November 1, 2022
California Public Utilities Commission
505 Van Ness Avenue
San Francisco, CA 94102
Re: Union Pacific Railroad Company Battery Electric Locomotives at West Colton Yard
To Whom it May Concern:
We are writing to express our strong support for Union Pacific’s (UP) planned use of battery electric locomotives (“BELs”) at its West Colton Yard in late 2023. We understand that in order to operate BELs, UP will need to install battery charging stations at West Colton Yard and that it will be seeking a variance from the overhead clearance requirement in the Commission’s General Order No. 26-D.
The communities surrounding the project site are ranked in the 99th percentile by the State’s Cal EnviroScreen4.0 tool for pollution burden, so this project is essential to help reduce some of that impact. In the Inland Empire region of Southern California, Class-1 railroads (UP and BNSF) are working to address these opportunities effectively and progressively.
UP’s introduction of the use of BELs aligns with California’s 100% clean energy goal. BEls do not use fuel and emit zero emissions. For every ten BELs used, approximately 4,000 tons of carbon will be eliminated annually, equaling the removal of 800 cars from the roads. There are numerous safety benefits with the use of BELs as well, including:
- Eliminating the need for railroad employees to handle diesel fuel.
- Eliminating the need for fueling stations, reducing the potential for fuel spillage.
- Reducing the distance locomotives must travel within the yard to charge (i.e. reducing the risk of accidental collision).
- Reducing railroad employees’ need to physically handle locomotives.
- Eliminating the need for fuel trucks moving about the yard, reducing the chance of fuel leaks and collisions with equipment in the yard.
With the ongoing need to reduce emissions in the South Coast Basin, we support the effort to introduce BELs at the West Colton railyard. Considering the broader benefits of BELs, while this letter focuses on the UP request, it is important to note that we support incorporation of BELs at all rail facilities across the State and ask that the Commission consider a categorical exemption statewide.
We respectfully request the Commission’s approval of Union Pacific’s request for variance from General Order 26-D. We appreciate your consideration.
Carole Beswick, CEO