Logistics, California Diesel, Truckers, & You

In a couple of other articles, and comments, the point has been raised that there’s a global “Logistics” problem right now with 44 ships stacked up at sea off of California Long Beach and with a big shortage of truckers to offload cargo and move it around the country.

While I don’t think it will “Freeze Up” as some have said, I do think that running slowly and clogged is going to create problems.

Others have pointed out the impacts of Covid Mandates & Restrictions & Lockdowns. Also the way that shutting down Australian coal imports to China stopped a lot of production. Ditto problems just getting crew to work the ships and docks.

I’m going to point out a couple of added bits of Aw Shit that have strongly reduced the available Trucker Fleet as well as bogged up what vehicles and ships can be used, at all, in California.

Simply put, 2 law changes screwed the pooch.

First off, a few years back the law was changed to MANDATE that truckers must have a 10 hour rest period, 8 hours of sleep and 2 hours to “ramp up and ramp down”. Just nuts. When I’m on the road, after 5 to 6 hours I’m ready to go again. Were I a trucker, I’d have to sit around wasting prime “refreshed and awake” time for another 4 to 5 hours because some idiot can’t function without 8 solid and a shower & foot massage.

My normal weekend do nothing at all sleep interval is at most 6 hours. Then I just wake up. I’m done.

Further to the idiocy, I thought I saw a mandate that a chunk of hours must be between 3-5 AM. For me, that’s the ideal running time. Roads are empty and you can get across the L.A. Basin in under 2 days… /snark; Now, EVERY truck is supposed to halt during those hours? I can’t find that reference now, so it may be it was a local thing or a different country.

Crossing the USA, as I’m flying by middle of the night, I see EVERY rest area chock full, trucks up the entrance and exit ramps. Often trucks parked on ramps of whatever place they could find.

You see, the law mandated the stop, but it didn’t provide the places to PUT the trucks. In San Jose, for example. it is illegal to park a big truck anywhere on the street, at your home, or at a truck stop (since they also banned them, too, so we don’t have any). So trucks need to be out and gone before their mandatory HALT hours arrive (by the clock or by the total drive hours) and find a place to do the HALT.

Guess what, halting all the trucks reduces total transport being done, but does not provide more trucks nor more truckers to get the capacity back up. Furthermore, many truckers are paid by the mile or by the hour. Since BOTH are reduced, net pay is not as good as it was before. Some percentage just cash in the chips and retire or find a different job.

Then along comes California and MANDATES you must change your engine for a new one or junk your truck. A WHOLE lot of folks just decide not to go to California (which would be fine, were it not that a LOT of freight for the rest of the country comes through California ports from Asia / China / Pacific).

It all adds up to not enough working truck hours and truckers in California, that then ripples through.

So here’s some links:

H/T/ Another Ian in a series of comments with links on Supply Chain issues. This is just one:

https://chiefio.wordpress.com/2021/10/01/w-o-o-d-1-october-2021/#comment-151432

another ian says:
5 October 2021 at 10:34 pm (Edit)
“The US economy is in imminent danger of seizing up solid”

To Sleep, Perhaps to Dream

https://www.fmcsa.dot.gov/regulations/hours-service/summary-hours-service-regulations

PROPERTY-CARRYING DRIVERS

11-Hour Driving Limit
May drive a maximum of 11 hours after 10 consecutive hours off duty.

14-Hour Limit
May not drive beyond the 14th consecutive hour after coming on duty, following 10 consecutive hours off duty. Off-duty time does not extend the 14-hour period.

30-Minute Driving Break
Drivers must take a 30-minute break when they have driven for a period of 8 cumulative hours without at least a 30-minute interruption. The break may be satisfied by any non-driving period of 30 consecutive minutes (i.e., on-duty not driving, off-duty, sleeper berth, or any combination of these taken consecutively).

60/70-Hour Limit
May not drive after 60/70 hours on duty in 7/8 consecutive days. A driver may restart a 7/8 consecutive day period after taking 34 or more consecutive hours off duty.

Sleeper Berth Provision
Drivers may split their required 10-hour off-duty period, as long as one off-duty period (whether in or out of the sleeper berth) is at least 2 hours long and the other involves at least 7 consecutive hours spent in the sleeper berth. All sleeper berth pairings MUST add up to at least 10 hours. When used together, neither time period counts against the maximum 14- hour driving window.

Adverse Driving Conditions
Drivers are allowed to extend the 11-hour maximum driving limit and 14-hour driving window by up to 2 hours when adverse driving conditions are encountered.

