As cumulative global emissions and CO2-attributable warming continue to rise annually, the need for immediate emissions reductions and smart policies to transition toward a net-zero economy is critical. Railroads remain a responsible partner capable of delivering sustainable transportation solutions in the near-term and for the long haul. In its newly updated report, the industry offers eight policy suggestions.

(1) Support ongoing research at the U.S. Department of Energy (DOE) to develop technologies to accelerate the commercial viability of low- and zero-emission locomotives.

Partnerships between the federal government, railroads and locomotive manufacturers will be essential to developing alternatives to traditional diesel-fuel-powered locomotives. Additional funding for research on these fuels and technologies will speed their adoption, inform the development of standards for such fuels, and advance ongoing private sector research, including at MxV Rail, the world’s premiere rail advisory.

As the DOT, DOE and EPA’s “U.S. National Blueprint for Transportation Decarbonization” (Blueprint) notes: “[Freight rail research should be prioritized] to determine the most promising paths to decarbonization, including a focus on sustainable fuels and the design and manufacture of new locomotive propulsion and fueling systems.”

Effective partnerships should rely on regular consultations with railroads, rail manufacturers, and suppliers to identify research projects that will significantly advance the commercial viability of respective technologies. Notably, zero-emission locomotives are still in a pre-commercial stage and do not currently meet freight railroads’ safety, reliability and functionality requirements. However, there are ongoing demonstrations and commercial testing initiatives for battery-electric and hydrogen fuel cell locomotives.

Railroads support grant programs that provide funding to further this research and undertake associated demonstration projects to test new technologies. By partnering with railroads who can offer technical and operational expertise, zero-emission locomotive technologies can move as quickly as possible from testing and development to real-world network demonstrations that are vital to proving commercial viability.

Accelerated, widespread availability of these technologies is crucial as locomotives are long-lasting capital assets, and any delay would hinder fleet transition and the rail industry’s ability to join the net-zero emissions economy.

(2) Help Class I railroads’ partners, including locomotive manufacturers, rail suppliers, and short line railroads, transition to the net-zero economy.

Freight railroads support robust funding for grant programs, such as DERA, CRISI, and Port Infrastructure Development, which help short line railroads improve fuel efficiency and reduce emissions by modernizing and/or retrofitting their equipment, including locomotives. Furthermore, these programs will assist short line railroads in addressing challenges associated with installing the infrastructure required for adopting alternative fuels.

Freight railroads support grant and loan programs for locomotive manufacturers and other rail suppliers to assist them in re-equipping, expanding, or establishing facilities to produce alternative fuel locomotives or related technologies and equipment. Incentives for locomotive manufacturers and other rail suppliers to invest in their facilities will accelerate the commercial viability and availability of low- and zero-emission locomotives.

(3) Allow railroads to transition their locomotive fleets when zero-emission technologies are commercially viable and operationally safe and reliable.

Policymakers should avoid imposing prescriptive means for reducing emissions in the rail industry. Because locomotives are long-lived assets and zero-emission locomotives are only now in the demonstration/prototype stage, short-sighted mandates that attempt to immediately reduce GHG emissions via premature replacement of locomotive fleets would compel freight railroads to purchase newer internal combustion engines that will then be in service for decades instead of zero-emission technologies. Such a regulatory misstep would result in wasting resources that could be used to develop zero-emission locomotives.

Instead, as the Blueprint discussed, “All levels of government and the private sector should align their efforts to enact solutions through technical assistance and collaborative work.” It is essential that any plan for reducing rail emissions developed by government partners be the result of a partnership with industry and, as called for in the Blueprint, provide “safe, effective, affordable, and sustainable solutions to existing and emerging challenges.” Rail stands ready to engage in a collaborative partnership with the federal government to reach goals based on “[t]imely and impartial data collection and analysis” and timelines grounded in a realistic understanding of the current state of technology.

(4) Encourage policies that recognize the value of rail as a low-carbon transportation solution.

A key strategy to reduce transportation emissions identified in the Blueprint is “improving efficiency through mode shift.” The Blueprint states: “Road freight vehicles such as trucks…are the largest contributor to freight emissions…. Using more efficient modes…is essential to reduce overall transportation emissions and energy use. Using more efficient modes could also reduce the number of vehicles on the road and reduce congestion, improving travel time and traffic flow, thereby further reducing GHG emissions and other harmful air pollutants.”

An effective means of accomplishing this goal is to address the solvency of the Highway Trust Fund (HTF) through a fuel tax increase and, eventually, the implementation of a vehicle miles traveled fee (VMT) that considers vehicle weight. The United States has historically relied upon a user-pays system to fund public road and bridge infrastructure investments. Unfortunately, revenues into the HTF have failed to keep pace with inflation and investment needs, requiring repeated general fund transfers, including $275 billion since 2008, to cover the shortfall.

The lack of adequate revenue raised for the HTF is partly the result of heavy trucks. Today, these large trucks don’t come close to paying for the damage they cause to our public highway system. The Tax Policy Center found that the current 18-cent tax per gallon of gas, which has not been adjusted since 1993, would today be about 38 cents per gallon if adjusted for inflation alone. Freight railroads support DOT’s expeditious completion of a Highway Cost Allocation Study, which will help Congress better ensure different highway users, including commercial motor vehicles, cover their fair share of costs to maintain our nation’s roads and bridges.

Furthermore, implementing a VMT could resolve the impending insolvency of the HTF, restore a user-pays model, and rebalance the ongoing modal inequity occurring in the freight transportation market stemming from the trucking industry’s underpayment into the HTF. Freight railroads support DOT’s work on the National Motor Vehicle Per-Mile User Fee Pilot. This program will demonstrate a national VMT system and help to identify technologies needed to implement this program.

