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New York (and elsewhere), get ready for new regulations affecting operators of major warehouses tied to the truck traffic they generate daily. The Clean Deliveries Act, now pending in the New York legislature, may be a harbinger of similar actions in other states.

Ft. Image - Everything You Need to Know About the New York Clean Deliveries ActMore and more, environmentalists, affected residents, and legislators are battling the effects of concentrated logistics operations. They see large warehouses as major polluters and disruptors that eat up hundreds of thousands of acres, including former farmland, and attract too much traffic. All of this is giving rise to a push for more sustainable logistics and supply chain operations.

The Background

In the name of efficient supply chain network design, certain areas of the country have been unofficially designated as logistics hubs. This is due to factors such as available land for development, proximity to metropolitan centers, access to transportation infrastructure, and the ability to service large swaths of the population with 1- and 2-day transit times.

This is why places like California’s Inland Empire (even though now going through a bust cycle) and central New Jersey have been magnets for e-commerce fulfillment centers. This has certainly contributed to a section of I-95 in Fort Lee, N.J., being designated the number-one spot in the country for truck congestion. Highway 60 at Highway 57 in Los Angeles also made the top 10, at number 7.

A secondary effect of all this is protests from residents near warehouse hubs and environmental groups, as well as legislation aimed at curbing or at least more closely examining future developments.

One particular target of these efforts has been the truck traffic servicing areas of concentrated logistics facilities, as well as the air pollution from generated carbon emissions. This output is increased when you have idling vehicles at the facility’s gate, the loading docks, or anywhere in between. When traffic is backed up at any point in the transportation flow in and out, the effect is obviously exacerbated.

While vehicle operators and fleet owners have always been subject to compliance with emission standards – particularly strict in California – a new wrinkle has emerged: the Indirect Source Rule (ISR).

California was the first to enact an ISR law, which went into effect in May 2021. Rule 2035 was passed by the South Coast Air Quality Management District (SCAQMD) in conjunction with the California Air Resources Board (CARB). The district covers 6,700 square miles in Orange, western San Bernardino, western Riverside, and southern Los Angeles counties, home to more than 17 million people, about 44% of the state’s population.

Other Related Initiatives

A companion to Rule 2035 in California is the Advanced Clean Trucks (ACT) rule and the related Advanced Clean Fleets (ACF) rule. Passed in 2020, ACT aims to reduce truck pollution by requiring manufacturers to sell an increasing percentage of vehicles with low or no emissions by 2035. As of Jan. 1, 2024, all trucks operating in California had to show proof of compliance with CARB regulations and be registered in the Clean Truck Check database.

Six other states – Maryland, Massachusetts, New Jersey, New York, Oregon, and Washington – have adopted California’s ACT rule. At the latest, another 15 states and the District of Columbia have pledged to ban the sale of carbon-emitting trucks by 2050.

While not everyone is standing up and cheering, including business groups and trucking associations who have filed lawsuits, the momentum behind these emission-targeting measures will be hard to reverse.

The Clean Deliveries Act Proposed in New York

New York state legislators have latched onto the idea of an indirect source rule for truck emissions at warehouses. S.2127, aka the Clean Deliveries Act (CDA), was submitted in January 2023 and now sits in the New York Senate’s Environmental Conservation Committee; a prior bill died there in 2022. It would require the state’s Department of Environmental Conservation to review carbon emissions produced by any warehouse, fulfillment center, or parcel hub larger than 50,000 square feet or with a total of 500,000 square feet across the state – including, of course, indirect sources like trucks.

Warehouse operators would be required to create an air emissions reduction and mitigation plan and could earn emission credit points through mitigation measures such as the use of EVs and charging stations; installation of solar generation systems; use of alternatives to truck or van trips; and by enacting “enhanced (emission) mitigation measures” when their facilities are near “schools, daycare centers, playgrounds, parks, hospitals, senior centers, nursing homes or disadvantaged communities.”

The legislation notes that Red Hook, Brooklyn, with a concentration of public housing residents, has five warehouses totaling 2 million square feet opening in the next year or so. They are “expected to bring a range of health and environmental hazards, including traffic,

congestion, road safety, pollution, and emissions impacts,” the bill states.

Warehouse operators would have to pay an annual registration fee and be subject to a fine of $50 per day for failing to submit an approved plan or otherwise be in non-compliance with the CDA.

