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However, only one- third of this reduction was attributed to freight mode shift from trucks to other modes, with the rest being attributed to improved truck freight efficiencies De Jong et al. Although significant public investment in pricing policies, targeted grants, and infrastructure investments aimed at pro- moting freight mode shift has had some impact in Europe, the full extent of benefits generated remains uncertain, and it is unclear whether similar benefits could have been attained at a lower cost through other means U.

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GAO, a. Mode shift over the ocean is usually between air and ocean- going vessels. The per ton-mile emissions of marine vessels are typically 2. EPA, b. Thus, significant emissions reduc- tion gains are possible through mode shift from air to marine modes. However, despite the cost competitiveness and com- parative environmental sustainability of marine shipping, the scope of mode shift from air to ocean carrier tends to be lim- ited given the requirements of just-in-time delivery schedules for certain products. Further, the emissions penalties associ- ated with shifts from marine to air cargo are significant.

There- fore, regulations that adversely affect the speed, reliability, and cost of marine shipping, resulting either in mode shift from marine vessel to air, or the diversion of marine cargo to ports with poorer or no rail connections, could risk signifi- cant overall increases in GHG emissions for that particular journey. Note that the research did uncover specific instances of this occurrence.

Truck Time and Weight Restrictions in Urban Areas Delivery time and weight restrictions in urban areas intended to reduce congestion and improve urban amenity have been shown to result in the need for additional trips, causing envi- ronmental and financial impacts Allen and Browne, Such restrictions can increase total time traveled due to the need for a greater number of vehicle trips using lighter vehi- cles. Environmental impacts worsen as a result of increases in total miles traveled Anderson, Research has found that social benefits such as reduced noise, vibration, and road accidents that accrue from time and weight restrictions tend to occur at the expense of environmental performance Quak and de Koster, However, in some cases, international agencies are slow or unable to reach agreement on emissions.

For example, the IMO has, to date, been unable to reach agreement on the regulation of international maritime GHG emissions. A myriad of locally or regionally defined emissions regulations can add significantly to administrative requirements and can result in increased costs for global carriers. This was applied without the prior agreement of the affected countries or airlines, and resulted in significant opposition from ICAO member countries.

Despite industry assertions to the contrary, studies esti- mate that the EU aviation ETS will not constrain growth in the U. This could increase the GHG intensity of passenger air travel, although in the absence of further study, the extent of this impact is unclear. There is also some concern that the EU aviation ETS may undermine the competitiveness of prod- ucts derived from outside the EU, because the costs of trans- port will increase and producers will have limited ability to pass on these costs.

Producers contend that this may, in some cases, unfairly prejudice products whose carbon footprint may actually be less than that of equivalent European prod- ucts New Zealand Productivity Commission, Notwithstanding the challenges that locally defined emis- sions regulations can pose for international carriers that are required to deal with administrative and technology require- ments that vary by jurisdiction, there are indications that the application of emissions regulations in one region can result in willingness on the part of carriers to engage in voluntary changes in other locations.

For example, regulations requiring a switch to lower sulfur fuels in certain areas e. Tractors and trailers subject to this regulation must either use EPA SmartWay-certified tractors and trailers, or retrofit their existing fleet with SmartWay- verified technologies, including trailer skirts. Consultation with industry revealed concerns that the necessary invest- ments in trailer skirts do not yield commensurate benefits in California where the Motor Vehicle Code prohibits a truck from exceeding 55 mph.

Fuel efficiency benefits of trailer skirts are only realized at 50 mph, with optimal bene- fits gained at speeds of 65 mph. For example, a large national truckload carrier interviewed by the research team consid- ered the California trailer skirts regulation to be the result of good intentions combined with poor understanding of local operating conditions. This carrier cites the following three issues: 1.

Carriers generally run three trailers per tractor, using a drop-trailer system. Yet the benefit only accrues to the one trailer being towed. The skirt is most effective at high speeds, as noted. At 55 mph the speed limit for trucks in California , there is little aerodynamic benefit. The carrier also cited the reporting and administrative requirements associated with this regulation as being time consuming for the private sector.

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Concerns about the impacts of these requirements on inter- state commerce have been voiced, particularly as the regula- tion places cost and administrative obligations on interstate fleets that often do not know in advance which equipment will be used in a particular region on a given day. Many carri- ers contend that the regulation potentially curtails flexibility and efficiency as they may be required to shift loads to dif- ferent vehicles to meet regulatory requirements when trav- eling between different states.

