Attachment 3 - 2022 Regional Warehouse Inventory — Mayor and City Council, October 7, 2026

APPENDIX 1
Exhausting Our Air
Environmental and Human Costs of Diesel Trucks
September 2023
Cover image:

Heavy Duty Diesel Truck
Photo Credit: Economic Roundtable
Exhausting Our Air
Environmental and Human Costs of Diesel Trucks
September 2023
Economic Roundtable
Daniel Flaming
Patrick Burns
Community profiles by
Peoples’ Collective for Environmental Justice
Andrea Vidaurre
Ivette Torres
Underwritten by the
Sierra Club
Report available at: www.economicrt.org
This report has been prepared by the Economic Roundtable, which assumes all responsibility for its contents. Data, interpretations and conclusions contained in this report are not necessarily those of any other organization.

This report can be downloaded from the Economic Roundtable web site:
www.economicrt.org
Acknowledgements
We would like to express our gratitude to the partners in this project who carried out frontline research and provided support and insights that made this study possible.

People's Collective for Environmental Justice (PC4EJ)
The People’s Collective for Environmental Justice champions clean air and environmental and racial justice. As members of the community they carried out the frontline of research for this study. The key research partners were:

Andrea Vidaurre, Senior Policy Analyst
Ivette Torres, Research Consultant
Sierra Club
The Sierra Club is a champion for the environment. They are working to get stronger environmental and energy laws that will reduce dependence on fossil fuels, protect the oceans and fragile coastal environments, and help protect jobs. Key partners for this study were:

Katherine Garcia, Director, Clean Transportation for All Yassi Kavezade, California Field Manager
Allison Kirsch, Senior Energy Campaigns Analyst

Table of Contents

1. Executive Summary................................................................................................................................. 1

2. Warehouse Expansion............................................................................................................................ 7 Overview................................................................................................................................................................................................................... 8 Large Warehouses................................................................................................................................................................................................ 9 Geography of Large Warehouses..................................................................................................................................................................... 9 Clusters of Large Warehouses ........................................................................................................................................................................13 Warehouse Locations and Economic Equity............................................................................................................................................... 15 Number of Warehouse Workers.....................................................................................................................................................................16 Occupations and Wages of Warehouse Workers...................................................................................................................................... 17 Community Profile: Cesar Avila, Truck Driver, and Maria Rubio, Retired...........................................................................................19

3. Truck Drivers and Trucking Companies..........................................................................................23 Overview.................................................................................................................................................................................................................24 Drayage Truck Drivers.......................................................................................................................................................................................26 Trucking Companies...........................................................................................................................................................................................29 Trucks.....................................................................................................................................................................................................................31 Emissions per Vehicle Mile..............................................................................................................................................................................33 Diesel Truck Emissions between Ports and Warehouses........................................................................................................................36 Clean Truck Mandate.........................................................................................................................................................................................37 Clean Trucks.........................................................................................................................................................................................................39 Community Profile: Ricardo Peraza, Trucking Company Owner............................................................................................................43

4. Impacts of Warehouse Trucking....................................................................................................... 49 Overview.................................................................................................................................................................................................................50 Warehouse Impacts on Air Quality................................................................................................................................................................51 Uncompensated Public Costs from Warehouse Truck Trips.................................................................................................................. 53 Unacceptable Road Conditions........................................................................................................................................................................56 Public Health Costs............................................................................................................................................................................................57 Community Profile: Ralph Sistos, Teamster................................................................................................................................................62

5. Workers and Jobs................................................................................................................................. 65 Overview.................................................................................................................................................................................................................66 Jobs Created by Electrical Infrastructure..................................................................................................................................................... 67 Job Growth in Electrical Construction and Power Generation...............................................................................................................69 Wages in Electricity Sector Industries..........................................................................................................................................................71 Occupations Employed in Electrical Construction......................................................................................................................................71 Warehouse Labor Force....................................................................................................................................................................................73 Change in Skill Requirements for Warehouse Jobs................................................................................................................................. 76 Wages of Frontline Warehouse Workers......................................................................................................................................................80 Community Profile: George Hauge, Environmental Advocate.................................................................................................................82

6. Impacts of Warehouses on Frontline Families..............................................................................85 Overview.................................................................................................................................................................................................................86 Incompatible Development ...............................................................................................................................................................................87 Zoning for Warehouses.....................................................................................................................................................................................89 Residents Living Near Large Warehouses...................................................................................................................................................91 Median Income....................................................................................................................................................................................................94 Families in Poverty.............................................................................................................................................................................................96 Housing Conditions.............................................................................................................................................................................................97 Community Profile: Cynthia Ayala, Amazon Air Worker, San Bernardino Airport ............................................................................99

7. Respiratory Distress...........................................................................................................................101 Overview..............................................................................................................................................................................................................102 Health Conditions Requiring In-Patient Hospitalization.........................................................................................................................103 Diesel Particulate Matter (PM) Emissions................................................................................................................................................103 Uneven Pollution Burden................................................................................................................................................................................104 PM 2.5 Spillover into Surrounding Neighborhoods................................................................................................................................105 Chronic Respiratory Disease Exacerbated by Air Pollution..................................................................................................................107 Community Profile: Henry James Vasquez, Indigenous and Mexican Elder..................................................................................110

8. Onsite Warehouse Emissions.........................................................................................................113 Overview..............................................................................................................................................................................................................114 Energy Consumption from On-Site Operations........................................................................................................................................115 How and Where Locally-Consumed Electricity is Generated..............................................................................................................116 Metric Tons of GHG Emissions from On-Site Energy Consumption..................................................................................................118 Criteria Emissions from On-Site Activities................................................................................................................................................119 On-Site Natural Gas Consumption..............................................................................................................................................................120 On-Site Water Consumption.........................................................................................................................................................................122

9. Data Appendix and Methodology...................................................................................................123

10. End Notes..........................................................................................................................................131 Exhausting Our Air 1

1. Executive Summary ----------------------------------------------------------------------------------------------------------------- Photo credit:

Economic Roundtable
2 Exhausting Our Air
Structural Inequity
Displacement of brick-and-mortar retail stores by online retailing and sprawling warehouses is coming at the cost of climate change, bad air, low wages, and extreme disparities between neighborhoods where consumer goods are warehoused and neighborhoods that can afford to buy the goods.

In each of the past three decades, 175 million more square feet warehouse space has been built in the four Southern California counties of Los Angeles, Orange, Riverside and San Bernardino. Each new warehouse has increased diesel truck emissions in working class neighborhoods where frontline warehouse workers earn median annual wages of $25,154.

Petroleum waste products produced by moving consumer goods from the seaports to warehouses, and then from warehouses to affluent homes, are released into the air we all breathe. But pollutants are most heavily concentrated in the neighborhoods of low-wage warehouse workers.

Battery-electric trucks will eliminate six million tons of emissions a year and create good jobs in the electricity sector, unless California’s mandate for clean trucks is derailed by utility district delays in providing electricity.

Trucking companies and electric truck dealerships report that it takes two years or more to get electricity for recharging the trucks. This is completely out of step with the Air Resources Board’s mandate for deploying zeroemission trucks starting January 1, 2024.

Neighborhoods with Warehouses
Warehouses and the workers employed in them are located in lower income communities. The consumers that benefit most from the logistics sector are higher-income communities, far-removed from the noise and emissions caused by diesel trucks and warehouses. There is fundamental environmental and economic inequity between the neighborhoods that do the heavy lifting of the logistics system and the neighborhoods that benefit.

There are over 3,300 warehouses with 100,000 or more square feet of space in the four county region. They cover over 800 million square feet and bring in over $6 billion a year in revenue.

Recent warehouse construction is concentrated in San Bernardino County, where low land costs offset the distance from retail stores, consumer neighborhoods, and the San Pedro Bay Ports.

Drayage Trucking Companies and Drivers
Drayage companies, which make short-haul trips with heavy cargo, are concentrated near the San Pedro Bay Ports, with secondary concentrations Exhausting Our Air 3
in the Inland Empire. Most truck drivers live near these trucking companies. Their livelihoods expose them to the emissions and noise of diesel trucks when they are working, and often these impacts are also part of the after-work environment in their neighborhoods.

Two-thirds of trucking companies are small businesses with nine or fewer trucks. However, large corporate trucking companies dominate the industry. Companies with 125 or more trucks own 95 percent of the trucks that move cargo into and out of the Ports of Los Angeles and Long Beach.

Diesel trucks have the second highest greenhouse gas emissions per tonmile of any mode to cargo movement, exceeded only by cargo aircraft.

Their high greenhouse emissions and wide deployment make them a significant contributor to climate change.

Deploying Electric Trucks
The California Air Resources Board (CARB) and South Coast Air Quality Management District (AQMD) have mandated a rapid transition to clean truck propulsion technology.

Beginning January 1, 2024, CARB is requiring all new drayage trucks entering seaports and intermodal railyards to be electric. Diesel trucks that that are registered with the state before the end of 2023 can remain in operation until 2035. This is the Advanced Clean Trucks Rule.

There is strong opposition to this regulation by trucking companies.

Nineteen states are seeking appellate court review in a challenge to the Environmental Protection Agency waiver granted for California’s Advanced Clean Trucks Rule.

Similarly, the California Trucking Association is challenging the AQMD rule that makes warehouses accountable for emissions from diesel trucks delivering cargo to and from warehouses in the district.

Eight heavy-duty truck manufacturers have initiated small-scale manufacturing and sales for zero-emission, battery-electric tractors. Most currently available heavy duty electric trucks are capable of meeting basic performance requirements for short-range drayage operations, roughly up to 175 miles between charges. This means that current battery-electric models are restricted to short-hauls or lighter-weight drayage tasks.

There is strong year-over-year progress in the robustness and capabilities of zero-emission trucks. The capabilities and reliability of electric trucks will continue to improve and in the coming years they will be able to perform all drayage functions currently performed by diesel trucks.

Given the current low-volume of electric truck sales, the purchase subsidies available in California are currently sufficient to reduce their cost to less 4 Exhausting Our Air
than the cost for a diesel truck. However, there are only enough subsidy funds to cover a small fraction of the zero-emission trucks that must be put in service by 2035. As sales ramp up, there will be an interval when subsidies are scarce and the cost of electric trucks has not come down to the cost for diesel trucks.

The current subsidy programs prioritize small truck fleets, but truck dealerships report that small operators are overwhelmed by the paperwork and documentation required to obtain subsidies, and often abandon the effort to obtain a subsidy as well as to buy an electric truck.

In the interest of equity, it is important to continue prioritizing small fleets for subsidies and also to streamline the application process and provide user-friendly technical assistance for small fleet owners seeking subsidies.

Electricity for Charging Stations
Electric truck dealers and fleet operators have identified delays in obtaining electric power for charging stations as the most serious obstacle for deploying electric trucks.

Impacts of Warehouse Trucking
Diesel trucks travel over 415 million miles a year to and from large warehouses in the four-county region. There are $1 billion in annual uncompensated public costs from wear and tear on roads and bridges; delays caused by traffic congestion; injuries, fatalities, and property damage from accidents; and harmful effects from exhaust. California ranks 46th among the 50 states in the share of roads that are in acceptable condition.

The 11 million annual heavy-truck trips produce almost six million tons of greenhouse gases that accelerate global warming. They also produce 1,161 tons of nitrogen oxides, which can irritate sensory organs, and cause shortness of breath with fluid build-up in the lungs. And they produce 29 tons of fine particulate matter, which causes bronchitis and asthma attacks.

The annual health costs for residents from current diesel truck emissions, and, conversely, the health benefits from having electric trucks move cargo instead of diesel trucks are an estimated $166 million a year.

Exhausting Our Air 5
Workers and Jobs
One job is created for every $111,512 spent on the electrical infrastructure required to recharge electric trucks. This includes jobs building electrical utility infrastructure and installing electrical wiring and equipment to charge trucks, as well as jobs in industries that provide supplies and services for electrical construction, and additional jobs that are created when workers in electrical construction and supplier industries spend their wages.

The electricity sector provides high-pay, living-wage jobs. The average hourly wage for frontline electrical construction is $35 an hour.

The introduction of new technology in warehouses and the rapid turnover of goods has increased the skill requirements for frontline warehouse jobs.

However, the wages paid to warehouse workers have decreased.

The average wage in 2022 for warehouse workers in frontline occupations was $18.95 an hour. This is less than half of a living wage.

The jobs to electrify the logistics chain that brings goods to warehouses are much better than the jobs inside warehouses. This includes jobs expanding the electrical transmission infrastructure, building recharging station for electric trucks and installing solar panels at warehouses.

Impacts of Warehouses on Frontline Families
There are just under 365,000 residential parcels located within 2,000 feet of large warehouses, across the four-county region. Three-quarters are singlefamily homes, and another quarter are multi-family properties. This housing provides homes for over 2.1 million residents.

Warehouses and the linked trucking and air cargo networks degrade the habitability of neighborhoods. Factors that diminish the desirability of housing in these neighborhoods include freeways, heavy traffic, truck-train intermodal facilities, cargo airports, truck depots, and warehouses.

Families living near large warehouses experience an elevated likelihood of poverty throughout the four-county region. In addition to economic distress, these families suffer from traffic noise and congestion, as well as long-term exposure to air pollution, that make it difficult to get the peace, quiet and cleaner air needed for a healthy life.

The median income within a 2,000-foot perimeter of large warehouses is 18 percent lower than in the rest of the four-county region, and the poverty rate is 22 percent higher than outside the perimeter.

Many families live near warehouses out of economic necessity, settling on less desirable neighborhoods where rent is lower. Even with lower rent, many families cannot afford housing that meets minimum standards of 6 Exhausting Our Air
space and privacy for household members. They often rent a smaller unit where more than one person is crowded into each room in order to reduce the rent. The rate of overcrowded housing is 38 percent higher within the 2,000 perimeter of large warehouses than in the region a whole.

Households living within 2,000 feet of a large warehouse are 10 percent more likely to have children, 23 percent more likely to be headed by a female, and 40 percent more likely to be Latino than in the overall region.

Respiratory Distress
The direct pollutants from diesel truck trips to and from large warehouses, cause elevated rates of respiratory distress. This is compounded by the indirect pollutants attributable to the electricity and natural gas that these buildings consume onsite.

Large swaths of the Inland Empire are in the highest quintile of the pollution burden index, meaning they have the highest exposure to criteria air pollutants, including ground level ozone, carbon monoxide, lead, nitrogen dioxide, sulfur dioxide, and particulate matter.

Homes near the large warehouse clusters by Ontario International Airport and San Bernardino International Airport breath air with the highest level of fine particulate matter, increasing risks of asthma and heart disease.

The rate of emergency department visits for asthma attacks reflects the location of manufacturing and logistics land uses. South Los Angeles, City of Industry, Ontario and San Bernardino have elevated rates of emergency department visits as well as the largest concentrations of logistics activity.

Recommendations

1. Equitably assess the full environmental and economic impacts of warehouses before approving any new warehouse construction or the expansion of air cargo facilities.

2. Fully enforce noise regulations for all warehouses.

3. Establish a living minimum wage for warehouse workers.

4. Protect the truck electrification timeline created by the Advanced Clean Fleets Regulation and the Warehouse Indirect Source Rule.

5. Proactively upgrade the electrical networks serving trucking companies and warehouses to ensure that electricity is available to recharge trucks as soon as it is needed.

6. Enact rules requiring the Los Angeles Department of Water and Power to provide technical and financial assistance for installing commercial recharging stations.

7. Safeguard electric subsidy funds to ensure ongoing support for small trucking companies after demand grows and subsidy funds shrink.

Exhausting Our Air 7

2. Warehouse Expansion
----------------------------------------------------------------------------------------------------------------- Routes from the San Pedro
Bay Ports to warehouses
Image credit: Economic
Roundtable
8 Exhausting Our Air
Overview
Economic Inequity
Warehouses and the workers employed in them are located in lower income communities. The consumers that primarily benefit from services of the logistics sector are higher-income communities, far-removed from the noise and emissions caused by diesel trucks and warehouses.

Growth
Over the past three decades, from 1993 through 2022, warehouse space in the four-county region has increased 42 percent, or 175 million square feet, each decade. This steep rate of growth shows no evidence of slowing.

The growth in warehouse space has been accompanied by a corresponding increase in diesel truck drayage.

Scale and Location
There are over 3,300 large warehouses with 100,000 or more square feet of space in Los Angeles, Orange, Riverside and San Bernardino Counties.

They provide over 800 million square feet of space for storing the things that we buy and bring in over $6 billion a year in revenue.

Recent warehouse construction has been concentrated in San Bernardino County, however Los Angeles County has the greatest number of large warehouses, followed by San Bernardino, Riverside and Orange Counties.

Low land costs offset the Inland Empire’s distance from retail stores, consumer neighborhoods, and the San Pedro Bay Ports. Equally important is some county and city governments’ willingness to approve the continued construction of large warehouses.

Economic Desperation
The City of Ontario is home to 278 large warehouses, by far the most warehouses of any city in the four-county region. The large number of warehouses in Ontario may be the result of economic downturns in the city’s recent past, as well as economic desperation for growth of any kind.

The city filed for bankruptcy in 2012 and remained bankrupt until 2017.

Wages
Nearly two-thirds of workers are employed in the transportation and material moving job family. These workers have median wages of $25,154 annually.

Exhausting Our Air 9
Large Warehouses
Large warehouses continue to be built in Southern California to satisfy growing consumer demand for retail goods. This growth generates more trips by diesel-powered trucks hauling goods between entry ports, intermodal facilities, warehouses, and retail stores.

The South Coast Air Quality Management District (SCAQMD) approved Rule 2305, the Warehouse Indirect Source Rule, in May 2021 to regulate indirect emissions linked to warehouses.

Evidence about the environmental and human costs of moving cargo with diesel trucks as well as the economic and social justice benefits from improving air quality supports implementation of Rule 2035. The baseline information in this report about conditions in the Inland Empire serves as a guide for communities in other regions of the country that are similarly impacted by warehouse operations.

Geography of Large Warehouses
There are over 3,300 large warehouses with 100,000 or more square feet of space in Los Angeles, Orange, Riverside, and San Bernardino Counties.

They provide over 800 million square feet of space for storing the things that we buy and bring in over $6 billion a year in revenue. 1 Los Angeles County has the greatest number of large warehouses, followed by San Bernardino,
Riverside and
Orange Counties, as
shown in Figure 1.

San Bernardino
County has the most
warehouses with
one-million or more
square feet of space,
as well as warehouses
with half a million
square feet or more.

This reflects a trend
toward increasingly
large warehouses as
well as a trend
toward locating new
warehouses in San
Bernardino County.

Figure 1: Number of Large Warehouses by County
Source: Economic Roundtable analysis; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, Appendix C and other sources. 1,638
885
404 399
0 200
400
600
800
1,000
1,200
1,400
1,600
1,800
Los Angeles San
Bernardino
Riverside Orange
1,000,000+ SF
500,000 to 999,999 SF
250,000 to 499,999 SF
100,000 to 250,000 SF
10 Exhausting Our Air
Sixty-two percent of large warehouses have less than 200,000 square feet of space, but they account for only 35 percent of total warehouse space. Nine Figure 3: Total Square Feet of Large Warehouse Space in the Four-County Region by Warehouse Size and Decade

0 100,000,000
200,000,000
300,000,000
400,000,000
500,000,000
600,000,000
700,000,000
800,000,000
900,000,000
1942 &
Earlier
1943 to
1952
1953 to
1962
1963 to
1972
1973 to
1982
1983 to
1992
1993 to
2002
2003 to
2012
2013 to
2022
Total Square Feet of Space in Large Warehouses
Decade
500,000+
SF
400,000 to
499,999 SF
300,000 to
399,999 SF
250,000 to
299,999 SF
200,000 to
249,999 SF
150,000 to
199,999 SF
100,000 to
149,999 SF
Figure 2: Number of Large Warehouses Built in Each Decade by County Source: Economic Roundtable analysis and South Coast Air Quality Management District (SCAQMD). 0 100
200
300
400
500
600
Pre-1970s 1970s 1980s 1990s 2000s 2010s
San
Bernardino
Riverside
Orange
Los Angeles
Exhausting Our Air 11
percent of warehouses have 500,000 or more square feet, and they account for 30 percent of total warehouse space.

Recent construction of large warehouses has been concentrated in the Inland Empire – San Bernardino and Riverside Counties (Figure 2). New warehouses continue to be built, and because many of them are very large, the total square footage of warehouse space is increasing rapidly.

Over the past three decades, from 1993 through 2022, an average of over 17 million square feet of warehouse space has been built each year in the four-county region, as shown in Figure 3. This is an increase of 42 percent, or 175 million square feet, each decade. This steep rate of growth shows no evidence of slowing.

Warehouses are nodes in a logistics network that moves goods from where they are produced to where they are consumed. The growth in warehouse space in accompanied by a corresponding increase in diesel truck drayage.

The City of Ontario is home to 278 large warehouses, with over 81 mission square feet of space - by far the most of any city in the four-county Figure 4: Total Square Feet of Space in Large Warehouses by City Source: Economic Roundtable analysis and South Coast Air Quality Management District (SCAQMD). 10,337,069
10,811,063
10,895,592
11,154,994
12,872,746
14,607,249
15,640,039
22,049,074
22,279,697
22,445,249
23,691,172
24,645,773
24,715,608
25,149,893
25,697,104
25,860,919
26,635,719
27,476,992
30,943,289
35,220,833
48,803,707
49,122,306
81,755,360
Irvine OR
Torrance LA
Long Beach LA
Corona RIV
Compton LA
Anaheim OR
Vernon LA
Jurupa Valley
Carson LA
Riverside RIV
Redlands SB
Commerce LA
Perris RIV
R. Cucamonga SB
Rialto SB
Santa Fe Springs LA
Moreno Valley SB
San Bernardino SB
Los Angeles LA
Chino SB
City of Industry LA
Fontana SB
Ontario SB
12 Exhausting Our Air
region, as shown in Figure 4. The large number of warehouses in Ontario may be the result of economic downturns in the city’s recent past, as well as economic desperation for growth of any kind.

Facing $296 million of unfunded liabilities, a $45 million budget shortfall, and depleted general fund reserves, San Bernardino filed for Chapter 9 bankruptcy on August 1, 2012. In the years leading up to bankruptcy, San Bernardino suffered heavily as important sources of revenue fell, notably property taxes, vehicle license fees, and redevelopment funds.2 The city remained in bankruptcy until 2017.3
There are 23 cities with over 10 million square feet of space in large warehouses shown in Figure 4 are home to 75 percent of all of the space in large warehouses in the four-county region. Ontario has 81 million square feet of large warehouse space, which is 10 percent of the total space occupied by large warehouses in the four-county region.

