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Comment 2 for Prop 1B: Goods Movement Emission Reduction Program Guidelines (prop1b2015) - Non-Reg.

First NameFrancisco
Last NameDonez
Email Addressdonez.francisco@epa.gov
AffiliationUS EPA Region 9
SubjectSwitcher locomotives
Comment
Thank you for the opportunity to comment on the updates to this
important program.

Regarding the change to "[m]odify the requirement for switcher
locomotives to operate 90 to 100 percent of their time in the four
trade corridors to 50 percent," I request that ARB provide
documentation or citations showing that this proposed change is
"consistent with the requirement for the other mobile source
categories." Additionally, unless there are compelling reasons for
the 50 percent requirement, I suggest that ARB consider modifying
this requirement to an intermediate level of 75 percent. This
change would ensure that funding is directed toward those switcher
locomotives that spend the most time within the four trade
corridors.

Attachment
Original File Name
Date and Time Comment Was Submitted 2015-06-18 16:38:31

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