American Trucking Associations

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Page 1 of 3 January 23, 2013

Clerk of the Board

California Air Resources Board

1001 I Street

Sacramento CA 95814 [Submitted electronically to: http://www.arb.ca.gov/lispub/comm/bclist.php ]

RE: Comments on the Proposed South Coast 2012 Air Quality Management Plan (2012 AQMP)

Dear Chairman Nichols and Members of the Board:

The American Trucking Associations (ATA) includes m any of the trucking companies that operate in the South Coast Air District. 1 These companies have made, and will continue to make, substantial investments in new equipment with lower emitting technologies. According to the Port of Los Angeles, drayage companies alone ha ve invested more than $1 billion in new trucks in order to reduce emissions by 80 percent. 2

The 2012 AQMP contains two new control measures tha t seek to further reduce emissions from heavy-duty vehicles:

ONRD-05 : Further Emission Reductions from Heavy-Duty Vehi cles Serving NearDock Rail Yards

ADV-01 : Actions for the Deployment of Zero and Near-Zero Emission On-Road Heavy-Duty Vehicles

While trucking companies have not shied away from m aking investments in new technologies, the proposed control measures fail to provide detai ls relating to cost or technical feasibility. The

Board should not include these control measures in the 2012 AQMP without analyzing their impact on state policy. For example, basing incent ive funding on the proposed optional NOx standard would likely foreclose further advancement s in the wide range of low emission technologies trucking companies are already investi ng in, including clean diesel, natural gas, hybrid electric, and even hydrogen. ATA urges the Board to reject control measures ONRD

05 and ADV-01 and instead work towards a comprehens ive, statewide approach that continues to incentivize technology advancement und er a fuel-neutral approach.

1 The American Trucking Associations is the national trade association of the trucking industry. Throu gh our affiliated state trucking associations, affiliated conferences and other organizations, ATA represents more than 37,000 trucking companies throughout the United Sta tes.

2 Clean Truck Program Fact Sheet , December 20, 2011.Page 2 of 3

Additional considerations that need to be incorpora ted into a comprehensive statewide approach are presented below.

Investment Decisions of Motor Carriers Shippers have choices in terms of where and how the y ship their products. Motor carriers compete for this business in terms of cost and serv ice. Greater consideration should be given to the level of investment required by motor carriers when implementing technology advancements

and how this investment can affect their financial viability in a highly competitive industry. A state-level process that involves motor carriers in put and perspective on financial barriers and opportunities associated with technology advancemen t would be helpful in this respect.

Equipment Utilization/Resale Motor carriers tend to maintain flexibility in the use of their equipment. A single truck will be used to transport freight between multiple origins or destinations, such as ports, rail yards, warehouses, drop yards, shippers and receivers. Th is flexibility not only helps maximize efficiency but also tends to create more resale opp ortunities by expanding potential markets. The impact of technology advancement on equipment utili zation and resale value should be considered. Similarly, a state-level process invol ving input from motor carriers should be pursued.

Funding Funding for technology advancement will be dependen t upon the extent of emissions reduced and the types of technologies used to achieve these reductions. A detailed financial analysis which identifies the amount of funding required for various emission reduction/technology options and the specific sources of this funding is needed to determine cost-effectiveness.

Technology/Fuel Neutrality Using technologies with “zero-emissions” or “95 per cent or greater reduction in NOx” as the criteria for incentive funding is overly restrictiv e. Without further substantiation, it appears othe r potential emission reduction options which are curr ently being used and/or tested by the trucking industry may be excluded, such as trucks running on clean diesel, natural gas, hybrid electric and hydrogen. Instead, an incentive approach which mai ntains the state’s commitment to fuelneutrality should be pursued.

Federal Regulation of Motor Carriers Congress has very broadly preempted state and local regulatory provisions that impact motor carriers rates, routes, and services. As a result, the motor carrier industry is shaped by the forces of competition, under a uniform federal regulatory env ironment. While state and local government actions necessary to meet the attainment demonstrat ion are mandated by the Clean Air Act, these actions cannot override the federal regulatory envi ronment under which motor carriers operate.

In closing, we ask the Board to reject proposed con trol measures ONRD-05 and ADV-01 and instead pursue a comprehensive statewide approach w hich maintains fuel-neutrality and

addresses the considerations we have listed above. We also would like to recognize and support the comments submitted by our affiliated state asso ciation, the California Trucking Association.Page 3 of 3

Please contact me if you have questions or need cla rification of these comments.

Sincerely,

Michael Tunnell Director, Energy & Environmental Affairs American Trucking Associations (916) 300-3161 mtunnell@trucking.org