The average year when warehouses in Ontario were built is 1997, a more recent vintage than warehouses in Los Angeles, as shown in Figure 5. The sequence of warehouse development reflects migration to more outlying Figure 5: Average Year when Warehouses Were Built by City

1971
1972
1973
1983
1983
1988
1989
1991
1991
1994
1997
1999
2000
2001
2004
2004
2008
2009
2010
2011
1950 1960 1970 1980 1990 2000 2010 2020
Commerce
Los Angeles
Vernon
Compton
La Mirada
City of Industry
Carson
Santa Fe Springs
Jurupa Valley
R. Cucamonga
Ontario
Corona
Riverside
Chino
San Bernardino
Fontana
Redlands
Perris
Rialto
Moreno Valley
Exhausting Our Air 13
areas in the past three decades as land in Los Angeles and Orange became increasingly expensive.

The runner-up with the second-most warehouses is the City of Industry in Los Angeles County. The average year of construction for these warehouses was 1988 - roughly a decade earlier than Ontario. They were built when there was low-cost, greenfield real estate in the San Gabriel Valley. Vacant fields with native plants in the City of Industry were declared to be blighted and a redevelopment authority was established to eliminate blight by building industrial and warehouse facilities along the Union Pacific railroad line.

The 114 large warehouses in the City of Carson are another example of development on low-cost land close to the urban center. The average year of construction for warehouses in Carson was 1989 – similar to the City of Industry. When Carson incorporated as a city in 1968, its landscape was pockmarked with the dozens of refuse dumps, landfills and auto dismantling plants that none of the neighboring cities would allow within their boundaries.4 The up-side for Carson was that it is close to the Ports of Los Angeles and Long Beach, and is bounded by four freeways. Carson’s dumping grounds were replaced by facilities such as the Watson Industrial Center, a large warehouse and light industry complex.

If the only objective were to minimize transportation logistics, warehouses would be concentrated by the Ports of Los Angeles and Long Beach.

However, land costs closer to these public ports are high, and the need for low land costs overrides the need for low transportation costs.

In the 1970s and 1980s, warehouse development was concentrated in Los Angeles County. In the 1990s it shifted to San Bernardino and Riverside Counties. Within the Inland Empire there has been further migration toward lower cost land, shifting most recently from Ontario to Redlands, Perris, Rialto, and Moreno Valley.

The largest warehouses cover more than 20 acres, so the cost of land is an important factor in determining where warehouses are built.

Clusters of Large Warehouses
The locations of large warehouses are the result of past infrastructure investments – such as railroad lines and rail yards, seaport drayage lands and the roads for bringing cargo in and out of the ports, as well as land costs and land use zoning. The locations of the largest warehouses, across San Bernardino, Riverside, Los Angeles and Orange Counties, with their actual building footprints, are shown in Figure 6.
14 Exhausting Our Air
There is a large cluster of warehouses along the rail corridor connecting Los Angeles’ Union Station north of downtown with the Union Pacific and Burlington Northern Santa Fe railyards Southeast of downtown.

Large warehouses are likewise clustered just north of the San Pedro Ports, where shipping containers arriving by sea have their contents unpacked, repalletized and put on truck chassis and railcars.

There is a crescent of large warehouses arcing along the Pomona Freeway in the City of Industry, Rowland Heights and Walnut, along the Union Pacific rail line.

The Inland Empire is where the newest clusters of large warehouses are located. The recent building boom of large warehouse is driven by lower warehouse leasing costs, access to interstate freeways and air cargo facilities at Ontario Airport, San Bernardino International Air Port and March Air Reserve Base.

Figure 6: Map of Large Warehouses subject to SCAQMD Rule 2305 Source: Economic Roundtable analysis, Southern California Air Quality Management District (SCAQMD) May 7, 2021, Board Meeting Packet for Agenda Item #27,” Proposed Rule 2305 – Warehouse Indirect Source Rule – Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program.” Data originally acquired from CoStar.

Exhausting Our Air 15
Low land costs offset the Inland Empire’s distance from retail stores, consumer neighborhoods, and the San Pedro Bay Ports. Equally important is some county and city governments’ willingness to approve the continued construction of large warehouses, opening the door to warehouse clusters in Ontario, Rancho Cucamonga, Chino, Rialto, Riverside, Redlands, Moreno Valley, and Perris.

Warehouse Locations and Economic Equity
In 2018, consumers in the four-county region purchased over $31 billion in retail goods.5 These non-food retail items account for roughly 16 percent of household expenditures.

The estimated average amount of household retail purchases in each census tract in 2018 is shown in Figure 7. These purchase levels are closely associated with household income in each tract. The darkest shade of brown shows tracts in which the average household made $16,000 or more in retail purchasers. These tracts are located in affluent coastal and foothill areas. At the low end of spending levels, tracts that spent less than $8,000 Figure 7: Estimated Average Retail Sales per Household by Census Tract Source: Derived from U.S. Census Bureau American Community Survey 2013-2017 household income data, U.S. Bureau of Labor Statistics Household Consumption breakout of household consumption by item and income level. 16 Exhausting Our Air
for retail goods are shown in yellow. These are lower-income tracts in flatland areas.

Warehouses and the workers employed in them are located in lower income communities. particularly areas south and east of downtown Los Angeles, in Ontario, and further east in San Bernardino County. These lower-income communities are also where warehouse workers live.

The communities that primarily benefit from services of the logistics sector are higher-income communities, far-removed from the noise and emissions caused by diesel trucks and warehouses.

Number of Warehouse Workers
The warehouse industry in the four-county region employs just under 93,300 people in all occupations in warehouses of all sizes (Table 1). 6 Los
Angeles County still accounts for the plurality of these workers, over 36,000, or 39 percent of the region’s total. Orange county has the lowest number of warehouse workers, just over 5,400, or six percent.

Table 1 All Warehouse Workers by County
County Employed Warehouse
Industry Workers
Percent of
all Workers
Los Angeles County 36,349 39%
Orange County 5,410 6%
Riverside County 18,973 20%
San Bernardino County 32,539 35%
Region Total 93,271 100%
Source: Economic Roundtable analysis; U.S. Census Bureau, 2020 5-Year American Community Survey (ACS) Public Use Microdata Sample (PUMS).

From this total, we estimate that just over 67,500 workers are employed at the region’s largest warehouses – those of 100,000 square feet or more (Table 2). Almost 44,000 of these workers, or 65 percent, work in the Inland Empire. Los Angeles County has a smaller share of workers in large warehouses – 29 percent, while Riverside and San Bernardino Counties account for a greater share of workers in large warehouses. Orange County has the same share of the four-county warehouse labor force in both large warehouse all warehouses.

Table 2 Large Warehouse Workers by County
County No. of Large
Warehouses
SF of Large
Warehouses
Employment
Estimate
Percent of
Employment
Los Angeles County 1,626 314,911,990 19,686 29%
Orange County 389 74,175,185 4,071 6%
Riverside County 402 131,212,586 17,238 26%
San Bernardino County 876 283,029,002 26,570 39%
Region Total 3,293 803,328,763 67,565 100%
Source: Economic Roundtable analysis; U.S. Census Bureau, 2020 5-Year American Community Survey (ACS) Public Use Microdata Sample (PUMS).

Exhausting Our Air 17
Warehouse employment changes by season and also when companies rearrange their supply chains because of changing demand in different regional markets. Our methodology accounts for the low vacancy rate in warehouse properties, since a small number sit idle at any given time.

The methodology for this employment estimate of workers in large warehouses, along with the occupational breakdown of this labor force, is described in the Data Appendix, which also includes a table of warehouse employment by city.

Occupations and Wages of Warehouse Workers
Workers in a wide range of occupations come together to operate warehouses, as shown in Table 3. The majority of the over 67,500 warehouse workers are employed in Transportation and Material Moving jobs, about 64 percent of the total. These workers include forklift operators and packers, as well as workers who control or tend to conveyor systems that move products to and from stockpiles. This job family also includes workers who move freight on and off trucks at warehouse docks, shipping machine feeders / off-bearers, who put goods into and remove them from automated packing and labelling equipment. There are about 60,000 of these workers in the four-county region, handling the stocking and filling of orders in warehouses. Their median annual pay is $25,154.

Table 3 Warehouse Worker Occupations and Median Wages
Occupation Groups
Number of
Workers
Percent of
Warehouse
Work Force
Median
Annual
Wage
11-0 Management 5,358 6% $52,169
13-1 Business Operations 1,168 1% $45,213
13-2 Financial 251 0.3% $30,432
15-0 Computer & Mathematical 348 0.4% $67,412
17-0 Architecture & Engineering 108 0.1% $30,683
23-0 Legal 102 0.1% $140,861
25-0 Education, Training, & Library 128 0.1% $85,422
27-0 Arts, Design, Entertainment, Sports, & Media 71 <0.1% $5,434 31-0 Healthcare Support 31 <0.1% $11,571
33-0 Protective Service 459 0.5% $24,546
35-0 Food Preparation & Serving Related 123 0.1% $36,551 37-0 Building & Grounds Cleaning & Maintenance 1,000 1.1% $23,491 39-0 Personal Care & Service 14 <0.1% $46,995
41-0 Sales & Related 902 1.0% $26,108
43-0 Office & Administrative Support 14,926 16% $28,475 45-0 Farming, Fishing, & Forestry 15 <0.1% $21,355
47-0 Construction & Extraction 255 0.3% $42,711
49-0 Installation, Maintenance, & Repair 769 0.8% $40,910 51-0 Production 7,598 8.1% $24,148
53-0 Transportation & Material Moving 59,645 64% $25,154 Total 93,271 100% $26,160
Source: Economic Roundtable analysis; U.S. Census Bureau, 2020 5-Year American Community Survey (ACS) Public Use Microdata Sample (PUMS), Occupational distribution for NAICS Industry (NAICSP) 493 (TRN-Warehouse and Storage), Employment Status Recode (ESR) is limited to “Civilian Employed, at Work” with at least $500 annual earnings. 18 Exhausting Our Air
The second largest job family Office and Administrative Support workers, accounting for just under 15,000 jobs in the region, or 16 percent of the industry’s labor force. This occupation group includes shipping, receiving, and inventory clerks, order clerks, weighers, measurers, checkers, recordkeeping clerks, general office clerks, production, planning, and expediting clerks, and their front-line supervisors. Their median annual pay is $28,475.

The third largest job family is Production workers, with an estimated 7,600 employed – just over 8 percent of the total industry workforce. This occupation group includes package inspectors, packaging assemblers and fabricators, packaging and filling machine operators and tenders, and their first-line supervisors. Their median pay is $24,148.

The fourth largest warehouse job family is Managers, which includes those overseeing general warehouse operations, sales, facilities maintenance, human resources and information systems. There are over 5,300 of these workers in the study region – about 6 percent of the labor warehouse force. Warehouse managers’ median annual pay is just over $52,000.

The remainder of warehouse occupations are small, adding up to just over 5,700 workers – 6 percent of the warehouse workforce.

The number of workers in large warehouses by county and rolled up into broad occupational category is shown in Figure 8. These occupational categories roll-up the detailed occupational breakout shown in Table 3.

Figure 8: Number of Workers in Large Warehouses, by Occupational Category and County
Source: Economic Roundtable analysis; U.S. Census Bureau, 2020 5-Year American Community Survey Public Use Microdata Sample, Occupational distribution for NAICS Industry 493 (TRN-Warehouse and Storage), Employment Status Recode (ESR) is limited to “Civilian Employed, at Work” with at least $500 annual earnings. 12,589
2,604
11,023
16,991
19,686
4,071
17,238
26,570
0 5,000
10,000
15,000
20,000
25,000
30,000
Los Angeles County Orange County Riverside County San Bernardino County
Management Occupations
Other Occupsations
Production Occupations
Office and Administrative Support
Transportation and Material Moving
Exhausting Our Air 19
Community Profile: Cesar Avila, Truck Driver, and Maria Rubio, Retired
Cesar Avila (65) and Maria Rubio (53) and their family live two blocks away from the San Bernardino International Airport. They are immigrants from Guatemala and Mexico who have been living in the United States for over 40 years. They have lived in San Bernardino for the past 12 years but are now at risk of losing their home because of a large redevelopment led by the airport to rezone their homes to make room for future warehouse development.
20 Exhausting Our Air
Cesar is an interstate truck driver who sometimes spends days or weeks on the road and Maria tends to their home and children. A typical day for Cesar and Maria when they are not working is to tend to the home, go to church, visit family and rest. Since 2020 Maria and Cesar have had to deal with the stresses of Maria’s health and wellbeing. Maria constantly deals with coughing, bronchitis and pneumonia. Last year, she had to start using an oxygen machine at night to help her with her breathing. The doctor says she has to use it for life. They both know it is from living so close to a growing freight international airport. Cesar and Maria are deeply involved in organizing in their neighborhood for justice for themselves and their neighbors.

What is your relationship to the logistics industry? How does it show up in your life? Or in your neighborhood?
“We have been living in the United States for over 40 years. We have been living in San Bernardino since 2012. It has been getting harder to live here. We live in a small apartment two blocks away from the San Bernardino International Airport. It used to not bother us to live so close to the airport, but recently there have been more flights because of Amazon, Fedex and UPS operations, it is hard to ignore. - Maria There is so much pollution that comes from the airport that it gives us coughing attacks and the flu. We have proof that it comes from the airport pollution! We went to our doctors when we got pneumonia and they said it was from the pollution. We have never smoked a day in our life but our lungs are weak. We feel like we are choking in this Country by the air pollution.” - Cesar
“I have been on an oxygen machine for the last eight months. I will have to use it my whole life because the doctor does not have a better recommendation for me. I want my health to get better, because there is not a life like this. I cannot always be plugged into a machine. It is also costly to constantly use it.” - Maria
“We cannot be enemies to them, but the truth is they contaminate and they do not filter or do anything about it. They are hurting us with their contamination. It is not just the airport - warehouses are hurting us. Too many trucks drive around here because of the warehouses that are in our neighborhoods, and nobody says anything. We hear the refrigerated trucks running all night. All of this causes too much noise - all the trucks and the planes that fly right over our heads. We have seen so much traffic and road damages because of them” - Cesar
Exhausting Our Air 21
“Lots of undocumented people live in these areas and they do not want to get into problems and there is a fear of deportation. Even if they are sick because of the pollution, they do not want to get involved because there is a lot of fear and discrimination.” - Cesar
How does the transition of the logistics industry impact you? “I have never used a compressed natural gas truck or an electric truck but I know that it is good for the environment but that the driver might lose 5 hours because of charging. As drivers we only get 11 hours to drive and 3 to rest, shower and refuel. This is the only thing I am worried about. I am not worried about the cost because my company would get the truck. I just hope that the wages are not lowered because they had to buy the truck. Right now, I get paid enough to live and pay all my rents and bills.

One big worry that I have is that trucks are not using the exhaust filter they need to use to make their engines cleaner. The big companies I have worked for have always used the filters but I have noticed when I park at truck stops that smaller company trucks do not have them. That is fraud.

And it causes constant headaches and causes you to wake up with a cough.

But I know that some companies do it to cut costs.

I want things to get better. I want the pollution to get better and require the environmental agencies to push the big companies to do something.

I don't think the politicians are doing anything about the issues. I don’t think they care. They only care about their purse. Politicians need to do more. Even the big companies, like Amazon, Walmart, UPS and Fedex do not care. We hear their workers complaining about them all the time too.

I used to work at a warehouse, I didn't need to go to the gym because they had me running. It squeezes you out of yourself, that's why I became a truck driver because I got paid more. Driving used to be more lucrative, but now our work has gone down one-third.” - Cesar
What gives you hope about our future?
“Better representatives, things changing, more housing coming in gives me hope. Being able to buy homes, retire and use the open land for our communities instead of warehousing gives me hope. We need to get more resources. With the hand of God, we have to win! Primero Dios (first God)! We know we are not doing anything bad. These are our rights we are fighting for” – Maria
22 Exhausting Our Air
Exhausting Our Air 23

3. Truck Drivers and Trucking
Companies
----------------------------------------------------------------------------------------------------------------- Trailer chassis with cargo containers
at Inland Empire warehouse
Photo credit: Economic Roundtable
24 Exhausting Our Air
Overview
Trucking Companies
Trucking companies are concentrated near the San Pedro Bay Ports, with secondary concentrations in the Inland Empire. Most truck drivers live near trucking companies. Truck drivers and warehouse workers often live in the same neighborhoods. Their livelihoods require exposure to the emissions and noise of diesel trucks when they are working, and often these impacts are also part of the after-work environment at their homes.

Two-thirds of trucking companies have nine or fewer trucks. Only eight percent of companies have 125 or more trucks. Truck companies are predominantly small businesses. However, large corporate trucking companies dominate the industry. Companies with 125 or more trucks own 95 percent of the trucks that move cargo into and out of the ports.

Trucking is a far riskier line of business for small companies than for large companies. Forty-three percent of companies with one or two trucks are inactive, but almost no companies with eight or more trucks are inactive.

Ninety-three percent (15,259) of trucks moving cargo at the Ports of Los Angeles and Long Beach are currently powered by diesel fuel. Trucks typically remain in operation for 12 years. Declining annual shares of the current diesel truck fleet are likely to remain in operation until 2035.

Diesel trucks have the second highest greenhouse gas emissions per tonmile of any mode to cargo movement, exceeded only by cargo aircraft.

Their high greenhouse emissions and wide deployment make them a significant contributor to climate change.

Deploying Electric Trucks
State and regional environmental regulations are driving a rapid transition to new truck propulsion technology. Beginning January 1, 2024, truck fleets are required to replace diesel trucks that reach the end of their duty cycle with battery-powered electric trucks.

There is strong opposition to this regulation by trucking companies.

Nineteen states are seeking appellate court review in a challenge to the Environmental Protection Agency waiver granted to California’s Advanced Clean Trucks Rule. Similarly, the California Trucking Association is challenging the South Coast Air Quality Management District’s rule that makes warehouses accountable for emissions from diesel trucks delivering cargo to warehouses.

Eight heavy-duty truck manufacturers have initiated small-scale manufacturing and sales for commercial Class 8, zero-emission, batteryelectric tractors. Most currently available electric trucks are capable of Exhausting Our Air 25
short-range drayage operations of roughly up to 175 miles between charges. This means that current battery-electric models are restricted to short-hauls or lighter-weight drayage tasks.

Given the current low-volume of electric truck sales, the purchase subsidies available in California are currently sufficient to reduce their cost to less than the cost for a diesel truck. However, there are only enough subsidy funds to cover a small fraction of the zero-emission trucks that must be put in service by 2035. As sales ramp up, there will be an interval when subsidies are scarce and the cost of electric trucks has not come down to the cost for diesel trucks.

Electricity Unavailable for Charging Stations
Electric truck dealers and fleet operators have identified delays in obtaining electric power for charging stations as the most serious obstacle for deploying electric trucks.

The need for electric truck charging stations is most concentrated above the ports, where many trucking companies as well as large warehouses are located, and at warehouse hubs in the City of Industry and in the Inland Empire from Ontario to the Moreno Valley. Charging stations will be needed at all of these sites.

Municipal utility districts, such as the Los Angeles Department of Water and Power, are regulated by city councils rather than the California Energy Commission and must be locally activated to build the infrastructure required to meet electrical demand for recharging battery-electric trucks.

The supply of electricity to recharge battery-electric trucks is lagging the timetable set by California Air Resources Board for the transition to zeroemission drayage. Utility districts will be a bottleneck unless they act proactively to build the electrical distribution infrastructure required to support clean trucking.
26 Exhausting Our Air
Drayage Truck Drivers
The San Pedro Bay ports are the primary gateway for the $350 billion in goods that are imported annually to satisfy enormous consumer demand in the Western United States.7 There are 2,327 active drayage trucking companies registered with the Ports of Los Angeles and Long Beach that move goods from the ports to warehouses with a total of over 800 million square feet of space in the four-county region.

Drayage trucking companies are concentrated near the ports, with secondary concentrations in the Inland Empire, as shown in Figure 9. This is logistically practical because of proximity to the San Pedro Bay Ports.

Most truck drivers live near trucking companies. This is shown by the background colors in Figure 9, where darker colors represent higher residential density of truck drivers.

The U.S. Census Bureau’s American Community Survey reports that there are 68,074 truck drivers employed by the truck transportation industry Figure 9: Locations of Trucking Companies and Homes of Truck Drivers Sources: Location of trucking companies is from the Port of Los Angeles truck registry. The residential density of truck drivers is from the American Community Survey Public Use Microdata Sample for 2016-2020. The red dots indicate trucking companies. The background colors indicate residential density of truck drivers.

Number of truck drivers
residing in community
Exhausting Our Air 27
within the four-county study area. Over half live in Los Angeles County, one quarter live in San Bernardino County, and roughly one-tenth live in each Riverside and Orange Counties, as shown in Figure 10.

Three-quarters of truck drivers report that they are employed by a private, for-profit business, as shown in Figure 11. Almost one-quarter (24 percent) Figure 10: Share of Truck Drivers Residing in Each County Source: U.S. Census Bureau, American Community Survey, Public Use Microdata Sample for 2016-2020, for Los Angeles, Orange, Riverside, and San Bernardino Counties. 57%, Los Angeles
25%, San
Bernardino
10%, Riverside
8%, Orange
Figure 11: Types of Establishments that Employ Truck Drivers Source: U.S. Census Bureau, American Community Survey, Public Use Microdata Sample for 2016-2020, for Los Angeles, Orange, Riverside, and San Bernardino Counties. Public sector employment is excluded.

Private
for-profit
75%
Self-employed
in own
unincorporated
business
17% Self-employed in own
incorporated business
7%
Nonprofit
1%
28 Exhausting Our Air
are self-employed in their own business, either unincorporated or incorporated, and one-percent work for a nonprofit group. This breakout excludes a small number of truckers employed by government agencies.

The type of employer impacts the amount of pay that truck drivers receive, as shown in Figure 12. The typical (median) truck driver earns $46,024 a year; this is also the typical pay for truckers working for private, for profit companies, which dominate the industry. Earnings are higher, $51,138, for self-employed truckers who own an incorporated business, and even higher, $60,369, for the small number of truckers employed by nonprofit groups.

Truck drivers and warehouse workers often live in the same neighborhoods. Both groups of workers are predominantly Latino. And both groups have very similar levels of educational attainment, with almost three-quarters having no college education, as can be seen in Figure 13.

Truck drivers and warehouse workers differ in gender and age. Both groups of workers are predominantly male, but truck drivers are almost exclusively male (97 percent vs 68 percent of warehouse workers).

Truck drivers tend to be older than warehouse workers. Sixty percent are 45 years of age or older, while 73 percent of warehouse workers are less than 45 years old.

Figure 12: Median Annual Earnings of Truck Drivers by Type of Employer Source: U.S. Census Bureau, ACS Public Use Microdata Sample for 2016-2020, for Los Angeles, Orange, Riverside, and San Bernardino Counties. Earnings in 2020 dollars are for employed truck drivers in truck transportation industry. $46,024 $46,024 $51,138 $60,369 $46,024 $0
$10,000
$20,000
$30,000
$40,000
$50,000
$60,000
$70,000
Private
for-profit
Self-employed
in own
unincorporated
business
Self-employed
in own
incorporated
business
Nonprofit ALL TRUCKERS
Median Annual Earnings in 2020 $
Exhausting Our Air 29
Trucking Companies
The registry of 2,997 drayage trucking companies authorized to transport cargo containers to and from the Ports of Los Angeles and Long Beach includes companies with as few as one truck and as many as 24,000 trucks.

