Comment Log Display

We submitted a detailed 30 page document at the last public meeting
with practical suggestions to improve the in-use rule.  This
document also detailed how poorly performing the current Tier 4
diesel passenger locomotives are:

•	Emitting actual in-use NOx emissions at 2 to 3 times the EPA
standard
•	One of the two OEM locomotives not being emissions tested in its
operating condition
•	Both of the locomotives apparently idling over 30 minutes when by
regulation the locomotives don't meet any of the exceptions to
disable the auto shutdown features

We were disappointed to observe that instead of taking serious the
deficiencies of the current Tier 4 diesel passenger locomotives,
CARB staff is instead giving the passenger rail agencies a free
pass on high in-use toxic emissions.    The NOx chart in the
document indicates that the AFMO plan predicts no reduction in
passenger locomotive NOx emissions through 2035 which is
unacceptable considering in-use NOx emissions are well above the
Tier 4 standard.`

We are resubmitting the previous suggestions and details of the
passenger locomotive emissions challenges with the hope that CARB
staff and leadership take this issue more seriously this time and
consider actually reducing passenger locomotive emissions instead
of committing more public funding to mediocre equipment and locking
in decades of unneccessarily high NOx emissions.

Also dissappointing was CARBs shortsighted elimination of the
benefits of devoping and operating near zero and/or hybrid
locomotives by creating such a restrictive definition of Zero
Emissions Capable Locomotive.  

We suggest:
•	The AFMO plan be scrapped and that CARB finally emissions test
these passenger locomotives in their actual operating condition.
•	Then use event recorder data, which is already collected,
archived and contractually available to CARB, to properly inventory
actual in-use emissions based on the operational configuration
emissions test data.
•	Seriously look into incentiving practical near-zero and hybrid
locomotives. 


M.T.