Letters to Washington
| July 9, 2024

NSSGA and CalCIMA Letter to House T&I Committee, Subcommittee on Railroads, Pipelines and Hazardous Materials on the Upcoming CARB Hearing

Ahead of the Railroads, Pipelines, and Hazardous Materials Subcommittee’s July 9th Hearing entitled “An Examination of the California Air Resources Board’s (CARB) In Use Locomotive Regulation” we write on behalf of the members of the National Stone, Sand & Gravel Association (NSSGA) and California Construction and Industrial Materials Association (CalCIMA), to express our concerns over the California Air Resources Board’s (CARB) request for EPA authorization of its In-Use Locomotive Regulation. The CARB rule would ban most locomotives that are more than 23 years old starting in 2030. It would require new passenger, switch, and industrial locomotives to have zero-emissions beginning in 2030 and new line-haul locomotives to have zero-emissions beginning in 2035. However, no commercially viable technology exists today for zero-emission locomotives for line haul service, making the petition unreasonable, arbitrary, and capricious. We are concerned that the rule is technically and economically infeasible, and therefore inconsistent with the Clean Air Act (CAA) requirements. We urge EPA to deny CARB’s request.