Technological limitations of California’s in-use locomotive rule

Like our cardiovascular system, freight trains work like arteries running 24/7 transporting bulk commodities and goods. This includes transporting everything from cardboard boxes for Amazon to feed crops from California’s Central Valley to hungry cows on dairy farms. Railroads, especially interstate short line railroads, operate largely out of sight and out of mind, taking burden and risk away from highways and keeping the economy alive.

Some California regulators don’t seem to appreciate the importance of rail, as demonstrated by the California Air Resources Board’s (CARB) new in-use locomotive regulation.

Starting in 2030, any locomotive 23 years or older would effectively be prohibited from operating in California. All new switch, industrial, and passenger locomotives would have to be zero emissions by 2030. Line-haul locomotives, which are the large freight locomotives, would have to be zero emissions by 2035. There are some alternative regulatory options, but as the American Association of Railroads explains, they “are unworkable for freight railroads.” CARB’s own analysis helps to support this contention. In its request to the EPA for authorization of its rule, CARB barely mentions these alternative options.

The regulation would force the transfer of freight shipments from rail to roads, since there are no commercially available electric locomotives for California freight companies to purchase. It’s important to note that this regulation is dependent on Biden’s Environmental Protection Agency granting CARB authorization for the state’s in-use locomotive regulation. Historically the EPA has granted CARB requests.

Strangely, even though the state of California has been trying to reduce congestion on roads for decades through various incentive programs and infrastructure bills, CARB’s new in-use locomotive regulation does just the opposite.

There are also numerous technology issues. CARB’s regulation mandating freight railroads transition to zero-emission locomotives faces daunting technological hurdles that have gone unaddressed.

Perhaps most glaring is the inadequacy of current battery technology. The Association of American Railroads points out in their comment to EPA that the largest batteries produced in North America today store no more than 15 megawatt-hours – a far cry from the 80-100 megawatt-hours required to replace a single diesel locomotive’s fuel tank.

Operating long-haul trains could require 5-6 batteries per locomotive, although there is a lot of ambiguity since this technology has not been adequately demonstrated.

Diesel powered trains can run continuously as long as they are being refueled. Electric trains, like the passenger Amtrak trains in the Northeast, can run continuously because they are physically connected to a line of power. A battery powered freight train (which does not exist in the United States) can only run as long as its battery is charged, like an electric car.

This means that there will be time when the batteries need to recharge, making it impossible to continuously operate with the same efficiency of diesel trains. Even if a commercial fleet of electric trains magically comes into existence in the next five years, railroads would still need to purchase more trains to maintain their normal operational schedule. These railroads would also need a major injection of capital to afford the purchase of new compliant locomotives and batteries.

Compounding the battery problem is the lack of charging infrastructure capable of supporting a massive electric locomotive fleet operating around the clock. As one California shoreline railroad representative told me, “The charging capability doesn’t exist…That’s something you can’t even have a conversation about because we don’t know the details.”

The current California electric grid simply cannot handle a sudden increase in the amount of energy needed to charge large train batteries, along with the increased demand from electric cars and trucks. Setting aside the issue of grid capacity, it’s also unclear how the state expects to build enough charging stations in the identified time frame that would allow for California’s 27 railroads to carry on business uninterrupted. Meeting such a statewide increase in electricity demand would require rethinking electrical distribution systems — a monumental undertaking.

Turning attention to the trains themselves, in CARB’s Technological Feasibility Document, they list technologies that “are meant to serve as examples of the types of technologies that are commercially available in the upcoming years and may be used to comply with the Proposed Regulation.” They list technologies as “examples” because they are not presently commercially available, as CARB admits. One of the more feasible (yet still infeasible) non-diesel train models would be a hydrogen powered train. There is one – only one – hydrogen freight train being developed at the Sierra Northern railroad in California. However, there is no clear timeline for when such a model would be commercially available.

CARB has also overlooked key supply chain hurdles. Production of batteries at the scale required would rapidly deplete domestic stores of critical raw materials like cobalt, graphite, lithium and nickel. Even alternative technologies like hydrogen fuel cells face imposing barriers, with the Federal Railroad Administration admitting they “would require an entirely new design of locomotive…new standards or requirements will need to be written for tanks to be located near the top of rail cars or include other design features…” The Federal Railroad Administration also expressed a desire for more information on unique risks with this new train model because “the vibration and shock experienced in the rail environment is significantly higher than current hydrogen fuel cell applications, such as light-duty vehicles and stationary applications. This makes vibration testing on all aspects of hydrogen fuel cell systems critically important…”

CARB’s regulation ignores technological and economic realities of the freight rail industry to the point of amusement.

CARB is unable in its analysis to answer essential questions: Where are the electric trains for railroads to buy? Who should build charging stations, and how should they be built? Where are the batteries?

Implementing this impractical mandate would kneecap California companies’ dependent on freight rail — which include well known major business including Frito-Lay, Amazon, and America’s largest wine companies.

CARB should, frankly, be reprimanded for irresponsible governance. The Board mandated companies plan to purchase technology that doesn’t exist yet in a commercially viable and scalable form. Additionally, the required supporting infrastructure, such as electrical distribution systems and charging facilities, is largely outside the railroads’ control and would require massive investments, likely by the state or federal government.

Some questions EPA and lawmakers should ask CARB to answer:

• Given that there are no commercially available electric locomotives capable of handling long-haul freight, how does CARB justify setting a mandate for zero-emission locomotives by 2035?
• Battery experts state that even optimistic projections put maximum battery capacities at only 20 MWh by 2030 – less than a quarter of what’s needed to replace a single diesel locomotive’s fuel tank. What specific battery breakthroughs are you anticipating that would make this regulation achievable?
• How will the regulation impact interstate commerce, and what discussions has CARB had with other states and the federal government regarding this transition?
• How does CARB plan to mitigate the economic impact on businesses that rely on freight rail, considering the increased costs and potential disruptions caused by the transition to zero-emission locomotives?
• How does CARB address concerns about the environmental impact of battery production and disposal, especially considering the scale required for freight locomotives?
• The regulation could force U.S. railroads to rapidly consume supplies of raw materials like cobalt and lithium that America has little domestic supply of. How does proposing rules that make us more reliant on foreign mineral sources enhance national security?
•  CARB’s own study from 2016 concluded that barriers impeding freight rail would likely shift the transportation of more goods to trucking, increasing emissions. Why are you proceeding with a regulation that CARB’s previous analysis suggests could be counterproductive?
• If this regulation drives smaller regional railroads out of business as you acknowledge it will, how will you address the loss of rail capacity and increased truck traffic on roads?
• What is your estimate of the total cost this regulation will impose on the freight rail industry and its customers? Have you examined whether the supply chain disruptions from such an enormous expenditure could trigger nationwide inflation?
• Why did CARB choose not to directly consult with actual railroad companies and operators in conducting its feasibility assessment for this regulation? Is their expertise not essential for evaluating real-world impacts?

CARB’s mandate for zero-emission locomotives by 2035, speaking realistically, isn’t possible and EPA shouldn’t grant an authorization to California for this rule.