Op-Ed: CARB Takes the Wrong Path to Reduced Emissions
The events of the past two years – from a global pandemic to the worst land war in Europe in 80 years – have underscored what has long been true about the tugboat, towboat and barge industry: that we are a critical economic contributor and a steadying, reliable force within the American supply chain. Our industry exists to move our customers’ – and the nation’s – vital commerce safely, securely, and efficiently and as the most environmentally sustainable mode of freight transportation, we are in constant pursuit of innovation to further reduce our impact on the natural environment, from water to air quality. To that end, we are committed to partnering with all stakeholders to achieve meaningful progress in reducing carbon emissions. But as the California Air Resources Board may soon regrettably illustrate, there is a right way and a wrong way to do that.
Barge transportation is the cleanest form of freight transportation in the United States today. One dry cargo barge moves the same amount of cargo as 16 railcars or 70 trucks, and a standard 15-barge tow keeps over a thousand trucks off our already congested highways. Marine transport emits 43 percent less greenhouse gasses than rail, and over 800 percent less than trucks. For shippers that want to substantially reduce their carbon footprint today, switching to marine transport is low-hanging fruit. And companies across the tugboat, towboat and barge industry are developing and deploying technologies that will improve environmental sustainability and reduce emissions even further.
As an industry, we are committed to building on our environmental record and pursuing continuous improvement in the quest for zero harm. But to bring about economically and environmentally sustainable change, government actions that seek to help drive that momentum must support commercial vessel owners in making tangible, achievable progress on emissions, not put companies out of business or stifle innovation and investment in new technologies.
What are the right kinds of policies to get us where we are aiming – and where society justifiably insists – that we go? First, truly effective decarbonization policies will take a holistic, supply chain-driven approach and take into account that the maritime ecosystem is more than just end-user vessels, but also shippers, engine manufacturers, ports and supporting infrastructure. Vessel owners cannot make investments and adopt new requirements in a vacuum. Every part of the maritime supply chain must move together.
The right kinds of policies will also provide reasonable lead time for companies to transition to technologies that substantially decrease carbon emissions while ensuring mariner and vessel safety; support learning and innovation; provide funding opportunities to support needed investment; and reduce regulatory uncertainty and delay. A regulatory framework that allows companies to plan, invest, and implement new (and costly) emission-reduction technologies in an orderly way – allowing vessel owners to use the revenue from well maintained and efficiently operated existing vessels to finance investments in new vessels and new engines using greener technology – will be most conducive to spurring innovation and positive change.
A far less helpful approach would be to embrace policies that force the retirement of properly maintained and economically viable vessels before the end of their useful lives; dictate specific technologies or fuels to be used; create advantages for foreign competitors or other, less efficient modes of freight transportation; or allow a patchwork of inconsistent state and federal laws to develop. Vessel owners are not afraid to embrace aggressive emissions targets, but government policies that ignore technological or economic reality, that fail to ensure mariner and vessel safety, or that attempt to impose “one size fits all” requirements are ultimately doomed to failure.
In what would be a highly unfortunate development for both marine transportation and environmental sustainability, California is poised to adopt the “don’t-do” approach.
This week, CARB is expected to finalize amendments to the Commercial Harbor Craft (CHC) rules that ostensibly aim to reduce engine emissions. The amendments would require companies to spend substantial resources modifying vessel hulls to accommodate Tier 4 engines with massive Diesel Particulate Filters (DPFs). (The U.S. EPA requires Tier 4 engines for newly built vessels only since these engines have significant implications for the size and layout of machinery spaces, vessel stability, and other factors that are best addressed at the time of vessel construction.) Moreover, there are no DPFs on the market for marine applications today, and no DPF that has been certified by the U.S. Coast Guard or engine manufacturers as safe for vessel use. In addition to safety concerns, size and engine space simply make Tier 4-with-DPF installation impossible on many existing vessels.
This unrealistic technology requirement is compounded by an unrealistic compliance timeframe. Compliance is mandatory beginning in 2023 and potential 2-year compliance extensions expire in 2035. For vessel owners to secure extensions, CARB requires evidence that either the vessels cannot be modified or that the owner cannot financially afford to comply. Even if an extension is granted, it expires by 2035 and if the vessel cannot comply, it must be removed from service.
These requirements are especially problematic because CARB developed them using flawed data. To take just one example, CARB counted the number of vessels in the CHC fleet using a Coast Guard database that was not designed to identify a vessel’s area of operations. The result: CARB significantly overestimated the size of the CHC fleet operating in California, along with the contribution of towing vessels to emissions inventories.
Regrettably, despite numerous industry attempts to work with CARB and communicate through constructive, comprehensive comments and testimony the substantial flaws in the agency’s approach – and to suggest a productive and achievable way forward – CARB has rebuffed those efforts, going so far as to suggest that no changes to the proposed rules based on public comments will be forthcoming.
The tugboat, towboat and barge industry is committed to action to address the environmental sustainability challenges of our time and welcomes the opportunity to work collaboratively toward bold and effective solutions. It is dismaying that approaches like CARB’s risk sidelining or crippling an environmental and supply chain leader at a time when our contributions and expertise are most needed.
Jennifer Carpenter is President & CEO of The American Waterways Operators.