(5) Empower railroads to make operational decisions to maximize fuel efficiency and meet growing freight transportation demand.

Policymakers should reject proposals imposing operational restrictions on railroads, such as limitations on train length, which undermine railroads’ efforts to improve fuel efficiency and reduce emissions associated with their operations. Moving a given amount of freight in fewer trains requires less fuel and creates fewer associated emissions. Emissions would increase if a cap on train length were imposed, and the subsequent reduction in rail efficiency could cause freight to divert to trucks. AAR analysis of federal data finds: If 25% of the truck traffic moving at least 750 miles went by rail instead, annual greenhouse gas emissions would fall by approximately 13.6 million tons.

(6) Further promote a broad-based, economy-wide transition to net-zero emissions.

The Blueprint noted, “[s}ustainable fuels can play a key role in reducing rail emissions, especially in the near and medium terms, but they are currently not cost competitive.”Freight railroads support mode-neutral programs to domestically produce a sufficient supply of alternative fuel sources and construct the necessary infrastructure to ensure supply meets demand.

Policymakers should ensure that programs that prioritize the availability of alternative fuels for specific transportation modes do not undermine other modes’ efforts to reduce their emissions. Railroads support programs that expand the availability, enhance the performance, and lower the costs of batteries, hydrogen, biodiesel, and renewable diesel. These programs will provide essential scaling to assist railroads in decarbonizing.

Additionally, policymakers should support funding for research to ensure that alternative fuel sources are developed from a broad base of feedstocks, minerals, and other natural resources. For example, freight railroads are supportive of DOE’s “Clean Fuels and Products Shot,” which seeks to accelerate the development of low-carbon fuels for heavy transportation, such as rail, and will experiment with various biomass and renewable fuel sources, such as municipal waste, agricultural and forest trimmings, algae and carbon dioxide. This effort will be essential to driving down costs and bringing to scale the technologies necessary to reduce emissions from the manufacturing of these fuels.

Finally, policymakers should continue to invest in developing and scaling carbon capture, utilization, and storage (CCUS) technologies and explore opportunities to expand their commercial use through market development programs. Encouraging storage and industrial utilization of captured carbon creates new economic opportunities, and railroads believe this technology can be an important part of a broad effort to address climate change.

As plans for new CCUS facilities are developed, the carbon captured at these facilities could be transported via rail. This would minimize additional GHG emissions, avoid unnecessary highway congestion, and take advantage of the world-class private rail network already in existence. It is likely the facilities where carbon would be captured, and the destination where it would be stored or utilized, already have rail service.

(7) Streamline agency requirements to encourage the testing and incorporation of new safety technologies that will improve the resiliency of the rail network.

Policymakers should provide railroads with needed operational and regulatory flexibility to encourage innovation and testing of new safety technologies and processes, including streamlining waiver reviews, encouraging pilot programs, and establishing performance-based thresholds.

Many of the technologies that railroads seek to incorporate will be used to increase the frequency and accuracy of track, infrastructure, and equipment inspections. The huge amounts of data from those inspections will improve railroads’ maintenance plans, inform how railroads should best allocate investments in the short- and long-term, and enhance operational safety.

Unfortunately, railroads often encounter significant regulatory barriers when incorporating new safety technologies. For example, safety data from test programs have shown that automated track inspections, when blended with more focused visual track inspections, increase track safety, especially in identifying and remedying invisible track geometry defects. However, despite strong evidence of improved safety, the Federal Railroad Administration (FRA) continues to impede the progress of long-overdue regulatory reform. These changes to how railroads can test and incorporate new safety technologies are imperative to reaching an accident-free future and a more resilient rail network.

(8) Ensure timely delivery of rail infrastructure projects through permitting reform.

Policymakers should enact reforms in federal permitting processes that speed project delivery, ensure timely, focused reviews of environmental impacts, and provide greater predictability, modal equity, and transparency for freight rail infrastructure projects. These reforms should strive to ensure timely consultations, provide pragmatic, politically-enduring policy solutions, and avoid reinforcing the existing patchwork of state regulations. Suggested economy-wide reforms include:

• Clarifying timelines and the scope of state reviews for water quality certification requests under section 401 of the Clean Water Act.

• Extending the application of One Federal Decision to include reviews under the National Environmental Policy Act (NEPA) of infrastructure projects undertaken by any federal agency.

• Allowing federal agencies to utilize the categorical exclusions of other federal agencies, including the Army Corps of Engineers and Coast Guard’s use of the FRA’s categorical exclusions for qualifying rail projects. This is important since DOT is not often the lead federal agency for most rail projects.

Additionally, policymakers should consider specific rail-specific reforms, such as:

• Aligning the timeframes for filing claims seeking judicial review of a permit, license, or approval for any railroad project issued by FRA under NEPA with those used for highway or public transportation projects. The deadline for highway and public transportation projects is 150 days after the publication of a notice in the Federal Register announcing that the permit, license, or approval is final. In contrast, the deadline for railroad projects is two years.

• Ensuring the Advisory Council on Historic Preservation’s (ACHP) compliance with the FAST Act, which directed ACHP to issue a final exemption from Section 106 requirements for railroad rights-of-way consistent with the exemption issued for interstate highways.

Too often, required permitting processes and related environmental reviews are overbroad, inefficient, and expensive and can unnecessarily delay critical infrastructure projects for years. The environmental benefits of transport by rail, coupled with its crucial role in the supply chain, underscore the importance of maintaining and improving its safety and efficiency. These reforms will help expedite the construction of rail infrastructure projects and help incorporate changes to the rail network needed to support greater resiliency to climate change.