BILL ANALYSIS                                                                                                                                                                                                    �



                                                               SB 1507
                                                                       

                      SENATE COMMITTEE ON ENVIRONMENTAL QUALITY
                        Senator S. Joseph Simitian, Chairman
                              2011-2012 Regular Session
                                           
           BILL NO:    SB 1507
           AUTHOR:     Fuller
           AMENDED:    April 25, 2012
           FISCAL:     Yes               HEARING DATE:     May 14, 2012
           URGENCY:    Yes               CONSULTANT:       Peter Cowan
            
           SUBJECT  :    CALIFORNIA GLOBAL WARMING SOLUTIONS ACT: 
                          TRACTOR-TRAILERS:  EXEMPTION
           
            SUMMARY  :    
           
            Existing law  , under the California Global Warming Solutions 
           Act of 2006 (CGWSA):

           1) Requires the California Air Resources Board (ARB) to 
              determine the 1990 statewide greenhouse gas (GHG) emissions 
              level and approve a statewide GHG emissions limit that is 
              equivalent to that level, to be achieved by 2020.  ARB must 
              adopt regulations for reporting and verification of GHG 
              emissions, monitoring and compliance with the program, and 
              achieving GHG emission reductions from sources or 
              categories of sources by January 1, 2011, to be operative 
              on January 1, 2012, subject to certain requirements.  
              (Health and Safety Code �38500 et seq.).

           2) Requires ARB on or before June 30, 2007, to publish and 
              make available a list of discrete early action GHG 
              reduction measures that can be implemented prior to the 
              above measures and limits.  On or before January 1, 2010, 
              ARB must adopt regulations to implement these early action 
              measures, and these regulations must be enforceable no 
              later than January 1, 2010.  (�38560.5).  An early action 
              measure regulation relating to reducing GHG emission from 
              heavy-duty tractors and 53-foot or longer box-type 
              semitrailers (trailers) was effective January 1, 2010 
              (referred to as the heavy-duty vehicle (HDV) regulation).  
              (17 Cal. Code Regs. �95300).

           3) Requires ARB to prepare and approve a scoping plan for 









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              achieving the maximum technologically feasible and 
              cost-effective reductions in GHG emissions from sources or 
              categories of sources of GHGs by 2020.  ARB must evaluate 
              the total potential costs and total potential economic and 
              noneconomic benefits of the plan for reducing GHGs to the 
              state's economy, environment, and public health, using the 
              best economic models, emission estimation techniques, and 
              other scientific methods.  The plan must be updated at 
              least once every five years.  (Health and Safety Code 
              �38561).

           4) Authorizes ARB to adopt GHG emission limits or emission 
              reduction measures prior to January 1, 2011, imposing those 
              limits or measures prior to January 1, 2012, or providing 
              early reduction credit where appropriate.  (�38563).

            This bill  : 

           1) Makes legislative findings relating to the HDV regulation, 
              the economic analysis prepared during the rulemaking, and 
              the assumptions made in calculating the cost, cost-savings, 
              and GHG reductions.

           2) Requires that any rule or regulation applying to owners or 
              drivers of heavy-duty tractors or the 53-foot or longer 
              trailers they pull pursuant to the CGWSA to include 
              exemptions for a tractor-trailer combination:

              a)    That travels within 100 air miles of the 
                 tractor-trailer's base.

              b)    That returns to its base within 48 hours of traveling 
                 outside of the 100-air-mile radius.

           3) Specifies that it is an urgency measure, noting among facts 
              constituting the necessity that the ARB economic analysis 
              assumes trucks travel in excess of the 55 mile per hour 
              speed limit during 84% of their operation.

            COMMENTS  :

            1) Purpose  .  According to the author, SB 1507 "seeks to 
              provide administrative flexibility to owners of truck 









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              trailers subject to the �ARB HDV regulation]. ?Commercial 
              trucks and trailers are very seldom matched with one 
              another for extended periods of time on a 'one to one' 
              basis.  This regulation allows exemptions for tractors that 
              travel under 50,000 miles annually or within a 100 mile 
              radius of a 'local haul terminal.'  Because regulated 
              trailer owners often do not control the truck that picks up 
              their trailer, the current exemption structure is almost 
              impossible to administer? a time-based exemption would be 
              easier to administer because it would not rely on a trailer 
              owner having administrative control over the truck which 
              hauls it."

            2) Background on the Heavy Duty Vehicle (HDV) Regulation  .  The 
              HDV regulation became effective on January 1, 2010 and 
              seeks to improve fuel efficiency, and thus reduce 
              associated GHG emissions, by requiring the use of 
              aerodynamic tractors and trailers that are also equipped 
              with low rolling resistance tires.  The regulation builds 
              upon the voluntary United States Environmental Protection 
              Agency (US EPA) SmartWay (SmartWay) program which certifies 
              tractors and trailers and retrofit technologies that reduce 
              fuel use.  The regulation requires that owners of 53-foot 
              or longer box-type trailers, and owners of the heavy-duty 
              tractors that pull them on California highways replace or 
              retrofit those tractors and trailers with compliant 
              aerodynamic technologies and low rolling resistance tires. 
              Beginning January 1, 2010, new tractors and trailers must 
              be SmartWay certified or retrofit with compliant technology 
              and use low rolling resistant tires.  Beginning January 1, 
              2013, all 2010 and older model year tractors must use 
              verified low rolling resistant tires.  Additionally, 
              trailers are required to have aerodynamic device retrofits 
              by January 1, 2013, or as prescribed by a fleet phase-in 
              plan, with all trailers having low rolling resistance tires 
              and aerodynamic devices by 2019.

