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!

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