The next iteration of the San Pedro Bay Ports Clean Air Action Plan was released as a draft document in mid-July, and various industry stakeholders are still combing through its pages as they formulate formal responses.
Initially, feedback appears mixed. Some groups have expressed satisfaction with certain provisions in the document, while others are wary of its reliance on technologies that are not yet available and potential cost impacts to private industry. Still others argue the plan is not aggressive enough.
The plan has changed somewhat from what was included in a draft discussion document released late last year due to the ports’ desire to tie their goals to upcoming state requirements.
Heather Tomley, director of environmental planning for the Port of Long Beach (POLB), is pictured in front of Long Beach Container Terminal, which features a variety of zero-emission technologies. POLB and the Port of Los Angeles recently unveiled their joint draft Clean Air Action Plan, which details goals for achieving zero-emissions from cargo handling equipment by 2030, among other strategies aimed at reducing pollution and greenhouse gas emissions. (Photograph by the Business Journal’s Larry Duncan)
“The majority of the strategies that we laid out in the discussion document have remained as they were presented in that document but with a little bit more detail, clarification, backup information, analysis, that sort of thing,” Heather Tomley, director of environmental planning for the Port of Long Beach, told the Business Journal.
“There were a couple strategies that have changed from the discussion document. Primarily, that is related to feedback that we got and then also activities that have taken place with regulatory changes or legislative changes,” Tomley explained.
Goals related to the Clean Trucks Program, which sets goals and requirements for integrating cleaner-running trucks in the dual port complex, are one such change. The discussion document set timeline goals for phasing out old trucks in 2018, 2020 and 2030, with the ultimate goal of only zero-emission trucks operating in 2035. State law caused the ports to change these requirements in the draft CAAP document.
Senate Bill (SB) 1, a bill taxing gas and creating a fee system based upon the model year of vehicles to fund infrastructure improvements, was signed into law in November and ultimately had an impact on the CAAP. The law creates requirements for phasing out old semi-trucks with cleaner ones but includes a “useful life” provision for existing trucks on the road.
Under SB 1, truck owners will not be required to purchase a new vehicle until their existing truck has reached 13 years from the certified model engine and emissions control system year, or until the truck has traveled 800,000 miles so long as the engine and emissions control system does not reach 18 years past their original certification date.
“Essentially what that means is the state is not going to be doing a new regulation on trucks anytime soon,” Tomley said. “What worked the last time around with our truck program is the state had their regulation that they were developing at the same time as we were doing our program. And we structured our program to essentially just accelerate the timelines,” she explained.
“Now that there won’t be a state regulation, we are not in that same position,” Tomley continued. “We won’t be able to accelerate anything that the state is doing. So, within the authority that we have, we are looking at the ways we can try to guide the turnover of the trucks into the type of trucks that we want to see.”
The draft CAAP, if passed, would require new trucks registering at the ports to be model year 2014 or later starting in 2018. In 2023, a state regulation requiring operation of near-zero emission trucks kicks in, and the ports would require that trucks meet this standard at that time.
“Then we have also proposed to establish a truck rate structure where all trucks would have to pay a rate after a certain year,” Tomley said. “But then we would provide exemptions to that rate for trucks that meet zero or near-zero emissions. So that would provide an economic incentive for use of those trucks.”
The draft CAAP also outlines goals to create a universal truck appointment system and to require all truckers entering the ports to make appointments at terminals. “Currently, nine of the 13 terminals have appointment systems, but they’re all independent systems that don’t communicate with each other,” Tomley said. “What we want to do is make sure we have an overlay where all of the systems can talk to each other so that if you are delayed at one terminal, you can make adjustments on your next appointment. So it can all be seamlessly integrated.”
Alex Cherin, intermodal conference chair of the California Trucking Association (CTA), told the Business Journal that the CTA is still reviewing the draft CAAP and reaching out to its members for feedback.
“I can tell you, though, initially, that we see that it tries to strike a balance between the need to continue robust trucking operations at the port while still incentivizing those who want to invest in newer and cleaner trucks,” Cherin said. “We are initially pleased to see that there is no hard ban on equipment and that the updates seem to tie themselves to what the California Air Resources Board has proposed.”
Cherin said the organization will submit an official comment letter to the ports within a few weeks after receiving comments from members. “There is always a concern about the costs. But again, I think the way that this CAAP update is written, it tries to strike a nice balance,” he said.
