low frequency service for decades, making these rail
lines uncompetitive with driving for workers who value their time.
Additionally, California High Speed Rail will use OCS, and rail
systems that use OCS, such as Caltrain, gain connectivity with a
statewide rail network. Investments in hydrogen trains, an
incompatible technology with different infrastructure needs,
exclude environmental justice communities from a statewide network
and access to jobs while disproportionately exposing them to
hazards associated with hydrogen refueling. 
Californians for Electric Rail requests that CARB fully evaluate
OCS in future zero emissions rail studies, retract and/or update
inaccurate publications, and shift funding (via the LCFS and other
programs) away from hydrogen trains and towards existing and new
OCS. See our attached letter and the RailPAC's whitepaper linked
within for more detail.