In May, the Environmental Protection Agency (EPA) published a request for information (RFI) about how the agency can best develop funding programs to support the build-out of zero-emission energy and transportation infrastructure at ports.
The 2022 Inflation Reduction Act (IRA) provides $4 billion to the EPA to develop grant and rebate funding programs to reduce greenhouse gases and improve air quality. There are two focuses: a $1 billion Clean Heavy-Duty Vehicles Program and the $3 billion Grants to Reduce Air Pollution at Ports.
Funds go to eligible recipients, with the money not dependent on annual federal budget cycles.
The EPA’s RFI lists a number of priority concerns, including:
- The availability, market price and performance of zero-emission trucks.
- Zero-emission port equipment, electric charging and other fueling infrastructure needs for zero-emission technologies in the near term, i.e., 1-3 years for trucks and vehicles and 1-5 years for port equipment, and:
- Whether the system components are manufactured in the U.S.
Future programs would be shaped by a mix of policy issues. With federal funds, for example, the Build America Buy America Act requires that iron, steel, manufactured products and construction materials used in infrastructure are produced in the U.S.
Waivers can be granted but that’s not an easy process and depends on many factors, including the price and availability of domestically sourced materials and products.
The EPA’s RFI asks numerous specific questions within five broad areas:
- Technology availability and market readiness. The focus is on zero-emission, heavy-duty trucks, up to Class 8 trucks greater than 33,000 pounds that can be used at seaports.
- Performance, including reliability and durability and how zero-emission equipment compares to diesel counterparts.
- Domestic materials sourcing and manufacturing.
- Other practical considerations, such as equipment implementation and related issues of training, maintenance and facility modifications, as well as the availability of hydrogen from different zero-emission sources.
- California and West Coast port and industry officials were among 96 groups and individuals that replied to the RFI. Their responses cover an extensive set of issues.
The following is a summary of some of the replies sent to EPA. All replies are available at https://www.regulations.gov/docket/EPA-HQ-OAR-2023-0216/comments.
Port of Los Angeles
The Port of Los Angeles’ comments are extensive and reference EPA’s inquiry about “other areas of consideration,” in this case, workforce challenges. POLA writes that “the deployment of (zero-emission equipment) will require a reskilling and upskilling of the relevant workforce. The challenges arise from the various types of workforce that utilize the equipment and trucks.”
POLA describes the status and role of the International Longshore and Warehouse Union and the Pacific Maritime Association, which POLA describes as “a multi-employer association made up of the various terminal operators and other companies in the maritime shipping industry.”
Port employees operate under a collective bargaining agreement that includes wages and training. New training, the port explained, would be conducted under the collective bargaining agreement. The port wrote that “the challenge for this workforce is to make sure that workers receive state-of-the-art training in a safe environment on how to use and maintain zero emission cargo handling equipment.”
The port also commented that zero-emission vehicles and technology will cause changes to the location of the port’s workforce because the companies and workers that make up this new energy sector are more geographically spread out and operate under different types of business models.
Therefore, the POLA advises EPA that “training a more separated workforce is going to require greater coordination across the region with employers, workers, academic institutions and state and local workforce development boards.”
Of the 1,200 companies registered in the San Pedro Bay drayage truck registry, 40% use five trucks or fewer. The port advises that in addition to subsidies for zero-emissions purchases, a prospective grant program should also make funding available to employers who want to partner with a port authority and academic institutions to provide training to their workforce on how to operate and maintain battery, electric or hydrogen fuel cell trucks.
Port of Long Beach
The Port of Long Beach’s comments included letting private entities qualify for funding.
“Public entities such as the port are resource limited,” the POLB wrote, “and cannot feasibly create access for terminal operators and other private entities to all of the state and federal incentive programs that are only eligible to public entities.”
A larger pool of eligible recipients could speed up new investments in a host of projects, from zero-emission cargo equipment to charging and fueling infrastructure for trucks to shore power deployments.
STAX Engineering, a company based in Long Beach, suggests that the EPA expand the zero-emission concept to include emission-capture technology, of particular importance for vessels at berth, many of which need to keep generating their own power, usually via oil or gas.
STAX supplies capture equipment on barges and is working on new CO2 capture technologies.
