BILL ANALYSIS                                                                                                                                                                                                    






           SENATE TRANSPORTATION & HOUSING COMMITTEE       BILL NO: sb 1156
          SENATOR ALAN LOWENTHAL, CHAIRMAN               AUTHOR:  cedillo
                                                         VERSION: 4/5/10
          Analysis by:  Jennifer Gress                   FISCAL:  yes
          Hearing date:  May 4, 2010                         URGENCY:  YES






          SUBJECT:

          Funding for heavy-duty diesel trucks

          DESCRIPTION:

          This bill appropriates $10 million from the Air Quality  
          Improvement Fund to provide grants to heavy-duty diesel truck  
          owners to comply with regulations adopted by the Air Resources  
          Board (ARB) to reduce emissions from those vehicles. 

          ANALYSIS:

           Air Resources Board (ARB) Regulations for On-Road Heavy-Duty  
          Diesel Trucks
           Existing law charges ARB with primary responsibility for the  
          control of mobile source air pollution, including the adoption  
          of rules for the reduction of harmful vehicle emissions and the  
          specification of vehicular fuel composition.  In the past two  
          years, ARB has adopted two significant regulations to reduce  
          emissions and public exposure to diesel particulate matter  
          (diesel PM), oxides of nitrogen (NOx), and other air  
          contaminants from heavy-duty diesel vehicles.
          
          Drayage Truck Regulation.  In the spring of 2009, ARB adopted  
          the In-Use On-Road Diesel-Fueled Heavy-Duty Drayage Trucks,  
          referred to as the drayage or port truck rule, by setting  
          emission standards for in-use, heavy-duty diesel-fueled vehicles  
          that transport cargo to and from California's ports and  
          intermodal rail facilities.  The rule establishes different  
          compliance standards and deadlines for different model-year  
          trucks and will be implemented in two phases, as described in  
          the following table:

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          |                   |                                              |
          |   Truck Engine    |        Emission Requirement Schedule         |
          |    Model Year     |                                              |
          |-------------------+----------------------------------------------|
          |                   |                                              |
          |  1993 and older   |Prohibited by December 31, 2009               |
          |                   |                                              |
          |-------------------+----------------------------------------------|
          |                   |Phase 1:  By December 31, 2009, reduce PM     |
          |                   |emissions by 85%                              |
          |    1994 - 2003    |                                              |
          |                   |AND                                           |
          |                   |                                              |
          |                   |Phase 2:  By December 31, 2013, meet 2007     |
          |                   |engine standards                              |
          |-------------------+----------------------------------------------|
          |                   |Phase 1:  By December 31, 2011, reduce PM     |
          |                   |emissions by 85%                              |
          |       2004        |                                              |
          |                   |AND                                           |
          |                   |                                              |
          |                   |Phase 2:  By December 31, 2013, met 2007      |
          |                   |engine standards                              |
          |-------------------+----------------------------------------------|
          |                   |Phase 1:  By December 31, 2012, reduce PM     |
          |                   |emissions by 85%                              |
          |    2005 - 2006    |                                              |
          |                   |AND                                           |
          |                   |                                              |
          |                   |Phase 2:  By December 31, 2013, meet 2007     |
          |                   |engine standards                              |
          |-------------------+----------------------------------------------|
          |                   |                                              |
          |  2007 and newer   |       Not applicable, fully compliant        |
          |                   |                                              |
           ------------------------------------------------------------------ 

          Truck and Bus Regulation.  In December 2008, ARB adopted the  
          In-Use On-Road Diesel Vehicle Regulation to reduce emissions  
          from existing on-road diesel vehicles operating in California.   
          The regulation establishes a variety of compliance options, but  
          in general, it requires trucks and buses to meet performance  
          requirements between 2011 and 2023.  By January 1, 2023, all  
          vehicles must have a 2010 model year engine or equivalent.

