Comment Log Display

Ariel Fideldy, Manager
Austin Hicks, Air Pollution Specialist
California Air Resources Board 
1001 I Street
Sacramento, California 95814 
(electronic submittal at
https://ww2.arb.ca.gov/applications/public-comments#COMM2
California Air Resources Board)
 
Subject:  Comments Submittal RE
2022 State Strategy for the State Implementation Plan January 31,
2022
 
I appreciate the great work by the CARB and
request your consideration of the Revision Recommendations and
Suggestions below.
 
Revision Recommendations
 
1.     Please
include in Appendix A Economic Analysis or elsewhere
the estimation/projection of potential economic gain that would
likely result from implementation of advanced technologies beyond
considering only the costs and costs savings associated with the
respective Strategy measures.  The design, development,
procurement, distribution, and implementation of new technologies
likely results in economic gain for profit-motivated entities
involved in technology advancements.  For example,
transition to zero emission equipment represents opportunities for
significant employment gains and return on investment in all phases
of the transition from design through certification and
operation.
 
2.     Please
consider the disincentivizing of natural gas heavy duty trucks due
to the continued release of methane associated with natural gas
production, transport, storage, and use.  The ARB is well
familiar with the harmful climate effects of methane (more than 80
times more potent than carbon) and of the increasing damage from
climate change compared to the potential reduction in NOx that
might be gained with the transition from diesel to natural gas in
heavy duty trucks.
 
3.     Please
consider limiting further regulatory actions for Ocean Going
Vessels only to those intended to achieve zero emission by 2030 and
the specific mitigations to reduce at-anchor emissions in the
immediate term.  The CARB is appreciated for both
the Vessel Clean Fuel Regulation and the At Berth
Regulation and, as ships are the greatest source of
pollution from port operations, the two CARB OGV regulations
resulted in the greatest reduction in Port emissions of all actions
to date.  I thank the CARB and recognize that recent and
key environmental declarations compel the CARB to continue the OGV
emission reduction success in partnership with others as very
significant cooperative opportunities now exist.  
The October 2021 US commitment to the
Clydebank Declaration (six zero emission corridors by mid-decade),
the November 2021 City of Los Angeles Resolution calling for the
transition to 100% Zero Emission shipping at the Port of Los
Angeles by 2030, and the January 2022 C40 Cities (including Ports
of Los Angeles and Shanghai) requiring low, ultra-low, and zero
carbon fueled ships through the 2020s with zero carbon
trans-Pacific container ships by 2030 are critically significant
actions that compel the CARB to quickly define the plan to help
achieve zero emission shipping by 2030.  
Of great urgency and importance, I ask that
the CARB participate in the C40 Cities meetings in process to
define their plan due by year end 2022 to achieve Zero Emission
shipping by 2030.
4.     The
evaluation of new OGV technologies in development must be largely
focused on those that achieve zero emission as batteries and fuel
cells and the evaluation of cleaner fuels must be focused on those
derived from 100% renewable sources as hydro, solar, and wind
(e.g., hydrogen produced through solar).
Suggestions
 
·      I
strongly encourage the Strategy of advocacy and “call to
action” by the federal government (reference Figure 5) for
key reasons including the encouragement of more standardized,
national approaches (both procedures and equipment), leveling of
competitive interests across the US, and to more likely ensure the
success of ARB measures in light of potential resistance from
entities that might claim federal preemption or other efforts to
undermine regulatory action.
·      I
ask that the CARB proceed urgently with our US Executive
Administration to advocate that the US EPA enable state leadership on
zero-emission trucks by prioritizing federal grants toward
zero-emission technology and associated
infrastructure. 
·      Please
also proceed with great urgency as planned in Chapter 5,
Zero-Emission Trucks measure, to support local zero-emission zones
and/or differentiated registration fees (higher rates for dirtier
trucks while zero-emission trucks receive consistent source of
incentive funding) and to phase in the registration requirements
defined in Chapter 5 applicable to Drayage
trucks. 
·      Please
proceed with great urgency in implementation and encouragement of
market signal tools to drive the transition to zero-emissions zones
as soon as possible and by 2035.
·      Please advocate in the
immediate term at the federal and international levels to achieve
additional emissions reductions from OGVs.
·      Please ensure the
timeliness of the Vessels at Anchor Evaluation and delivery of the
public report by December 1, 2022. 
·      Please pursue
regulatory measures to achieve further emissions reductions from
OGVs such as cleaner technologies than those required by US EPA and
the IMO and that are consistent with the goal to achieve Zero
Emission shipping by 2030.
Thank you,
 
 
Richard Havenick
3641 South Parker Street
San Pedro CA 90731

310 832 8070;
havenick@cox.net