ASSOCIATION OF AMERICAN RAILROADS [www.aar.org]

Problem
Between 1991 and 1997, America’s freight railroads and Amtrak for the first time faced sweeping regulatory proposals from federal, state, and local regulatory agencies for locomotive emissions reductions with a focus on Southern California operations. One of the local agencies proposed a requirement for freight railroads to electrify operations in Southern California at a cost of $4-6 billion. The Association of American Railroads (AAR), the railroads’ trade organization, was interested in:

• Achieving uniform national regulations based on the appropriate statutory authorities and the limits of known technologies, while avoiding a patchwork of different state and federal regulations.
• Building coalition support of state and federal regulators, politicians, unions, and shippers to ensure reasonable regulation by the federal government.

Solution
CEA worked with industry, government, and environmental stakeholders to find a long-term solution that served the needs of all parties. Specifically, CEA:

• Coordinated the railroad industry’s position before five agencies at the federal, state, and local levels incorporating policy, legal, technical, and communications perspectives.
• Served as the project manager of a cross-functional team of railroads to comprehensively assess the impact of the various regulatory initiatives.
• Initiated dialogue and educating key decision makers to build trust and develop a mutual understanding between regulators and railroad executives.
• Developed an economic and technical analysis of various proposals to determine their impact on the railroad industry and emissions in the Los Angeles area.
• Worked with AAR staff and advisors to build consensus among the nation’s railroads for an affirmative proposal to regulate emissions in a comprehensive yet practical manner.
• Helped to shape a successful communications campaign to educate the public and government officials about the advantages of rail transportation.

Results
Working with legal counsel, technical experts, and AAR staff, CEA helped the railroads establish consensus among state and federal regulators that a comprehensive nationwide regulatory scheme was the only appropriate structure for the regulation of locomotive emissions. In December 1997, EPA promulgated a locomotive emissions regulation that, when fully implemented, will avoid conflicting state and local requirements and will establish an aggressive yet achievable emissions reduction program over the next fifteen years.