Short-Haul Exception
A driver is exempt from the requirements of §395.8 and §395.11 if: the driver operates within a 150 air-mile radius of the normal work reporting location, and the driver does not exceed a maximum duty period of 14 hours. Drivers using the short-haul exception in §395.1(e)(1) must report and return to the normal work reporting location within 14 consecutive hours, and stay within a 150 air-mile radius of the work reporting location.

Got that? Nice and clear, eh? What I think it says is you can DRIVE for 11 hours, but if you come on duty and take an hour to load, and have an hour of lunch, and there’s a inspection station where you are not driving for 2 hours but are talking to the inspectors, and then hit 14 hours “on duty” you must stop anyway.

Then 60 in 7 is 8.57 hours / day. Where 70 in 8 days is 8.75 hours. So you get ONE long day in a week, basically, then the rest must be regular shift length.

Then what happens to “folks like me” when I wake up after 6 solid and I’m DONE? I must spend an hour laying in the sleeper watching my watch? Can’t go into the Truck Stop for a donut?

There’s a similar but slightly different (worse) set of these if you are hauling passengers. Here’s the Sleeper Berth requirement for example:

Sleeper Berth Provision
Drivers using a sleeper berth must take at least 8 hours in the sleeper berth, and may split the sleeper berth time into two periods provided neither is less than 2 hours. All sleeper berth pairings MUST add up to at least 10 hours.

So now I’ve got to lay in the berth for 2 hours after I’m fully awake and can not sleep again at all no matter what? If I go get the donut after 6, then I’ve got to do 4 more in the berth to get to 10 total?

No wonder so many trucks and buses are stopped by the side of the freeway all across the nation. No wonder there’s a lot of drivers have just said “I’m done”. Somebody telling me when I MUST sleep even if I’m not able to sleep as I’m fully slept out?

Those who are truly brave can read some of the “Guidance” on all this:
https://www.fmcsa.dot.gov/regulations/title49/section/395.8

I especially like the guidance about foreign drivers (like from Mexico) needing to account for the past 6 days (say, in Mexico) if they cross into the USA for one day to drop off a load. Yeah, right.

And it keeps mutating:

https://www.fmcsa.dot.gov/regulations/federal-register-documents/00-10703

Action
Notice of proposed rulemaking (NPRM); request for comments.

Summary
The FMCSA is proposing to revise its hours-of-service (HOS) regulations to require motor carriers to provide drivers with better opportunities to obtain sleep, and thereby reduce the risk of drivers operating commercial motor vehicles (CMVs) while drowsy, tired, or fatigued to reduce crashes involving these drivers. This action is necessary because the FMCSA estimates that 755 fatalities and 19,705 injuries occur each year on the Nation’s roads because of drowsy, tired, or fatigued CMV drivers. The regulations proposed in this document would: First, revert to a 24-hour daily cycle, and a 7-day weekly cycle. Second, adjust the work-rest requirements for various types of operations. Third, emphasize rest. Require for long-haul and regional drivers a period of 10 consecutive hours off duty within each 24-hour cycle, and two hours of additional time off in each 14-hour work period within each 24-hour cycle. Fourth, require weekends, or their functional equivalent, to include at a minimum a rest period that includes two consecutive periods from 11:00 p.m. to 7:00 a.m. Fifth, require the use of electronic on-board recorders (EOBRs) in CMVs used by drivers in long-haul and regional operations.

So what about folks like me who are natural Night Owls and do not typically sleep until after midnight and rarely get up at 7 AM? (OR, if I do, it is because I woke up at 5 AM and could not sleep anymore…)

The notion that some butthead sitting at a desk in D.C. knows when I must sleep and want’s an ankle monitor telling him I complied would drive me out of trucking. (In fact, is likely preventing me doing my own move. I got started on this by looking at a Box Truck and just driving my own stuff. Cheap enough, and I have a suitable license for a 26,000 lb GVWR: But,… the garbage rules…)

Somewhere I’d thought I saw a prohibition on driving between about 3 AM and 5 AM, but I can’t find it now. So I’m wondering if it was some local area or other country.

Anyway, while I’m sure many truckers appreciate being able to say “I’m going to pull over and sleep for 8” and the boss can’t gripe at me: The specification down to the detail they do is not compatible with the normal sleep patterns of many folks. Me among them.

Then all the logging and tracking involved. Sheesh. I can see why there is a trucker shortage. I’d not want to deal with all that “in my face” stuff.

On to smog compliance.

