CARB Board Meeting to Review Truck & Bus Regulation
Some CCTA “Asks” for Thursday’s CARB Meeting (10/24/13):
According to DMV registration information, there are approx. 451,000 in-state registered commercial trucks and 1.35 million IRP registered trucks that operate in California. See attached DMA state for 2012.
We believe that 99% of IPR (out-of-state registered trucks are heavy trucks) are long-haul (100,000 mi./yr.+) all based outside of CA and should be the focus of existing CARB regulations. The 452,000 in-state registered are those of most interest to us.
Links below is the proposed CARB Staff Presentation for 10/24/13 (as usual it comes out 2 hours before the meeting) and body type here, are some of our (CCTA) industry comments and recommendations, that will be proposed by Betty Plowman after 1 PM.
See Link PDF’s
We believe about 40% are of the weight class and vocation of interest – construction. Of those approx. 176,000 trucks, 25% or 44,000 trucks are construction related (including pumps, cranes water trucks etc.) and we strongly believe our industry needs additional compliance time.
Again, we are focused on the approx. 2.4% or 44,000 construction industry heavy trucks and related diesel powered vehicles that are now not in compliance – for these reasons and caveats.
The economy is still in poor shape for the construction industry – For example private Construction lending has dropped from $632b to $210b annually in 2013 (70% below peak in 2008).
According to Cumming Corp., CA Construction Cost Forecast, the state’s construction industry is far from healthy.
California’s ‐ Conflicting Regional Factors Have Set the Stage for Cost Volatility:
◊ Public non-residential construction is slowing
◊ Residential construction is showing signs of recovery
◊ Passed Props 30 & 39 – will raise $7b in revenue
◊ Passed 88 School Bonds – totaling $13.3b
◊ State Budget Deficit – expected to drop to <$2b next year
◊ San Francisco/San Jose – best growth market in the country
◊ Los Angeles – largest market in the state
◊ Sacramento – continues to struggle, is seat of government
◊ San Diego – smaller market with strong job growth
◊ Attrition is occurring among subs, smaller GC’s and architects
California has lost 40% of its construction workforce since the peak in 2006. The majority of owner-operator truckers in California (including construction) are Latino and cannot realistically buy a new truck or even a DPF.
1.) CARBs Staff Historically Poor/Inaccurate Estimate of Diesel Engine Emissions Inventory and Cost of the Regulations – Off-road diesel equipment emissions estimates were proven to be inaccurate by 350% (AGC 2010). CARB also estimated that the cost of the rule would be $2-billion, the industry now believes that it will be closer to $4-billion. For the on-road emissions and costs, a study was performed in 2011 and it was discovered that there where similar inaccuracies by at least 100% for emissions and 300% higher for costs. State based construction today is still off by at least 50% from 2006, the year CARB utilized in the emission inventory studies. Incidentally, environmental regulations has increased the cost of new trucks/engines by over $34,000 in addition there has been much documented downtime and lost utilization as a result of this technology.
2.) No Used Truck Inventory: There is a serious used truck inventory in the U.S. and especially here in California. In September, Ritchie Bros. Auctioneers Inc. announced 7% lower net earnings than a year ago and blamed a shortage of late model used trucks and off-road equipment for the seven percent drop in earnings, year over year. Due to the 2006 truck pre-buys, very few 2007, ’08 and ’09 were ever built or purchased thus adding to the shortage of used trucks today.
3.) California Requires 4-years of Truck Manufacturing Capacity – by Itself: Assuming that 60% of all state-based heavy trucks (451,000 CVRA) and IRP trucks (1.352-mil) are now in compliance with the regulation (we believe only about 30%) are actually in compliance. But we will assume that it’s 40% or 720,000 that are non-compliant trucks. The present manufacturing capacity of all the major truck manufacturers is about 15,500 new trucks per month or 186,000 trucks per year. Assuming 100% of all new trucks are going to California (which would never happen) it would take 4 years to build-out these trucks for the remaining 720,000 trucks based here or that come here – to become compliant. DMV could easily confirm these estimates. That’s early 2018 at best. Clearly the regulations are not achievable!
4.) Reform the Entire Diesel Emission Testing Program (PSIP). Create a useful and accurate emissions testing program for all diesel trucks/engines. Pre-2010 and then post 2010. The testing would be required in all areas of the state including attainment areas. Remove or repair all dirty trucks that can’t meet low maximum emission standards. Also, DPF retrofitting is far more successful, the cleaner the engine. All emissions tests to be reported to CARB. With no test, CARB reports withholding of registration to DMV. 2010 truck would not have to be tested for 5 years, every 2 years after that. Put a maximum charge of $100 to test a truck, and a minimum of $50.
5.) Ask for a Green Zone “attainment areas” carve-out amendment (extension) to the rule to the end of 2020 – on emissions tested and qualified engine.
6.) Low Mileage Trucks – Create three categories of Lower Mileage Construction Trucks engine 1994 mo-yr or newer on an emission verified clean truck.
a. Less than 1,000 miles/yr. (exempted)
b. Ultralow Mileage: 1,001 to 6,000 mi./year – Compliance extension to the end of 2019
c. Very-low Mileage: 6,001 to 30,000 to mi./yr. – Compliance extension to the end of 2018
d. Low Mileage: 30,001 to 75,000 mi./yr. – Compliance extension to the end of 2017
Allow at least 4,000 in the Ultra and 20,000 “construction” trucks in each of the last two categories or some combination thereof. “Must be a member of an Assoc.?” or those paying attention. These extensions would allow the used truck market to produce enough “newer” used trucks to meet these vocational businesses needs by 2017. There are too few used trucks even today 3 years after the new engine standard. Most trucks are on 4-5 years (500,000 – 600,000 mi.) leases. There is no “greener” program than reusing, repurposing, recycling of newer used trucks.
7.) Demand Fair Access to Grant, 1B etc. funding and low interest loans for this same group of trucking businesses in the carve out. CARB bases grant funding on mileage but the rule itself does not contemplate mileage at all?
8.) Ask for a “Detailed” 6-year Analysis of where all the grant (1B, Moyer etc.) funds went – to in-state, out-of-state, fleet size, owner-operators. Remind them of the funds repeatedly given to billion dollar trucking companies (based in Arizona), Swifty Trucking is a great example:
Swift and Port of LA reach port truck cash settlement. The Port of Los Angeles and Swift Transportation have reached a settlement over the mega-carrier’s $11.8 million grant grab from the port to purchase new trucks. In 2010, the port revealed that only 30 percent of the 2,000 trucks purchased with port money had made the required 300 trips per year. At that time, nearly 400 trucks purchased with the port money hadn’t made a single trip to the port. Swift will pay the port $4 million, confirmed Phillip Sanfield, Los Angeles port spokesman. “We’re pleased the Los Angeles Harbor Commission approved the settlement between the port and Swift,” Sanfield said. “The settlement avoids any potential for a costly and protracted legal battle.” (Who wouldn’t want this loan program, still received $8-million?)