Concerns were expressed that trailer skirts present safety risks, because they can be dam- aged during situations such as while crossing railroad tracks and driveways, and during loading and unloading. Drivers face a liability risk of damaged devices detaching from the trailer while driving.

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Others contend that the operation of aerodynamic side-skirts under treacherous weather condi- tions could compromise device safety and result in failure at high speeds Tata, One carrier interviewed stated that this and other regulations cause them to try to avoid Califor- nia altogether, although the research found no evidence that this is occurring on a widespread basis. At-Berth Ocean-Going Vessels Regulation California has mandated that ocean-going vessels plug in to the electric grid or use an equivalent emissions-reduction option while docked at California ports, rather than using onboard auxiliary engines.

It offers the added benefit of reduced CO2 emissions. The regulation applies to container fleets making. This onboard infrastructure is only usable when vessels are docked at ports equipped with shore power facilities. In the future, if the adoption of shore power becomes more widespread with other ports providing at-berth shore power infrastructure, shipping lines will have more opportunities to plug in during port calls, thereby improving their return on investment over time, as well as their flexibility to rotate vessels.

However, as is generally the case in global transporta- tion, the adoption of international standards is essential to ensuring full compatibility, and wider adoption and cost- effectiveness of the technology, and it will likely take some time for ports to become shore-power enabled. The reaction to this regulation on the part of ocean carri- ers is driven by concerns about the high capital costs, associ- ated with shore power technology combined with the lack of technological alternatives and perceived lack of flexibility in the regulation.

For example, APL supports seawater scrub- ber technology, arguing that this technology is effective in emissions reduction and is cheaper than shore power. The At Berth Ocean-Going Vessels Regulation permits operators the use of alternative emission-control strategies, provided the requisite emissions reductions can be obtained. The regulations also place limitations on carriers changing from cold ironing to an alternative technology.

Ocean carriers are required to choose the equivalent emissions reduction EER approach early in the program, and may not switch from cold ironing to EER APL, , pers. Nevertheless, ocean carriers are reportedly adopting inno- vative approaches to the adoption of shore power technology. This cost is based upon placing the necessary shore power equipment transformer, switchgear, and associated controls in a container at the berth. This container can then be placed on each ship equipped to use shore power, and the necessary equipment can be moved from ship to ship on an as-needed basis instead of fully retrofitting each ship.

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It is, at present, too soon to assess whether the shore power regulation in combi- nation with other regulations has had unintended impacts in terms of the diversion of cargo away from Californian ports as a result of higher costs, and whether these costs outweigh the benefits of shipping via California.

Ocean-Going Vessel At-Sea Low-Sulfur Marine Fuel Requirements Several ocean carriers interviewed expressed concern about overlapping regulation that applies to the use of low-sulfur marine fuel, particularly in California. In their Initial Statement of. Despite these air quality benefits, international ocean carri- ers like APL are concerned about having to use three different types of fuel during a single voyage requiring separate fuel stor- age, crew time, and recordkeeping APL, , pers.

CARB has acknowledged that uniform national and international regulation is preferable to individual state regu- lation, and the Low-Sulfur Marine Fuel Regulations include a sunset clause that provides for the termination of this regulation once CARB determines the federal government has adopted, and is enforcing, requirements that will achieve equivalent emission reductions in California. Efforts to Address Port Operational Practices State legislation aimed at addressing emissions can be slow to take effect and may not always address issues in the most responsive manner.

For example, of the 17 bills aimed at regu- lating port operating practices put before the California state legislature since , only 3 have passed Giuliano, AB, introduced in , focused on changing dock oper- ational practices at the Ports of Los Angeles and Long Beach in order to reduce truck emissions in the vicinity of the ports.

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Marine terminal operators MTOs were required to pay fees for trucks idling more than 30 minutes at terminal gates, or could avoid fees by extending operating hours or offering gate appointments for trucks dropping off or picking up contain- ers. No terminals opted to extend gate hours due to the costs involved , with most implementing an appointment system. However, surveys indicate that drayage operators made few appointments, and that the appointment system was being used to achieve compliance and avoid fines, rather than to promote efficiencies.