          Air Quality Improvement Program (AQIP)




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           AB 118 (N??ez), Chapter 750, Statutes of 2007, established the  
          AQIP, which is a voluntary incentive program administered by ARB  
          to fund clean vehicle and equipment projects, research on  
          biofuels production and the air quality impacts of alternative  
          fuels, and workforce training.  Each fiscal year, ARB adopts a  
          Funding Plan that establishes priorities for the funding cycle,  
          describes the projects ARB intends to fund, and sets funding  
          targets for each project.  About 80 percent of AQIP funds for  
          the 2009-10 fiscal year will be used to support vehicle and  
          equipment deployment projects for what ARB considers to be the  
          next generation of advanced technology vehicles and equipment  
          just reaching commercialization, including hybrid trucks and  
          buses.
          
           This bill  appropriates $10 million from the Air Quality  
          Improvement Fund to ARB for purposes of providing grants to  
          heavy-duty diesel truck owners to comply with regulations  
          intended to reduce emissions from those vehicles. 
          
          COMMENTS:

           1.Purpose  .  According to the author, this bill is intended to  
            address the economic hardships truck drivers face complying  
            with ARB standards by appropriating $10 million dollars for  
            the purposes of providing grants to truckers in order to  
            retrofit their vehicles.  Currently, there is incentive money  
            available in many areas of the state but none to cover the  
            immediate cost of retrofitting to help meet compliance  
            standards. 

            The author affirms that emissions from diesel trucks have  
            adverse effects on human health and lead to 4,500 premature  
            deaths per year.  By large majorities, Californians support  
            clean air laws and reducing air pollution saves the state  
            billions of dollars per year in reduced hospitalizations and  
            emergency room visits, health care costs, and lost work days  
            due to illness.
           
            At the same time, these laws sometimes impose hardships on  
            small businesses and others who, in a tough economy, may not  
            have the financial resources necessary to comply with  
            regulations.  Rather than weaken the laws by relaxing the  
            standards or delaying their implementation, this bill provides  
            additional funding to help small- and medium-size trucking  
            businesses retrofit or replace their trucks.  
           




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            In doing so, this bill will allow more truckers to stay in  
            business regardless of their ability to pay to comply with the  
            rules, helping to ensure that the state experiences the  
            economic benefits derived from maintaining goods movement  
            businesses such as drayage trucking, while simultaneously  
            advancing clean air efforts.
            
           2.Need  ?   The problem this bill seeks to address is unclear.   
            With regard to port trucks, ARB contends that there are  
            currently a sufficient number of drayage trucks in compliance  
            with the drayage truck rule to meet the freight movement needs  
            at the state's ports and rail yards.  When ARB initially  
            designed the drayage truck rule, it estimated that about  
            20,000 trucks would need to comply in order to support goods  
            movement operations in the state.  With the global recession  
            and the corresponding reduction in freight movement, ARB now  
            estimates that only about 14,000 drayage trucks are needed to  
            support goods movement. Thirteen thousand drayage trucks are  
            currently in compliance with the rule.  

            Moreover, due to the state's difficulties issuing bonds in  
            2008 and 2009, ARB was unable to fund some truck emission  
            control projects ahead of the January 1, 2010 compliance  
            deadline and thus extended the deadline to April 30, 2010 to  
            allow more truck owners to take advantage of bond funding.   
            About 4,500 trucks applied for the extension, of which 2,500  
            are expected to obtain the financing needed to comply. 

            Other than port trucks, all other heavy-duty diesel trucks  
            eligible for funding under this bill are subject to the bus  
            and truck rule, which includes different compliance deadlines  
            for different model-year trucks.  The earliest compliance  
            deadline for that rule is January 1, 2011, by which time  
            pre-1994 model-year trucks must be equipped with a retrofit  
            device.  Because this rule is not yet in effect, it seems  
            unlikely that any truck owner subject to this rule has ceased  
            operations as a result of it.  Furthermore, ARB is currently  
            conducting workshops to invite input on a set of proposals  
            that would ease some of the requirements of the rule,  
            including a proposal to delay implementation by two years. 

            Finally, several financial assistance programs exist to  
            provide grants, loans and loan guarantees, vouchers, or  
            rebates to help truck owners with the purchase of cleaner  
            trucks and equipment.  These include the Proposition 1B Goods  
            Movement Emission Reduction Program and the Carl Moyer  




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            Memorial Air Quality Standards Attainment Program. These  
            programs, consistent with all other financial assistance  
            programs that support clean air efforts, fund emission  
            reductions that are not otherwise required by law or  
            regulation.  In addition, ARB, in partnership with the  
            California Pollution Control Financing Authority (CPCFA),  
            offer Providing Loan Assistance for California Equipment  
            (PLACE), which is a loan guarantee program to assist equipment  
            owners with financing upgrades.  

