Monday, May 18, 2015

Back from the Drawing Board - CARB Releases Sustainable Freight Plan

Part 3 of 3: The Facility Cap

There isn’t much the regulatory regime in California can do anymore to surprise businesses and fleets operating in the golden state. But the CARB Sustainable Freight Plan (SFP) comes staggeringly close.

Beyond enforcement enhancements, federal or California-only new engine standards, zero emission mandates and potential efficiency metrics, one of the most controversial measures CARB is considering under the SFP is the so-called facility cap.

Although it is here, it is real, and it means business, fleets have been reluctant to dive head first toward the zero and near zero emission future CARB has laid out in this plan. Currently, zero emission heavy-duty equipment offerings are limited at best. Technology that is in development has yet to prove itself in an actively competitive and commercial environment.

The SFP is seeking to resolve this situation; CARB’s strategy is to encourage adoption of this emerging technology through incentives and regulatory measures – or as it is technically designated – the carrot and stick approach.

The SFP is multi-faceted. It is a framework that outlines several strategies for potential incentives (carrot), as well as regulatory development and forced behavioral modifications (stick).

Distribution centers, warehouses, airports, seaports, and quite possibly truck stops and other locations that attract heavy-duty trucks may all find themselves policing truck traffic and implementing other reduction measures to remain under imposed emission caps. It is very likely that the primary behavior that facility operators will need to change is the way they monitor their daily ingress and egress of trucks.

If emissions exceed the cap for any given time period, the facility may face fines. The fine structures will more than likely be based on information derived from audits of data that the facility will be responsible for managing (e.g., number and emissions profiles of trucks, TRU’s and TBD’s). 
This will force the facility to closely monitor traffic and quite possibly turn trucks away at the gates if it is determined the facility is close to an established cap.

While no one wants to turn trucks away at the gates, it is possible that a PM retrofit may not be enough to enter into a facility if that facility is struggling to maintain levels under the cap.

A close read of this concept shows the underlying, back-of-the-hand objective in the SFP; forcing covered facility operators to require trucks that enter their property to meet the lowest emissions standards available.

It is assumed that shippers will gravitate toward fleets that operate the cleanest equipment, possibly those that use alternative fuel, hybrids, or at minimum 2010 diesel engines. The clean trucks will give shippers assurances that their motor carriers will be able to enter distribution centers to drop off or pick up cargo without incident.

It is also possible that facility operators may impose a fee if a “dirty” truck is needed to pick up cargo from a covered facility. It worked in the ports of Los Angeles and Long Beach with the clean truck fee under the Clean Air Action Plan (CAAP), so why wouldn’t it work everywhere else?

Granted, this is a developing process. CARB has indicated that they will be first looking to facilities located in parts of the state with the highest health risks.

Areas such as parts of San Bernardino and Riverside counties, the ports of Los Angeles and Long Beach, and Central Los Angeles have been mentioned more than once in planning documents released by CARB and the South Coast Air Quality Management District (SCAQMD).

Other parts of the state with high health risk areas such as the Port of Oakland and parts of the Central Valley are also in the facility cap crosshairs. Most large metropolitan areas have highly sensitive receptors in many parts of their regions. For decades, the state has sought policies to help protect these communities from harmful toxic air exposure. Most, if not all air quality improvement measures have been adopted to offset these side effects. In this sense, the facility cap is not a new concept.

The SCAQMD and the State of California have wanted to go after facilities as “diesel magnet sources” (i.e., facilities) for quite some time. Whether it is through a cap based on facility emissions, a cap based on units of freight activity or a cap based on facility cancer risk, the outcome is the same; facilities will be capped. Rest assured, business as usual is changing. The State of California will not relent until the freight transport network folds under pressure or ends up saving us from ourselves.

C&C will be back with more on the SFP. Stay tuned!

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