The ports are the primary entry point for consumer goods coming into the region, so this registry provides a reliable profile of the trucking companies trucks that deliver cargo to warehouses in the four-county region.8 Two-thirds of drayage trucking companies have nine or fewer trucks, as shown in Figure 14. Only eight percent of companies have 125 or more trucks. Truck companies in the region are predominantly small businesses.

Figure 13: Profile of Warehouse Workers and Truck Drivers in the 4-County Study Area Source: U.S. Census Bureau, American Community Survey, Public Use Microdata Sample for 2016-2020, for Los Angeles, Orange, Riverside, and San Bernardino Counties. 10%
18%
21%
31%
21%
3%
23%
45%
29%
2%
3%
8%
6%
81%
32%
68%
26%
34%
23%
17%
2%
6%
22%
40%
32%
2%
8%
7%
16%
68%
3%
97%
0% 20% 40% 60% 80% 100%
55 +
45 - 54
35 - 44
25 - 34
18 - 24
AGE
B.A. Degree+
Some College
High School Diploma
No High School Diploma

EDUCATION
Other
Asian Am or Pac Islander
African American
European American
Latino

ETHNICITY
Female
Male
GENDER
Truck Driver
Frontline
Warehouse
Worker
30 Exhausting Our Air
However, large corporate trucking companies dominate the industry.

Companies with 125 or more trucks own 95 percent of the trucks that move cargo into and out of the ports, as shown in Figure 15.

Figure 14: Distribution of Trucking Companies Serving the San Pedro Bay Ports by Number of Trucks Owned
Source: Random sample of 304 trucking companies registered with the Ports of Los Angeles and Long Beach, and data for each company from the U.S. Department of Transportation FMCSA Safety and Fitness Electronic Records System. 26%
22%
18% 17%
9% 8%
0%
5%
10%
15%
20%
25%
30%
1 Truck
2-4
Trucks
5-9
Trucks
10-28
Trucks
29-124
Trucks
125+
Trucks
Percent of Trucking Companies
Size of Company Based on Number of Trucks Owned
Figure 15: Share of All Trucks Owned by Companies in Each Size Category Source: Random sample of 304 trucking companies registered with the Ports of Los Angeles and Long Beach, and data for each company from the U.S. Department of Transportation FMCSA Safety and Fitness Electronic Records System.

0.1% 0.3% 1% 2% 3%
95%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
1 Truck
2-4
Trucks
5-9
Trucks
10-28
Trucks
29-124
Trucks
125+
Trucks
Percent of All Trucks Owned
Size of Company Based on Number of Trucks Owned
Exhausting Our Air 31
Large companies serving the ports include J.B. Hunt Transport, Inc., headquartered in Arizona with 24,040 trucks and Swift Transportation Company, headquartered in Arizona with 15,907 trucks
Twenty-nine percent of trucking companies registered with the Ports of Los Angeles and Long Beach have gone out of business. Nearly all of the companies that close have only one or two trucks. In the sample of 304 trucking companies analyzed, 43 percent of companies with one or two trucks are inactive, but no companies with eight or more trucks have gone out of business, as shown in Figure 16. Trucking is a far riskier line of business for small companies than for large companies.

Trucks
Ninety-three percent (15,259) of trucks moving cargo at the Ports of Los Angeles and Long Beach are currently powered by diesel fuel, six percent (872) use natural gas in compressed (CNG) or liquid (LNG) form, and 0.3 percent (81) are electric, as shown in Figure 17. This is a total of 16,232 trucks serving the ports.9
The shift from diesel fuel to electricity that has been mandated by the California Air Resources Board is a massive technological transition.10 Figure 16: Business Closure Rate for Trucking Companies Based on Size Source: Random sample of 304 trucking companies registered with the Ports of Los Angeles and Long Beach, and data for each company from the U.S. Department of Transportation FMCSA Safety and Fitness Electronic Records System. 57%
84%
98% 100%
43%
16%
2% 0%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
1-2 Trucks 3-5 Trucks 6-18 Trucks 19+ Trucks
In Business Out of Business
32 Exhausting Our Air
Detailed records for truck trips at the San Pedro Bay Ports are available for November 2022, a month when there were 305,234 trips. Over half of the Figure 17: Fuel Type of Trucks Transporting Containers in the San Pedro Bay Ports Source: Port of Los Angeles Clean Truck Program, Gate Move Analysis (includes the Port of Long Beach), November 2022.

Diesel, 93%
CNG, 4%
LNG, 2%
Electric, 0.3%
Figure 18: Truck Trips at the Ports of Los Angeles and Long Beach by Engine Year Source: Port of Los Angeles Clean Truck Program, Gate Move Analysis (includes the Port of Long Beach), November 2022. 5%
6%
4%
5%
6%
4%
8%
13%
16%
8%
5%
4%
4%
3%
4%
4%
0% 2% 4% 6% 8% 10% 12% 14% 16% 18%
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
Exhausting Our Air 33
trips (52 percent) were by trucks with engines built before 2015, as shown in Figure 18.

Trucks typically remain in operation for 12 years, although 20 percent of the trips shown in Figure 18 were by trucks with engines that were older than this – older trucks with engines manufactured from 2007 to 2010.

Nevertheless, the 12-year life cycle is a benchmark for projecting emissions produced by the current fleet of diesel trucks transporting cargo containers to warehouses, and the rate at which electric trucks will replace this fleet.

Declining annual shares of the current diesel truck fleet are likely to remain in operation until 2035.

Emissions per Cargo Mile
Cargo is moved by trains and planes, as well as diesel trucks, with the prospect of an increasing share being moved by electric truck. The most common choice is whether to move cargo containers by truck or train.

Different modes of transportation have significantly different environmental impacts.

Cargo aircraft produce 50 times more greenhouse gas emissions per ton-mile of cargo movement than trains, as shown in Figure 19.

Figure 19: Grams of Greenhouse Gas Emissions per Ton-Mile of Cargo Movement Source: Congressional Budget Office and Economic Roundtable analysis of electric trucks based on utility emissions. 1,166
181
44 23
0 200
400
600
800
1,000
1,200
Cargo Planes Diesel Trucks Electric Trucks Trains
34 Exhausting Our Air
The energy required to lift cargo aircraft off of the ground and move rapidly through the air produces 1,166 grams of carbon dioxide and related greenhouse gas (GHG) emissions per ton-mile of flight.

Diesel trucks have the next highest GHG emissions, producing 181 grams per ton-mile.

Electric trucks produce 44 grams of GHG per ton-mile based on the greenhouse gas emission from generating electricity for the electricity grid.11
The large volume of cargo moved by a single train requires a small amount of fuel compared to the overall weight of the cargo, with only 23 grams of GHG produced per ton-mile.

The quantity of criteria emissions produced by transporting cargo is about one-thirtieth the quantity of the greenhouse gas emissions. This can be seen by comparing grams of greenhouse gas emissions in Figure 19 to grams of criteria emissions in Figure 20.

Figure 20: Grams of Criteria Emissions per Ton-Mile of Cargo Movement Source: California Air Resources Board and Economic Roundtable analysis of electric trucks based on utility emissions.

Trains Cargo
Planes
Diesel
Trucks
Electric
Trucks
Sulfur dioxide (SOx) 0.1 0.03
Particulate matter (PM) 0.5 0.1 0.0005
Hydrocarbons (HC) 1.7 0.001
Carbon Monoxide (CO) 7.7 0.01
Nitrogen oxide (NOx) 19.4 3.7 0.1 0.03
0 5
10 15
20 25
30 Exhausting Our Air 35
These emissions and their effects include:
• Nitrogen oxide (NOx), which contributes to ozone depletion in the upper atmosphere12 and damages the human respiratory system. • Carbon monoxide (CO), which can cause fatigue, headaches, confusion, and dizziness due to inadequate oxygen delivery to the brain, and also has a weak direct effect on climate by contributing to ozone formation.
13 • Particulate matter (PM), which can cause premature death in people with heart or lung disease, nonfatal heart attacks, irregular heartbeat, aggravated asthma, and decreased lung function. In addition to these health impacts, it is a main cause of reduced visibility (haze).14 • Sulfur dioxide (SOx), which can irritate the skin and mucous membranes of the eyes, nose, throat, and lungs. It can also damage vegetation, affect soils, acidify lakes and streams, and ruin memorials and building facades.
15 Trains
Trains have the lowest greenhouse gas emissions of any mode of cargo movement but produce 32 times more criteria emissions per ton mile than any other mode of cargo transportation. This is because many of the locomotives are old and have old engine technology with little if any emission controls.

Over one-third of locomotives (37 percent) were manufactured from 1973 to 1992, and are fuel guzzlers. These old locomotives produce 15.7 grams of criteria emissions for each brake-horsepower-hour of operation.

Over another third (39 percent) of locomotives were manufactured from 1993 to 2011 and also are energy-intensive, producing 10.4 grams of emissions per brake-horsepower-hour of operation.
16 Cargo Airplanes
Cargo airplanes have the highest greenhouse gas emissions of any mode of cargo movement – six times more per ton-mile than diesel trucks. They also produce the second greatest quantity of criteria emissions - 42 times more per ton-mile than diesel trucks.

Transporting cargo by plane gets goods into the hands of consumers quickly but is not friendly to the environment.

Diesel Trucks
Diesel trucks have the second highest greenhouse gas emissions per ton-mile and the second lowest criteria emissions per ton-mile of any mode of cargo 36 Exhausting Our Air
movement. Their high GHG emissions make them a significant contributor to climate change, while their more recent engine technology and stricter air quality controls yield lower criteria emissions.

Electric Trucks
Electric trucks have very low greenhouse gas emissions, created upstream from generating utility electricity used to recharge truck batteries. GHG emissions from electric trucks are slightly greater than from trains.

Criteria emissions from generating power for electric trucks are infinitesimal – by far the lowest of any mode of cargo movement. This is because the power generation facilities that produce electricity for utilities have low emissions, using air quality controls at scale and at centralized locations.

Electric trucks stand out as the cleanest mode of cargo movement.

Diesel Truck Emissions between Ports and Warehouses
Criteria Emissions
Warehouses in the four-county region are an average of 55 miles from the Ports of Los Angeles and Long Beach. In 2022, the two ports recorded Figure 21: Estimated Annual Tons of Criteria Emissions in 2022 by Diesel Truck Trips at the Ports of Los Angeles and Long Beach
Source: Port of Los Angeles Clean Truck Program Gate Move Analysis and CARB emissions inventory. 594
62 15 13 1
0 100
200
300
400
500
600
1 Annual Tons of Emissions
NOx
(Nitrogen
Oxides)
N2O
(Nitrous
Oxide)
PM2.5 (Fine
Particulate
Matter)
ROG
(Reactive
Organic Gas)
CH4
(Methane)
Exhausting Our Air 37
over four million truck trips at the ports, representing over 212 million miles traveled to large warehouses by diesel trucks.17 This is only part of total drayage activity moving consumer goods in the four-county region, but the detailed port records make it possible to calculate the criteria emissions produced by these truck trips, which are shown in Figure 21.

Diesel truck trips from the ports to warehouses produced an estimated total of 685 tons of criteria emissions in 2022. Nitrogen oxides made up most of these emissions - 87 percent. Nitrous oxide made up 9 percent of the emissions. Fine particulate matter and reactive organic gas each made up 2 percent, and methane made up 0.1 percent.18
Greenhouse Gas Emissions
California’s current diesel truck fleet produces 3.7 pounds of carbon dioxide for each mile it travels.19 The more than 212 million miles of travel to large warehouses by diesel trucks at the ports in 2022 produced an estimated 390,459 tons of carbon dioxide that was released into the air.

Uncompensated Public Costs from Diesel Trucks
Because trucks share the road with many other types of vehicles, they have less accountability for their impacts on the routes they travel than trains.

Railroads must repair and maintain their rail systems, whereas trucking companies pay fuel and tire taxes that contribute to road maintenance.

The Congressional Budget Office determined that uncompensated public costs for wear and tear on roads and bridges; delays caused by traffic congestion; injuries, fatalities, and property damage from accidents; and harmful effects from exhaust emissions are eight times greater per ton-mile for goods transported by truck than for goods transported by train. 20 Clean Truck Mandate
Drayage truck regulations under the California Air Resources Board’s Advanced Clean Fleets Regulation and warehouse accountability standards under the South Coast Air Quality Management District’s Indirect Source Rule 2305 create a rapid timeline for conversion to zero-emission trucks.21 California Air Resources Board
On April 28, 2023, the California Air Resources Board (CARB) passed the Advanced Clean Fleets regulation, which will require truck owners to transition their vehicles to zero-emission trucks.
38 Exhausting Our Air
Trucks must register with CARB in order to obtain a California vehicle license. Beginning January 1, 2024, all new drayage trucks registering in the CARB Online System must be zero-emission. Existing internal combustion engine vehicles can remain in the Drayage Truck Registry until 2035. After that, no internal combustion engine vehicles will be allowed in the registry.

Drayage trucks are heavy-duty (Class 8) trucks that transport containers and bulk freight between ports and intermodal rail facilities or warehouses.

There are also requirements for high priority fleets, which are fleets with 50 or more trucks or annual revenue of $50 million or more. High priority fleets can only purchase zero-emission trucks starting in January 2024 and must take trucks with internal combustion engines out of their fleets by the start of 2025. There are different annual milestones for the share of the fleet that must be zero-emission based on whether the vehicles are day-cab tractors or sleeper-cab tractors.

Government fleets must have 50 percent zero-emission truck purchases starting in 2024 and 100 percent zero-emission purchases by 2027. A fleet of fewer than 10 vehicles can wait until 2027 before being required to buy only zero-emission vehicles.

This regulation will result in nearly half of heavy-duty trucks becoming zero-emission by 2035 and about 70 percent to be zero-emission by 2042.

This will reduce the harmful impacts of tailpipe emissions and disruptive noise in neighborhoods located near seaports, intermodal railyards, warehouses, and distribution centers.

There is strong opposition to this regulation by trucking companies.

Nineteen states have sought appellate court review in a challenge to the Environmental Protection Agency waiver granted to California’s Advanced Clean Trucks Rule. This includes Arizona and Nevada, which have less restrictive emission regulations and where many large trucking fleets that serve California are based. In addition, the size of California’s trucking network might well cause its zero-emission standards to become national standards, affecting truck fleets throughout the nation.22 South Coast Air Quality Management District
The South Coast Air Quality Management District adopted the Warehouse Indirect Source Rule, Rule 2305 to reduce nitrogen oxide and particulate matter emissions produced by trucks traveling to and from large warehouses. The rule regulates owners and operators of warehouses greater Exhausting Our Air 39
than 100,000 square feet as indirect sources of nitrogen oxide and particulate matter emissions from trucks.

The rule establishes a menu-based system of points requiring warehouse operators to earn a specified number of points annually by completing actions such as acquiring near zero emission or zero emissions on-road trucks, cargo-handling equipment, charging infrastructure, solar panels, or particulate filters for nearby sensitive land uses. Alternatively, warehouse operators can pay a mitigation fee.23
An accompanying Rule, number 316, establishes fees for the reports, notifications, applications, and mitigation fees called for by Rule 2305.

The California Trucking Association is challenging Rule 2305 in federal court, asserting that it is preempted by the federal Clean Air Act. The suit asserts that Rule 2305 is designed solely to accelerate the transition of truck fleets to zero-emission and near-zero-emission trucks.
24 Rapid Change
State and regional environmental regulations are driving a rapid transition to new truck propulsion technology. Beginning in 2024, truck fleets are required to replacing diesel trucks that reach the end of their duty cycle with battery-powered electric trucks.

Clean Trucks
Availability
Eight heavy-duty truck manufacturers have initiated small-scale manufacturing and sales for early commercial Class 8 zero-emission battery-electric tractors.
25 These are heavy-duty or semi-trucks that pull
trailers, for example, chassis loaded with cargo containers. The manufacturers and truck models are:

1. BYD, 8TT (T9/Q3M)

2. Freightliner (Daimler), eCascadia

3. Kenworth, T680(e)

4. Lion Electric, Lion 8T

5. Nikola, Tre BEV

6. Peterbilt, e579

7. Tesla, Semi

8. Volvo, VNR Electric 6x4
These trucks are available from manufactures with a typical delivery time of six months.
40 Exhausting Our Air
Functionality
Most currently available electric trucks are capable of meeting basic performance requirements for short-range drayage operations, roughly up to 175 miles between charges. Actual mileage is often less than the listed mileage. Some routes require climbing grades, such as over the Kellogg Pass, while hot weather increases the use of air conditioning, and the weight of loads varies. This means that current battery-electric models are largely restricted to short-haul or lighter-weight drayage tasks.

Despite these limitations, current battery electric trucks can perform a significant share of drayage functions related to moving cargo containers from the ports to warehouses, for example, warehouses in Los Angeles and Orange Counties, as well as distributing goods from warehouses to retail locations within 50 miles.

The California Air Resources Board has documented strong year-over-year progress by major manufacturers in designing, testing, improving, and commercializing Class 8 battery-electric trucks suitable for drayage. 26 This
indicates that the capabilities and reliability of electric trucks will continue to improve and that they will be able to perform all drayage functions currently performed by diesel trucks.

Cost
Truck dealerships interviewed by the Economic Roundtable cited costs of $500,000 to $550,000 for Class 8 battery electric trucks. However, subsidies that currently are available can reduce the purchase cost to less than the cost for a conventional diesel truck.

The subsidy programs include
• San Pedro Ports Clean Trucks Program, which will disburse approximately $45 million a year to accelerate the deployment of zero-emission trucks serving the ports.27
• California Hybrid and Zero-Emission Voucher Incentive Project (HVIP), which will provide an estimated $157 million in subsidies for zeroemission drayage trucks.28 • South Coast AQMD Voucher Incentive Program for On-Road HeavyDuty Vehicles, which has $100 to $150 million to subside small fleets in replacing trucks with engines manufactured in 2017 or earlier with new zero-emission vehicles.29
• Southern California Edison Charge Ready Program, which has $432 million to subsidize the costs for installing charging equipment, including helping offset the cost to design, construct, and install charging infrastructure for both cars and trucks.30
Exhausting Our Air 41
These subsidies add up to half a billion dollars over the next five years to support purchases of electric trucks, with additional subsidies for charging infrastructure in areas served by Southern California Edison.

The subsidies far exceed current purchases of electric trucks, which now are in the single digits in Southern California from most manufacturers.

However, there are approximately 16,232 trucks active in the San Pedro Bay Ports. Diesel trucks have a roughly 12-year life span. This means that approximately 1,353 new trucks typically enter service at the ports every year.

If the new battery electric trucks cost half a million dollars each, the cost for the typical truck replacement cycle would be $676 million a year. This would deplete the subsidies that are available in a single year.

The practical reality is that many truck companies are likely to defer purchases of new battery-electric trucks for several additional years and that costs will come down as sales volume increases. Nevertheless, there will be an interval when subsidies are scarce and the cost of battery-electric trucks has not come down to the cost for diesel trucks. This will be particularly problematic for owner-operators and owners of small fleets, who do not have the financial resources or sophistication of large fleet owners.

Infrastructure
Charging stations for battery-electric trucks represent growth for electric utilities. It is reasonable for utilities to support commercial customers with electric truck adoption by offering financial incentives and rebates for charging infrastructure, as well as hiring and training experts who can help fleets design and implement necessary facility and electrical upgrades.

The California Energy Commission adopted Rule 29, which requires utilities to provide this support. Southern California Edison (SCE) explains that:

Under Rule 29, SCE will coordinate and pay for the design and deployment of eligible electrical service extension work from SCE’s electrical distribution line facilities to the customer installed meter panel or meter pedestal on the utility side of the meter for separately metered EV charging station projects.31
42 Exhausting Our Air
However, electric truck dealers and fleet operators have identified delays in obtaining electric power for charging stations as the most serious obstacle for deploying electric trucks. There is a mismatch between the multi-year timeline that is typical for upgrading the utility infrastructure and the rapid deployment of electric trucks required by the California Air Resources Board. Fleet operators report that they are being told it will take two years to obtain electric power for their charging stations.

Southern California Edison has stated that they are experiencing supply chain constraints in critical equipment necessary to complete and energize electric truck charging stations. This includes utility transformers and switch gear. Edison also noted that electrical capacity is inadequate in some areas of its distribution grid.32
The need for electric truck charging stations is most concentrated above the ports, where many trucking companies as well as large warehouses are located, as shown in Figure 22. The utility districts serving this area are the City of Los Angeles Department of Water and Power (DWP) and Southern California Edison.

In addition to overnight charging at trucking establishments, batteryelectric trucks will sometimes need to recharge after delivering cargo to warehouses. This includes warehouse hubs in the City of Industry and in the Inland Empire from Ontario to the Moreno Valley.

Figure 22: Utility Districts, Trucking Companies and Large Warehouses in the Four-County Region Source: Economic Roundtable analysis, Southern California Air Quality Management District data from CoStar, and California Energy Commission.

Exhausting Our Air 43
Municipal utility districts, such as DWP, are regulated by city councils rather than the California Energy Commission and must be locally activated to build the infrastructure required to meet electrical demand for recharging battery-electric trucks.

One challenge facing DWP is a low-voltage electrical distribution system, which makes it harder to move large amounts of power to new locations.

A second challenge is that its policies do not encourage on-site electrical generation, such as through photovoltaic arrays, which can supply some of the electricity needed for charging stations. A third challenge is that the City of Los Angeles has not adopted a counterpart to California’s Rule 29, requiring DWP to provide technical and financial assistance for installing commercial recharging stations.

The demand for electrical power to charge electric trucks is already known based on where truck companies and large warehouses are located.

Charging stations will be needed at all of these sites, and both trucking companies and warehouses are clustered in specific areas.

Both Southern California Edison, the Los Angeles Department of Water and Power, and other municipal utility districts must become proactive in identifying the system requirements for providing power for electric trucks and move expeditiously to build the necessary distribution infrastructure in advance of the oncoming wave of commercial applications for electrical service upgrades.

The supply of electricity to recharge battery-electric trucks is lagging the timetable set by California Air Resources Board for the transition to zeroemission drayage. Utility districts will be a bottleneck unless they act proactively to build the required electrical distribution infrastructure. 44 Exhausting Our Air
Community Profile: Ricardo Peraza, Trucking Company Owner Ricardo Peraza (45) is an immigrant from Maya Quintana Roo, Mexico, who lives in San Bernardino and is the owner of a small trucking company, Rope Trucking. Ricardo has built his business from the ground up and hopes to continue growing it, even through the changes in truck regulation. He lives in the Airport Gateway Specific Plan area, a neighborhood that the San Bernardino International Airport is planning to rezone for industrial use, which would cause the displacement of thousands of families. Even though he might be one of them, Ricardo is optimistic that he will be able to fight for his rights.

