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39 Table 4-3. Estimate of ECA cost. ments may be concerned about pavement damage caused by ECA Distance from Coast heavy trucks. Such policies have recently become more Sulfur Content 100 nautical miles 200 nautical miles widespread at the state level, with both New Jersey and New 0.5 percent $94 million $180 million York adopting rules confining line-haul truck movements 1.5 percent $73 million $140 million to certain main roads. New Jersey's rule designates the Na- tional Network as the roads to be used for line-haul move- Source: Wang, Chengfen and James J. Corbett, University of Delaware, A Preliminary Estimation of Costs and Benefits for Reducing Sulfur ments and a New Jersey Access Network to be used until a Emissions from Cargo Ships in the U.S. West Coastal Waters, prepared for truck reaches the appropriate local roads for getting to a ship- 2007 TRB Annual Meeting (TRB 07-302). per or receiver.45 The New York State DOT's (NYSDOT's) regulation designates certain highways, Interstates, and other main inter-city routes for line-haul movement and an ECA in U.S. waters only, or in U.S. and Canadian waters, but access network for getting to, or close to, pickup and deliv- not in those of Mexico. These officials suggested that a na- ery points.46 Other states, including Maryland, Virginia, and tionwide or, better yet, a continent-wide, ECA would keep Oregon, have implemented truck routing restriction rules the playing field level among North American ports. These that vary in their scope. initial concerns were likely instrumental in the decision to propose an ECA for all U.S. coasts. Shippers have been supportive of international regulation Policy Impacts of oceangoing vessels. For example, the Pacific Merchant These rules force truckers, at least in some instances, to use Shipping Association (PMSA) and the World Shipping Coun- routes other than those they would have chosen. To the degree cil endorsed the October 2008 amendments to Annex VI. this is the case, these rules impose costs in terms of operating This support seems to stem from a desire for uniform regu- costs and transit time, if not in other ways. The research team's lation. Such a desire helps explain PMSA's opposition to a re- interviews with trucking firms suggest that a requirement to cently proposed California regulation that would require stay on major highways for through travel is not viewed as too oceangoing vessels to use low-sulfur fuel when traveling within onerous, provided the requirement does not force them to run 24 nautical miles of the state.43 on toll roads. Trucking executives emphasized, however, that there Unexpected Impacts were frequently major problems with the access routes they were required to use and, beyond that, with local restric- Because an ECA has not yet been established in the United tions affecting the roads, or types of equipment, that could States, it is not possible to assess the degree to which impacts be used to reach facilities of shippers and receivers. It was are unexpected. The IMO requires that extensive analysis and these rules, they said, that imposed the greatest costs and documentation accompany a country's ECA application. Ac- operating problems. Several industry experts observed that, cordingly, EPA has already begun to estimate the economic if rules on local roads and access roads became too restric- impacts of an ECA designation.44 The analyses done thus far tive for 18-wheelers, distribution centers and LTL terminals do not appear to estimate the diversion of cargo activity that would have to move out of the state, with local service pro- could result from designation of a North American ECA. vided by straight trucks. The effect of this would be higher costs of doing business for a wide range of businesses and a State Truck Route Restrictions negative economic-development effect from the departure of the terminals and warehouses. Policy Description Local governments often discourage heavy trucks from Unexpected Impacts traveling on their roads because of concerns about noise, emissions, and safety impacts of trucks. In addition, govern- The negative impacts of these policies generally are not un- expected. When state and local officials restrict heavy-truck movement, they certainly know that there will be a negative 43John McLaurin, President, Pacific Merchant Shipping Association, comment effect on the trucking industry. Trucking-industry represen- submitted to CARB regarding its Proposed Regulation Order Airborne Toxic Con- tatives and lobbyists will have made that case. But this, of trol Measure for Fuel Sulfur and Other Operational Requirements for Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline, July 23, 2008. 44For example, see U.S. EPA, Global Trade and Fuels Assessment Future Trends 45 NJDOT, Truck Access: Adopted Repeal and New Rules [N.J.A.C. 16:32]. and Effects of Requiring Clean Fuels in the Marine Sector, November 2008. 46 See NYSDOT, https://www.nysdot.gov/programs/truckpolicy