By Paul Rosenberg, Senior Editor
In mid-July, the Port of Los Angeles released its draft Zero Emission White Paper, soliciting comments before consideration by POLA’s board, originally scheduled for Aug. 20, but now postponed until September.
“While we’ve made great strides in reducing emissions and greenhouse gas emissions over the last decade, the Port of Los Angeles continues to look for new opportunities to further cut pollutants, especially greenhouse gas,” said Chris Cannon, POLA’s chief sustainability officer and director of environmental management, in a press release. “We think zero emission technology in key operational sectors has strong potential to help us achieve these reductions.”
According to the white paper, POLA “is committed to expanded development and testing of zero emission technologies, identification of new strategic funding opportunities to support these expanded activities, and new planning for long-term infrastructure development.”
In addition, “By 2020, the Harbor Department hopes to have facilitated testing and development of up to 200 additional zero emission vehicles at the Port of Los Angeles, and to have these vehicles evaluated using a standardized testing protocol developed in partnership with a regional stakeholder group.”
But a group of 10 organizations concerned with port pollution, environmental justice and global warming issues drafted a detailed comment letter, not only urging more intensive action, but a whole different framework for moving forward, including a timeline of for achieving 100% zero emissions by 2030.
“Advancing zero emission freight technologies at the Port is one of the most important environmental challenges this Harbor Commission will need to achieve,” Said Earthjustice attorney Adrian Martinez, principal drafter of the letter. “We need a bold, smart vision, and we hope the Harbor Commissioners will direct that when this is presented to the Commission.” As the letter explains:
“The current approach simply takes a stab at what staff thinks is politically feasible and sets targets from there. This paradigm must shift to the following framework. First, the Port should set a goal of zero emission equipment powered by renewable energy port-wide by 2030. Second, staff should explore how to get there for all terminals. For some types of equipment, subsidies may be the strongest options. For others, it may make more sense to do port-wide programs. The plan must include timelines, benchmarks, and other guideposts to be effective. Finally, the plan should include a comprehensive infrastructure planning component”
Other signatories include the Natural Resources Defense Council, Communities for a Better Environment, Coalition for a Safe Environment, San Pedro Peninsula Homeowners Coalition, and East Yards Communities for Environmental Justice. These are many of the same folks who first pushed the ports into the clean air era in the first place, so their perspective carries a good deal of weight.
“The largest port in the nation must recognize that it has the largest obligation to push for this change, plan for this change and implement this change,” said Kathleen Woodfield, who signed the letter as San Pedro Peninsula Homeowners Coalition vice president. “If the port is reluctant to acknowledge this obligation, timelines will continue to be abandoned and rewritten, goals will continue to act as tools for expansion but not change, and community health will continue to be abused by the port’s statements of overriding considerations.”
In addition to calling for a new framework, other major points the letter makes involve considering life cycle emissions for all equipment; considering a wider range of means to push zero-emission technology, including the use of port-wide tariffs and leases; developing turnover plans where zero emission technologies are now available, and having more frequent board updates (every six months rather than yearly), as well as “a stakeholder process that includes ample representation from community groups and environmental groups.”
The letter also suggests considering the hiring of an outside consultant to aid in the project, and recommends developing a robust legislative and regulatory priority list and committing resources to push for them.
“The port needs to move into the driver’s seat by lobbying for zero emissions regulation both on a state and national level and stop using the lack of such regulation as an excuse for inaction,” Woodfield added.
“Overall, we are deeply supportive,” the letter read. “We fully endorse the White Paper’s conclusion that ‘zero emission container movement technologies show great promise for helping to reduce criteria pollutant and greenhouse gas emissions in the future.’”
It went on to note that “Transition to zero emission technologies is the now the well established consensus goal across the State,” citing a July 17 executive order by Gov. Jerry Brown, as well as the California Air Resources Board’s “Sustainable Freight” document from April.
Brown’s order directs relevant state entities to “develop an integrated action plan by July 2016 that establishes clear targets to improve freight efficiency, transition to zero-emission technologies, and increase competitiveness of California’s freight system.”
This freshly-declared broad unity of purpose provides hope that, rather than faltering, as has happened in the past, the port can be moved to strengthen its efforts to achieve a zero emissions system.
On the plus side, the organizations praised POLA’s broad view of driving concerns:
“We are pleased that the White Paper anchors the discussion of this important modernization effort in three main objectives: 1) reducing toxic health risk from Port operations; 2) reducing harmful criteria pollutant emissions (i.e., NOx, SOx, VOC, PM); and 3) reducing harmful GHG emissions.”
But they expressed deep disappointment that “significant commitments to push zero emission equipment” that were included in POLA’s 2012-2017 Strategic Plan were dropped from the 2014 update. Specifically cited was the dropped commitment to “[i]ncrease zero emission truck trips to and from the Port to 50% including 100% of the trucks to and from the near dock rail yards through the development of an action plan to be completed by 2014.”
They called for both the reinstatement of those interim commitments, along with a longer-term commitment to 100 percent zero emissions by 2030.
Next, they argued that “near-zero” emission technologies shouldn’t be allowed to divert attention from the larger goal. They reject the white paper’s rationale that “health-related benefits are likely attainable on a larger scale, at lower cost, and within a much shorter timeframe” via “near-zero” technologies and therefore are worth prioritizing. They point out that this approach is inconsistent with another assessment in the white paper that, “[e]conomies of scale may eventually lower the prices for zero-emission equipment, but for large-scale production – and the consequent lowering of prices – to occur, a market must develop.”
They continued, “Overall, a two-phase investment approach of moving to non-hybrid, ‘near-zero’ emission equipment now will likely only distract from developing the equipment necessary to ultimately resolve the problems the Port seeks to tackle,” particularly since “There is no technology overlap between non-hybrid combustion technologies and zero-emitting technologies.”
“The white paper should reflect a real sense of urgency and a meaningful plan for moving to zero emissions technology starting now, not sometime in the future,” Woodfield said. “We have outlined opportunities for immediate change that the port should start implementing without hesitation.”