Comment Submitted to the U.S. Environmental Protection Agency: California Air Resources Board Request for EPA Waiver

The Environmental Protection Agency should reject the California Air Resources Board request for authorization of its In-Use Locomotive Regulation. The published CARB analysis of the electric power requirements for only switcher locomotives in railyards understates the power consumption effect of its rule by a factor of twelve, using the CARB projection of electric power needs for line-haul locomotives. Accordingly, the CARB conclusion that “the California grid can handle electrification of all switchers in all railyards” is thus a blatant obfuscation of the issue of power needs attendant upon the Regulation. CARB’s analysis of electrification costs is based in part upon an assumed price path for electric power that is over 18 percent too low, while real (inflation-adjusted) prices are likely to rise by 21.6 percent. A central reason for this analytic problem is the failure of CARB and the California Energy Commission to evaluate correctly the costs of the battery backup system that is an integral part of the planned CEC electric power capacity shift through 2045. Moreover, the power cost and reliability issues attendant upon the Regulation are not limited to California. Should EPA approve this authorization request, it will prove necessary to create analogous railroad electric charging infrastructure across the country, for the simple reason that the national rail network cannot be segregated by state. The CARB discussion of “disadvantaged communities” ignores the effect of higher electricity prices on lower-income households. For California, data from the Bureau of Labor Statistics demonstrate that expenditures for electricity as shares of both household income and total household expenditures decline monotonically as incomes and total household expenditures increase. The CARB analysis shunts this aside by assuming a real price path for California electricity prices that is approximately flat. The likely increases in electricity prices thus are incontrovertibly regressive, in particular because the historical evidence shows that household incomes for the two lowest income quintiles have risen far more slowly than is likely for California electricity prices. Under reasonable assumptions about demand conditions, the annual power consumption for households in the two lowest income quintiles would fall by 10.8 percent, and total annual expenditures on electricity would rise in real terms by $82 and $117, respectively, or about 8.5 percent. Those figures underestimate the adverse impacts on low-income households because they exclude the net value of the power no longer consumed because of the price increases. CARB asserts over $32.3 billion in health benefits from reductions in PM2.5 and NOx emissions. But those reductions asserted by CARB are a maximum of 0.9 percent and 3.8 percent, respectively, of all such California emissions, both anthropogenic and natural. Therefore, the health benefits of the Regulation asserted by CARB are not plausible. This basic error obtains in the CARB analysis because CARB implicitly has adopted the “linear/no threshold” approach for the analysis of health risks from emissions of air pollutants, a framework that shunts aside the effects on ambient concentrations of a small change in emissions. CARB asserts that the Regulation would reduce GHG emissions by a total of 21.74 million metric tons over the period 2030-2050. The average annual reduction is 1.04 mmt; application of the EPA climate model, under assumptions that exaggerate the future temperature effects of reduced emissions of GHG, yields a predicted decline in global surface temperatures in 2100 of 0.000028°C. If we assume an annual reduction of 2.3 mmt — the largest reduction for a single year in the CARB analysis — the effect would be 0.000063°C. Such zero impacts cannot yield economic benefits under any set of assumptions. CARB attempts to circumvent this obvious problem by substituting the social cost of carbon as estimated by the federal government as the benefit of reduced GHG emissions. The SCC is a fatally-flawed, wholly politicized, and wholly fictitious parameter. It is based upon a future atmospheric GHG concentration pathway that is virtually impossible, and that the Intergovernmental Panel on Climate Change itself views the likelihood of which as “low.” The SCC is derived from climate models that on average overstate the tropospheric temperature record by a factor of 2.3. The SCC includes the asserted global impacts of GHG emissions, a methodology that is not correct and that would yield serious inefficiencies in international climate policies even under the assumption that such policies might yield net improvements in resource allocation. The SCC ignores the important benefits of increasing GHG concentrations and moderate warming; examples are sharply reduced net mortality from heat and cold, longer growing seasons, improved water efficiency by plants, and planetary greening. The SCC includes the asserted benefits of reductions in criteria and hazardous air pollutants already regulated under various provisions of the CAA. The SCC calculations utilize discount rates that are artificially low, thus biasing upward the calculations of net benefits substantially. That methodology will make future generations worse off, notwithstanding the assertions of the federal government analysts. Because the SCC as calculated is highly sensitive to choices among discount rates, the use of the SCC is arbitrary and capricious. Finally, the SCC mischaracterizes the prospective GDP effects of rising GHG concentrations as predicted by the central integrated assessment models, and by IPCC itself. Because the SCC includes the asserted adverse effects of NOx emissions, CARB’s inclusion of both the SCC and the asserted health effects of reductions in NOx emissions is a blatant exercise in double-counting. The terms “clean” electricity and “carbon pollution” are political propaganda, shunting aside the large environmental problems attendant upon an expansion of unconventional energy and electricity, and the fact that volcanic eruptions can emit huge amounts of water vapor into the atmosphere. CARB claims total benefits from the Regulation of about $34.3 billion and total net amortized costs of $15.9 billion. But the latter figure includes the asserted savings in diesel fuel costs of about $11 billion, with no consideration of the economic cost of the certain reduction in such quality attributes of freight transportation services as timeliness, flexibility, reliability, tonnage per delivery, and many others. In the CARB methodology, a prohibition on any motorized rail freight technology — diesel, electric, and any others — combined with a return to horse-drawn wagon trains for the transport of goods would yield enormous benefits in terms of energy cost savings, but with no decline in the quality attributes of freight transportation. This CARB approach is deeply unserious. Correction of this bias reduces the net benefit calculation to a number that cannot inspire confidence in terms of the likelihood that there are any net benefits at all. Finally, the asserted benefits of the Regulation comprise almost wholly the climate effects of the purported decline in GHG emissions and the health effects of reductions in emissions of PM2.5 and NOx. For the reasons discussed, those benefits in reality approximate zero. Accordingly, whatever the problems inherent in the CARB cost analysis, the Regulation cannot satisfy any rigorous benefit/cost test. The EPA should not authorize it. Read the full comment below. Zycher-comment-EPA-CARB-waiver-elec-locomotive-rule-Apr-22-2024 Download