February 28, 2018
In July 2015, the California Air Resources Board (CARB) implemented Governor Jerry Brown’s Executive Order B-32-15. This order directed several agencies to collaborate with stakeholders to develop integrated action plans that would improve the efficiency of the state’s goods movement systems and reduce related emissions. CARB, Caltrans, and the Governor’s Office of Business and Economic Development took the lead on this effort, and prepared the Sustainable Freight Action Plan, commonly referred to as the Action Plan.
In the Action Plan, CARB recommended against the implementation of Indirect Source Rules (ISRs) or facility cap regulations, rightly recognizing that additional study was necessary to ensure that such an action would not undermine the state’s shipping system and industry competitiveness. Instead, the Action Plan called upon CARB to collect data on various aspects of the shipping industry in order to further the development of analytical tools that could improve the industry’s efficiency and productivity, consequently reducing adverse environmental consequences.
Despite the guidance laid out in the Action Plan, in March 2017 the CARB Board asked their staff to consider a process for the development of ISRs or similar alternatives. While CARB’s staff have clarified that this request was a formality, we believe it necessary to reiterate and clarify our stance on ISRs.
On February 28, 2018, the Coalition for Responsible Transportation along with numerous other industry stakeholders submitted a letter to the California Air Resources Board stating that the CARB staff recommendation not to pursue statewide ISRs should be supported.
The implementation of ISRs would be contradictory to the three chief goals of the Action Plan and Governor Jerry Brown’s Executive Order B-32-15: to improve freight efficiency, increase competitiveness, and transition to zero emissions freight transport solutions. ISRs are essentially volume caps which would cripple the development of California’s goods movement industry, disincentivizing the very investments in new facilities and environmental equipment needed to achieve the goals laid out in the Action Plan and Executive Order B-32-15.