How do you feel about the Airport Gateway Specific Plan? I live in that area. Some people are going to get really rich off of this project. Even those landowners! But for me, who rents, I am at risk. But I am not going to back down. I am not going to leave unless I am compensated for my move. I know sooner or later, they will try to get rid of me. This is going to impact me, my family and my money. I feel lucky I have my trucks to hold me down in case this happens. But I feel for the people who are retired or do not have those assets to move. This is just going to make more people homeless.

I see the cities widening the freeways for this project. I have a friend who had an auto body shop right in front of the San Bernardino Airport who was leasing the land and has been forced to move. I offered to help him move with my truck.

Exhausting Our Air 45
How do you feel about the explosion of warehouses in the Inland Empire? I don't think there is more productivity or gain because of all the warehouses that have come in. I think it is the investors who are the only ones winning here. They are buying up land, pushing out the poorest people and making money off of it. I think the situation is going to keep getting worse.

Also with so many warehouses, where are the trucks supposed to go! Some warehouses do not allow the trucks to wait outside of the warehouse.

Truckers have nowhere to go! They have to find a place to go to the bathroom off the side of the road because there are not places for trucks to go! Sometimes we cannot even find a place to eat because places do not have parking for our trucks. It can be hours before we eat or go to the bathroom because nothing is set up for us. Police and code enforcement are always on our backs.

I don't know what is going to happen with all these warehouses being built. It is so hard for us to go through neighborhoods or commercial areas because they were not built for our trucks! Many times, we have to drop off loads and go through these areas and we knock down lights and signs because the roads aren’t wide enough.

I also recognize how loud our trucks are. We need a dedicated industrial area where we can drive in and out without bothering people. However, I don’t think people understand my work. I think it is easy to complain about the noise. Sometimes, residents stay up all night partying and that is okay. But when I leave at three in the morning for work and turn on my truck, people can't see that I am just heading to work. I can’t help it.

How did you get into trucking?
I started working trucking by working for companies that would supply the truck for me and I would get paid only $300 even though the truck owner would get paid triple that.

I met a man, Don Carlos, who had a couple trucks and saw me struggling working for the trucking company. He let me borrow one of his trucks to start making trips until I made enough money to buy my own. He has had a contract for UPS moving packages for them for over twenty years. He has been able to buy multiple trucks over the years and has multiple homes paid off because of the pay. I was lucky to meet him! This is a very competitive industry and people are selfish.
46 Exhausting Our Air
One of the only reasons I was able to buy this new truck was because of the pandemic and how much work I received during that time. Amazon used to give me a lot of money during the pandemic to move packages for them. Now they barely offer $400 for a load. And I think because truckers accept these loads at low rates, the companies take advantage of that and look for the cheapest option.

These big trucking companies are also a big threat to us smaller trucking companies. They are the ones that negotiate year-long contracts and take all the contracts away from us. I would not work for them, because they do not pay their drivers well.

I used to be a drayage driver at the Ports of Los Angeles. I was part of the group of truckers that got into the work after the Port Truck Rule happened. I bought a new enough truck to be able to go in. But I know many people who lost their jobs because their truck wasn’t allowed in the Port of Los Angeles anymore.

What are your thoughts on the diesel fuel that your truck uses? Any truck has little gaps or leaks so we are exposed to diesel throughout the day. I have noticed on days that I work 10 hours or more that my shirt gets covered in diesel. I leave my truck smelling like a mechanic who has been working all day. On hot days, I have to keep my truck engine running, because it is hot. I know I am getting covered in emissions and am breathing it. I do not smoke, but I have chronic allergies. I think sooner or later it is going to make us sick. There is a huge risk of fires and overheating. There are trucks that combust because of the heat. But this is the cheapest system that we can use in this business.

They are forcing us to buy electric trucks, but we will not be able to afford them, even if the government tries to give us money for them. There are so many costs that are not accounted for like repairs, part replacement and fueling. Right now, I repair my truck by myself because I know how too.

I wouldn’t know how to repair an electric truck! And it probably would be so costly since there aren’t many electric truck mechanics. I think the young people should start focusing on that industry.

I think I am also really scared of overheating and fires in an electric truck.

If it overheats and a fire starts, the battery would cause an explosion. With diesel, it takes time for the truck to burn. With electric and natural gas, we are talking about an explosion.

But really, it comes to who is going to be able to pay for it. I do not trust hydrogen and natural gas. I see them on the side of the road broken down.

Exhausting Our Air 47
I am part of the old school, and this is what we prefer. I worry too that these new trucks are all coming out automatic, and you need a manual to help reduce the speed or go up a hill.

If you could pilot or try using an electric truck, would you? Depending on the programs that the government has to help us keep up with the business and maintenance of the truck. It is not just about giving us money to buy it and then us having to figure it out after. We need support throughout the life of the truck.

There are so many permits that my truck needs! I need a permit to drive the truck for the fuel I use, for crossing into other states, plus insurance and plates. These are all costs that are never accounted for that are part of the business. Depending if I enter into an airport - the insurance cost goes higher. I have to pay for background checks and fingerprints every year.

I support change but we have to make sure it works for us. I have never been spoken too about the transition the government requires. Amazon sometimes sends me emails about conferences I can go to about this, but I know it is probably for their benefit and not mine. This is a big risk! If I could get my truck traded in for a new electric truck with 50 percent covered for 5 years, I would do it. But right now, that cannot come out of my pocket - it will hurt me. I need to have a safety net. I know California has to do it. They have a lot of money, especially money that comes from us paying for permits and licenses. The government isn’t going to lose.

How do you feel about the new truck regulations that the State of California has passed?
I think it is too short of time! I think in ten years I want to retire so these truck regulations are not going to impact me. I am trying to avoid it.

I would tell the younger people that the golden era of trucking is over.

There is always going to be an option to work for the big companies and keep making them rich. Having your own company is better but it is a lot of work and investment. I would tell them to study the electric trucks, circuitry and data systems for the trucks - I think that's what the future is.

I have a granddaughter, and I know the future is not going to be okay for her because of climate change. I think it is important to fight these things. I know that we are going to run out of water, that we are going to need to buy our clean air and that we are going to keep hurting the land. I think whatever we can do to delay the climate crisis, we need to do. 48 Exhausting Our Air

Exhausting Our Air 49

4. Impacts of Warehouse
Trucking ----------------------------------------------------------------------------------------------------------------- Photo credit:

Freightliner Cascadia
50 Exhausting Our Air
Overview
Truck Mileage and Uncompensated costs
Trucks travel over 415 million miles a year to and from large warehouses in the four-county region.

The destinations of trip trips include:
• The San Pedro Ports account for one-third of truck trips. • Freight rail intermodal yards account for over one-quarter of trips. • Other warehouses account for over one-fifth of trips. • Local retail stores account for 14 percent of trips.
• Cargo airports account for three percent of trips.

There are an estimated $1.07 billion in annual uncompensated public costs from warehouse diesel trips caused by wear and tear on roads and bridges; delays from traffic congestion; injuries, fatalities, and property damage from accidents; and harmful effects from exhaust. Almost 6 million tons of CO2, the primary greenhouse gas, are produced. California ranks 46th among the
50 states in the share of its roads that are in acceptable condition.

Health Impacts
The 11.5 million annual heavy-truck trips produce:
• 29 tons of fine particulate matter associated with increased bronchitis and asthma attacks.
• 7 tons of sulfur dioxide, a highly reactive gas that severely irritates breathing passages, eyes, and skin.
• 1,161 tons of nitric oxides and dioxides, which can irritate sensory organs, and cause shortness of breath and fluid build-up in the lungs.
• 100 tons of ammonia, which can irritate and burn the skin, mouth, throat, lungs, and eyes.
• 26 tons of volatile organic compounds, which can cause damage to the liver, kidney, or central nervous system.

The annual health costs for residents of the four-county region from current diesel truck emissions, and, conversely, the health benefits from having electric trucks move cargo instead of diesel trucks, range from $65 million up to $146 million, based on different epidemiological studies.

Emissions produced in the South Coast Air Basin spill over into other parts of California and have additional adverse health impacts outside of the four-county region. The statewide public health costs for different medical conditions caused by diesel emissions range from $74 million to $166 million. This is 13 percent more than costs in just the four-county region.

Exhausting Our Air 51
Warehouse Impacts on Air Quality
Large warehouses in Southern California are hubs in moving goods from cargo ships and aircraft to distribution centers, businesses and households.

Heavy-duty diesel trucks are the dominant method of goods movement, often in tandem with oceangoing container ships and sometimes freight trains and cargo aircraft.

Truck Mileage
Trucks travel over 415 million
miles a year to and from of
large warehouses in the fourcounty region, as shown in Table 4.
33 Over two-thirds of
these truck trip miles are for
bringing goods in and out of
warehouses in San Bernardino
and Riverside Counties, as
shown in Figure 23.

Riverside and San Bernardino
Counties also stand out for
having the most truck mileage
per warehouse. Both have
over twice as many annual
truck trip miles per warehouse
as warehouses in Los Angeles
and Orange Counties.

Table 4: Truck Mileage to and from Large Warehouses in the Four-County Region County
Annual Truck Trip
Miles Percent
Number of
Large
Warehouses
Average Truck
Miles per
Warehouse
Los Angeles 100,801,918 24% 1,626 61,994
Orange 28,811,511 7% 388 74,256
Riverside 92,231,705 22% 402 229,432
San Bernardino 193,671,306 47% 875 221,339
Region Total 415,516,440 100% 3,291 126,258
Source: Economic Roundtable analysis; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, Appendix C; Southern California Association of Governments (SCAG) Regional Data Platform and Parcel Locator; U.S. Census Bureau. 2019. TIGER/Line Shapefiles; and other sources.

These trip mile estimates are calculated based on roundtrips from the origins and to the destinations of warehoused goods: port facilities, other warehouses, intermodal facilities, airports, and retail stores.

Figure 23: Percent of Truck Mileage by County
Source: Economic Roundtable analysis; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet,
Appendix C; Southern California Association of Governments (SCAG) Regional Data Platform and Parcel Locator; and U.S.

Census Bureau. 2019. TIGER/Line Shapefiles.

Los
Angeles,
24%
Orange,
7%
Riverside,
22%
San
Benrardino,
47%
52 Exhausting Our Air
The types of origins and destinations of the truck trip generated by large warehouses are broken out in Figure 24. The Ports of Los Angeles and Long Beach account for one-third (34 percent) of truck trips Freight rail intermodal yards account for over one-quarter (27 percent) of trips.34 Other warehouses account for over one-fifth (22 percent) of trips.

Local retail stores account for 14 percent of trips, and cargo airports35 account for three percent of trips.
36 Ton-miles of Truck Travel
The impact of trucks on roads and the environment can be measured by converting trip mileage to ton-miles. Ton-miles are calculated by multiplying the weight of a truck in tons by the distance it travels. For example, a 40,000-pound truck traveling one mile represents 20 ton-miles.

We estimated the ton-weight per truck using the following factors:
• Cargo weight per 40' container 13.15 tons37
• Empty 40' container 4.13 tons
38 • Tractor truck 17 tons39
• Empty trailer chassis 3.3 tons40
Figure 24: Distribution of Truck Trips between Warehouses and Other Logistics Nodes Source: South Coast Air Quality Management District. Economic Roundtable design; images from openclipart.org, under the Creative Commons Zero 1.0 License.

Exhausting Our Air 53
Diesel truck trips in our analysis are divided equally between empty and full trips. This assumption that flows of goods are always one-way, singlestop drop offs produces conservative ton-mileage estimates. Averaging the loaded and empty weights below we get an average trip weight of 31 tons. • Loaded: Tractor + Chassis + Container + Cargo = 37.6 tons • Empty: Tractor + Chassis + Container = 24.4 tons
The greater number of ton-miles is linked to large warehouses in San Bernardino and Los Angeles Counites, while the average truck ton-miles per large warehouse is highest in Riverside and San Bernardino Counties, as shown in Table 5.

Table 5: Truck Ton-Miles to and from Large Warehouses in the Four-County Region County Annual Truck TonMilesPercent Number of
Large
Warehouses
Average Ton-Miles
per Warehouse
Los Angeles 6,251,549,358 24% 1,626 3,844,741
Orange 1,786,836,889 7% 388 4,605,250
Riverside 5,720,040,528 22% 402 14,228,957
San Bernardino 12,011,137,814 47% 875 13,727,015
Region Total 25,769,564,589 100% 3,291 7,830,314
Source: Economic Roundtable analysis; 2022 SCAQMD Rule 2305 Packet, Appendix C; SCAG Regional Data Platform and Parcel Locator; U.S. Census Bureau. 2019. TIGER/Line Shapefiles; and other sources.

The scale of diesel truck ton-mileage attributable to each warehouse is shown in Figure 25. Bigger circles in the map represent more ton-mileage.

The largest clusters of large circles are in the Inland Empire, along with the crescent-shaped cluster along the Union Pacific rail lines that runs through the City of Industry.

Uncompensated Public Costs from Warehouse Truck Trips
Moving goods by truck creates uncompensated public costs that include wear and tear on roads and bridges; delays caused by traffic congestion; injuries, fatalities, and property damage from accidents; and harmful effects from exhaust emissions. These costs are proportionate to the diesel truck mileage attributable to warehouses:
• 36,065 truck trips daily
• 11,495,607 truck trips annually
• 415,516,440 truck trip miles traveled annually
• 25,769,564,589 ton-miles of truck travel annually
• 5,993,583 tons of CO2, the primary greenhouse gas component 54 Exhausting Our Air
The uncompensated costs to the public per ton-mile that are not covered by taxes or fees that trucks pay have been estimated by the Congressional Budget Office to be:41
• Pavement Damage $0.0096
• Traffic Congestion $0.0066
• Accident Risk $0.0156
• Particulate Matter and Nitrogen Oxide Emissions $0.0069 • Greenhouse Gas Emissions $0.0022
• Noise (cost per mile) $0.0304
Based on these cost factors, large warehouses’ trucking operations in the four-county region in 2023 are creating an estimated $1.07 billion in uncompensated public costs, as shown in Figure 26.

Figure 25: Truck Ton-Miles Generated by Large Warehouses, Annually, by Warehouse Location Source: Economic Roundtable analysis; 2022 SCAQMD Rule 2305 Packet, Appendix C; SCAG Regional Data Platform and Parcel Locator; U.S. Census Bureau. 2019. TIGER/Line Shapefiles; and other sources.

Exhausting Our Air 55
The $1.07 billion in uncompensated public costs from warehouse diesel trips includes:
• $402 million in injuries, fatalities and property damage from accidents.
• $247 million from wear and tear on roads and bridges. • $178 million in harmful effects from exhaust emissions of particulate matter and nitrogen oxides.
• $170 million in delays caused by traffic congestion
• $57 million in climate impacts from CO2 greenhouse gas emissions • $13 million in loss of value caused by truck-related noise for adjacent properties.

These uncompensated costs are shouldered by residents of the four counties in the form of higher taxes for infrastructure repairs, impaired road conditions because of damaged and unrepaired infrastructure, as well as harmful health effects from diesel emissions.

Figure 26: Uncompensated Public Costs from Diesel Trips to and from Large Warehouses in the Four-County Region (in millions)
Source: Economic Roundtable Analysis; 2022 SCAQMD Rule 2305 Packet, Appendix C; SCAG Regional Data Platform and Parcel Locator; U.S.

Census Bureau. 2019. TIGER/Line Shapefiles; and other sources. U.S. Congressional Budget estimates of uncompensated public costs per mile traveled. $13
$57
$170
$178
$247
$402
$0
$50
$100
$150
$200
$250
$300
$350
$400
$450
Noise GHG
Emissions
Traffic
Congestion
PM & NOx
Emissions
Pavement
Damage
Accident Risk
Millions of Dollars
56 Exhausting Our Air
Unacceptable Road Conditions
The U.S. Highway Trust Fund continues to spend more on designated highway improvements and maintenance nationally each year than it collects. In 2022, the national fund received $41.9 billion from fuel and Figure 27: Acceptable Road Conditions, by State
Source: Economic Roundtable Analysis; U.S. Department of Transportation, Bureau of Transportation Statistics. 2023. State Transportation Statistics: Road Condition.
52%
55%
60%
66%
67%
67%
69%
72%
72%
72%
73%
74%
74%
75%
76%
77%
78%
78%
78%
79%
79%
80%
80%
81%
81%
81%
82%
82%
84%
84%
86%
86%
87%
87%
88%
89%
89%
90%
90%
91%
91%
91%
92%
92%
93%
93%
93%
94%
94%
94%
95%
50% 60% 70% 80% 90% 100%
Rhode Island
New Jersey
Hawaii
New Mexico
California
Connecticut
West Virginia
Washington
Maryland
Pennsylvania
Massachusetts
Mississippi
New York
Wisconsin
Missouri
Louisiana
Arizona
Texas
Colorado
Michigan
Maine
Utah
Illinois
Vermont
Alaska

UNITED STATES
Indiana
New Hampshire
Delaware
Ohio
Nevada
South Dakota
Virginia
Montana
Florida
Kansas
Oregon
North Carolina
Idaho
Minnesota
Alabama
Iowa
South Carolina
Arkansas
Kentucky
Georgia
Nebraska
Oklahoma
North Dakota
Wyoming
Tennessee
Percent of Roads in Acceptable Condition
Exhausting Our Air 57
vehicle taxes but had highway maintenance outlays of $46.4 billion, a $4.5 billion shortfall for taxpayers to cover.
42 At the state level, California has been much less successful than other states at maintaining roads in acceptable condition. California ranks 46thamong the 50 states in the share of its roads that are in acceptable condition, as shown in Figure 27.

The uncompensated wear and tear of heavy trucks on California roads – the ton-miles of which are rising each year – increases the state’s road maintenance deficit and increases the likelihood that it will remain fifth from the bottom in the nation in terms of the quality of its roads. 43 Public Health Costs
To measure the potential for electric trucks to reduce air pollution in the South Coast Basin, and in doing so improve public health and wellbeing, we calculated emissions generated by the current diesel-powered, heavy trucks travelling to and from just under 3,300 large warehouses. The 11.5 million annual heavy-truck trips produce an estimated:
• 29 tons of PM2.5, fine particulate matter 2.5 microns or less, which is associated with increased bronchitis and asthma attacks. • 7 tons of SO2, sulfur dioxide, a highly reactive gas that severely irritates breathing passages, eyes, and skin.
• 1,161 tons of NOx, nitric oxides and dioxides, which can irritate sensory organs, cause shortness of breath, and fluid build-up in the lungs.
• 100 tons of NH3, ammonia, high levels of which can irritate and burn the skin, mouth, throat, lungs, and eyes.
• 26 tons of VOCs, volatile organic compounds, which can cause damage to the liver, kidney, or central nervous system.

These diesel truck emissions are calculated using the most recent California Air Resources Board fleet factors database and applying these factors to the number of miles travelled for trips to and from large warehouses in the four-county region.
44 The tons of heavy truck emissions appear in Figure 28, broken out by county. San Bernardino County stands out due to its large number of warehouses, their large square footage and the distance from the seaports.

This is estimated to result in 617 tons of five health-impacting emissions, including 541 tons of Nitrous Oxides (NOX).

Los Angeles and Riverside Counties make up the next largest shares, 321 and 294 tons respectively, which includes 282 and 258 tons of nitrous oxides, respectively. This parity stands out given that Riverside County 58 Exhausting Our Air
only has a quarter as many large warehouses as Los Angeles County has, and only 42 percent of the latter’s square footage. They have similar quantities of criteria emissions because trucks travel a greater distance to and from warehouses in Riverside County.

Orange County, with its smaller number of large warehouses, their smaller square footage, and shorter trip distances to the seaports, have the lowest volume of criteria emissions, 92 tons, including 81 tons of nitrous oxides.

The local health impacts on residents from current diesel truck emissions, and, conversely, the health benefits from having electric trucks move cargo instead of diesel trucks, are shown in Table 6. Health costs for different health conditions range from $74 million up to $166 million.45 Potential health benefits from electric trucks include reductions of: 6 to 13 deaths annually, 10 acute bronchitis diagnoses, 187 upper and 131 lowerFigure 28: Tons of Diesel Truck Emissions by County Source: Economic Roundtable Analysis; California Air Resources Board. 2021. EMFAC2021 v1.0.2 CA ARB Emission Factors (EMFAC) model; 2022 SCAQMD Rule 2305 Packet, Appendix C; SCAG Regional Data Platform and Parcel Locator; and other sources. Total tons of criteria emissions in each county are shown above each column in the chart. 282
81 258
541
321
92 294
617
0 100
200
300
400
500
600
700
Los Angeles Orange Riverside San Bernardino
VOC
NH3
NOx
SO2
PM2.5
Exhausting Our Air 59
respiratory disorders, 194 asthma attacks, and 983 lost workdays – all tied to current diesel emissions.

Table 6: Local Residents’ Health Impacts from Diesel Truck Trips to and from Large Warehouses in the Four-County Region
Incidence
(annual cases)
Monetary Value
(annual dollars)
Low High Low High
Mortality * 5.867 13.279 $64,201,139 $145,310,590
Nonfatal Heart Attacks * 0.235 2.180 $35,320 $328,165
Infant Mortality 0.029 0.029 $356,900 $356,900
Hospital Admits, All Respiratory 1.338 1.338 $52,465 $52,465 Hospital Admits, Cardiovascular ** 1.120 1.120 $57,080 $57,080 Acute Bronchitis 10.327 10.327 $6,373 $6,373
Upper Respiratory Symptoms 187.053 187.053 $7,992 $7,992 Lower Respiratory Symptoms 131.377 131.377 $3,548 $3,548 Emergency Room Visits, Asthma 2.379 2.379 $1,341 $1,341 Asthma Exacerbation 194.84 194.84 $14,458 $14,458
Minor Restricted Activity Days 5,783.90 5,783.90 $507,045 $507,045 Work Loss Days 982.83 982.83 $196,749 $196,749
Total Health Effects $65,440,408 $146,842,704
Source: Economic Roundtable analysis; U.S. Environmental Protection Agency. 2023. CO-Benefits Risk Assessment Health Impacts Screening and Mapping Tool (COBRA); 2022 SCAQMD Rule 2305 Packet, Appendix C; SCAG Regional Data Platform and Parcel Locator; California Air Resources Board. 2021. EMFAC2021 v1.0.2 CARB Emission Factors (EMFAC) model; and other sources. Notes: * indicates that the Low and High values represent differences in the methods used to estimate some of the health impacts in COBRA. For example, high and low results for avoided premature mortality are based on two different epidemiological studies of the impacts of PM2.5 on mortality in the United States. ** indicates that heart attacks are excluded from the data for cardiovascular hospital admissions.

Emissions produced in the South Coast Air Basin spill over into other parts of California and have additional adverse health impacts outside of the four-county region. The statewide health impacts of current emissions of diesel truck trips linked to warehouses in the four-county region are shown in Table 7.

The statewide public health costs for different medical conditions range from $74 million to $166 million. This is 13 percent more than costs in just the four-county region.