            There is no question that upgrading a truck, either by  
            retrofitting or replacing it, can be expensive.  The average  
            cost to retrofit a truck, for example, ranges from $11,000 to  
            $20,000 per truck.  Furthermore, given the current economic  
            climate, it is likely that many truck owners have struggled to  
            stay in business over the past few years.  It is unclear,  
            however, whether their difficulties are due to ARB regulations  
            or to reduced freight activity caused by the global recession.  
             Equally unclear is whether providing funds to help truck  
            owners comply with ARB rules will help restore their business  
            in this environment.  

           3.Paying for compliance  .  As a general principle, financial  
            assistance or incentive programs do not pay for emission  
            reductions that an existing rule or regulation requires an  
            equipment owner to achieve.  Doing so would be the equivalent  
            of paying a person to follow the law.  Three reasons that make  
            paying for compliance undesirable concern equity,  
            cost-effectiveness, and the slippery slope effect.  

            Equity.  Thirteen thousand drayage trucks are already in  
            compliance with the law, in advance of the deadline.  In many  
            cases, these owners had to upgrade their truck, either by  
            retrofitting or replacing it, the costs of which were borne in  
            part by the truck owners.  Is it fair now to pay to upgrade  
            trucks that are not in compliance with the law when so many  
            paid to comply in advance?

            Cost-effectiveness. The resources available to support clean  
            air efforts are not without limit and should be used in a  
            cost-effective manner that improve air quality to the greatest  
            extent possible.  Using funds to pay for emission reductions  
            that are above and beyond the law, as current financial  
            programs do, will achieve greater emission reductions over the  
            long-term than paying for compliance.





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            Slippery slope.  By paying for compliance now, it will be  
            increasingly difficult to establish regulations that could  
            impose costs on equipment owners without offering compliance  
            assistance.  Given that resources are limited, demand to pay  
            for compliance may have the effect of tempering regulatory  
            efforts to improve air quality. 
           
          4.Implementation issues  .  This bill does not provide much  
            guidance regarding how ARB would implement compliance  
            assistance for truck owners, thus making it difficult to fully  
            assess the implications of the bill for air quality.  Some  
            questions include:

                 What share of equipment costs should be eligible for  
               funding under the bill?

                 Should the share of costs vary according to the  
               compliance option chosen or by emission reductions achieved  
               or by some other factor?

                 Should the program impose a cost-effectiveness standard  
               or an overall funding cap for each equipment project?

            The author states that his intent is to provide ARB the  
            discretion to determine these program elements.

            In addition to the dearth of detail, if bill were to move  
            forward, it would need a series of amendments to achieve the  
            author's goal.  Some issues include:

                 Current law requires that AQIP funds be used for  
               emission reductions not otherwise required by law or  
               regulation.  If this bill moves forward, existing law would  
               need to be amended to allow AQIP funds to be used to comply  
               with ARB rules.

                 The background statement prepared by the author  
               emphasizes retrofit projects for small businesses.  Under  
               this bill, however, any project that leads to compliance,  
               including truck replacement, for trucks in any size fleet  
               would be eligible for funding.  To limit this bill to  
               provide funding only for retrofit devices for trucks in  
               small fleets (fleets with three or fewer trucks), the  
               author or committee may wish to amend the bill specifying  
               these parameters.





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           5.Urgency clause  .  This bill contains an urgency clause.  It is  
            therefore not subject to legislative deadlines and, if passed  
            by the Legislature and signed by the Governor, would go into  
            effect immediately.  Given that the measure is not subject to  
            deadlines, the committee may wish to hold this bill to provide  
            the author more time to work out implementation issues and to  
            explore alternative policies that would assist truck owners in  
            a manner that maximizes the emission reduction benefits of the  
            state's limited financial resources.

           POSITIONS:  (Communicated to the Committee before noon on  
                     Wednesday,                              
                      April 28, 2010)

               SUPPORT:  None received.
          
               OPPOSED:  None received.