The Coalition for Renewable Natural Gas would like to see more aggressive requirements for trucks.
“When you compare the discussion document to the draft CAAP, the draft CAAP took some significant walks away from some of the aggressive parts of the discussion draft,” Greg Roche, vice president overseeing sustainable trucking for coalition member Clean Energy, told the Business Journal. Clean Energy is a provider of natural gas fuels and fueling stations.
“It waits until 2023 before it starts imposing fees to encourage changeover of trucks,” Roche said of the draft CAAP. “And there is a significant delay in when emission reductions would occur between the draft CAAP and the original discussion draft.”
Roche pointed out that near-zero emission RNG-fueled semi-trucks will be commercially available in 2018. “Our view is that with the technology available, we could complete the transition to clean trucks by 2023 versus getting started then,” he said.
Tomley said the ports’ power to make such requirements without state guidelines in place is limited. “We don’t have the same authority that the air agencies have to implement requirements, develop rules, that sort of thing,” she said. Requiring new trucks registering at the ports to have newer engines and imposing rates are within the port’s authority, she noted.
The draft CAAP’s requirements for cargo handling equipment also changed from the discussion document. Originally, the discussion document included a goal to require all cargo handling equipment to be zero emission by 2030.
Now, the California Air Resources Board is developing regulations to achieve the goal of all such equipment operating at up to 100% zero emissions by 2030. “The state identified that they will be moving forward with amendments to their regulation,” Tomley said. “So our process that we’ll be going through will be participating in their rule-making effort to identify ways that we can help ease barriers to implementation, accelerate the timeline where we can and stay on track for meeting the 2030 timeline, but [also] participate in the rule-making process.”
While Long Beach Container Terminal now has mostly zero-emissions equipment at Middle Harbor, that equipment is automated, and the ports would not be requiring a switchover to automated terminals, according to Tomley. “It doesn’t require automation. Traditional operations we think will also be feasible,” she said.
But zero-emission versions of equipment such as top picks and yard tractors are not yet available. “One of the comments that we hear from folks is ‘This equipment is still just being developed.’ Some of it hasn’t even been developed as a prototype yet,” Tomley said. “But we’re working through that process.” She noted that several demonstrations of zero-emission yard tractors are underway. The Port of Long Beach has a Technology Advancement Program which primarily uses grant funding to demonstrate new, cleaner technologies, she added.
A Moffatt & Nichol study commissioned by the Pacific Merchant Shipping Association (PMSA) found that converting the San Pedro Bay ports to all-electric, zero-emission equipment would cost as much as $29 billion, according to Thomas Jelenic, PMSA vice president.
It would cost about $2 billion to install infrastructure necessary to support zero-emissions cargo handling equipment, according to the draft CAAP. It “may cost upwards of $1.8 billion to replace the existing fleet with zero-emissions equipment,” the document also states.
Jelenic does not believe these cost estimates stand up to scrutiny. “The concern is with assumptions. First, the fact is the equipment doesn’t exist,” he said. He also argued that the batteries necessary to power zero-emission equipment at terminals would not last long enough, which would require investing in multiple machines to carry out the tasks that one used to do.
Tomley acknowledged that the draft CAAP relies upon assumptions and that those assumptions differ from PMSA’s views. “With our study, we assumed that . . . the technology will be developed to a point that it can do the job of sort of traditional diesel equipment,” she said. The assumption in the document is that technology would exist to make one-for-one replacement of technology feasible, she explained. “We assume that the battery technology will continue to advance.”
While the ports will make investments and seek grants to aid in funding these changeovers, Jelenic said the cost to private industry would still be significant. “It’s still an enormous amount of money, particularly for an industry that is struggling with overcapacity, that has lost money pretty much every year for the past decade,” Jelenic said.
“Is there still room to revise it? Absolutely. Which we think they should,” Jelenic said.
The draft CAAP also lays out plans to invest in more on-dock rail infrastructure and continue to reduce emissions produced by harbor craft and ships.
Overall, the ports estimate it could cost between $7.3 billion to nearly $14 billion to implement the proposals in the draft CAAP.
A public workshop on the draft CAAP is being held on August 30 at 5 p.m. at Banning’s Landing, located at 100 E. Water St. in Wilmington.
The public comment period for the draft CAAP closes on September 18. Comments, questions or requests for presentations may be sent to email@example.com.
According to Tomley, the joint boards of harbor commissioners are expected to vote on the final CAAP in November.