Statewide health benefits from converting warehouse-linked diesel trucks to electric trucks include reductions of: 7 to 15 deaths annually, 12 acute bronchitis diagnoses, 211 upper and 148 lower-respiratory disorders, 220 asthma attacks, and over 1,103 lost workdays – all attributed to diesel emissions.
60 Exhausting Our Air
Table 7: California Residents’ Statewide Health Impacts from Diesel Truck Trips to and from Large Warehouses in the Four-County Region
Change in Incidence
(annual cases)
Change in Monetary Value
(annual dollars)
Low High Low High
Mortality * 6.639 15.028 $72,652,573 $164,446,723
Nonfatal Heart Attacks * 0.329 3.059 $50,204 $466,453
Infant Mortality 0.033 0.033 $408,554 $408,554
Hospital Admits, All Respiratory 1.528 1.528 $59,573 $59,573 Hospital Admits, Cardiovascular ** 1.328 1.328 $67,756 $67,756 Acute Bronchitis 11.661 11.661 $7,195 $7,195
Upper Respiratory Symptoms 211.15 211.15 $9,021 $9,021
Lower Respiratory Symptoms 148.32 148.32 $4,005 $4,005
Emergency Room Visits, Asthma 2.861 2.861 $1,612 $1,612 Asthma Exacerbation 219.99 219.99 $16,325 $16,325
Minor Restricted Activity Days 6,490.54 6,490.54 $568,992 $568,992 Work Loss Days 1,103.35 1,103.35 $220,877 $220,877
Total Health Effects $74,066,687 $166,277,086
Source: Economic Roundtable analysis and sources shown for Table 6.

The public health costs of current diesel truck emissions by county appear in Figure 29, highlighting the uneven burden put on the residents of less populous San Bernardino and Riverside Counties.

Figure 29: Public Health Costs of Diesel Truck Emissions by County Source: Economic Roundtable analysis; U.S. Environmental Protection Agency. 2023. CO-Benefits Risk Assessment Health Impacts Screening and Mapping Tool (COBRA);
Los Angeles
$40,337,872
Orange
$11,529,494
Riverside
$36,908,333
San Bernardino
$77,501,387
Exhausting Our Air 61
An important caveat is that this data is based on the location of large warehouses, however thee truck trips to and from these warehouses pass through many communities. The health impacts from diesel truck drayage are really a shared regional burden.

These public health impacts represent opportunities for public health improvements and cost savings as the South Coast AQMD implements and enforces Rule 2305, the Warehouse Indirect Source Rule. In the absence of enforcement, the pollutants emitted in Southern California communities will increase, because the region continues to build more warehouses and, by extension, experiences a continuing increase in truck trips. 62 Exhausting Our Air
Community Profile: Ralph Sistos, Teamster
Ralph Sistos (60) is a longtime resident of the Inland Empire, whose Mexican family has lived in this region for generations before it was even considered the United States. He currently lives in Redlands with his wife and daughters.

Ralph is a lifelong labor movement leader and truck driver who held a shop steward position for over 20 years with the Teamsters. Ralph retired some years ago from working at Sysco but still works at Costco as a truck driver. Ralph has dedicated his career to improving the workplace conditions at different companies for himself and his coworkers.

Ralph started working at a young age at Budweiser and was successful in organizing his coworkers to vote down a contract proposal because he Exhausting Our Air 63
knew they could win a better contract. He then moved to work at Sysco Los Angeles where he was a shop steward for over ten years, helping secure contract language for route autonomy, wages, and safety conditions. At Sysco Riverside, where he ended his career, Ralph helped strengthen the contract language and worked every position he could at the company.

I’ve always said that respect allows you to go a long way. And that's what happened at my job at Sysco. As a worker, I had the right to make my point and call out when there were grievances. Management didn’t always like the grievances we brought up, but they respected us enough to fix it. I was a shop steward for more than 25 years. I always tell our members - we are a union house, we fought for it and you are entitled to these rights.

You have to learn to fight for yourself. When you win, you get respect. It was my job to look out for my coworkers and communicate to the union and the company. My sole focus has always been our members. However, I have always thought that the big picture is the labor movement and not just my house.”
What is your relationship to the logistics industry? How does it show up in your life? Or in your neighborhood?
My parents live in Highland, so when the growth at the San Bernardino International Airport happened, I got involved with the local Teamsters because of how it was going to impact my family. I feel I have an obligation as a Teamster to help and participate in these fights in our community. I try to push people to get involved. It is a part of me that I was born with.

I grew up in Beaumont. The property value was low, and there was a lot of vacant land. So it was a perfect location for our family. But in the past ten years, Beaumont has exploded with warehouses. It has taken all the beautiful scenery that we had. And we know who did it - the council people! They are allowing this to happen! It all goes back to the people in power. These people have allowed the destruction of their own community. All you see is these eye-sores.

Also the air! Who knows the particles in the air that we are breathing in? I drive a diesel truck now at Costco but I used to drive a liquefied natural gas (LNG) truck at Sysco. The problem with the LNG truck was that it couldn’t go very far because we didn’t have enough reliable fueling stations. Perhaps in the inner city it would be fine, but not for long distances. I was pulling 53-foot container and the truck had the same power as the diesel.
64 Exhausting Our Air
What can be done differently?
I think the truck routes are very important for us to focus on. From the 60 Freeway to Redlands, there is a road along the mountain called San Mateo that is used by cyclists, commuters and people running. This is a curvy road that you often see trucks driving on. This is dangerous! Drivers can be reckless.

Some places like Riverside have put restrictions on truck routes. I think this makes it safer for drivers and community members. It also should be the responsibility of the companies to ensure that the trucks do not go on these routes!
I also think air purifiers and air filters are important! There should be rebates and tax reimbursements for these things! Better window panes too! If you live close to any polluting industry, the companies should be obligated to provide them, whether it is a home, school or business. I think that city council members should not sell out their neighbors! Do you think electric warehouses and electric trucks could be a solution? I think eventually it will be the solution but we still have to work out the kinks and bugs such as charging all of these vehicles. I am afraid of the charging. How will we charge these trucks? Sometimes we have to make trips to San Luis Obispo or San Francisco. We would have to get a hotel room and spend the night if we had to wait more than six hours to charge.

We need more training too, so we can operate the equipment correctly.

We cannot stop progress. It is inevitable and technology is always going to change. About two years ago, Sysco ordered 30 electric trucks and built out the solar panels and charging stations for them.
“I think that technology is always getting better. I am grateful for the advocates who care about the future for others and get us involved.

What is our biggest strength in this fight?
I believe that we need regulation and accountability from warehouses and trucking companies. Residents should be given the ability to protect their own health and hold companies accountable to the community. These companies should be contributing to a community. And this needs to happen now and not get lost in legislation.

I think the biggest strength in our fight is that we have lots of people on our side. The problem is that most people don't see what's going on and need to hear the right messages.

Exhausting Our Air 65

5. Workers and Jobs ----------------------------------------------------------------------------------------------------------------- Electrical construction,
Photo credit: IBEW Local 6
66 Exhausting Our Air
Overview
Jobs in the Electricity Sector
One job is created for every $111,512 spent annually on electrical infrastructure. Some of the jobs are from direct employment in electrical construction, other indirect jobs are industries that provide supplies and services for electrical construction, and additional induced jobs are created when workers in construction and supplier industries spend their wages.

Employment in the four counties of Los Angeles, Orange, Riverside and San Bernardino in industries that build electrical utility infrastructure and install electrical wiring and equipment in commercial buildings has grown by 749 jobs a year since 2004. This growth will accelerate with the conversion to electric trucks and the electrification of logistics infrastructure.

The electricity sector provides high-pay, living-wage jobs. The average hourly wage for all frontline electrical construction workers is $35 an hour.

Jobs in Warehouses
The introduction of new technology in warehouses and the rapid movement of goods passing through them has made warehouse jobs more complex. However, the wages paid to warehouse workers in the fourcounty region decreased an average of $13 dollars each year from 2001 to 2022, when adjusted for inflation.

The average wage in 2022 for warehouse workers in the five largest frontline occupations was $18.95 an hour. This is less than half of a living wage.

Conclusions
The jobs to electrify the logistics chain that brings goods to warehouses are much better than the jobs inside warehouses. This includes jobs expanding the electrical transmission infrastructure, building recharging station for electric trucks and installing solar panels at warehouses.

Electrical construction jobs are growing and have strong multiplier impacts in the supplier chain as well as the consumer sector. Every 10 jobs in electrical construction create 7 additional jobs in other industries.

Skill requirements for jobs in warehouses have increased over the past 20 years, but pay in real dollars has decreased. Consumer costs are lower and warehouse corporation profits are higher at the expense of under-paying warehouse workers.

Exhausting Our Air 67
Jobs Created Building Electrical Infrastructure
Jobs will be created by building charging stations and electrical infrastructure for zero-emission electric trucks, as well as by cleaning up the emissions footprint of warehouses through installation of on-site solar panels.

One job is created for every $111,512 spent annually on building electrical infrastructure.46 Some of the jobs are from direct employment in electrical construction, other indirect jobs are in industries that provide supplies and services for electrical construction, and additional induced jobs are created when workers in electrical construction and supplier industries spend their wages. The jobs created by $1 billion in revenue for electrical construction are shown in Figure 30.

Over half of the jobs (59 percent) are in the electrical construction industry, 14 percent are in supplier industries, and one-quarter (27 percent) are in the communities where these employees spend their wages.

Supplier Industries for Electrical Construction
The supplier industries for electrical construction provide more services than goods, as shown in Figure 31. Architects and engineers are the leading Figure 30: Jobs Created by $1 Billion in Revenue for Electrical Construction Source: IMPLAN 2019 model for construction of new power and communication structures in California with dollars adjusted to 2023 values.
5,289
1,236
2,443
0 1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
9,000
10,000
1 Induced jobs from
employees
spending their
wages
Indirect jobs in
supplier industries
Direct electrical
construction jobs
8,968 Total Jobs
68 Exhausting Our Air
supplier, followed by building material companies, temporary employment agencies, wholesalers, and real estate services.

Figure 31: Indirect Jobs in Supplier Industries for Electrical Construction Source: IMPLAN 2019 model for construction of new power and communication structures in California. Smaller supplier industries that account for 43 percent of goods and services purchased for electrical construction are not shown in this chart. 2%
2%
2%
2%
2%
2%
2%
2%
4%
4%
5%
5%
6%
8%
10%
0% 2% 4% 6% 8% 10% 12%
Accounting services
Screws, nuts & bolts
Ready-mix concrete
Vehicle maintenance
Legal services
Equipment repair
Services to buildings
Holding companies
Truck transportation
Equipment leasing
Real estate
Durable goods wholesale
Temp agencies
Building materials
Architecture & engineering
Figure 32: Induced Jobs from Employees Spending their Wages Source: IMPLAN 2019 model for construction of new power and communication structures in California. Smaller supplier industries that account for 57 percent of goods and services purchased by workers are not shown in this chart. 2%
2%
2%
2%
2%
2%
2%
2%
2%
3%
3%
3%
4%
4%
5%
5%
0% 1% 2% 3% 4% 5% 6%
Passenger transportation
Nonstore retailers
Nursing care facilities
Automotive repair
Financial investments
Personal care services
Employment services
Department stores
Grocery stores
Other food & drinking places
Offices of physicians
Real estate
Hospitals
Social services
Limited-service restaurants
Full-service restaurants
Exhausting Our Air 69
Industries that Meet the Consumer Needs of Workers
Every industry that helps fulfill consumer needs receives a share of the wages spent by workers in electrical construction and its supplier industries, as shown in Figure 32. Restaurants are the largest beneficiaries, followed by social services, health care, real estate, and retail stores. As shown earlier, these consumer industries create 27 percent of the jobs that result from investments in building electrical infrastructure.

Job Growth in Electrical Construction and Power Generation Employment in industries that build electrical utility infrastructure and install electrical wiring and equipment in commercial buildings in the fourcounty region has grown by 749 jobs a year since 2004, as be seen in Figure

33. These construction jobs accounted for almost three-quarters (72 percent) of all jobs in the electricity sector in 2022. This sector includes building electrical infrastructure, generating electricity, distributing electric Figure 33: Electrical Construction and Power Generation Jobs in Los Angeles, Orange, Riverside and San Bernardino Counties
Source: California Employment Development Department, Quarterly Census of Employment and Wages, 2004 to 2022. 0 5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
50,000
55,000
Electric Power
Distribution
Electric Bulk Power
Transmission
Fossil Fuel Electric
Power Generation
Hydroelectric Power
Generation
Solar Electric Power
Generation
Power/Communication
System Construction
Nonresidential Electrical
Contractors
70 Exhausting Our Air
power, and installing electrical wiring and equipment in nonresidential buildings.

Generating electricity is the most essential component of the electricity sector, but in 2022, it accounted for only six percent of jobs in the electricity sector in the four counties. Solar electric and hydroelectric power generation each accounted for two percent of jobs.

Figure 34: Weekly Wages in 2022 in Electricity Sector Industries Source: California Employment Development Department, Quarterly Census of Employment and Wages. Wages are a weighted average of weekly earnings in 2022 in Los Angeles, Orange, Riverside, and San Bernardino Counties. $1,695
$1,725
$2,156
$2,330
$2,358
$2,530
$2,827
$0 $500 $1,000 $1,500 $2,000 $2,500 $3,000
Hydroelectric Power Generation
Nonresidential Electrical Contractors
Fossil Fuel Electric Power Generation
Electric Bulk Power Transmission
Power/Communication Sys. Const.

Electric Power Distribution
Solar Electric Power Generation
Figure 35: Largest Occupations Employed for Building Electric Utility Infrastructure Source: U.S. Bureau of Labor Statistics occupational matrix for NAICS 237130, the power and communication system construction industry. Smaller occupations that account for 21 percent of employment are not shown in the chart. 1%
1%
1%
1%
1%
2%
2%
2%
3%
4%
6%
7%
7%
7%
16%
18%
0% 5% 10% 15% 20%
Plumbers & pipefitters
Accounting clerks
Wind turbine technicians
Heavy truck drivers
Secretaries & admin. assistants
Project management specialists
Office clerks
Operations managers
Construction managers
Electricians
First-line supervisors of mechanics
Telecommunications equip. installers
First-line construction supervisors
Construction equip. operators
Construction laborers
Electrical power-line installers
Percent of Industry Workforce
Exhausting Our Air 71
The number of jobs in the four counties in electric power distribution surged in 2022, growing to account for 22 percent of employment in the electricity sector. This industry operates the lines, poles, meters, and wiring that transfer electricity to consumers. Most of the growth was in Los Angeles County, where Southern California Edison and the City of Los Angeles Department of Water and Power are the largest electric utilities.

Wages in Electricity Sector Industries
The solar electric power generation industry is deploying the newest technology in the electricity sector and pays the highest wages, as shown earlier in Figure 34. However, the entire electricity sector provides highpaying jobs.

These wages are the average of all occupations employed in an industry, ranging from managers and professional specialists to frontline workers.

They are an indication of job quality. If workers are employed full-time and year-round, average annual wages range from $88,120 in hydroelectric power generation to $147,030 in solar electric power generation.

Occupations Employed in Electrical Construction
The occupations of workers who build electric power lines, towers and generating facilities are shown in Figure 35. And the occupations of Figure 36: Largest Occupations of Electric Wiring and Equipment Installation Workers Source: U.S. Bureau of Labor Statistics occupational matrix for NAICS 238210, the electrical contractor industry. Smaller occupations that account for 16 percent of employment are not shown in the chart. 1%
1%
1%
1%
2%
2%
2%
2%
2%
2%
2%
3%
3%
6%
7%
49%
0% 10% 20% 30% 40% 50% 60%
Solar photovoltaic installers
Sales representatives
Accounting clerks
Cost estimators
Telecommunications installers
Secretaries & admin. assistants
Security & alarm systems installers
Construction managers
Construction laborers
Project management specialists
Telecommunications equip. installers
General and operations managers
Office clerks, general
First-line construction supervisors
Helpers--electricians
Electricians
Percent of Industry Workforce
72 Exhausting Our Air
workers employed to install electrical wire and equipment in buildings are shown in Figure 36.

Workers who build the electric utility infrastructure are largely employed to build the distribution systems. This includes electrical power line installers (18 percent), construction laborers (16 percent), and construction equipment operators (seven percent).

Workers who install wiring and electrical equipment in buildings are largely electricians (49 percent), and electrician helpers who assist them (seven percent).

Wages in Electrical Construction Occupations
Frontline electrical construction occupations pay living wages. All of the eight largest frontline occupations pay over $20 an hour, including the lessskilled helper and laborer occupations. Higher skilled occupations pay from $33 to $50 an hour, as shown in Figure 37.

The highest-paid occupation – and the largest occupation for building electrical infrastructure – is electrical power-line installer, which pays from $47 to $50 an hour, depending on the county where the job is located.

The average hourly wage for all frontline electrical construction workers employed in Los Angeles County is $35.60 an hour. In Orange County, it is $35.26, and in Riverside and San Bernardino Counties, it is $33.64.

Figure 37: Average Hourly Wage of Frontline Electrical Construction Workers in 2022 Source: California Employment Development Department, Occupational Employment and Wage Statistics (OEWS) Survey. $20.49
$24.63
$33.95
$34.74
$37.51
$39.80
$39.63
$47.31
$20.40
$26.04
$34.94
$35.74
$40.33
$43.48
$41.27
$45.39
$21.98
$25.17
$34.69
$36.08
$38.36
$42.41
$43.13
$50.89
$0 $10 $20 $30 $40 $50 $60
Helpers--electricians
Construction laborers
Telecommunications equip. installers
Electricians
Construction equip. operators
First-line construction supervisors
First-line supervisors of mechanics
Electrical power-line installers
Average Hourly Wage in 2022
Los Angeles
County
Orange
County
Riverside &
San
Bernardino
Counties
Exhausting Our Air 73
Warehouse Labor Force
In 1970, 82 percent of warehouse workers in the four-county region lived in Los Angeles County, as shown in Figure 38. Ten percent lived in Figure 39: Employment in Five Largest Frontline Warehouse Occupations 1970-2020 Source: U.S. Census Bureau, Decennial Census Public Use Microdata records for 1970, 1980, 1990, 2000, 2010, and 2020. 0 10,000
20,000
30,000
40,000
50,000
60,000
70,000
1970 1980 1990 2000 2010 2020
Shipping &
receiving
clerks
Stockers &
order fillers
Forklift
operators
Hand
packers
Stock
movers
Figure 38: Residential Distribution of Warehouse Workers by County 1970-2020 Source: U.S. Census Bureau, Decennial Census Public Use Microdata records for 1970, 1980, 1990, 2000, 2010, and 2020. 0 10,000
20,000
30,000
40,000
50,000
60,000
70,000
80,000
90,000
100,000
1970 1980 1990 2000 2010 2020
San Bernardino
Riverside
Orange
Los Angeles
74 Exhausting Our Air
Orange County, two percent in Riverside County and six percent in San Bernardino County.

After modest growth from 1970 to 2000, the number of warehouse workers grew 81 percent from 2000 to 2010, and then increased even more rapidly from 2010 to 2020, with 168 percent growth.

Altogether, the number of warehouse workers in the four-county region increased by 665 percent from 1970 to 2020, with explosive growth in the Inland Empire. The number of warehouse workers increased 4,548 percent in San Bernardino County and 6,224 percent in Riverside County.

Figure 41: Growth in Five Largest Frontline Warehouse Occupations from 2000 to 2020 Source: U.S. Census Bureau, 2010 and 2016 to 2020 Public Use Microdata Sample for Los Angeles, Orange, Riverside, and San Bernardino Counties.
1857%
473% 467% 392% 321%
0%
200%
400%
600%
800%
1000%
1200%
1400%
1600%
1800%
2000%
Hand
packers
Stock
movers
Stockers &
order fillers
Forklift
operators
Shipping &
receiving clerks
Figure 40: Employment in Five Largest Frontline Warehouse Occupations in 2020 Source: U.S. Census Bureau, 2016 to 2020 Public Use Microdata Sample for Los Angeles, Orange, Riverside, and San Bernardino Counties.
20,891
15,816
11,451
7,717 6,131
0 5,000
10,000
15,000
20,000
25,000
Stock
movers
Hand
packers
Forklift
operators
Stockers &
order fillers
Shipping &
receiving clerks
Exhausting Our Air 75
Occupations of Frontline Warehouse Workers
The largest frontline warehouse occupation since 2000 has been stock movers, as shown in Figure 39.
47 In the preceding 30 years, from 1970
through 1990, forklift operators were the largest occupation. Simpler moving equipment, such as pallet jacks, as well as the development of semiautomated conveyor systems, have reduced reliance on larger and more powerful forklifts that are hazardous in the hands of unskilled operators.

There are 20,891 stock movers working in warehouses in the four-county region, as shown in Figure 40. The second largest occupation is hand packers, with 15,816 workers.

The greatest growth over the past 20 years has been among hand packers, who have increased by 1,857 percent, as shown in Figure 41. These workers, for example, pick up, move, sort and pack the goods for an Amazon order, mark and label the package, and seal it.

The least growth has been among shipping and receiving clerks, who verify and maintain inventory records for incoming and outgoing shipments. Bar code reading equipment has automated their work.

Figure 42: Job De-Skilling for Shipping and Receiving Clerks from 2001 to 2022 Source: U.S. Dept. of Labor, Employment and Training Administration, O*NET versions 1.0 and 28.0, SOC 43-5071. 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Operations Monitoring
Mathematics
Negotiation
Active Learning
Instructing
Service Orientation
Writing
Persuasion
Social Perceptiveness
Complex Problem Solving
Coordination
Judgment & Decision Making
Time Management
Monitoring
Critical Thinking
Reading Comprehension
Active Listening
Speaking
Percent of Employers Identifying Skill as Important
2022
Importance
2001
Importance
76 Exhausting Our Air
Change in Skill Requirements for Warehouse Jobs
The skills, knowledge and abilities that workers need to perform their job can change over time, as technological innovation changes their tools and tasks. This simplifies some jobs and makes other jobs more complex.

Shipping, Receiving and Inventory Clerks – De-Skilled
The work of shipping and receiving clerks has been de-skilled by bar code readers, as can be seen in Figure 42.
48 In 2001, 88 percent of employers said
that mathematical skills were important for this job. Twenty-one years later, in 2022, only 31 percent of employers say that this skill is important.

Of the 18 skills shown for shipping and receiving clerks in Figure 42, only two have become more important – persuasion and instructing. These are social rather than intellectual tasks. The intellectual tasks have been automated.

The average importance of the skills for shipping and receiving clerks shown in Figure 42 decreased from 61 percent in 2001 to 44 percent in 2022.

