Friday, April 24, 2015

Back from the Drawing Board - CARB Releases Sustainable Freight Plan

Part 2 of 3 – ZEV Mandate
The Sustainable Freight Plan (SFP) is a comprehensive approach to reducing emissions across the entire freight sector. While ocean going vessels and locomotives are also being looked at for reductions, trucks are at the forefront of CARB’s diabolical scheme to regulate the heck out of everything they can.

Whether it’s back door or straight through the front, CARB will reach every mode of the transportation sector with the SFP. Their position is that in order to meet federal air quality guidelines and protect public health, they need to transition the trucking fleet into zero emissions and near zero emissions across most sectors.

The trucking sector is no stranger to the whims and fancies of CARB, but the SFP is some next level stuff. Right as the industry thought they were out of the woods with the on-road truck and bus rule – once it was finalized (again) last year – another set of regulations is headed down the pike. It turns out, the light the industry saw at the end of the tunnel was actually a train headed right for them.

CARB will start small; drayage trucks, short haul delivery, urban delivery, and recycle transfer trucks are all up first on the chopping block. They will then move to the larger over-the-road industry once there is an actual engine and infrastructure available to meet their “vision.”

In the urban delivery sector, CARB is not only seeking to set efficiency standards to accelerate Zero Emission Vehicle (ZEV) demonstration projects, but they are also looking to mandate ZEV according to fleet volume or vehicle size, beginning with last mile delivery vehicles. 
CARB on more than one occasion alludes to the fact that complementary incentives will be available to assist in deployment of this technology. Nevertheless, with limited technology offerings currently available, it will be hard to convince fleet operators to shift platforms into commercially untested equipment, even if CARB is throwing money at the problem.

This approach is consistent across all the sectors that CARB is seeking to regulate. Short haul and transfer trucks are dead center in the ZEV crosshairs with Zero Emission Vehicle mandates being proposed along with the complementary incentives for vehicles and infrastructure. There is also consideration of a pilot project for long haul trucks that would encourage zero emission travel and idling reduction strategies in impacted communities.
All in all, CARB is looking at a wholesale change of the freight transport network. Although there are limited available equipment offerings for the trucking sector, the agency is moving full steam ahead toward consideration. And despite the enormous technological and economic challenges, the trucking industry can expect more of the same from our favorite four letter agency.

Next up in C&C, the dreaded “Facility Cap” will be reviewed. The Facility Cap is the crown jewel of the SFP and will touch practically all facets of the freight transport industry…be afraid, be very afraid.

Stay tuned!

Wednesday, April 15, 2015

Back from the Drawing Board - CARB Releases Sustainable Freight Plan

Part 1 of 3 - CARB Enforcement Enhancements

The highly anticipated Sustainable Freight Plan (SFP) hit the streets last week. In it, CARB outlines their vision for the future of the freight transport sector in California. The document describes actions  covering trains, trucks, ships, distribution centers, forklifts, refrigerated units,  airport shuttles and transit busses, to name a few. 
The document is in draft discussion form and will be presented to the Board next week in Sacramento on the 23rd. Although there are no specific details on how each emission reduction measure will be carried out, it is clear from the document that CARB is quite serious about this plan. They consider it the touchstone of emission reduction efforts from the freight transport sector, now and for decades to come.

While details are still being refined, facility operators and trucking companies should be prepared for a wholesale change in how they conduct business in California.  In the SFP, the trucking sector is the most comprehensively covered entity; and since the trucking sector is the most regulated entity when it comes to CARB in general, it would seem only fitting that efforts to enhance enforcement of existing programs would be the first order of business. It would be disingenuous of the agency to propose a host of new regulations without getting a firm grip on the ones that are currently on the books…right?
It is no secret that many carriers in California are unimpressed with CARB’s enforcement capability. This mindset is only encouraged after hearing directly from CARB staff that their enforcement capabilities are, well…limited. Out of state carriers are even less impressed, leaving the in-state carriers to wonder when or where they might ever run into a CARB enforcement team.
The SFP is a harbinger of the changing tides; the “businesses as usual” perspective will no longer be the norm. With a limited number of in-field enforcement personnel at its disposal, CARB makes no bones about their number one enforcement referral being the industry itself; which allows them to target and prioritize fleet audits depending on severity and number of industry complaints. 

The SFP is seeking not only to add to the overall number of inspectors, but also seeks to reassign existing enforcement personnel to focus their efforts at or near truck stops and freight hubs such as seaports, intermodal rail yards and distribution centers.
CARB is also seeking partnerships with USEPA Region 9 and local jurisdictions to enhance enforcement efforts; local district personnel will be charged with enforcement of CARB standards within respective jurisdictions and will be able to issue citations as they encounter non-compliant carriers. USEPA region 9 personnel will be utilized to go after out of state carriers who are violating current rules.
Beyond additional personnel and targeted local and national enforcement, CARB is also proposing a strategy to go after sizable carriers and brokers, with the thought that these enforcement actions will then encourage smaller fleets to come into compliance with existing regulations. Since carriers and brokers are responsible for confirming compliance, many small fleets and contractors may find themselves in an enforcement audit resulting from a broker citation (See “Skin in the Game”
It is clear that the SFP is a serious effort to change the future of freight transport. In the next installment, C&C will cover the proposed low NOX, Zero and Near Zero Emission mandates that are being proposed. Folks must remember and understand that in CARB’s world, “regulate it, and it will come” (regardless of limited technology availability) is a mantra that is not going away…
Stay Tuned!