There was also no evidence that appoint- ments generated time savings for carriers, and the measure proved difficult to enforce Giuliano, Revenues are returned to the MTOs to cover the costs of extended hours of operation. It has resulted in redistribution of heavy truck traffic from the midday peak period, shifting it to nighttime Giuliano, The shift also enabled growth in container activity to be accommodated without adverse impacts on CAP emissions. Nevertheless, the program has had some unintended con- sequences, with those in weaker positions finding themselves somewhat disadvantaged.

For example, drayage operators are now required to work nights with no change in pay, and no evident improvement in turn times. Distribution centers, warehouses, and exporters are required to modify their oper- ations e. Further downsides include increased nighttime truck traffic and noise in local communities Giuliano, One shipper with which the research team spoke urged regula- tors to review regulations that in their perception restrict com- panies in their ability to implement sustainability innovations.

On the other hand, several interviewees criticized well-intended regulations for overestimating the available technology. Rail operators, for example, express frustration about the lack of available technology to meet new EPA Tier 4 locomo- tive emission standards. The Tier 3 standard is already effective. The Tier 4 standard applies to newly built engines and is based on the application of high-efficiency catalytic after-treatment technology ECOpoint Inc.

According to the railroad industry, Tier 4 technologies are not yet commercially avail- able, even though they are mandated for introduction by Currently, the only way to meet these pollutant emis- sions standards is through processes that increase locomotive fuel consumption.

Thus, although this federal policy seeks to improve air quality, the practical effect will be to increase GHG emissions, effectively conferring a local benefit but applying a global cost.

Rail sources indicate these regulations. It is recognized that in some cases, the private sector has been known to overstate the adverse impacts of regulation on their ability to do business, and that comments should not always be taken at face value. Nevertheless, the research team did come across instances where private-sector interviewees identified specific regulations as being particularly restric- tive.

At one extreme, a motor carrier and one of the shippers interviewed stated that they would prefer to avoid operat- ing in California if they could, due to the tougher environ- mental regulations in the state. A manufacturer stated that Californian air and water emissions regulations have led them to minimize the number of plants in the state.

Were other states to follow the Californian regulatory example, several interviewees claim that doing business would become more difficult. Some carriers claimed that they might have to signif- icantly alter their operations and ultimately become less sus- tainable in the process e. Several interviewees mentioned particular triggers or breakpoints that could result in major changes to their operations, rang- ing from equipment deployment decisions to port gateway selection.

Despite these claims the research team did not uncover any quantitative evidence through the literature or interviews that such shifts in the location of business or cargo routing had actually occurred to the extent that this is having an impact on CO2 emissions. An ocean shipping industry association expressed the view that environmental requirements in certain states e. In general, according to this view, states should not be involved in decisions affecting the inter- national shipping arena.

In this view, as sustainability issues increasingly come to the fore, such conflicts are becoming more common. A motor carrier claimed that the combination of reduced highway infrastructure investment and curtailed hours of service for drivers which require more vehicles on the high- way to deliver the same level of service has an adverse impact on economic efficiency and freight emissions.

This carrier supports the regulatory change to permit the use of doubles, triples, and other alternative truck configurations to improve efficiency and cut emissions. In the view of this carrier, this solution could make better use of existing infrastructure and potentially removes trucks from the highway. The role of public agencies, in the industry view, should either be to improve the capacity of freight corridors or allow carriers to operate more efficiently on existing highways.

It is not only air quality and GHG regulations that are of concern. For example, a container shipping line cited changes in ballast water regulations would require them to shift their operations and strategies. Several carriers and shippers referred to the high cost of fuel as a potential future breakpoint, driving them to switch to alternative fuels, as well as to improve optimization and efficiency.


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However, other stakeholders told the research team that they do not have a specific regulatory breakpoint in mind because their supply chain networks are fairly balanced and large scale in nature and are unlikely to change significantly. Lack of Evidence Regarding Shifting Coastal Cargo Shares Due to Local Regulatory Actions In the United States, one of the major potential unintended consequences of local regulatory action could be the shifting of transportation activity between nodes and corridors.

That is, although federal environmental regulations would be expected to affect all regions equally, stricter state or local regulations could impact supply chains passing through multiple regions. One of the oft-cited examples of the potential for such dis- ruption to established supply chains relates to stricter air and water quality requirements on the West Coast, California in particular, than in other parts of the country.