Figure 43: Job Up-Skilling for Hand Packers and Packagers from 2001 to 2022 Source: U.S. Dept. of Labor, Employment and Training Administration, O*NET versions 1.0 and 28.0, SOC 53-7064. 0% 10% 20% 30% 40% 50% 60%
Writing
Mathematics
Learning Strategies
Complex Problem Solving
Operation and Control
Active Learning
Social Perceptiveness
Service Orientation
Operations Monitoring
Quality Control Analysis
Judgment & Decision Making
Time Management
Reading Comprehension
Speaking
Coordination
Active Listening
Critical Thinking
Monitoring
Percent of Employers Identifying Skill as Important
2022
Importance
2001
Importance
Exhausting Our Air 77
Hand Packers and Packagers – Up-Skilled
In contrast, the skill requirements for hand packers have increased over the past two decades, as shown in Figure 43. Even though employers give less importance to the skills of hand packers than the skills of shipping and receiving clerks (i.e., fewer employers identify their skills as being important), the average importance of the skills shown in Figure 43 increased from 23 percent in 2001 to 33 percent in 2022.

For example, in 2001, only 10 percent of employers said that critical thinking and active listening were important. By 2022, the share of employers saying that these skills are important had increased to 44 percent.

Mental engagement, collaboration and communication have become more important for doing this job.

Hand Laborers and Freight, Stock and Material Movers – Up-Skilled The importance of critical thinking, coordination with other workers, speaking, monitoring operations, judgement and decision making, social perceptiveness, troubleshooting, instructing and active learning for stock movers has more than doubled over the past 21 years, as shown in Figure 44.

Figure 44: Job Up-Skilling for Hand Laborers and Freight, Stock, and Material Movers from 2001 to 2022
Source: U.S. Dept. of Labor, Employment and Training Administration, O*NET versions 1.0 and 28.0, SOC 53-7062. 0% 10% 20% 30% 40% 50% 60%
Active Learning
Instructing
Repairing
Equipment Maintenance
Service Orientation
Troubleshooting
Complex Problem Solving
Social Perceptiveness
Writing
Judgment & Decision Making
Time Management
Monitoring
Active Listening
Operations Monitoring
Reading Comprehension
Speaking
Coordination
Critical Thinking
Operation and Control
Percent of Employers Identifying Skill as Important
2022
Importance
2001
Importance
78 Exhausting Our Air
These workers move stock manually in warehouses. They have to identify and categorize the goods, recognize differences or similarities, and detecting changes in the work environment.

The introduction of new technology in warehouses and the rapid turnover of goods has made their job more complex. The average importance of skills shown in Figure 44 for material movers increased from 20 percent in 2001 to 35 percent in 2022.

Industrial Truck and Tractor (Forklift) Operators – Up-Skilled The importance of social perceptiveness, time management, reading comprehension, judgment and decision-making, service orientation, and systems evaluation for forklift operators has more than doubled over the past 21 years, as shown in Figure 45.

These workers operate lifting devices, such as forklifts, to load, unload, transport, or stack material. Increasingly, they use electronic software to inspect loads for accuracy and safely move loads around the warehouse to ensure timely and complete delivery.

Figure 45: Job Up-Skilling for Industrial Truck and Tractor (Forklift) Operators from 2001 to 2022
Source: U.S. Dept. of Labor, Employment and Training Administration, O*NET versions 1.0 and 28.0, SOC 53-7051. 0% 10% 20% 30% 40% 50% 60% 70% 80%
Service Orientation
Systems Evaluation
Learning Strategies
Active Learning
Mathematics
Complex Problem Solving
Repairing
Writing
Social Perceptiveness
Judgment & Decision Making
Critical Thinking
Monitoring
Speaking
Reading Comprehension
Active Listening
Time Management
Troubleshooting
Coordination
Equipment Maintenance
Operations Monitoring
Operation and Control
Percent of Employers Identifying Skill as Important
2022
Importance
2001
Importance
Exhausting Our Air 79
The introduction of new technology in warehouses and the rapid turnover of goods has made their job more complex. The average importance of skills shown in Figure 45 for forklift operators increased from 31 percent in 2001 to 42 percent in 2022.

Stock Clerks - Stockers and Order Fillers – Up-Skilled
The importance of personnel management, time management, monitoring, social perceptiveness, persuasion, and instructing for stock clerks has doubled, or nearly doubled, from 2001 to 2022, as shown in Figure 46.

These workers answer questions about merchandise, transfer the goods for an order to coworkers who complete the next step for shipping the order, read orders to ascertain catalog numbers, sizes, colors, and quantities of goods keep records of out-going orders, attach labels to goods, and organize new goods.

The introduction of new technology in warehouses and the rapid turnover of goods has made their job more complex. The average importance of Figure 46: Job Up-Skilling for Stockers and Order Fillers – Stock Clerks from 2001 to 2022
Source: U.S. Dept. of Labor, Employment and Training Administration, O*NET versions 1.0 and 28.0, SOC 53-7065. 0% 10% 20% 30% 40% 50% 60% 70% 80%
Service Orientation
Systems Evaluation
Learning Strategies
Active Learning
Mathematics
Complex Problem Solving
Repairing
Writing
Social Perceptiveness
Judgment & Decision Making
Critical Thinking
Monitoring
Speaking
Reading Comprehension
Active Listening
Time Management
Troubleshooting
Coordination
Equipment Maintenance
Operations Monitoring
Operation and Control
Percent of Employers Identifying Skill as Important
2022
Importance
2001
Importance
80 Exhausting Our Air
skills shown in Figure 46 for stock clerks increased from 33 percent in 2001 to 39 percent in 2022.

Wages of Frontline Warehouse Workers
Workers’ pay determines their economic well-being and reveals economic inequities within industries. Despite providing the energy and effort that produces large profits in a growing industry, warehouse workers do not receive a living wage, as shown in Figure 47.

The average wage in 2022 for warehouse workers in the five largest frontline occupations was $18.95 an hour. This is less than half of a living wage.

A living wage for workers in households with two working adults and two children is $45.22 in Los Angeles County, $47.78 in Orange County, $41.77 in both Riverside and San Bernardino Counties.49 Wages range from $17.04 an hour for hand packers to $20.13 an hour for shipping and receiving clerks.

These low wages do not compensate for increased skill requirements, or corresponding increases in worker productivity, for frontline warehouse workers. There have been large increases in skill requirements for four of the five frontline occupations.

Warehouses bring in $106,709 in revenue each year for every worker. Six percent of this revenue is profit. This means that there is $6,005 in annual corporate profit for each worker.50
Figure 47: Average Hourly Wage for Frontline Warehouse Workers in the 4-County Region in 2022
Source: California Employment Development Department, Occupational Employment and Wage Statistics (OEWS) survey, Los Angeles, Orange, Riverside, and San Bernardino Counties. $18.95
$20.13
$18.75
$18.53
$17.88
$17.04
$15 $16 $16 $17 $17 $18 $18 $19 $19 $20 $20 $21
ALL 5 FRONTLINE

OCCUPATIONS
Shipping &
Receiving Clerks
Stock Movers
Stock Clerks
Forklift Operators
Hand Packers
Exhausting Our Air 81
The wages paid to warehouse workers in the four-county decreased an average of $13 dollars each year from 2001 to 2022, when adjusted to constant dollars, as shown in Figure 48. Workers’ pay was 18 percent less in 2022 than it was in 2001.Workers who are increasingly skilled and productive are being paid less and less.

The warehouse industry pays bottom-feeder wages to warehouse workers who assemble, package and send out goods that often have high value to consumers throughout Southern California who are preponderantly affluent. This is an uncompensated transfer of wealth from under-paid workers to corporate warehouses and affluent consumers.

Figure 48: Average Weekly Pay for All Warehouse Workers in the 4-County Region, 2001 to 2022
Source: US Bureau of Labor Statistics, Quarterly Census of Employment and Wages, Los Angeles, Orange, Riverside, and San Bernardino Counties. Wages are adjusted to 2022 dollars based on the CPI for the Los Angeles region. $0
$200
$400
$600
$800
$1,000
$1,200
$1,400
2001200220032004200520062007200820092010201120122013201420152016201720182019202020212022 82 Exhausting Our Air
Community Profile: George Hauge, Environmental Advocate George Hauge grew up in the Pacific Northwest but has spent the majority of his life in the Inland Empire. In 1976 George moved to Moreno Valley to be a school teacher. During that time the population was around 25,000 and Ironwood Ave was not developed.

People would tend sheep up and down the road. Moreno Valley was extremely rural, a different landscape from what you find today with the influx of housing and warehouses.

George mentions that the shift from rural to town happened in the early 1980s to 90s, when elected officials’ motto was: “build the housing and we’ll guarantee you’ll have the jobs.”
It wasn’t until 2005 when George saw the first multi-million square foot warehouse approved and began to challenge these projects more seriously in the following years.

George mentions the multi-million Skechers warehouse that was approved in 2008. It was one of the first to cause relocation. The school district had already purchased the site and had been approved by the city for a new Exhausting Our Air 83
High School, but the school was not built to make room for the warehouse project. They never found another site for the high school.

Battles to stop these multi-million hubs became the normal, voluntary way that George spends his days. To this day, George’s schedule involves litigation calls four to five times a week. George mentions that the hardest part about fighting these logistic projects in a pro-warehouse city is not that you can’t stop them or remove a warehouse, but the litigation cases.

If it’s a CEQA (California Environmental Quality Act) lawsuit, the most one can do is mitigate and the developers usually claim to do that. They show mitigations for the CEQA requirements, go back to the city council and get their million square foot warehouses approved.

George says that in some cases developers are willing to improve their plans, but the planning commission and planning staff aren’t requiring anything at all. Then, mitigation of adverse impacts is eventually added after litigation. That means for a project, that could have solar included as a mitigation requirement by the planning commissions, this improvement is not even brought up until the litigation is settled. The city and developers leave it to volunteers like George to sue for improvements like solar panels that are essential for the environment.

George is currently working on four law suits. In one, a warehouse shares the backyard of a home. In the second, a warehouse is 19 feet away from homes. In the third, a warehouse is across the street from homes. And in the fourth, another warehouse is across the street from homes.

He says that Moreno Valley just keeps approving warehouse projects. “We might get some change but don’t know yet.” The developer is offering an 18 acre furnished and landscaped sports park, a million dollars in improvements and pavement that have nothing to do with the project, and funds for the city council.

George says that many of these projects are not making it better for those who live nearby, but making it a “nice package for the city council.” George explains how one project, the Moreno Valley Trade Center, was in planning as the same time that the city approved its general plan in June of 2021. The proposed location of the project site was shown in the general plan that was approved as being zoned for residential land use.

The developer of the project bought residential land cheaply, then put forward the project forward and asked the city to amend the general plan and rezone the land the as industrial.
84 Exhausting Our Air
George explains that the developer has been in hearings for 17 months trying to get project approved and has been told what changes are needed to mitigate the adverse impacts of the project.

The developer claims that these components of the project cannot get changed and the project must be approved based on overriding considerations about the benefits it will provide. Three of the four negative impacts of the project that the developer wants to override are air quality, greenhouse gas emissions and aesthetics.

George mentions his personal relationship with logistics are air quality and traffic impacts, they impact his life because he is continuing to fight while others are traveling, he doesn’t mind actively fighting. It has given him relationships with good attorneys. “Fortunately, we have a couple of lawyers who care.”
“We are up against pollution, traffic impacts, truck lanes, and low-paying warehouse jobs. Open space that should be set aside is being consumed for job producing lands that produce very few jobs per square foot. Now with automation and robotics, there will be less jobs per square foot than there are now."
Every warehouse they build means looking for employment outside since warehousing will rely on automation and robotics. George recommends that warehouses should only build on industrial lands, ideally 500 meters or more from sensitive community or open-space sites.

Logistics needs to move away from fossil fuels as much as possible. We need to get HVAC systems installed throughout the community and allelectric buildings There should be auxiliary power units for truckers so that they don’t have to leave their engines running and a cooling center for truckers. And solar panels should be installed on warehouses to reduce their environmental footprint.

Exhausting Our Air 85
‘

6. Impacts of Warehouses
on Frontline Families ----------------------------------------------------------------------------------------------------------------- Photo credit:

Economic Roundtable
86 Exhausting Our Air
Overview
Homes
There are just under 365,000 residential parcels located within 2,000 feet of large warehouses, across the four-county region. Three-quarters are singlefamily homes, and almost another quarter are multi-family properties.

Single-family homes usually hold multiple family members and apartment buildings hold multiple families. There are over 2.1 million residents within 2,000 feet of a large warehouse.

Warehouses and the logistics networks that they support degrade the habitability of neighborhoods. Factors that diminish the desirability and cost of housing in these neighborhoods include freeways, heavy traffic, truck-train intermodal facilities, cargo airports, truck depots, and warehouses.

Poverty
Many families live near warehouses out of economic necessity, settling on less desirable neighborhoods and inadequate housing within those neighborhoods because rents are lower. Data on families living near large warehouses shows an elevated likelihood of poverty throughout the fourcounty region. In addition to economic distress, these families have longterm exposure to air pollution, as well as traffic noise and congestion that make it difficult to get the peace and quiet needed for a healthy life.

The median income within a 2,000-foot perimeter of large warehouses is 18 percent lower than in the four-county region, and the poverty rate is 22 percent higher than outside the perimeter.

When families cannot afford to rent an apartment that meets minimum standards of space and privacy for household members, they often rent a smaller unit where more than one person is crowded into each room in order to reduce their rent. The rate of overcrowded housing is 38 percent higher within the 2,000 perimeter of large warehouses than in the region as a whole.

Households living within 2,000 feet of a large warehouse are 10 percent more likely to have children, 23 percent more likely to be a female-headed household, and 40 percent more likely to be Latino than in the overall four-county region.

Exhausting Our Air 87
Incompatible Development
Large warehouses of 100,000 square feet or more, and sometime more than one-million square feet, are being developed in existing neighborhoods, sometimes just across the street from people’s homes. The impacts of cargo handling spillover onto resident who live in close proximity to large warehouses and the diesel trucks that come and go create emissions, noise, congestion and traffic risks.

Homes Near Warehouses
Large warehouses are important logistics nodes for transporting goods from manufacturers to end consumers. In the four-county region, the presence of this global flow of goods includes truck – and sometimes train – trips between large warehouses, the Los Angeles and Long Beach Ports, cargo airports, intermodal truck-train yards, other warehouses, and retail stores.

The impacts of large warehouse on their neighborhoods are directly measurable. There are just under 365,000 residential parcels located within 2,000 feet of a large warehouse. Almost two-thirds (64 percent) are located in Los Angeles County, followed by Orange, then San Bernardino and Riverside Counties, as shown in Figure 49.

Photo credit: Economic Roundtable
88 Exhausting Our Air
Nineteen thousand parcels are next door, or almost next door to warehouses. In San Bernardino and Los Angeles Counties, 0.5 percent of all residential parcels are located within 300 feet of large warehouses, while Riverside County has 0.4 percent and Orange County 0.2 percent are within 300 feet, as shown in Figure 50.

Figure 49: Number of Housing Parcels Near Large Warehouses Figure 50: Cumulative Percent of Housing Parcels Near Large Warehouses Sources: Economic Roundtable GIS analysis; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, Appendix C; Southern California Association of Governments (SCAG) Regional Data Platform and Parcel Locator; U.S. Census Bureau. 2019. TIGER/Line Shapefiles; and other sources. 232,180
55,990 52,388 24,243
66,924
15,126 15,757
5,927
12,417
2,421 3,061
1,086
0 50,000
100,000
150,000
200,000
250,000
Los Angeles Orange San Bernardino Riverside
300 Feet or Less
301 to 1,000 Feet
1,001 to 2,000 Feet

0.6% 0.4% 0.2%

0.6% 0.5%
4%
3%
1%
3% 3%
11%
9%
4%
9% 9%
0%
2%
4%
6%
8%
10%
12%
14%
Los Angeles Orange Riverside San Bernardino Total
300' or Less 1,000' of Less 2,000' or Less
Exhausting Our Air 89
Single family homes are the type of residential unit that is most often close to a large warehouse, as shown in Figure 51. Apartment buildings are near warehouses almost as often as single family homes in Los Angeles County, but not in the other three counties. Mobile home parks are more frequent neighbors of warehouses in Riverside County.

Across the four-county region, 75 percent of properties within 2,000 feet large warehouses are single family homes, another 23 percent are multifamily properties, and two percent are mobile home parks, with a smattering of other types of dwellings.

Zoning for Warehouses
Large warehouses in Southern California are predominately zoned as industrial, industrial / commercial or specific plan/project as shown in Figure 52.

In Riverside County, six percent of large warehouses are zoned residential and two percent agricultural, indicating that zoning changes after land uses materialize, rather than providing a framework for authorizing land uses.

Large warehouses are often constructed on land that was previously zoned for housing or agriculture, especially in Inland Empire communities.

Figure 51: Types of Housing Units within 2,000 Feet of Large Warehouses Sources: Economic Roundtable GIS analysis; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, Appendix C; Southern California Association of Governments (SCAG) Regional Data Platform and Parcel Locator; U.S. Census Bureau. 2019. TIGER/Line Shapefiles; and other sources. 158,953
40,961 50,399
21,972
71,927
6,883
4,159
2,766
1,300
4,544 97
840
0 50,000
100,000
150,000
200,000
250,000
Los Angeles San Bernardino Riverside Orange
Mixed Use, Mobile Home, Other
Multi-Family Residential
Single Family Residential
90 Exhausting Our Air
Although the most common land use designation for large warehouses is industrial, some warehouse parcens are classified as vacant or commercial and services, as shown in Figure 53. A small number of warehouses in each county are on parcels classified as transportation, communications and utilities uses.

Figure 52: Municipal Zoning of Existing Large Warehouses, by Square Footage Sources: Economic Roundtable GIS analysis; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, Appendix C; Southern California Association of Governments (SCAG) Regional Data Platform and Parcel Locator. 87%
72%
58%
46%
66%
2%
5%
13%
1%
4%
8%
15% 21%
46%
24%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Los Angeles Orange Riverside San Bernardino Total
Transportation
Specific Plan/Special Project
Residential
Public Facilities
Parking
Office
Mixed-Use
Industrial / Commercial
Industrial
Commercial
Agriculture
Agricultural / Residential
Figure 53: County Land Use Classifications of Large Warehouses, by Square Footage Sources: Economic Roundtable GIS analysis; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, Appendix C; Southern California Association of Governments (SCAG) Regional Data Platform and Parcel Locator. 3%
10%
3% 1% 3%
92%
87%
79%
90% 89%
11%
5% 4%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Los Angeles Orange Riverside San
Bernardino
Total
Water
Vacant With Limited Improvements
Vacant Undifferentiated
Vacant
Dairy, Intensive Livestock
Orchards and Vineyards
Cropland
Agriculture
Urban Vacant
Open Space and Recreation
Under Construction
Mixed Residential and Commercial
Transp., Communications, Utilities
Industrial
Commercial and Services
Residential
Exhausting Our Air 91
Residents Living Near Large Warehouse
Within the housing units just described, there are almost 110,000 people living on residential blocks within 300 feet of large warehouses across the four counties, just over 730,000 living within 1,000 feet, and over 2.1 million residents within 2,000 feet, as shown in Table 8. 51 Table 8 Population Living Near Large Warehouses
County Population
County Total
Population
Within 300’
Population
Within 1,000’
Population
Within 2,000’
Los Angeles 10,013,759 69,453 471,277 1,375,776
Orange 3,186,941 15,994 114,826 351,509
Riverside 2,418,119 6,974 46,219 142,014
San Bernardino 2,181,580 17,520 97,903 266,630
Region Total 17,800,399 109,941 730,226 2,135,930
Source: Economic Roundtable analysis; U.S. Census Bureau, 2020 Census National Redistricting Data (P.L. 94-171) Summary File, Table P1. Released 2021; U.S. Census Bureau, TIGER/Line Shapefiles. Block-level decennial data.

Housing Characteristics
It is more common for apartment buildings to be near warehouses in Los Angeles and Orange Counties than in the Inland Empire, where singlefamily homes and mobile homes are more common, as shown in Figure 54.

Figure 54: Number of Households by Type of Building and Proximity to Warehouses Source: Economic Roundtable analysis; U.S. Census Bureau, 2021 American Community Survey 5-Year, Tables: B11011 61%
61%
60%
53%
58%
59%
57%
68%
72%
73%
74%
77%
67%
67%
67%
78%
63%
63%
62%
62%
36%
37%
37%
45%
39%
38%
40%
30%
20%
19%
19%
15%
27%
27%
27%
17%
33%
34%
35%
35%
3%
3%
2%
1%
3%
3%
3%
2%
8%
8%
7%
8%
6%
6%
6%
5%
4%
4%
3%
3%
0% 20% 40% 60% 80% 100%
Within 300'
Between 301' and 1,000'
Between 1,001' and 2,000'
Beyond 2,000'
Within 300'
Between 301' and 1,000'
Between 1,001' and 2,000'
Beyond 2,000'
Within 300'
Between 301' and 1,000'
Between 1,001' and 2,000'
Beyond 2,000'
Within 300'
Between 301' and 1,000'
Between 1,001' and 2,000'
Beyond 2,000'
Within 300'
Between 301' and 1,000'
Between 1,001' and 2,000'
Beyond 2,000'
Los Angeles Orange Riverside San Bernardino Regional Total 1-unit structures 2-or-more-unit structures Mobile homes / all other 92 Exhausting Our Air
Household Structure
Family households52 are more common close to large warehouses than in household located more than 2,000 feet from a large warehouse. This is particularly true in Los Angeles and Riverside Counties, as shown in Figure

55. Across the region, family households make up 74 percent of those living within 2,000 feet of warehouses, and 67 percent beyond 2,000 feet.

Figure 55: Percent of Households with Families, by Proximity to Large Warehouses Figure 56: Percent of Female-Headed Households, by Proximity to Large Warehouses Source: Economic Roundtable analysis; U.S. Census Bureau, 2021 American Community Survey 5-Year, Detailed Tables:

B11011 Household Type by Units in Structure. Released December 2022. Census Tracts. 73%
73%
75%
78%
74%
73%
72%
76%
78%
74%
72%
71%
77%
78%
73%
63%
71%
73%
76%
67%
50% 55% 60% 65% 70% 75% 80%
Los Angeles
Orange
Riverside
San Bernardino
Regional Total
300 Feet or Less Between 301-1,000 Feet
Between 1,001 to 2,000 Feet Balance of Communities
18%
14%
15%
17%
16%
18%
14%
15%
18%
16%
17%
13%
15%
17%
16%
13%
10%
12%
16%
13%
0% 5% 10% 15% 20%
Los Angeles
Orange
Riverside
San Bernardino
Regional Total
300 Feet or Less Between 301-1,000 Feet
Between 1,001 to 2,000 Feet Balance of Communities
Exhausting Our Air 93
Female-headed families53 are also more common closer to large warehouses than outside the 2,000-foot perimeter, as shown in Figure 56. Households headed by women make up 16 percent of households within 2,000 feet of large warehouses, compared 13 percent of households outside of the 2,000- foot perimeter.54 This reflects the reality that households headed by women often have low incomes and fewer housing choices.

