A Politburo for a New Era
By Thomas Jelenić, Vice President, Pacific Merchant Shipping Association
With the California Air Resources Board’s (CARB) decision to adopt the Advanced Clean Fleets (ACF) Rule, California is moving effortlessly into the carbon-free era of goods movement. For the uninitiated, ACF will radically remake the California trucking industry, but as I’ve discussed before1, the impact to port drayage will be immediate and intense. Listening to commentary from California policy makers, it is clear that there are challenges that may arise over the next 10 years or more, but according to policy makers the State will rise to meet those problems. In any case, those are problems for another day. What is clear in order for the ACF rule to be successful, milestones (if you can call continuous progress a collection of milestones) need to be made every month, starting today, through rule initiation on January 1, 2024, and continuing forward with implementation. However, there is no discussion of what the State needs to meet targets. So, can one safely assume that everything is proceeding as expected and the focus is rightly on the long-term horizon?
I am not optimistic. California continues to ignore short- term planning in favor of large ambitious goals, which have two main features: “being audacious” and progress being unmeasurable in the near term. Here are three examples of why I am so concerned:
Project 800 was announced by CARB with much fanfare in December 2020. The goal was “to support the deployment of zero-emission trucks serving California ports by setting a goal of 800 zero-emission (ZE) drayage truck orders in 2021”. The program was such a big deal when launched, there was a 7-½ hour webinar with guest appearances by several legislators and state-wide elected officials. A website was set up to track progress of the program. Two and half years later there are currently 86 ZE trucks serving the ports of Los Angeles and Long Beach according to the Port of Los Angeles’ April Gate Move Analysis (latest available as of this writing) and the tracking website has disappeared. While the program was tracked, it was showing over 700 orders for zero- emissions trucks, and then, along with the website, all references to the program vanished. That has left so many unanswered questions. Where are the other 700+ trucks? Has State money been spent on those 700+ orders and, if so, to what result? It is not even clear that the 86 ZE trucks in the Drayage Truck Registry, which completed 0.8% of truck moves, were even part of Project 800. No one that I have asked, including CARB staff, seems to know anything about the program. You would be forgiven for thinking that results of such a broad program would be communicated to the public and used to inform rule development.
A second concern is the basis on which the ACF rule was adopted. According to numbers obtained from CARB’s EMFAC database3, CARB projects that over 1,750 ZE trucks will be deployed next year. By 2025, that number is supposed to grow to almost 4,500 trucks to be deployed in California. Yet, with a nearly three-year lead time and program specifically designed to deploy ZE drayage trucks, the 100-unit mark is barely being scratched. That, of course, goes hand in hand with the non-existent infrastructure that is needed to support ZE trucks. It has become clear that both public and private infrastructure to support that number of trucks will take years to decades for the utilities to deliver, yet ACF is premised on thousands of trucks in the near term.
The final concern to raise is the incredible mismatch between what the ACF rule will impose and the likely resources that will be available, primarily through its accompanying rule, Advanced Clean Trucks. The ports of Los Angeles and Long Beach did an excellent job describing the discontinuity in the new adopted rules in a formal letter to CARB.4 As that letter points out, Advanced Clean Trucks will only require approximately 230 trucks to be manufactured for California in 2024. But analysis of the Drayage Truck Registry data indicates that up to 3,500 trucks may be needed in the first year of ACF (which also represents a significant mismatch from CARB’s number of nearly 1,750 trucks for the entire State!). Given that ACF creates a capped legacy fleet that can only be supplemented with ZE trucks and average drayage fleet turnover of 15%, the only thing that may save California from a trucking capacity crisis is a recession. Should we thank God that cargo volumes are down 30%?
As California officials talk about this regulatory milestone, the focus is on meeting the needs ten years from now. The success of the program in the near-term is a given. Yet, the trucks necessary to meet goals a mere six months from now do not exist. The infrastructure to support the trucks does not exist. The energy to power the infrastructure is not available. The disconnect between what Advanced Clean Fleets envisions and the reality on the ground has become so strong that port staff raise serious concerns while some port executives praise the effort. Listening to California officials talk about future hurdles and how we will collectively rise to meet the challenge is reminiscent of the apparatchiks of the Soviet Union talk about the success of the next five-year agriculture plan while people stood in line for bread. California seems to have mastered delivering plans without delivering results, a politburo for a new era.