Here’s a “how to comply” pdf:

http://www.aqmd.gov/docs/default-source/ab-617-ab-134/steering-committees/wilmington/handouts-may9-2019.pdf

This is PART of the TOC (Table Of Contents):

What diesel rules apply to you? 3
Trucks and Buses 4
Truck & Bus Regulation Compliance Options 5
DMV Compliance Verification Begins in 2020 6
Drayage Trucks 7
Transportation Refrigeration Units 8
Tractors & Box-Type Trailers 9
Other Diesel Programs 10
Diesel Particulate Filter Care & Maintenance 11-12

Note that Drayage Trucks are the ones that take stuff from Ships at Docks to other trucks or trains for travel onward. Basically old gear gets scrapped or taken out of service for maintenance / engine replacements.

Note the Refrigeration Units (TRUs). Those are the refrigerators hung on the front of big box trucks carrying things like refrigerated food or drugs. They, too, are to be scrapped or out for upgrades if not relatively new.

Note the “Other Diesel Programs”. That includes ships at sea and various other bits of kit. Ships must plug into “shore power” and not make their own with their engines. What happens if your ship is not equipped with a giant plug? Or the wrong one for the port?…

On-road diesel vehicles with a GVWR that is 14,001+ lbs. must reduce exhaust emissions by meeting particulate matter (PM) filter requirements and upgrading to newer engines. Vehicles with 2010 engine model year (EMY) or newer are fully compliant. Heavier Vehicles with a GVWR greater than 26,000 lbs. must upgrade as shown in the table. Reporting is optional when exclusively using the Engine Model Year schedule for heavier vehicles below.
[…]
Lighter Vehicles with a GVWR between 14,001 and 26,000 lbs. need to be upgraded with 2010 or newer EMY. Check the table to determine your replacement date. Older vehicles may be upgraded to newer used equipment that is still in compliance with the schedule. No retrofit PM filter or reporting is required for lighter vehicles.

Note that lighter vehicles have no “reporting” required? The others get to regularly fill out usage and maintenance reports to CARB.

So ANY truck that was older than 10 years was to have perfectly good engines removed and replaced with newer “Engine Model Year” EMY compliant ones.

Or the driver can just leave the State and go to a more sane place to work…

And now folks are surprised there is a shortage of Drivers and Trucks in the Ports of California…

Here’s the chart (in poor formatting) for “heavier” vehicles:

EMY Schedule for Heavier Vehicles (>26,000 lbs. GVWR)
EMY PM Filter* 2010 EMY by
Pre-1994 Not required January 1, 2015
1994-1995 Not required January 1, 2016
1996-1999 January 1, 2012 January 1, 2020
2000-2004 January 1, 2013 January 1, 2021
2005 or newer January 1, 2014 January 1, 2022
2007-2009 If already equipped January 1, 2023
 *Level 3 PM filter

Note that a bunch of this hit in 2020 and is hitting in 2021? More to come in the next 2 years, too.

For folks not familiar with Commercial Diesel Engines, these things often go 1/2 MILLION MILES without an overhaul, and at least one I know of (Detroit Diesel 80 series) has a recommended overhaul at 3/4 Million Miles. A 10 year old truck often has decades of life left in the engine. But hey, if you have an older truck you may have just paid it off anyway, so pony up the bucks to trash the engine…

So what has happened is that fleets of newer trucks get the business and at higher prices while folks with older trucks just leave and take both the truck and driver with them.

Leaving a Truck and Driver shortage that’s especially acute at the docks. And offering more money will not get that truck or driver back into the State as they are banned by law.

When did this all hit the fan? Why in the middle of the Covid Scare and Lockdowns:

2020 DMV Registration Requirements
You must be in compliance with the Truck and Bus Regulation in
one of the following ways in order to register your vehicle with the
DMV:
• The vehicle is using an allowable compliance option
AND is reported into the TRUCRS reporting system
• The vehicle is compliant with the Engine
Model Year Schedule (see page 4)
• The vehicle is equipped with a 2010 or newer model year
engine (usually a 2011 or newer model year vehicle) OR
is repowered with 2010 or newer model year engine
Currently out of compliance? Don’t wait until 2020.
CARB can issue DMV registration blocks now if your vehicle
does not meet air quality requirements. The State of California is
enforcing all diesel regulations in preparation for 2020.

Note too that you get tagged and tracked in Yet Another Database.

So say you have a $100,000 truck, finally paid off, and are told you can buy a new one at $240,000, or drop $10k to $20k on a new engine swap. What are the odds you think: “Maybe now is the time to move to Texas”… and avoid all this crap.

How about picking up at the Dock?

