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June 11, 2015

California Air Resources Board Remains Extremely Active

The California Air Resources Board (CARB) continues to be one of the most active agencies within California government.

A host of state and federal laws and regulations mandate that California make further progress in reducing greenhouse gas (GHG), nitrous oxide (NOX) and particulate matter (PM) emissions.  These mandated reductions are in addition to the significant and costly emissions reductions that have already been made in our state under the AB 32 mandate.  AB 32 (2006) requires California to reduce its GHG to 1990 levels by 2020.  California is well on its way to reach this target, but more reductions are required to meet the goal.  In fact, the bar was just elevated by Governor Jerry Brown in April.  He issued an executive order establishing a new California GHG target of 40 percent below 1990 levels by 2030.  This order represents the first phase of his ultimate goal of attaining an 80 percent reduction in emissions by 2050.

It is important to note that Cap and Trade and other AB 32 related programs have largely targeted the large GHG emitters, such as power plants and refineries.  However, the need to make additional major emissions reductions provides certainty that California’s smaller emitters and other types of emissions sources will come under increasing scrutiny by both the legislature and CARB to evaluate potential emissions reduction strategies.  WG staff maintains an active presence at CARB to ensure that both the board members and staff have a solid understanding of how agriculture will be impacted by their regulatory decisions.  This understanding is especially important given the challenges our industry is facing with the consequences imposed by the ongoing drought.  Agriculture is recognized by CARB for being a leader in supporting emissions reduction efforts like the Carl Moyer Program, which encourages growers to reduce emissions by obtaining grants to offset part of the cost of purchasing cleaner engines and equipment.  This is a cost-effective and voluntary program that many growers continue to utilize.

CARB is also looking at other aspects of transportation and goods movement.  In April, CARB updated its Sustainable Freight Strategy (SFS), which identifies the goal and pathways for California to reach zero and near-zero emissions within the freight transport system.  The freight system covers trucks, aircraft, ocean vessels and rail.  The SFS is designed to impact seaports, airports, rail yards and lines, distribution centers, warehouses, high traffic roads and border crossings.  WG staff provided testimony at the meeting expressing significant concerns about the likely impacts that the SFS will have on the overall functioning and cost effectiveness of California’s freight system.  This impact is tangible because our members and workers provide half of the nation’s fresh fruits, vegetables and tree nuts and nearly half of America’s fresh organic produce.  This food has to be transported a number of times before it is able to be enjoyed by consumers.  Growers are not price-makers, they are price-takers.  The CARB board members and staff appeared to pay particular notice to the comment that growers are unique in that they are not able to shift increased costs along by increasing food prices.

We are particularly concerned about the following items within the SFS: a proposed facilities emissions cap, a transportation refrigeration units (TRU) phase out, large spark-ignition equipment (forklifts), an opacity limit reduction and the renewable gas standard.  As an illustration, the facilities emissions cap would implement an emissions reduction target for an entire facility.  This is very problematic because agricultural facilities are already complying with numerous air quality regulations and could now be further burdened with overlapping restrictions and costs targeting the same facility and equipment.  Many facilities also operate on a seasonal basis, and the impact that this proposed cap would have on their operation is not clear.  The SFS proposes to target TRUs by developing a regulatory requirement to prohibit the use of fossil-fueled TRUs for cold storage in phases.  Incentives would be utilized to support infrastructure for new technology.  There are many open questions that need to be answered by CARB.  Will the new TRUs be efficient in keeping food safe?  Will they be cost-effective, reliable and easily maintained?  These are but a few of the many concerns that WG staff will be ensuring CARB understands and helps resolve as the SFS continues to be developed and implemented.

WG members are encouraged to learn more about these issues.  We will provide periodic updates and links to proposed rules in “Spotlight,” and of course members are always welcome to contact WG staff ([email protected]) at any time.