              ARB estimates the regulation will reduce statewide GHG 
              emissions by 1 million metric tons (MMT) of CO2 per year by 
              2020 and nationwide emissions by 6.7 MMT CO2.

              Several tractor and truck categories are exempted, such as 
              authorized emergency vehicles, specified drayage tractors, 









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              and solid waste vehicles.  The regulation also exempts 
              tractors and trailers they pull as long as the tractor 
              travels less than 50,000 miles per year.  Local haul 
              tractors and trailers are those traveling within 100 miles 
              of the local haul tractors base and are exempted from the 
              aerodynamic device requirements, but must still have low 
              rolling resistance tires.

              According to the regulation's Initial Statement of Reasons, 
              these and other exemptions reduce the covered vehicle miles 
              traveled (VMT) to approximately 38% of total VMT from heavy 
              duty trucks. 
               
               SB 1507 expands this current local haul exemption by:
            
               a)    Specifying the air miles for the 100-mile radius 
                 rather than ground miles the bill increases the exempted 
                 range to 115-120 miles.  

               b)    Exempting any tractor-trailer combination that 
                 returns to its local haul base within 48 hours of 
                 leaving the 100-air-mile radius would allow trucks to 
                 travel several hundred miles and remain exempt from the 
                 HDV regulation.  
                 
              These exemptions could significantly reduce the amount of 
              covered VMT, and exempt most intrastate and some interstate 
              HDV travel.  

           3) Economic analysis  .  The legislative findings and the 
              urgency provisions of SB 1507 refer to the economic 
              analysis for the HDV regulation which is based, in part, on 
              the fuel saving determined by US EPA in the SmartWay 
              certification and verification process which typically 
              relies on standardized tests of tractors and trailers 
              traveling at approximately 60 miles per hour (mph), above 
              the 55 mph allowed for heavy trucks in California.  The 
              sponsors of SB 1507 note that operators in California would 
              not be able to achieve the fuel efficiencies that ARB 
              calculates without violating the Vehicle Code.  

              At least one US EPA study found reductions in fuel 
              consumption for various combinations of the SmartWay 









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              technologies, including aerodynamic devices alone, under a 
              variety of different operation patterns.  Savings from the 
              use of aerodynamic devices when the tractor-trailer 
              combination did not exceed 50 mph, were negligible.
            
           4) Achieving GHG Reduction Goals  .  Under the CGWSA, ARB is 
              required to develop a scoping plan for achieving the GHG 
              reduction goal established under the act (existing law #3). 
               In its scoping plan ARB anticipates 0.9 MMT CO2 reductions 
              resulting from the HDV regulation due to reduced fuel 
              consumption.  ARB has also established a market-based 
              mechanism under the CGWSA, commonly referred to as 
              cap-and-trade, which will reduce emissions resulting from 
              various sources including, beginning in 2015, 
              transportation fuels.  To the extent that reductions in GHG 
              emissions fall short of the scoping plan estimate, either 
              as a result of overestimation of the savings or due to 
              changes in the HDV regulation, they must be achieved by 
              other means such as new GHG reduction regulations or 
              through the cap-and-trade program.  The requirement of 
              additional GHG reduction through the cap-and-trade 
              mechanism could increase compliance costs for entities 
              covered under that regulation.  
               
           5) Support concerns  . The California Trucking Association 
              (CTA), sponsors of SB 1507, note that the fuel efficiency 
              improvements for aerodynamic devices estimated by ARB are 
              unlikely to be achieved by many trucking companies as they 
              seldom reach speeds used in those estimates.  They also 
              have concerns that a rulemaking would make assumptions 
              about tractor-trailer speeds that presume significant 
              violation of speed limits.  Additionally, CTA expressed 
              concerns that current exemptions in the regulation do not 
              provide the necessary flexibility to fleet managers to 
              dispatch trucks on routes of varying distance.

            6) Outstanding Issues  . Is it appropriate for interests that 
              participated in ARB's regulatory process to now seek 
              statutory exemptions from those regulations?  How will such 
              exemptions affect the need for further reductions from 
              other sectors?  Also, SB 1507 applies the expanded 
              exemption of local haul tractors and trailers not just to 
              requirement for aerodynamic devices, but to any GHG 









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              emission reduction rule or regulation under the CGWSA.
               
           7) Double Referral to Senate Committee on Rules  .  If this 
              measure is approved by this committee, the do pass motion 
              must include the action to re-refer the bill to the Senate 
              Committee on Rules.
            
           SOURCE  :        California Trucking Association
            
           SUPPORT  :       None on file.
            
           OPPOSITION  :    None on file.