Diesel-fueled trucks transporting cargo destined for or coming from
California’s ports and intermodal rail yards (including bobtails and
transporting chassis) must be registered in the statewide Drayage
Truck Registry prior to entry. Drayage fleets must comply with
requirements by operating only vehicles with 2007 MY engines
or newer.

Drayage Compliance Schedule (GVWR 26,001 lbs. or more)
Truck Engine Model Year Emission Requirements
2006 and older Not allowed
2007-2009 Compliant through 2022
2010 and newer Fully compliant

By January 1, 2023, all class 7 and 8 diesel-fueled drayage trucks must have 2010 or newer engines. Trucks with 2010 or newer engines are fully compliant with both the Truck and Bus and Drayage regulations.

The exchange of marine or rail cargo (e.g. containers) between compliant and noncompliant drayage trucks is not allowed anywhere in California.

So a great way to create a shortage of trucks is to ban anything older than 10 years in a fleet with 20 year plus design life.

Got an expensive Refer Box truck? Yeah, them too:

All transport refrigeration units TRU) and TRU generator sets that operate in California must meet the in-use performance standards (see compliance table below). Every California-based TRU and TRU generator set must be registered in Air Resources Board Equipment Registration (ARBER) and be labeled with a CARB Identification Number. All terminals that are located in California where TRUs are based must submit operator reports to CARB at: arber.arb.ca.gov.

So what’s a fella to do? Be mired in paperwork, tracked tagged and bagged, and having your box refrigeration unit replaced way ahead of schedule? Or just go somewhere else…

But wait, there’s more! CARB even wants to tell you what kind of tires to buy and what kind of box you can tow:

The Tractor-Trailer Greenhouse Gas Regulation applies to 53-foot or longer box-type trailers and 2013 MY or older heavy-duty tractors that pull these trailers.

Low-Rolling Resistance Tire Requirements*

Tractors Trailers
2013 and older MY Required Required
2014 and newer MY N/A Required

Tractor Requirements All 2011 through 2013 MY sleeper-cab tractors must be SmartWay™ designated models. 2014 MY or newer tractors are covered by a federal regulation and are exempt from this rule. Trailer Aerodynamic Requirements All trailers must be either SmartWay™-certified or aerodynamically retrofitted to a minimum standard.

But you are not done yet…

OTHER DIESEL PROGRAMS
CARB continues to actively enforce long-standing requirements
for diesel vehicles including:

Idling Limits

Idling Limits restrict diesel vehicles from idling more than five minutes. Idling in school zones is not allowed, with limited exceptions. See: http://www.arb.ca.gov/noidle

Emission Control Labels

Emission Control Labels must be affixed to engines of all commercial heavy-duty diesel vehicles, and must be legible as proof the engine, at minimum, meets U.S. federal emissions standards for the engine model year.

Periodic Smoke Inspection Program

The Periodic Smoke Inspection Program requires owners of California-based fleets of two or more diesel vehicles to perform annual smoke opacity tests and to keep records for at least two years for each vehicle. The requirement does not apply to cars or trucks that must undergo a Smog Check.

Heavy-Duty Vehicle Inspection Program

The Heavy-Duty Vehicle Inspection Program uses random roadside inspections to verify that diesel engines do not smoke excessively and are tamper-free. See: http://www.arb.ca.gov/enf/hdvip/hdvip.htm

Public Fleets and Others

Vehicles with a GVWR of 14,001+ lbs. that are owned by state and local government fleets, private utilities, and solid waste collection vehicles, must already have particulate matter (PM) filters (retrofit or originally equipped).

Sound like the kind of Royal PITA you would want to deal with every day at work? Especially knowing that just over the hill you can once again live free?

But wait, we’ve not talked about the actual ports, cranes, ships, et. al.

The Regulation for Mobile Cargo Handling Equipment at Ports
and Intermodal Rail Yards
Rule to achieve significant emission reductions and protect public health The California Air Resources Board (ARB) has in place a regulation, which took effect in 2006, to reduce emissions from mobile cargo handling equipment (CHE) operating at California’s ports and intermodal rail yards.
[…]

Basically more of the same.

Boats & Ships too:

Commercial Harbor Craft Regulation

On November 15, 2007, the California Air Resources Board (ARB) approved a regulation to reduce emissions from diesel engines on commercial harbor craft vessels. Amendments were approved in June 2010. Regulation compliance is significantly reducing diesel particulate matter (PM) and oxides of nitrogen (NOx) emissions from harbor craft engines.

What types of vessels are subject to this regulation?