Ethnicity
People living near large warehouses are more likely to be Latino and less likely to be European American than in the rest of the four-county region, as shown in Figure 57.

Figure 57: Race/Ethnicity by Proximity to Large Warehouses, by County Source: Economic Roundtable analysis; U.S. Census Bureau, 2020 Census National Redistricting Data (P.L. 94-171 block-level) Summary File, Table P4 (Age 18+). Released 2021; U.S. Census Bureau, TIGER/Line Shapefiles. 8%
11%
9%
9%
2%
3%
2%
2%
6%
7%
8%
7%
8%
11%
10%
9%
6%
9%
8%
8%
16%
12%
12%
13%
23%
24%
22%
22%
8%
8%
8%
8%
9%
9%
10%
10%
15%
13%
13%
14%
45%
63%
64%
62%
31%
41%
42%
42%
46%
61%
60%
61%
50%
61%
61%
62%
43%
59%
60%
59%
28%
12%
12%
14%
41%
29%
30%
30%
37%
20%
21%
21%
29%
16%
16%
16%
32%
16%
16%
17%
3%
3%
3%
3%
4%
4%
4%
3%
4%
4%
3%
3%
4%
3%
3%
3%
4%
3%
3%
3%
0% 20% 40% 60% 80% 100%
All County Residents
300' or Less
Between 301' - 1,000'
Between 1,001' - 2,000'
All County Residents
300' or Less
Between 301' - 1,000'
Between 1,001' - 2,000'
All County Residents
300' or Less
Between 301' - 1,000'
Between 1,001' - 2,000'
All County Residents
300' or Less
Between 301' - 1,000'
Between 1,001' - 2,000'
All County Residents
300' or Less
Between 301' - 1,000'
Between 1,001' - 2,000'
Los Angeles Orange Riverside San Bernardino Total
African American Asian American, PI Latino European American Other Ethnicity 94 Exhausting Our Air
Latinos make up 59 percent of residents living within 2,000 feet of a warehouse, but only 43 percent of the total population in the four-county region. This reflects economic inequity in the four-county region and the unfair reality that many Latino workers are paid wages that are insufficient to pay for rent in neighborhoods that are not impacted by trucking and warehouses.

Median Income
Incomes are lower and poverty rates are higher among people living near warehouses. Median annual household incomes55 within 2,000 feet of large warehouses are $86,000, compared to $105,000 in the balance of the 4- county region, as shown in Figure 58.

Figure 58: Median Income of Households Near Warehouses, by Ethnicity Source: Economic Roundtable analysis; U.S. Census Bureau, 2021 American Community Survey 5-Year, Detailed Tables:

S1903 Median Income Past 12 Months (In 2021 Inflation-Adjusted Dollars) Released December 2022. Census Tracts. $75,656
$80,980
$83,318
$90,094
$99,601
$85,611
$76,199
$81,514
$84,200
$89,976
$96,908
$86,014
$76,960
$80,234
$84,877
$90,555
$97,541
$86,355
$87,700
$84,279
$94,580
$102,190
$101,521
$105,498
$50,000 $70,000 $90,000 $110,000
Latino
African
American
Other Ethnicities
European
American
Asian American,
PI
ALL

HOUSEHOLDS
300 Feet or Less
Between 301-1,000 Feet
Between 1,001 to 2,000 Feet
Balance of Communities
Exhausting Our Air 95
Incomes vary based on ethnicity among households with homes near warehouses. Incomes are lowest for Latinos, who make up a majority of households near warehouses and have median incomes of $76,000.

African American households near warehouses are next lowest, with median annual incomes of $80,000.

Households near warehouses that are grouped under “other ethnicities,” who are primarily individuals identifying with two or more ethnicities, have median annual incomes of $84,000.

European American household near warehouses have the second highest median income, $90,000 a year.

Asian American and Pacific Islander households living near warehouses have the highest median income, $97,000 a year.

Across all four counties, neighborhoods closest to large warehouses have lower median incomes, as can be seen in the map in Figure 59. Factors that diminish the desirability of these neighborhoods, and therefore the cost of housing, include freeways, heavy traffic, seaports, rail intermodal facilities. cargo airports, truck depots, and warehouses.

Figure 59: Median Income of Households, with Proximity to Large Warehouses Source: Economic Roundtable analysis; U.S. Census Bureau, 2021 American Community Survey 5-Year, Detailed Tables: S1903 Median Income Past 12 Months (In 2021 Inflation-Adjusted Dollars) Released December 2022. Census Tracts. 96 Exhausting Our Air
Examples of neighborhoods near warehouse clusters where incomes are low include the East Highlands, Northwest Redlands, North Norton and Riverview neighborhoods surrounding the San Bernardino International Airport. Other examples include the Ontario and Upland neighborhoods northwest of Ontario International Airport; the Los Angeles East Yard, Vermont Square, South Park, Huntington Park and Maywood; the South Los Angeles communities of Compton, Carson, Willowbrook, West Athens, and Rancho Dominguez.

Families in Poverty
The median income of households in an area is one measure of socioeconomic wellbeing, but it reports the income of just the “middle” household in that area. The percent of families living below the annuallyadjusted poverty threshold reveals the degree of acute economic distress in a community.56 Eleven percent of families living close to large warehouses are living in poverty compared to nine percent of families in the entire four-county region, as shown in Figure 60.

The poverty rate for families living near warehouses who have children under 18 years of age is even higher – 16 percent. In comparison, families with children in the balance of the region have a poverty rate of 12 percent.

The poverty rate among families is mapped in Figure 61. Neighborhoods in Riverside County that are near large warehouses and have high family poverty rates include the Home Gardens, Eastside (City of Riverside), and Mead Valley.

Figure 60: Families Below the Poverty Threshold, by Proximity to Large Warehouses Source: Economic Roundtable analysis; U.S. Census Bureau, 2021 American Community Survey 5-Year, Detailed Tables:

S1702 Poverty Status Past 12 Months of Families. Released December 2022. Census Tracts. 12%
16%
11%
16%
11%
15%
9%
12%
0% 5% 10% 15% 20%
All Families
Families with
Children Under 18
300 Feet or Less
Between 301-1,000 Feet
Between 1,001 to 2,000 Feet
Balance of Communities
Exhausting Our Air 97
San Bernardino County neighborhoods that are near warehouses and have high family poverty rates include Perris Hills, Delman / Mt. Vernon, and eastern Upland.

Orange County neighborhoods that are near warehouses and have high family poverty rates include Rustic Lane, Midway City (City of Westminster) and Pico-Lowell / Wilshire Square (City of Santa Ana).

Families living near large warehouses have an elevated risk of poverty throughout the four-county region. In addition to economic distress, these families have long-term exposure to air pollution, as well as traffic noise and congestion that make it difficult to get the peace and quiet needed for a healthy life.

Housing Conditions
Living in overcrowded housing is detrimental to human wellbeing.57 Overcrowding is the result of economic desperation. Families cannot afford to rent an apartment that meets minimum standards of space and privacy Figure 61: Families Below the Poverty Threshold, with Proximity to Large Warehouses Source: Economic Roundtable analysis; U.S. Census Bureau, 2021 American Community Survey 5-Year, Detailed Tables: S1903 Median Income Past 12 Months (In 2021 Inflation-Adjusted Dollars) Released December 2022. Census Tracts. 98 Exhausting Our Air
for household members, so they rent a smaller unit where more than one person is crowded into each room in order to reduce their rent.58 Renter households situated closest to Southern California’s large warehouses have a higher percentage of residents living in overcrowded housing – 18 percent, compared to 13 percent in the balance of the fourcounty region, as shown in Figure 62.

Figure 62: Rental Household Overcrowding, by Proximity to Large Warehouses Source: Economic Roundtable analysis; U.S. Census Bureau, 2021 American Community Survey 5-Year, Detailed Tables:

B25014 Tenure by Occupants per Room. Released December 2022. Universe: Occupied Housing Units. Census Tracts. 82%
82%
82%
87%
11%
11%
11%
7%
7%
7%
7%
6%
50% 60% 70% 80% 90% 100%
300 Feet or Less
Between 301-1,000 Feet
Between 1,001 to 2,000 Feet
Balance of Communities
Not Overcrowded Overcrowded Severely Overcrowded
Photo credit:

Economic
Roundtable
Exhausting Our Air 99
Community Profile: Cynthia Ayala, Amazon Air Worker, San Bernardino Airport
Cynthia Ayala is an Amazon Air worker at the San Bernardino Airport and has been living in the Inland Empire for the past two and a half years.

Cynthia has experienced logistics directly as a worker at the Amazon Air in San Bernardino, as an organizer with her peers, and as a resident of two cities that are huge warehouse hubs: Moreno Valley and Fontana.

For Cynthia, warehouse was a word she knew early on, as her Dad was a warehouse manager for an online clothing store in Commerce, California.

Yet her experience working in logistics and her father’s are completely different. The warehouse her father worked in was not the 100 million square feet hubs we see in the Inland Empire but a smaller scale online store.

Cynthia started working at the Amazon Air Hub over two years ago. She had no idea that she would be dealing with jet fuel impacts daily, as she 100 Exhausting Our Air
now works directly with airplanes. She is outside all day. Whether it is raining or more than 100 degrees, she is loading and unloading, dealing with migraines, back pain, and brain fog coming from direct exposure to the jet fuel.

Workers like Cynthia argue that the effects of jet fuel have to be studied more carefully. She has noticed symptoms of brain fog and migraines beginning and increasing during with her time at Amazon.

Many workers are punished for making mistakes with machinery they were not trained on but just assumed to know how to handle. Some have been fired instead of being provided with correct training.

A management culture of negligence and favoritism is part of the safety problem. Older workers, for example, cannot get reasonable accommodation for handling heavy items or machinery unless they have a medical note. This is unjust because many Amazon workers do not have access to health insurance or medical doctors.

Cynthia has seen warehouses impact people in their neighborhoods as well as at work. Cynthia met a family whose home was displaced so that a warehouse could be built. Only one home in that neighborhood was saved.

Warehouses create infrastructure issues from potholes to congestion of traffic. She and many others must take surface streets to get home because the freeways are too congested.

Cynthia says she can feel a drastic difference in her health and breathing when she visits the coast compared to the constant air quality issues in the Inland Empire. She urges elected officials to get involved in preventing pollution from getting worse, and trying to reverse the decline.

Cynthia knows there are ways to alleviate the harmful impacts of warehouses. She mentions zero-emissions trucks, eliminating Amazon Air and warehouses from the area, creating more parks and green areas, and building warehouses in Beverly Hills or areas most dependent on Amazon.

She says there should be bypass routes that keep heavy-duty trucks away from people’s homes. And they need to stop building warehouses in the Inland Empire. Enough is enough. Warehouses need to focus on lowering air pollution and being good neighbors. This means lowering the noise volume at the facilities. Logistic hubs need to pay livable wages so workers can afford health care.

Exhausting Our Air 101

7. Respiratory Distress ----------------------------------------------------------------------------------------------------------------- Looking at Riverside from
Mount Rubidoux
Photo credit:

John Ko on Upsplash
102 Exhausting Our Air
Overview
Criteria Emissions
The direct pollutants from diesel truck trips to and from large warehouses, as well as the indirect pollutants attributable to the electricity and natural gas these buildings consume onsite, affect public health. Residents of the four-county region have elevated rates of respiratory disease.

Diesel trucks driving to and from large warehouses release criteria emissions each mile, including elemental carbon, which is the primary component of PM 2.5 fine particulates. These pollutants are unhealthy even when low levels are in the air.

High Pollution Burden
Many single- and multi-family homes near the large warehouse cluster abutting Ontario International Airport experience the highest concentrations of elemental carbon in their air, extending far beyond just the residential blocks adjacent and across the street.

Similarly, people living near San Bernardino International Airport, and the adjacent cluster of large warehouses, are exposed to the highest levels of elemental carbon concentrations.

Residents near the cluster of large warehouses growing around March Air Reserve Base in Riverside, and extending up to the junction of the US 215 and CA 60 freeways, are breathing air with moderate or higher levels of elemental carbon.

As developers continue building large warehouses across the Inland Empire, the associated diesel truck trip emissions will add further pollutants to the already unhealthy air.

Asthma Attacks
The rate of emergency department visits for asthma attacks reflects the location of manufacturing and logistics land uses. South Los Angeles, City of Industry, Ontario and San Bernardino have elevated rates of emergency department visits as well as the largest concentrations of logistics activity.

Exhausting Our Air 103
Health Conditions Requiring In-Patient Hospitalization
The direct pollutants from diesel truck trips to and from large warehouses, as well as the indirect pollutants attributable to the electricity and natural gas these buildings consume onsite, affect public health. Residents of the region reflect this in their rates of respiratory disease. 59 Pollution together
with socioeconomic factors such as limited income and overcrowded housing make frontline families living near warehouses vulnerable to health risks from pollution caused by warehouses.

Diesel Particulate Matter (PM) Emissions
Freight trucks are an important source of diesel particulate matter. Diesel particulate matter is most concentrated near hubs of trucking activity, as shown in Figure 63. This includes the San Pedro Bay Ports, airports, rail yards and warehouses.

The transformation of the Inland Empire from small communities dominated by agriculture into a warehouse logistics hub for goods consumed by residents of Southern California and beyond is particularly notable. Few neighborhoods in the Inland Empire are untouched by diesel Figure 63: Diesel Particulate Matter and Large Warehouses Source: Economic Roundtable analysis; California Office of Environmental Health Hazard Assessment (OEHHA), CalEnviroScreen 4.0: Diesel PM. Released:

November 2021; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, Appendix C and other sources. Note: Includes diesel particulate matter (PM) from on-road and non-road sources. https://oehha.ca.gov/calenviroscreen. Percentile ranking is for the State of California. 104 Exhausting Our Air
particulate matter. Residents’ and workers’ continued exposure to this pollutant has numerous adverse health effects including irritation to the eyes, throat and nose, cardiovascular and pulmonary disease, and lung cancer.
60 Uneven Pollution Burden
Diesel particulate matter combines with other pollutants to create a cumulative impact on residents and workers that is more harmful than any single component. A pollution burden index showing the combined harmful exposures to toxic chemicals and the environmental effects of pollution in each community in the four-county region is shown in Figure

64. 61
Large swaths of the Inland Empire are in the highest quintile of the pollution burden index, meaning they have the highest exposure to criteria air pollutants, including ground level ozone, carbon monoxide, lead, nitrogen dioxide, sulfur dioxide, and different varieties of particulate matter.

While it is expected that large warehouses are built on land zoned for industrial uses such as factories and utility facilities, the enormous size of Figure 64: Pollution Burden and Large Warehouses
Source: Economic Roundtable analysis; California Office of Environmental Health Hazard Assessment (OEHHA), CalEnviroScreen 4.0: Pollution Burden.

Released: November 2021; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, Appendix C and other sources. Note:

Includes diesel particulate matter (PM) from on-road and non-road sources. https://oehha.ca.gov/calenviroscreen. Percentile ranking is for the state of California.

Exhausting Our Air 105
large warehouses increases the pollution burden for nearby communities, where homes, schools, parks, churches and shopping centers are sometimes immediately next to warehouses.

PM 2.5 Spillover into Surrounding Neighborhoods
Poor air quality from industrial land uses has a spillover effect into surrounding neighborhoods, beyond what was previously known. Diesel trucks driving to and from large warehouses release criteria emissions each mile, including fine particulates (PM 2.5), which are unhealthy even when the level in the air is low.

The predicted extent of elemental carbon, a principal component of PM

2.5 and mainly emitted from truck traffic, at 50-meter resolution is shown for different communities in Figures 65, 66, and 67.
62 Many single- and multi-family homes near the large warehouse cluster abutting Ontario International Airport experience the highest concentrations Figure 65: Elemental Carbon Concentrations around Ontario Warehouse Cluster Source: Economic Roundtable analysis; Amini, H. at al. 2023. Annual Mean PM2.5 Components (EC, NH4, NO3, OC, SO4) 50m Urban and 1km NonUrban Area Grids for Contiguous U.S., 2000-2019 v1. Palisades, New York: NASA Socioeconomic Data and Applications Center (SEDAC). https://doi.org/10.7927/7wj3-en73. Accessed March 7, 2023.; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, Appendix C and other sources.
106 Exhausting Our Air
of elemental carbon in their air, extending far beyond just the adjacent residential blocks, as shown in Figure 65.

Figure 66: Elemental Carbon Concentrations around San Bernardino Airport Warehouse Cluster Figure 67: Elemental Carbon Concentrations around March ARB Warehouse Cluster Source: Amini, H. at al. 2023. Annual Mean PM2.5 Components (EC, NH4, NO3, OC, SO4) 50m Urban and 1km Non-Urban Area Grids for Contiguous U.S., 2000-2019 v1. Palisades, New York: NASA Socioeconomic Data and Applications Center.

Exhausting Our Air 107
When residents breath in unhealthy levels of PM 2.5 components daily over many years, it can increase their risk of heart disease, asthma, and low birth weight, among other health problems. People living near San Bernardino International Airport, and the adjacent cluster of large warehouses, are exposed to the highest levels of elemental carbon concentrations, as shown in Figure 66.

As developers continue building large warehouses across the Inland Empire, the associated diesel truck trip emissions will add further pollutants to the already unhealthy air.

Chronic Respiratory Disease Exacerbated by Air Pollution In addition to air pollution directly causing new health problems among nearby residents, those with existing chronic obstructive pulmonary disease (COPD) – a family of diseases that cause breathing-related problems and blockages, such as asthma, emphysema and chronic bronchitis – are also negatively affected.63
People with asthma are generally considered to be sensitive to the effects of air pollution. Across California, just under 2.7 million adults currently have Figure 68: Number of Asthma Emergency Department Visits by County Source: Economic Roundtable analysis; California Department of Public Health. 2022. Asthma Emergency Department Visit Rates, 2019. https://data.ca.gov/dataset/asthma-emergency-department-visit-rates 17,076
4,010 3,496 3,124
29,817
7,701 6,247 5,359
0 5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
50,000
Los Angeles San Bernardino Riverside Orange
Age 0 to 17 Age 18+
108 Exhausting Our Air
asthma, many more have had it at some point in their lives, and it is the leading cause of over 350 annual deaths in California.
64 Children, the
elderly and low-income Californians suffer disproportionately from asthma.65
Exposure to air pollutants, including criteria emissions associated with large warehouses’ diesel truck trips and indirect onsite energy consumption, can trigger episodic asthma attacks of breathlessness, wheezing, coughing, and chest tightness.
66 Such attacks can be a life-threatening and require
emergency department visits, which number in the tens of thousands in the four-county region, as shown in Figure 68.

Los Angeles County, with its much larger population and expansive industrial economy has the highest number of asthma emergency department visits –just under 30,000 by adults and just over 17,000 for children under age 18.

San Bernardino County, with just a quarter of Los Angeles County’s population, had 7,701 adult visits to emergency departments for asthma and 4,010 visits by children.

The rate of asthma emergency department visits per 10,000 residents reveals greater parity among counties. Los Angeles has the highest rate of visits to emergency rooms by children with asthma attacks, followed closely by San Bernardino, Riverside and Orange, as shown in Figure 69.

San Bernardino has the highest rate of emergency department visits for adult asthma attacks, followed by Los Angeles, Riverside and Orange.

Figure 69: Asthma Emergency Department Visits per 10,000 Residents, 2019 Source: Economic Roundtable analysis; California Department of Public Health. 2022. Asthma Emergency Department Visit Rates, 2019. https://data.ca.gov/dataset/asthma-emergency-department-visit-rates Note: Age Adjusted Rate = (Cases in Age Group x Total Population in Age Group) * 10,000. 83 73
59 47
37 47
34 21
0 10
20 30
40 50
60 70
80 90
Los Angeles San Bernardino Riverside Orange
Age 0 to 17 Age 18+
Exhausting Our Air 109
Poor air quality creates costs for patients, the care provider, medical insurers, and tax payers, even when it is not the direct cause of chronic conditions such as asthma.

Figure 70: Asthma Emergency Department Visits per 10,000 Residents, 2019 Source: Economic Roundtable analysis; California Department of Public Health. 2022. Asthma Emergency Department Visit Rates, 2019. https://data.ca.gov/dataset/asthma-emergency-department-visit-rates; 2022 South Coast Air Quality Management District (SCAQMD) Rule 2305 Packet, App. C and other sources. Notes: Age Adjusted Rate = (Cases in Age Group x Total Population in Age Group) * 10,000. Data by ZCTA ZIP Code. 110 Exhausting Our Air
Community Profile: Henry James Vasquez, Indigenous and Mexican Elder Henry James Vasquez (73) is an Indigenous/Mexican elder in the Colton and greater San Bernardino community. He has lived in the Inland Empire for over 50 years. Henry grew up in San Bernardino but has generations of relatives that have lived in the Colton community, where he now resides.

He is a retired school teacher who spends most of his time uplifting and supporting the cultural and historical preservation of native history as the Chair of the Native American Community Council of San Bernardino and Riverside. He is also on the Board of the Future Leaders Program which supports Latinx youth as they navigate school and early adulthood; and is part of the Old Spanish Trail Association that has been fighting to preserve the Agua Mansa Settlement which has been a target for warehouse development for the past two decades. Henry is an active member of his Exhausting Our Air 111
community, fighting for the rights of mother nature, native sovereignty and environmental justice.

What is your relationship to the logistics industry?
The Agua Mansa Settlement is almost covered in warehouses now. It was one of the first settlements that Mexican people made in this region.

Protecting Agua Mansa is important to me because my cousins are from a family that lived in the original settlement. The idea of paving over the area is insulting. It is also right across the street from the Agua Mansa Cemetery.

When I was a child we could see open land from there to the Santa Ana River. The Santa Ana River is important to us and it is a Native American legacy of the Inland Empire. It is criminal to be covering everything up with warehouses.

I fight against these warehouses because I am fighting for the respect we should have, as people living here and for the families that have lived in South Colton for decades. It’s all about making money and it’s incredibly disrespectful.

I have been in opposition to the warehousing and trucking industry for a long time. I have worked with people in Colton, Riverside, San Bernardino and other cities to show up at different commission meetings and planning meetings to oppose these developments. In the City of Colton, we have been able to win a moratorium against warehouses for almost two years, but it is not enough. We need a real solution to all the warehouse proposals.

Is there any way the warehousing industry could be better neighbors? It would be best if they stayed away from us. I am disgusted by the idea they pick lower income neighborhoods to put their stuff in and disrespect us. They could use smaller trucks and electric vehicles that don’t put out as much pollution. That would be some accommodation. But even with those accommodations, they are still taking away all of the beauty and taking up all the land. Seeing open land is not ugly, it is nature, it is beautiful. A developer sees it as ‘aha this is a place we can put a warehouse or trucking – cha-ching making money.’
All these warehouses impact our health. This area used to have us breathing in an old cement plant and that was hurting us. But now it is replaced with diesel trucks and rail yards which are even more toxic and cause even more noise and traffic than we had before.
112 Exhausting Our Air
I remember going on a field trip with a botany professor in the 60s and he told us as he picked up some earth, this is the most fertile earth of all of this region.

