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AGENCY TESTIMONY

Explanation of indirect source rule concept

0:30:21

ยท

105 sec

Commissioner Aggarwala explains the concept of an indirect source rule and its potential application to warehouses in New York City to address air pollution from freight movement.

  • Indirect source rule regulates indirect air pollution related to a facility
  • Direct air pollution from warehouses (e.g., heating systems) already regulated by DEP
  • Indirect air pollution comes from trucks attracted to the facility
  • DEP currently does not have a mandate to regulate indirect sources
  • Southern California's 2021 warehouse indirect source rule cited as an example
  • Rule could apply to both new and existing large warehouses
  • Differs from proposed last mile facility zoning special permit, which focuses on new warehouses
Rohit Aggarwala
0:30:21
Understanding these factors is important for designing an indirect source rule because they help us project how the warehousing industry might respond to increasing regulation.
0:30:31
Different warehouses with different ownership models, traffic patterns and performance standards will have different opportunities to become less polluting.
0:30:39
A warehouse indirect source rule is a strong policy tool the city can use to address air pollution from freight movement.
0:30:46
It's neatly at the intersection of the long standing need to green our freight industry and the more recent growth and recognition of the acute impacts in neighborhoods with concentrations of warehouses.
0:30:57
An indirect source rule is just that, a rule that regulates the indirect air pollution related to a facility.
0:31:04
The direct air pollution from a warehouse might come from the building's heating system.
0:31:08
DEP already regulates those.
0:31:10
The indirect air pollution from a warehouse comes from the vans and trucks that are attracted to the facility and therefore the warehouse is indirectly generating the pollution leaving these trucks' tailpipes.
0:31:22
Currently, DEP does not have a mandate to regulate indirect sources.
0:31:28
The most significant indirect source rule in place today is Southern California's twenty twenty one warehouse indirect source rule.
0:31:35
An important element of an indirect source rule is that it could apply to both new and existing large warehouses.
0:31:43
There is also a separate but related proposal that the Department of City Planning is advancing, a last mile facility zoning special permit.
0:31:51
That special permit would focus on the siting and opening of new last mile warehouses.
0:31:56
In contrast, the indirect source rule proposal could be broader in scope impacting existing and future large warehouses and the pollution they create each year.
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