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AGENCY TESTIMONY
Proposed structure for warehouse indirect source rule
0:32:06
ยท
133 sec
Commissioner Aggarwala outlines the proposed structure for a warehouse indirect source rule in New York City, including compliance requirements and options for warehouse operators.
- Large warehouses would need to earn points proportionate to their vehicle trips
- Heavy-duty truck trips would be weighted more heavily than smaller vehicles
- Operators would have a menu of options to meet compliance obligations
- Options include using zero-emission vehicles, installing EV chargers, and other green initiatives
- Rule would apply to the 500 largest warehouses, accounting for 40% of total warehouse space
- Manufacturing facilities would be exempt from the rule
- Diverse points menu provides flexibility for different types of warehouse operators
- Concept of a custom plan to incentivize initiatives like marine and rail investments
Rohit Aggarwala
0:32:06
We envision a warehouse indirect source rule in which the city's largest warehouses are required to earn a number of points each year that is proportionate to the number of vehicle trips made to their warehouse.
0:32:18
Trips made in heavy duty trucks, which pollute the most, would be weighted more heavily than trucks trips made in smaller vehicles, but all motor vehicles making deliveries would count towards a warehouse's compliance obligation.
0:32:30
Large warehouse operators would have a menu of options they could mix and match to meet their compliance obligation.
0:32:36
This would include points for both acquiring and using zero emission and near zero emission vehicles, cargo bikes, and EV chargers.
0:32:45
It would also include menu items beyond delivery fleet conversion.
0:32:49
This could include installing anti idling technology in existing vehicles, electrifying yard trucks or forklifts, or investments in tree preservation or planting.
0:32:58
It would also provide a powerful incentive to adopt rail, marine or bike freight alternatives to trucking.
0:33:05
As I've said, an indirect source rule need not apply to all warehouses to be effective.
0:33:11
New York City's Five Hundred largest warehouses account for more than 40% of total warehouse space.
0:33:17
As we see it, the rule should apply to large warehouses which generate the most pollution and likely have the greatest capacity to make investments to reduce their pollution.
0:33:27
Facilities that are primarily doing manufacturing should not be subject to these rules.
0:33:32
We can design the policy to have a large enough impact that we see air quality improvements without including small operators or New York City manufacturing.
0:33:41
A diverse points menu is important to providing the diverse set of warehouse operators with options that work for them whether they own and operate their own fleets or outsource that function to third parties.
0:33:52
It also reflects the fact that some investments take time and planning.
0:33:56
So a warehouse owner might choose certain compliance options in early years as it plans for the long term.
0:34:02
We also see a lot of promise in the concept of a custom plan which would incorporate the potential to incentivize things like marine and rail investments and allow owners to make use of new technology or support other key initiatives such as micro hub development, off hour deliveries or EV fleet resilience.