The regulation applies to all commercial harbor craft vessels including, but not limited to, ferries, excursion vessels, tugboats (including ocean-going tugs), towboats, push boats, crew and supply vessels, barge and dredge vessels, work boats, pilot vessels, and commercial and charter fishing boats. There are about 4,200 harbor craft vessels, and 8,300 diesel engines on these vessels, currently in use in California. Of these, nearly 800 are ferries, excursion vessels, tugboats, towboats, push boats, crew and supply vessels, barge and dredge vessels equipped with about 2,500 propulsion and auxiliary engines that are subject to in-use engine emission limits.

What does the commercial harbor craft regulation require?

The regulation includes requirements for both new and in-use diesel engines used on commercial harbor craft operating in Regulated California Waters. Below is a brief discussion of these requirements; specific details can be found in the regulation, which is available online:
http://www.arb.ca.gov/ports/marinevess/harborcraft/hcregulatory.htm

Operational Requirements for All Commercial Harbor Craft

Commercial harbor craft owners/operators are required to fuel their diesel engines with California ultra low sulfur diesel and install (if not already installed) a non resettable hour meter on each engine. All owners/operators are required to submit an initial report to ARB within 30 days of first operating in Regulated California Waters. Vessel owners/operators must keep a copy of their initial report and annually up-dated records on the vessel or in a central dockside location to be made available upon request by ARB staff.

So “your papers please!” for your boat.

Then skipping way down… One bit that surprised me, is that California is “regulating” the fuel you can use if you are 24 miles off the coast! I thought that was international waters? Yes, the “exclusive economic zone” goes to 200 miles, but that is about extracting resources. Whatever.

November 2011
Advisory to Owners or Operators of Ocean-Going Vessels
Visiting California Ports

Changes to the Regulation on Fuel Sulfur and Other Operational Requirements for Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline

The purpose of this advisory is to notify owners and operators of ocean-going vessels (OGVs) of changes to the OGV Fuel Regulation. California’s ARB will begin enforcement of the changes to the rule on December 1, 2011. This advisory is only a summary of the requirements and does not contain all the information that may be needed to comply with the regulation. The regulations can be found at the following:
http://www.arb.ca.gov/regact/2011/ogv11/ogv11.htm

What are the changes to the fuel requirements? The revised fuel requirements are summarized in Table 1 below. These fuel requirements apply to ocean-going vessel main (propulsion) diesel engines, auxiliary diesel engines, and auxiliary boilers.

So basically unless you have several fuel tanks and can swap between them, you MUST BUY expensive and rare California Diesel Fuel to come to California…

It goes on and on from there, covering off-road Diesels (think lift trucks, water pumps, etc.) and more. Limits idling to 5 minutes (so better be able to take a dump fast…) and a whole lot more reporting and labeling and inspection costs and requirements.

Basically they are trying to kill any use of a Diesel engine.

Now when wondering just why so much cargo is not making it through California ports very fast, ask yourself how much equipment was “retired” or is in parts at the shop being “re-engined” and not available to work? How many support vessels and intermediate handling drayage just quit or left? How many truckers just took their trucks to other ports in other States?

In Conclusion

I’m of the opinion that all this “crap regulation” has driven a fair percentage of Trucks and Truckers out of California, and in some cases out of the business.

I think a significant fraction of the problems with transport come down to mandating retirement of equipment and less work per driver with inflexible scheduling; while not having any offsetting increase in trucks in service or available drivers.

One example: It is a 7 hour drive from San Francisco area to Los Angeles area. In the past, many truckers would do that as a round trip. I’ve done it in a car for various reasons. With a 2 hour meeting or drop off of stuff for the kid at school, it’s a total of about 15 to 16 hours. A simple “double shift”. There’s a LOT of stuff goes between the two areas. Now, with an 11 drive hours and 14 on duty, then 10 mandatory off: that’s a 2 day run. At the end of 14 hours, you have driven 7+5 and had 2 “doing the delivery”. That would put you in the middle of nowhere I-5 Central Valley with no place to eat, sleep, whatever. Now you sit for 10 hours.

But it gets worse. L.A. traffic is so horrible now that the round trip in one go mostly works great if the drop off is dead of night. With the 2 segments approach, you will likely get stuck in “rush hour” traffic if you have an arrival during any normal business hours. Where before you could get there about 6 AM, nap until 8 when things open and you deliver the goods, get a late brunch, and be on the road for a noon pause in the gridlock and get out of the basin before the afternoon lockup; NOW you can’t just take a 2 hour nap and call it good. Instead you either try to sleep all day and leave the next night, or you get to slog your way out during the morning rush hour. It’s just a mess no matter what.

That doubling of on-the-road time means more costs and fewer deliveries. Simple as that.

Subscribe to feed