Boasting the most diverse economy in America and the nation’s fifth highest GDP, Illinois relies heavily on our innate infrastructure and logistics advantages to keep us on the right track for continued growth.

One of our greatest strengths is our freight rail network. Illinois has 47 freight railroads that carry almost 500 million tons of goods across our state annually—the equivalent of about 25 million annual truckloads of freight. Any diversion of current rail freight to highways will worsen congestion and road damage while also vastly increasing transportation related emissions and pollution.

Ironically, a proposal by the California Air Resources Board (CARB) before the U.S. Environmental Protection Agency to require zero-emission locomotives could bring about just such a scenario. In addition to increasing carbon emissions by shifting millions of tons of freight to trucks, the California rule would also disrupt rail operations nationwide, including in Illinois.

Railroads are the least carbon-intensive way to move freight on land. They produce less than two percent of the nation’s transportation emissions while moving more than two-thirds of long-distance freight. And their efficiency advantage is constantly improving due to advances in locomotive technology and improved routing software like battery-electric and hydrogen locomotives already in development.

Rather than incentivizing these steps and other responsible progress toward shared emissions reduction goals, the California rule would ban locomotives unless they are “zero-emission” beginning in 2030. This is an unrealistic timetable. While battery technology is quickly evolving, it is currently unable to produce enough megawatts to power a locomotive.

With 65 percent of the U.S. locomotive fleet operating in California at some point, this rule could disrupt rail service throughout the entire 140,000-mile North American rail system. Our state relies heavily on access to California’s ports for a vast array of consumer products and other goods that arrive in Illinois by rail, as well as for efficient train transport of products grown, mined or manufactured here and destined for export. EPA approval of this flawed plan would wall off our access to these key California ports, and shift freight from the rails to the roadways.

“Imagine the downstream consequences for us in Illinois, where we have 52 separate freight railroads operating over the second-largest state rail network by mileage,” wrote over two dozen Illinois state and local leaders in a recent letter to the EPA.

One unintended impact of the CARB plan, emphasized byCongresswoman Robin Kelly last month to the EPA, is that it “could inadvertently move freight from the rail sector to heavy-duty trucking sector.” According to Federal Highway Administration data, diverting just 10% of freight from rail to truck would result in an additional 1.8 billion gallons of diesel fuel being burned, the equivalent of approximately over 20 million tons of CO2.

As the nation’s third largest ethanol producer, Illinois provides an obvious advantage to companies concerned with operating sustainably in a clean energy economy. Illinois is also the single largest hub of the North American freight rail system, and our unequaled rail access has been a magnet for attracting investment and advanced manufacturing jobs.

Railroads spend huge sums—$23 billion annually in recent years—on the infrastructure, technology and people needed to make rail transportation ever safer, more fuel efficient and productive. With more rail freight moving through Illinois than any other state, we have an outsize interest in ensuring railroads maintain high levels of investment. This includes the money spent directly in our state as well as elsewhere, because the North American freight rail system is one vast, interconnected network and Illinois is its undisputed hub.

Senseless policies like the one being pushed in California undermine the fluidity, efficiency, and productivity of a key part of the rail network. They also undercut the value of our rail connections here in Illinois, weakening job creation and economic growth. That, taken with the fact that this rule would lead to more, not fewer transportation-related emissions, the EPA’s rejection of California’s waiver request ought to be a no-brainer.

-Mark Denzler, President and CEO, Illinois Manufacturers’ Association