National Association of Manufacturers (NAM)
EPANonrulemakingEPA-HQ-OAR-2023-0574

California’s Section 209(e) Authorization Request for its In-Use Locomotive Regulation

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Last modified
Jan 14, 2025
Comment window
closed 827d ago
National Association of Manufacturers (NAM) filings
2

Activity

National Association of Manufacturers (NAM) filed 2 comments on this docket between Apr 23, 2024 and Apr 24, 2024. 61 other organizations filed here. The comment window closed 827d ago.

What National Association of Manufacturers (NAM) filed (2)

Apr 24, 2024· Comment submitted by National Association of Manufacturers , et al.· EPA-HQ-OAR-2023-0574-0170

We, the undersigned trade associations have members that collectively employ millions of Americans in all sectors of the U.S. economy. Our members are committed to environmental stewardship and to policies that encourage domestic emissions reductions that address climate change. Yet, we write to raise serious concerns about an authorization request from the California Air Resources Board (CARB) pertaining to rail locomotive emissions.

Apr 23, 2024· Comment submitted by National Association of Manufacturers et al.· EPA-HQ-OAR-2023-0574-0108

We, the undersigned trade associations have members that collectively employ millions of Americans in all sectors of the U.S. economy. Our members are committed to environmental stewardship and to policies that encourage domestic emissions reductions that address climate change. Yet, we write to raise serious concerns about an authorization request from the California Air Resources Board (CARB) pertaining to rail locomotive emissions and respectfully urge you to deny their petition. This regulation from CARB has the potential to create significant disruptions in the supply chain for all sectors of the U.S. economy, especially manufacturers and shippers who rely on consistent, reliable rail service. This rule could lead to delays for businesses and increased costs for both shippers and consumers that could ultimately lead to a massive supply chain crisis. If railroads are forced to spend large amounts of money to ensure compliance with this rule, those costs will be passed along the entire supply chain and could inhibit rail service at facilities across the country – not just in California.

Abstract

California’s Section 209(e) Authorization Request for its In-Use Locomotive Regulation

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