Tuesday, June 2, 2015

Too Much or Not Enough?

CARB’s Sustainable Freight Plan Using Old Numbers to Mitigate New Risks

It should be no secret by now that the entire freight transport network is being looked to help secure California’s low carbon future. Although energy production and light duty vehicles constitute a hefty portion of carbon emissions in the golden state, CARB is looking to the freight network to squeeze out every reduction they can on the path to this lofty goal. CARB will beg, borrow and sue their way to the vision they have laid out in the SFP, seeking to save California from itself, one step at a time.

Their vision however, is not without its detractors. More than one major trade organization has raised concerns with the freight growth forecasts that CARB is using to justify their ambitious emission reduction plans contained in the SFP. With rosy freight estimates based on high growth years prior to the Great Recession, CARB is basically using outdated projections to plan for future programs aimed at offsetting emissions from growth that will not be realized in their time frame or possibly ever.

Although the agency has entertained the thought of using revised cargo estimates to update their plan, they have given no indication that they will be easing potential restrictions on facilities that are located near sensitive receptors or in areas with high cancer risk from toxic air quality exposure; more on this in a minute.

Historically speaking, CARB has typically changed their tune if they find emissions estimates are clearly inflated. The Off-Road regulation got an overhaul after it was discovered that the load factors being used for estimating in use emission were significantly exaggerated. And the truck and bus rule received a tune up once it was clear that the recession was having a severe impact on truck activity directly leading to lower emissions during the economic downturn. 

Although there were some questions regarding the useful life and mileage accumulations CARB was using to justify the entirety of the on-road regulation, the rule was significantly modified to account for real, current economic and environmental factors that couldn’t be ignored. 
There are other examples of CARB using new data to modify existing and proposed regulation, especially when they have underestimated emissions. But, suffice it to say, CARB never has come to a regulatory roll back conclusion by themselves.

The industry has always been quick to point out flaws in CARB’s analysis when it comes to major emissions reduction measures. More often than not, industry claims are brushed aside in the name of protecting public health, leaving industry an open invite by staff to basically camp out in the CARB library to directly investigate the sources used in the development of the regulation, but not much else.
This tactic amounts to providing all the ingredients of the “whole enchilada” but not the cooking temperature.

Nevertheless, if there is an obvious flaw in their data (such as using 10 year old cargo estimates that were 43% higher than actual cargo volume for major California ports in 2014), CARB has no choice but to acknowledge and adjust as necessary.
Unfortunately, even with reduced cargo volumes, the revised methodology of carcinogenic risk from Office of Environmental Health Hazard Assessment (OEHHA) that was used in the South Coast AQMD  Multiple Air Toxics Exposure Study  IV(MATES-IV) Click HERE  indicates that previous toxic air exposure and subsequent cancer risk numbers  are significantly higher than previously estimated.  In all likelihood, these higher exposure numbers may offset any potential reductions in freight emissions from revised cargo volume estimates.  (See maps below)

Regardless, the freight movement industry should stay engaged and encourage CARB to take a hard look at their growth estimates; after all, sound public policy is supposed to be grounded in some tangible reality, even in California.

Stay Tuned!   


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