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35 Trucking Associations (ATA) and state trucking associa- standardize state idling laws may help remedy this situation tions, do not object to reasonable idling laws. With high fuel in the near future. prices and corporate environmental initiatives, many large carriers have similar internal policies to discourage long- term idling. Restrictions on Port Drayage Trucks CARB performed a cost-benefit analysis when developing Policy Description the state's idling regulation.31 CARB estimated that the truck- ing industry would experience a net benefit from the law, Trucks serving ports can be a significant source of air pollu- with fuel savings offsetting the cost of APU installation within tant emissions, in part because they tend to be older and higher 5 years. The total statewide cost savings estimated by CARB polluting than long-haul trucks. As part of a joint effort to re- was nearly $500 million for the period 20052009, and an ad- duce air pollutant emissions related to their operations, the ditional $100 million for the period 20102013. Ports of Los Angeles and Long Beach have recently launched The major trucking industry objection to idling laws comes the Clean Truck Program. The goal of this program is to reduce from the inconsistencies in laws among different jurisdictions. emissions from drayage trucks by 80 percent by 2012. This pro- gram is just one component of the San Pedro Bay Ports Clean This is particularly true at the city level, where some cities have Air Action Plan, which the two ports adopted in November imposed very strict idling limits or "no idle zones" in delivery 2006. The Clean Truck Program is designed to replace the old- areas. Carriers report that they can have difficulty complying est and dirtiest of the roughly 16,000 to 18,000 trucks that visit with laws when each state and city has a different time limit and the ports regularly and retrofit others with pollution-control set of exemptions. The net impact on the trucking industry of equipment. The program is being phased in over 4 years and the differing laws is likely minimal, however, serving more as will ultimately affect most trucks that serve the ports. an annoyance than a significant cost impact. CARB has also enacted a statewide regulation to reduce UP and BNSF voluntarily entered into the California emissions from drayage trucks that operate at California's agreement and both report that it has not been burdensome ports and intermodal railyards. This rule, which went into ef- to them. There have been no significant impacts on opera- fect in December 2008, is very similar to the drayage restric- tional efficiency. The cost of installing idling reduction de- tions in the ports' Clean Truck Program, albeit with a slightly vices has been minimal and is soon recovered through fuel longer implementation timeline. savings. As a consequence, the railroads are voluntarily apply- To help the owners of drayage trucks (mostly owner- ing similar practices outside of California. Some argue that operators) purchase new trucks or retrofit their existing the railroads would benefit by more aggressive adoption of trucks, the ports are providing $1.7 billion in leases, loans, idle-reduction technologies and practices, particularly in the and grants. To generate funding, the ports have adopted fees eastern United States. of $35 per 20-foot-equivalent unit on loaded containers en- tering or leaving the ports by drayage truck. The state of Cal- ifornia is providing an additional $400 million to help finance Unexpected Impacts retrofits and replacements. Even with this assistance, how- The impacts of idling restrictions are not unexpected. State ever, vehicle owners will be asked to shoulder 20 to 50 percent agencies that have adopted idling limits are probably aware of the cost of the new vehicle or retrofit.32 that truck owners may be compelled to install idle-reduction The Clean Truck Program also includes non-environmental devices. State agencies also likely believe that trucking com- provisions, some of which aim to reshape significantly the panies benefit from reduced idling in the long run, which is structure of the drayage market. These provisions have gen- supported by the fact that large carriers and trucking associ- erated strong opposition from the motor-carrier industry and ations typically support reasonable state idling laws. some Federal agencies. These provisions are included in con- The team's research suggests that many state and local gov- cession agreements that the ports are requiring carriers to sign ernments are not aware of the inconsistencies in regulations to continue servicing the ports. The most controversial provi- across jurisdictions. There is little evidence that states and sion requires carriers to switch from using owner-operators to cities have attempted to harmonize their idling laws with using employee drivers. Currently, drayage is handled prima- their neighbors. Again, the impacts of inconsistent regula- rily by independent owner-operators who contract with tion, by itself, are probably not significant. EPA's efforts to 32The Ports of Los Angeles and Long Beach Clean Truck Program, "Program An- 31 CARB, Staff Report: Initial Statement of Reasons for Proposed Rulemaking, Air- nouncement #SPBP-PA002: Availability of Truck Replacement Funds Under the borne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Goods Movement Emissions Reduction Program, Fiscal Year 200708," Octo- Idling, July 2004. ber 20, 2008.