The California Association of Port Authorities (CAPA) said that funds are critical to projects, citing its work to electrify the Port of San Francisco waterfront and downtown ferry terminal. The project, according to CAPA, will require three times as much power compared to the current load.
“EPA funding programs are critical to the ports reaching these goals,” CAPA wrote, referencing funding needed by the San Pedro Bay ports. “We encourage the EPA to move swiftly given the urgent need to reduce the carbon footprint of our ports and protect the surrounding communities.”
NW Seaport Alliance
The Northwest Seaport Alliance’s comments cover shore power, drayage trucks and cargo handling equipment, assessing related issues of technology, cost, domestic materials and performance.
The NWSA notes that while shore power has been in use for over a decade, project costs are a major barrier for implementation.
“Our latest estimates,” NWSA wrote, “are that installing shore power at a single container berth costs between $8 and $15 million.”
The Seaport Alliance asks that a minimum of 50% of total project costs are covered by federal funds. Cost savings, which are relatively small, are realized by the vessel operator, not the port.
“Additionally,” NWSA commented, “labor arrangements to perform the shore power connection and disconnection are needed and generally will require additional negotiation.”
NWSA recommendations include:
- Allowing utility grid upgrades to be included as part of grant-eligible projects.
- Maximizing the use of waivers for Buy America and domestic preference requirements, likely to be a barrier to implementing port projects.
- Performing targeted outreach to original equipment manufacturers to help inform waiver policies and decisions.
Design and manufacturing company BorgWarner, which has two offices in Oregon and one in San Diego, suggests focusing on direct current fast chargers (DCFCs) to meet fleet operational requirements. This focus would send a clear signal to electric utilities regarding related investments, the company said.
BorgWarner advises against an open, unrestricted waiver policy. In its comments, which were extensively on hydrogen’s potential, the company suggests that if officials included “H2ICE (internal combustion engines) in its clean transportation strategy, the EPA would help create demand to nurture and grow the developing hydrogen fuel market.”
“A vehicle powered by H2ICE,” the company stated, “will produce significantly less CO2 than natural occurring processes like a human breathing (1kg per day of CO2 for average human) or decaying plants (plants release half the CO2 they absorb in total life).”
The American Trucking Associations’ comments were submitted with three other trucking groups, including the California Trucking Association.
“Insufficient charging infrastructure is a direct and significant barrier to ZEV adoption in drayage operations,” they stated. “Drayage carriers consistently encounter substantial delays in permitting, approving and installing charging stations.”
The truckers reference future bottlenecks, citing a California utility’s request to abandon car charger investments in response to ratepayer concerns.
Regarding performance, the truckers cite the need for dependable long-haul power, particularly with perishable products like agriculture. Battery weight is also an issue. Because of problems with duty cycles and charging capacity, Class 8 BEV (battery electric vehicle) performance does not match conventional trucks, ATA writes.
The truckers ask that next steps are linked to an achievable timeline, and called on the EPA to “help fleets reduce the financial burden of acquiring heavy-duty vehicles and equipment.”
Forum Mobility, Inc., headquartered in Oakland, operates a range of heavy-duty charging infrastructure and buys and leases Class 8 BEVs. Its operations are sited at brownfield locations near ports and along shipping routes.
The company estimates that about 2,400 medium and heavy-duty chargers would have to be installed annually to serve California’s 30,000 drayage BEVs by 2035. That deployment would require about 1,650 acres of land. Electric load will increase to over 5,000 megawatts of new demand—two times the amount of power produced by the Diablo Canyon nuclear plant.
Forum writes that its service models offer trucking companies “a complete turn-key product,” one with the flexibility to source truckers’ own BEVs with access to cost-effective, long-term, and reliable charging.
This approach “greatly simplifies the transition from diesel to electric.” However, Forum also told EPA that public funding is necessary to be able to reduce upfront costs and accelerate adoption of BEV technology for trucks and cargo equipment.
The EPA was asked in an email about an approximate timeline to complete its port guidance project. As of this summer, an agency spokesperson said they were still reviewing all comments, but did not say when the project might move forward.
Tom Ewing is a freelance writer specializing in energy, environmental and related regulatory issues.