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CNGVC Comments on South Coast AQMD Warehouse Indirect Source Rule

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On April 16, the South Coast Air Quality Management District (SCAQMD) staff presented to the Mobile Source Committee their latest Proposed Rule 2305 – Warehouse Indirect Source Rule (PR2305).  This rule is intended to capture area emission sources associated with a warehouse inside the South Coast air basin.  CNGVC members successfully petitioned for the inclusion of near zero yard hostlers on the Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program menu.  However, staff passed on providing more equitable WAIRE points for near zero vehicles, citing that the WAIRE values are based on 3 factors: NOx reductions (90% credit); particulate matter reductions (100%); and cost. 

A consideration of “cost” actually penalizes near zero vehicles given they are more cost-effective than their significantly more expensive zero emission vehicle counterparts.  CNGVC believes the Board should minimize the “cost” value and instead prioritize the value of “emissions reductions” when calculating WAIRE compliance points.  After all, the intention of the PR2305 has always been to deliver significant and meaningful near-term emissions reductions, unlike CARB’s Advanced Clean Truck and Fleet rule that focuses on the transition to zero emission vehicles over the next several decades. 

SCAQMD will consider PR2305 on Friday, May 7, at 9am.  Meeting details are coming and will be available at: http://www.aqmd.gov/home/news-events/meeting-agendas-minutes.  CNGVC will be in attendance to comment on the need to prioritizes significant and near term emissions reductions in the PR2305.


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