California Air Resources Board vs. Reality – California Globe

There’s a reason the California Air Resources Board, known as “CARB,” is not actually called the California Air Reality Board.

In the recent past, CARB has tried to mandate anti-pollution technology on boats, trucks, and trains. The problem with each of these proposed regulations is that the technology being mandated doesn’t actually exist yet.

Even more disturbing is CARB’s tendency to use these nonexistent standards as benchmarks for further regulation.

Take trains for example. Last fall, CARB filed a request with the federal Environmental Protection Agency for a waiver to require all trains in the state to meet newer — and much more restrictive — regulations. pollution standards.

The effort has two major problems. First, railroads would have to upgrade their fleet of locomotives to technology that doesn’t exist on a large scale and likely won’t exist when the full rules go into effect in 2035. The rules also require locomotives more than 23 years old to be replaced soon.

Locomotives are very expensive, costing between $4 million and $5 million each. And while the larger national freight railroads can afford them, the smaller “short rail” lines that crisscross the state and serve important functions may not be able to, effectively bankrupting many of them.

Second, California plays such an important role in the transportation of goods and cargo (the ports of Los Angeles and Long Beach account for more than a third of the country’s total imports) that if an exemption were granted, the entire country would be affected. Many would support California, but many would also oppose it, creating a logistical nightmare that would require changing locomotives at the state line.

CARB needs this waiver because the federal government regulates railroads and needs permission (similar to an exemption from stricter-than-national auto emissions standards) to implement new regulations.

The Environmental Protection Agency (EPA) is currently considering its decision, but there has already been significant national opposition – mostly from other federal agencies – to the proposal. No deadline has been set for a decision.

Here’s the unreal part: During a recent congressional hearing on the subject, a representative from the Bay Area Air Quality Management District stated, contrary to popular belief and common sense, that trucks are often a cleaner way to transport goods than trains.

The claim was made in response to claims from rail industry representatives that if railways, especially “short line” ones, are forced to close, it will mean many, many more trucks on the roads.

A train can carry a ton of freight about 450 miles on one gallon of diesel fuel, and each freight car carries the same amount of cargo as three or four trucks, so fewer trains means more trucks.

CARB says this isn’t a major problem because their analyses show trucks are cleaner.

How did they come to this seemingly impossible conclusion? By basing their truck emissions estimates on something that doesn’t yet exist—again.

The analysis compared trucks and trains, assuming the trucks met a new regulatory standard known as “Advanced Clean Fleets”

The implementation of California’s Advanced Clean Fleets (ACF) regulations, which went into effect January 1, 2024, is intended to complement the Advanced Clean Trucks (ACT) regulations, which mandate a significant increase in the number of medium- and heavy-duty zero-emission vehicles (ZEVs) on California roads.

CARB, of course, has been sued over the rule, with opponents arguing that the bill would do to trucking what their proposed rules did to trains — again, because California makes up such a huge chunk of the country’s freight transportation infrastructure, the rule would essentially become a de facto national standard.

“The ability to reliably and affordably move people and goods is the foundation of free enterprise and a functioning marketplace that serves American consumers,” said Gentry Collins, CEO of the American Free Enterprise Chamber of Commerce. Carriee’s Commercial Diary. “California’s current attempt to ban liquid fuels and internal combustion engines poses a serious threat to the American way of life and is bad climate policy.”

So, while CARB says trucks are cleaner, they will only become cleaner when the new standard goes into effect: The “methodology report” of this study clearly states this:

“Tier 4 and 5 locomotives can haul containers with fewer emissions than trucks in communities within 20 miles of ports until 2035, until the Advanced Clean Fleets Regulation goal of 100% zero-emission freight trucks is achieved. The analysis also shows that Tier 4 and 5 locomotives can haul containers more cleanly than long-haul trucks until the Advanced Clean Truck Fleets Regulation (ACF)9 leads to zero emissions for all trucks in 2045.”

In other words, CARB is not comparing current reality to, well, current reality and is simply assuming that its stringent regulations scheduled to be in place for the next 20 years will remain in place.

This analysis fails on another level, namely because more trucks on the roads means more traffic, which in turn means both annoyance for people and more air pollution as cars sit in traffic jams.

And it’s not the first or second time CARB has mandated the use of non-existent technology – port vessels have also been a recent target.

But CARB’s regulatory presumption was so egregious that even the state legislature thought it had gone too far. A bipartisan bill is currently making its way through the legislature to roll back CARB’s boating regulations:

The bill was written in response to latest CARB regulations which requires port ships to have cleaner engines and install particulate filters to reduce pollution. However, the ruling has caused many problems. One of the biggest is that DBFs simply don’t exist for some types of boats and are not close to development at present. Another is that US Coast Guard They said they wouldn’t enforce the new CARB regulations.which essentially renders CARB regulations powerless, and also highlights how CARB ignored safety letters from the Coast Guard. Safety concerns about installing untested DPFs have also worried many, saying they risk damaging vessels. Finally, if CARB regulations remain as they are, the installation deadlines could significantly reduce the number of usable port vessels in the state, which would hurt both the industry and the state economically.

CARB defended its attempt to make fundamental changes to national rail standards, citing the aforementioned study as one reason.

“This comparison is important because there is a misconception that trains have a smaller environmental impact than trucks, which is not true for criteria emissions such as nitrogen oxides and particulate matter, for which there are no known safe exposure levels,” a CARB spokesman said. “As emissions regulations have reduced pollution from trucks, locomotives now emit relatively higher levels of criteria pollutants.”

CARB regulations are somewhat more specific, which may partially explain the analysis results. CARB focused solely on particulate matter and nitrogen oxides – these are not considered “greenhouse gases” but only local pollutants, hence the claim that these regulations will significantly improve the health of trackside/port communities.

“For communities that struggle with excessively concentrated sources of pollution due to proximity to freight-moving operations, regulating locomotives will be a significant public health measure that will result in an estimated $32 billion in health care savings, preventing 3,200 premature deaths and 1,500 emergency room visits and hospitalizations,” a CARB spokeswoman said. “The risk of cancer from exposure to airborne toxins within one mile of a locomotive’s operating location is expected to be reduced by 90%.”

Interestingly, CARB has used a rather odd way of defining emissions for longer trips:

“The analysis assumed that first-mile and last-mile emissions (e.g. from freight handling equipment) were similar for trucks and trains, so initial and target emissions are omitted from the analysis,” the spokeswoman said. “Therefore, neither total emissions nor emissions per mile decrease with the distance the train travels. The emissions shown in the analysis are the TOTAL emissions generated over the 300-mile journey. The further the train and trucks travel, the more emissions will be generated.”

In other words, the analysis did not take into account the concept of “economies of scale,” which seems counterintuitive. It should also be noted that the comparison was only for “California” trucks and is therefore nationally valid.

It is unclear whether the EPA will grant the waiver or not, but opposition is fierce and if it does, the number of lawsuits will increase massively.

Or a whole train – choose what is more environmentally friendly.