Brattle Experts Author Memorandum Analyzing Potential Costs and Feasibility Implications of CARB Regulation
Prepared for the Association of American Railroads (AAR)
Brattle experts prepared a memorandum for the Association of American Railroads (AAR) in response to the “In-Use Locomotive Regulation” passed by the California Air Resources Board (CARB) in April 2023.
The regulation aims to address greenhouse gas (GHG) emissions and air quality concerns from locomotives and California railyards by phasing out higher-emitting locomotives and increasing the adoption of zero-emissions (ZE) locomotives. The Brattle memorandum focuses on the potential costs and feasibility implications on the power grid of complying with the proposed regulation in California using battery-electric locomotives as the ZE technology of choice. The authors find that the railroad industry and the power industry will face significant barriers – including technological, logistical, and cost hurdles – in complying with the proposed CARB regulation within the prescribed timeframe. AAR cited the memo in its April 2024 public filing to the US Environmental Protection Agency (EPA).
The memorandum, “Review of CARB’s Proposed Regulation,” was authored by Principal T. Bruce Tsuchida, Managing Energy Associate Dr. Long Lam, Energy Research Associate Kailin Graham, Energy Specialist Sylvia Tang, and Senior Energy Analyst Megan Diehl.