The Potential Impact of CDA on Warehouse Operations

Under the CDA, warehouse operators would be required to establish extensive, ongoing monitoring and reporting on a variety of activities, both theirs and by third parties, including:

  • Average daily inbound and outbound trips by vehicle weight and class, time of day, and day of the week
  • Average daily vehicle miles traveled for all inbound and outbound vehicles
  • A heat map of the frequency data for trip destinations
  • Headcount, including including drivers working for outside carriers, broken down by full and part-time, union vs. non-union, and contractor vs. employees
  • The percentage of zero-emission vehicles used, the number of EV and hydrogen stations, and their usage
  • The number of owned vehicles leased to a third party
  • The identity of subcontractors handling more than 10% of total delivery trips from the site

In addition, any proposed warehouse development in New York would require a permit demonstrating that any additional traffic it generated wouldn’t result in a violation of EPA air quality standards.

How Warehouse Operators Can Prepare for CDA or Related Emission Requirements

Given the increased emphasis on sustainability, including reducing vehicle emissions at warehouse facilities, it’s important that warehouse operators initiate a plan of action to address the issue. Here are some suggested steps.

Conduct an Environmental Assessment

This should include an analysis of energy consumption and all transportation activities, as well as waste management practices.

Optimize Transportation Logistics

This can include a plan to consolidate shipments, if possible, to reduce truck traffic; implementing route optimization software to minimize mileage and fuel consumption; and encouraging the use of low-emission or alternative fuel vehicles.

Track and Monitor Carbon Emissions

Consider investing in carbon accounting software, as well as conducting regular emissions audits. Set achievable goals for emission reduction.

Technology Solutions to Address CDA

An assist from technologies on the market today can help warehouse operators mitigate the risks associated with compliance with stricter carbon emission standards, including those of ISR, CDA, ACT, CARB, and the EPA.

Yard Management Systems (YMS)

A YMS is designed to oversee the movement of trucks and trailers in and out of warehouses, fulfillment centers, and manufacturing facilities. It adds efficiency to yard operations by keeping track of assets such as trucks and trailers, and coordinating logistics functions such as gate access.

Artificial Intelligence

Systems built on artificial intelligence (AI) technology have come to the fore in recent years, creating an emerging category of yard vision and automation solutions. Importantly, these AI systems, such as technology from category visionary EAIGLE, complement and augment, rather than replace, a legacy YMS.

These systems can take advantage of assets that most facilities already have in place, such as security cameras located around the property. By syncing with the cameras and leveraging their video streams, they capture dozens of vehicle elements via optical character recognition.

Benefits of an AI-Based Approach

These advanced systems optimize gate access operations by speeding up truck and driver verification and authorization. Also, by leveraging data from sensors via the Internet of Things (IoT), yard assets can be automatically tracked and managed, making it easier for workers to quickly locate and access trucks, trailers, and chassis.

How EAIGLE’s AI-Based Yard Operations Technology Helps Address New Environmental Requirements

EAIGLE, a company that is front-and-center in the emerging AI-based yard vision space, has developed technology that is a natural fit for warehouse and manufacturing operations managers looking to prepare for stricter environmental mandates.

EAIGLE’s Automated Vehicle Access Control (AVAC) solution provides automated vehicle identification and tracking. Using robust optical character recognition that captures 25 vehicle data points, AVAC helps organizations optimize gate operations while enhancing security. And the significant reduction in dwell time means reduced carbon emissions, aiding in compliance and sustainability efforts.

YardSight is an intuitive AI-based solution that powers real-time monitoring of loading docks and truck parking availability in the yard. It improves queueing and bay assignments, saving time and labor by reducing reliance on visual audits and reducing manual data entry errors.

CDA Is Just One of Several Mandates Affecting Logistics Operators, So Be Ready

While ISR is law in California (although being challenged) and CDA is pending in New York, other environmental mandates affecting warehouse and logistics operations are sure to follow. Momentum continues to build behind efforts to curb emissions from thousands of trucks servicing major warehouses coast to coast.

EAIGLE’s innovative AI-based technology is purpose-built to drive greater efficiency, performance, cost savings, and environmental compliance in logistics, manufacturing, and retail operations. To find out more, request a demo today.