Comment Log Display

We are writing to provide comments on the proposed updates to the
Proposition 1B: Goods Movement Emissions Reduction Program
Guidelines (Program Guidelines). While we support the intent of the
Air Resources Board (ARB) staff to make this program more effective
for local agencies, we are submitting comments on some issues that
would put projects in the San Diego region at a disadvantage.

Administering truck funds as a single category
The proposed modifications to the category funding targets that
would combine funding for drayage trucks with funding for
non-drayage trucks would be detrimental to trucks serving the Port
of San Diego.  This change would put drayage trucks at a
competitive disadvantage because they can no longer receive credit
(in the form of cost-effectiveness) for particulate matter (PM)
reductions that are now required by the ARB Drayage Truck
Regulation. Although ARB staff is recommending to reserve up to
$100 million to replace drayage trucks that are equipped with PM
retrofits, the conditions on these funds limits the number of
trucks that will be eligible in San Diego. Therefore, we would
expect few drayage trucks to qualify for this reserve funding and
that most of that funding will be spent in other air
districts/trade corridors. 

Allowing Limited Truck Operations Outside of California
Truck activities at the Port of San Diego do not fit the typical
drayage truck model that occurs at ports such as Oakland, Los
Angeles, and Long Beach.  We operate as a "niche port" and deal
with a variety of cargo. As such, our truck population varies
depending on the economy and the type of cargo we receive.   The
original requirement of 100% California operation has been a
significant issue for the Port of San Diego.  Many of the trucks
servicing our port make occasional trips across the border into
Nevada, Arizona, and Mexico, making them ineligible for funding. 
Often, these are independent owner-operators and small fleets that
cannot afford to take advantage of these grants unless they can
retain the ability to take occasional jobs outside of California.
While we appreciate the willingness of ARB staff to allow an option
of 90% California operation, the reduced funding available for this
option and the additional expenses required to verify compliance
are an extra burden. We understand the need to verify compliance,
but feel funding amounts should not be different between 90% and
100% California operation.
  
The Port is committed to reducing air emissions from goods
movement activities in the San Diego region and we appreciate the
opportunity to provide comments on the proposed Program Guidelines.
 

Sincerely,

David Merk
Director, Environmental Services Department
San Diego Unified Port District