We love the land, we love the landscape, we love the trees, we love the mountains, the river but everything is being torn up for people that don't live here to make money and it just hurts.

How do you think politicians deal with this?
Generally speaking, if you go back to the 1940s and 1950s when Colton was controlled by the Anglo politicians, they gave lip service to caring about South Colton, but they always voted in favor of North Colton.

When Chicano politicians started getting involved in politics, for the first few years they fought for the rights of the people. But now it’s almost like the Anglo politicians are back even though they are Chicano members. they vote against our favor and vote in favor of the industry. Some of the current politicians are even related to our families but they still vote for destroying our heritage. I know some politicians are pushing back, but it is not the majority right now.

What will happen if development continues the way it is? I think people will be forced to move out. I think the warehouse industry will make people offers and buy up their lands. We are already seeing it in places like Bloomington. People are getting pushed away by the warehousing industry and housing prices continue to go up. We are being left with astronomically high priced housing.

What gives you hope about our future?
Networking with others likeminded people, the Native American community and other community groups are what help me feel hopeful.

We are all fighting for justice. When we work together, we give each other hope. There are people that are always going to fight us - always.

What is our biggest strength in this fight?
That we are fighting together. It encourages me to see people proud of their history and their lifestyle. We are teaching bird singing, our languages, our histories, we are reviving mariachi music. We might not be professional yet but our cultural is not dying and people are proud of their identity.

Exhausting Our Air 113

8. Onsite Warehouse Emissions ----------------------------------------------------------------------------------------------------------------- Photo credit:

Pickawood on Unsplash
114 ERt-SC Warehouse Equity 2023
Overview
Warehouses are the most common type of commercial building in the United States. On-site warehouse operations have environmental impacts from upstream emissions that result from consumption of electricity, and water, and from on-site combustion of natural gas.

Large warehouses in the four-county region consume 15.5 terajoules of electricity onsite annually.

Electricity consumed by large warehouses in the four-county region is accountable for upstream releases of over one-million metric tons of greenhouse gas (carbon dioxide) into the atmosphere annually.

Natural gas provides 34 percent of the energy that warehouses consume.

Natural gas combustion at large warehouses produces 1.6 billion pounds of greenhouse gas emissions annually.

A total of 101,603 pounds of very fine-sized particulate matter is estimated to be released annually into the region’s air by natural gas combustion at large warehouses.

Large warehouses in Southern California consume an estimated 2.7 billion gallons of water annually.

Exhausting Our Air 115
Energy Consumption from On-Site Operations
Warehouses are the most common type of commercial building in the United States.
67 Activities inside each warehouse have environmental
impacts from upstream emissions that result from consumption of electricity and water, and from on-site combustion of natural gas.

Large warehouses in the four-county region consume significant amounts of electricity onsite, approximately 15.5 terajoules annually (Table 9).

Warehouses in Los Angeles County use the most electricity, just over 6 terajoules per year, while the growing warehouse inventory in San Bernardino County is close behind, consuming 5.7 terajoules Warehouses use electricity to operate heating, ventilation, and air conditioning systems, water heating, lighting, security systems, employee monitoring systems, refrigeration, and material moving equipment such as conveyors for bins and containers, automated and semi-automated packaging equipment, and forklifts and pallet movers.

Table 9 Annual Electricity Consumption of Large Warehouses County
Large Warehouse
Square Feet
Electricity
Consumption
(kWh)
Electricity
Consumption
(Terajoules)
Los Angeles 315,772,032 1,670,280,021 6,013
Orange 75,633,453 394,489,145 1,420
Riverside 131,212,586 695,426,705 2,504
San Bernardino 283,677,944 1,591,637,075 5,730
Region Total 806,296,015 4,351,832,946 15,667
Source: Economic Roundtable analysis; U.S. Energy Information Administration. Commercial Buildings Energy Consumption Survey (CBECS) Table C22. “Electricity consumption totals and conditional intensities by building activity subcategories, 2018.” Release date: December 2022: https://www.eia.gov/consumption/commercial/reports/2012/water/ Electricity is the primary source of energy for warehouses in the fourcounty region. 68 This is true for commercial buildings in general in
Southern California, which draw 87 percent of their energy from electricity.69
Warehouses use over twice as much electricity to meet their energy needs as the next largest source, natural gas. Natural gas provides 34 percent of the energy that warehouses consume, as shown in Figure 71.

Other forms of gas, including bottled gas, liquefied petroleum gas (LPG) and propane provide just over eight percent of the energy used by warehouses.
116 ERt-SC Warehouse Equity 2023
Less than one percent of the on-site energy used by warehouses comes in the form of petroleum products such as fuel oil, diesel or kerosene.

How and Where Locally-Consumed Electricity is Generated California generates three-quarters (78 percent) electricity of the electricity it uses within the state. We purchase 18 percent our electricity from other Figure 71: Energy Mix for Warehouses by U.S. Region (multiple types per warehouse) Source: Economic Roundtable analysis; U.S. Energy Information Administration. Commercial Buildings Energy Consumption Survey Public Use Microdata, 2018, for non-refrigerated warehouses. Buildings use multiple types of energy. 0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Percent Using Each Type of Energy
Electricity Natural gas Fuel oil/diesel/kerosene Bottled gas/propane Figure 72: Location where Electricity Consumed in California is Generated Source: Economic Roundtable analysis; U.S. Energy Information Administration. Commercial Buildings Energy Consumption Survey (CBECS) Public Use Microdata, 2018.
0 50,000
100,000
150,000
200,000
250,000
300,000
2009201020112012201320142015201620172018201920202021
Gigawatts of Electricity
Southwest
Northwest
California
Exhausting Our Air 117
states in the Southwest region. The remaining 12 percent is imported from Northwest states.70
This balance among California’s sources of electricity has held relatively steady for over a decade, as shown in Figure 72. Roughly two-thirds of the environmental impacts of electricity generation are within California and one-third in adjacent states.

California’s mix of energy sources used to generate electricity includes natural gas and other fossil fuels, as shown in Figure 73. Fossil fuel combustion releases planet-warming greenhouse gases and criteria emissions that cause life-harming respiratory illness.

Electricity production was the source of 25 percent the United States’ greenhouse gas emissions in 2021.71
Figure 73: Energy Sources for Generating Electricity in California and the United States Sources: Economic Roundtable 2021 data from the Emissions & Generation Resource Integrated Database (eGRID) released January 30, 2023. https://www.epa.gov/egrid/power-profiler#/CAMX 38 48
22 4
19 8
3 19
6 7
9 8
1 3
4 0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
United States California
Unknown
Geothermal
Biomass
Wind
Hydro
Solar
Nuclear
Other Fossil
Fuel
Oil
Coal
Gas
California
renewable
energy
40%
California
fossil fuel
52%
118 ERt-SC Warehouse Equity 2023
California uses renewable energy to generates twice as much of its electricity as the nation as a whole – 40 percent versus 20 percent. This supports a cleaner environmental footprint for electricity generated within the state than for energy imported from other states.

This is largely because California uses solar energy to generate more of its electricity than other states – 19 percent versus 3 percent.

However, 52 percent of the electricity generated within California is generated using fossil fuels. This is smaller than the 61 percent share of electricity from other states that is generated using fossil fuels, but it still has large environmental impacts.

California generates less of its electricity using nuclear power than other states - 8 percent compared to 19 percent.

Reducing the amount of electricity that warehouses draw from the utility grid and increasing the amount that is generated from renewable sources, such as on-site solar panel arrays, will help shrink the environmental footprint of warehouses.

Metric Tons of GHG Emissions from On-Site Energy Consumption Carbon dioxide (CO2) makes up the vast majority of greenhouse gas emissions from electricity production nationwide, but smaller amounts of methane (CH4) and nitrous oxide (N2O) are also emitted.72 Photo credit:

Cole Patrick on Unsplash
Exhausting Our Air 119
Electricity consumed by large warehouses in the four-county region is accountable for releasing over one-million metric tons of greenhouse gas (carbon dioxide) into the atmosphere annually, as shown in in Table 10.

Table 10 Metric Tons of Greenhouse Gas Emissions from Electricity Consumed by Large Warehouses
County
Large
Warehouse
Square Feet
Carbon Dioxide
CO2 Emissions
(MT)
Methane CH4
Emissions (MT)
Nitrous Oxide
N2O Emissions
(MT)
Los Angeles 315,772,032 403,676 23.5 3.0
Orange 75,633,453 95,341 5.6 0.7
Riverside 131,212,586 168,072 9.8 1.3
San Bernardino 283,677,944 384,670 22.4 2.9
Region Total 806,296,015 1,051,759 61.3 7.9
Source: Economic Roundtable analysis; U.S. Environmental Protection Agency, Center for Corporate Climate Leadership. 2023 “Emissions & Generation Resource Integrated Database (eGRID) - Emission Factors for Greenhouse Gas Inventories.

Table 6. Electricity. https://www.epa.gov/egrid/download-data Warehouses in Los Angeles County are responsible for 38 percent of these greenhouse gas emissions and those in San Bernardino County are responsible for 37 percent.

Warehouses in Riverside and Orange Counties are responsible for 16 percent and 9 percent, respectively, of upstream emissions from generating electricity.

The four counties share the same distribution of responsibility for the 61 metric tons of methane (CH4) and the 8 metric tons of nitrous oxide (N2O) that are released annual because of electricity consumed by large warehouses.

Criteria Emissions from On-Site Activities
Air pollution harms people’s health and is also harmful for pets, vegetation and buildings. National ambient air quality standards for the most common air pollutants – known as “criteria pollutants” – include nitrogen dioxide and sulfur dioxide.

Criterion emissions attributable to electricity consumption by large warehouses in the four-county region add up to 1,028 metric tons of nitrogen dioxide and 75 metric tons of sulfur dioxide annually, as shown in Table 11. The highest levels of criteria emissions are attributable to large warehouses in Los Angeles and San Bernardino Counties.

Emissions linked to large warehouses will change as diesel trucks are replaced by electric trucks for warehouse drayage. There will be an overall 120 ERt-SC Warehouse Equity 2023
reduction in emissions, but some increase in upstream emissions because of electricity consumed by charging stations.

Table 11 Metric Tons of GHG Emissions from Electricity Consumption of Large Warehouses
County
Large
Warehouse
Square Feet
CO2e Emissions
(MT)
NOX
Emissions (MT)
SO2
Emissions (MT)
Los Angeles 315,772,032 405,119 394.8 28.9
Orange 75,633,453 95,682 93.2 6.8
Riverside 131,212,586 168,673 164.4 12.0
San Bernardino 283,677,944 386,044 376.2 27.5
Region Total 806,296,015 1,055,517 1,028.6 75.2
Source: Economic Roundtable analysis; U.S. Environmental Protection Agency, Center for Corporate Climate Leadership. 2023 “Emissions & Generation Resource Integrated Database (eGRID) - Emission Factors for Greenhouse Gas Inventories.

Table 6. Electricity. https://www.epa.gov/egrid/download-data Warehouses may add more solar electric panels to their roofs to increase the amount of renewable energy in their power fuel mix. This will provide credits under the South Coast Air Quality Management District’s Rule 2305 – the Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program.

On-Site Natural Gas Consumption
Warehouses use natural gas for space heating.73 The environmental impact report for a large warehouse in San Bernardino County identifies the annual amounts of natural gas consumer per square foot, as shown in Table

12. Table 12 Large Warehouses Natural Gas Consumption per Square Foot Warehouse Type
Natural Gas
Btu Consumed per Cubic Square Foot per Year
Non-Refrigerated 19,063
Refrigerated 27,580
Source: Economic Roundtable analysis; Urban Crossroads. 2022 Nevada Street Warehouse, Appendix F: Energy Analysis, County of San Bernardino, pages 9, 37; Southern California Gas Company. 2017. SoCalGas Natural Gas Quality Standards 1-Sheet. Natural gas standard heating values are in British thermal units (Btu) per Standard Cubic Foot (SCF).

The global warming and air pollution effects of onsite space heating in large warehouse are shown in Tables 13. In natural gas combustion, 99.9 percent of the fuel is converted to carbon dioxide.
74 This produces 1.6
billion pounds of greenhouse gas emissions annually.

Exhausting Our Air 121
Criteria emissions are also shown in Table 13, including particulate matter, which causes adverse health effects among children, people with asthma and older adults with chronic cardiovascular and pulmonary diseases.75 Table 13 Annual Emissions from Onsite Natural Gas Combustion at Large Warehouses Los Angeles Orange Riverside San
Bernardino Total
Large Warehouse SF: 315,772,032 75,633,453 131,212,586 283,677,944 806,296,015 Emissions:

CO2 626,890,307 148,059,857 261,007,888 568,299,372 1,604,257,424 NH4 12,015 2,838 5,003 10,892 30,748
N2O* 11,493 2,714 4,785 10,419 29,411
N2O** 3,343 790 1,392 3,031 8,556
SO2 3,134 740 1,305 2,841 8,021
PM (Total) 39,703 9,377 16,530 35,992 101,603
PM (Condensable) 29,777 7,033 12,398 26,994 76,202
PM (Filterable) 9,926 2,344 4,133 8,998 25,401
Lead 2.612 0.617 1.088 2.368 6.684
Volatile OCs 28,732 6,786 11,963 26,047 73,528
Total OCs 57,465 13,572 23,926 52,094 147,057
Source: Economic Roundtable analysis; Urban Crossroads. 2022 Nevada Street Warehouse, Appendix F: Energy Analysis, County of San Bernardino, pages 9, 37; Southern California Gas Company. 2017. SoCalGas Natural Gas Quality Standards 1-Sheet; U.S. Environmental Protection Agency. 1998. AP 42, Compilation of Air Pollutant Emission Factors:

Table 1.4-2. Emission Factors for Criteria Pollutants and Greenhouse Gases from Natural Gas Combustion.

Notes: Nitrous oxide (N20) is split into Uncontrolled (*) and Controlled-low-NOX burner (**).

Particulate matter from natural gas combustion is estimated to be smaller than one micron. The volume of particulate matter that is emitted increases if there are improper fuel-to-air mixing ratios because, for example, of poor maintenance of heating systems.
76 Photo credit:

Martin Martz on Unsplash
122 ERt-SC Warehouse Equity 2023
A total of 101,603 pounds of this very fine-sized particulate matter is estimated to be released annually into the region’s air by large warehouses.

On-Site Water Consumption
Large warehouses have relatively low water usage, compared to other large commercial buildings.77 However, new California regulations, amidst historic drought and emerging climate change, aim to curb water use at commercial properties across the state as urban residents and rural farmers are already mandated to cut their water use.
78 Large warehouses in the four-county region consume an estimated 2.7 billion gallons of water annually, or 7.4 million gallons per day (Table 14).

Warehouses in Los Angeles and San Bernardino Counties consume the most water, 1.07 billion and 0.97 billion gallons annually.

Table 14 On-Site Water Consumption of Large Warehouses
County
Large
Warehouse
Square Feet
On-Site Water
Consumption,
Annual (Gallons)
On-Site Water
Consumption, Daily
(Gallons)
Los Angeles 315,772,032 1,071,500,391 2,930,869
Orange 75,633,453 253,068,508 692,217
Riverside 131,212,586 446,122,792 1,220,277
San Bernardino 283,677,944 965,989,480 2,642,265
Region Total 806,296,015 2,736,681,171 7,485,628
Source: Economic Roundtable analysis; U.S. Energy Information Administration. 2017. Commercial Buildings Energy Consumption Survey (CBECS). Table W1. Water consumption in large commercial buildings, 2012. https://www.eia.gov/consumption/commercial/reports/2012/water/ Photo by Martin Martz on
Unsplash
Exhausting Our Air 123

9. Data Appendix and
Methodology
----------------------------------------------------------------------------------------------------------------- Photo credit:

Economic Roundtable
124 Exhausting Our Air
List of Large Warehouses by City
San Bernardino County
City or CDP Warehouse Sites Square Feet Employment
Bloomington ....................................... 16 6,093,244 571 Chino ................................................ 117 35,220,833 3,308 Chino Hills ............................................ 3 382,180 36 Colton ................................................. 22 6,516,848 611 Eastvale .................................................. 1 171,112 16 Fontana .............................................. 140 49,122,306 4,612 Grand Terrace ....................................... 1 130,695 12 Mentone ................................................ 2 431,466 40 Montclair ............................................... 3 389,247 36 Ontario .............................................. 289 81,755,360 7,616 Rancho Cucamonga .......................... 107 25,149,893 2,367 Redlands .............................................. 56 23,691,172 2,220 Rialto .................................................. 47 25,697,104 2,404 Riverside ............................................... 2 1,130,721 106 San Bernardino .................................... 76 27,476,992 2,583 Upland .................................................. 3 318,773 30 County Total................................... 885 283,677,944 26,570 Riverside County
City or CDP Warehouse Sites Square Feet Employment
Banning ................................................. 1 173,101 23 Beaumont .............................................. 7 3,013,628 396 Coachella ............................................... 3 448,476 59 Corona ................................................ 65 11,154,994 1,467 Desert Hot Springs ................................. 1 77,662 10 Eastvale ................................................ 22 9,201,729 1,208 Hemet ................................................... 1 126,611 17 Indio ...................................................... 2 209,161 27 Jurupa Valley ....................................... 80 22,049,074 2,896 March Air Reserve Base....................... 13 5,642,754 741 Mira Loma ............................................. 3 1,213,565 159 Moreno Valley ..................................... 48 26,635,719 3,497 Murrieta ................................................ 3 307,852 40 Norco .................................................... 2 284,664 37 Nuevo ................................................... 1 105,833 14 Palm Springs .......................................... 1 116,497 15 Perris ................................................... 45 24,715,608 3,251 Riverside ............................................. 80 21,314,528 2,798 San Jacinto ............................................. 1 72,308 10 Temecula ............................................. 23 4,108,079 541 Exhausting Our Air 125
Thermal ................................................. 2 240,742 32 Grand Total ..................................... 404 131,212,586 17,238 Los Angeles County
City or CDP Warehouse Sites Square Feet Employment
Alhambra ................................................ 4 411,713 30 Arcadia ................................................... 4 1,046,486 56 Azusa .................................................... 13 1,708,497 124 Baldwin Park .......................................... 4 472,983 42 Bell ...................................................... 15 3,107,155 179 Bell Gardens ........................................... 2 698,629 36 Burbank ................................................. 5 737,700 40 Calabasas ................................................ 1 111,945 10 Canoga Park ........................................... 7 938,764 72 Carson ................................................ 119 22,173,745 1,357 Cerritos ................................................ 33 5,177,116 349 Chatsworth ........................................... 20 3,479,363 230 City of Industry .................................. 197 48,803,707 2,788 Commerce ......................................... 121 24,645,773 1,484 Compton.............................................. 80 12,872,746 873 Cudahy .................................................. 1 88,966 10 Diamond Bar .......................................... 1 104,780 10 Downey ................................................. 9 2,139,819 109 Duarte .................................................... 3 312,601 30 El Monte .............................................. 11 2,551,025 151 El Segundo ............................................. 6 2,041,733 110 Gardena ................................................ 30 3,967,840 303 Glendora ................................................ 1 119,875 10 Hacienda Heights ................................... 4 568,537 40 Hawthorne ........................................... 14 4,275,451 228 Huntington Park .................................... 4 431,679 40 Inglewood .............................................. 4 568,013 40 Irwindale .............................................. 20 5,585,245 318 La Mirada ............................................. 40 9,039,564 528 La Puente ............................................... 3 423,135 30 La Verne ................................................ 1 113,070 10 Long Beach .......................................... 50 10,895,592 678 Los Angeles ........................................ 165 30,943,289 1,980 Lynwood .............................................. 10 2,360,065 126 Monrovia ............................................... 1 290,914 15 Montebello ........................................... 24 4,098,538 278 North Hills ............................................. 3 396,640 30 North Hollywood .................................. 8 1,299,374 87 Northridge ............................................. 3 527,201 27 Norwalk ................................................. 7 787,295 70 126 Exhausting Our Air
Pacoima ................................................. 9 1,056,289 84 Panorama City ....................................... 6 1,033,418 70 Paramount ............................................. 8 1,820,676 105 Pasadena ................................................ 1 106,000 10 Pico Rivera.......................................... 27 4,860,155 285 Pomona ............................................... 41 7,874,276 462 Rancho Dominguez ............................ 35 5,355,937 363 Redondo Beach ..................................... 7 1,322,758 74 Rowland Heights ................................... 1 112,536 10 San Dimas .............................................. 3 396,830 30 San Fernando ......................................... 5 752,606 50 San Pedro .............................................. 5 1,987,882 102 Santa Clarita........................................... 5 2,134,685 117 Santa Fe Springs ................................. 126 25,731,687 1,578 Santa Monica ......................................... 1 150,212 10 Signal Hill .............................................. 2 420,807 26 South El Monte ..................................... 3 394,082 30 South Gate ........................................... 27 3,449,912 279 Sun Valley ........................................... 11 1,499,734 110 Sunland .................................................. 1 79,907 10 Sylmar ................................................. 22 2,992,894 227 Torrance .............................................. 61 10,811,063 681 Valencia ............................................... 40 5,380,176 404 Van Nuys ............................................ 12 3,435,490 201 Vernon ................................................ 96 15,640,039 1,034 Walnut ................................................ 17 3,281,456 202 West Covina .......................................... 1 147,530 10 Whittier ................................................. 8 1,337,124 84 Wilmington ........................................... 7 1,006,218 71 Woodland Hills ...................................... 2 647,906 35 Grand Total ................................... 1,638 315,536,848 19,686 Orange County
City or CDP Warehouse Sites Square Feet Employment
Aliso Viejo ............................................. 1 307,425 10 Anaheim .............................................. 75 14,456,068 767 Brea ..................................................... 22 3,577,177 222 Buena Park .......................................... 37 7,149,647 378 Costa Mesa ............................................ 5 1,036,786 51 Cypress ................................................ 16 2,950,770 165 Foothill Ranch .................................... 12 2,364,811 110 Fountain Valley ...................................... 4 561,912 40 Fullerton .............................................. 51 9,821,033 519 Garden Grove ...................................... 16 2,834,824 160 Huntington Beach ............................... 18 3,436,316 180 Exhausting Our Air 127
Irvine ................................................... 47 10,231,521 497 La Habra ................................................ 3 1,340,437 42 La Palma ................................................. 6 1,400,941 65 Lake Forest ............................................. 5 946,746 50 Los Alamitos ........................................... 3 349,135 30 Orange ................................................. 12 2,048,008 120 Placentia ................................................. 3 478,145 30 Rancho Santa Margarita ......................... 4 651,943 40 San Juan Capistrano ................................ 2 397,526 20 Santa Ana ............................................. 42 6,718,461 419 Seal Beach .............................................. 3 376,871 30 Stanton ................................................... 1 118,059 10 Tustin ..................................................... 8 1,351,219 86 Westminster ........................................... 2 360,706 20 Yorba Linda ........................................... 1 110,238 10 Grand Total ..................................... 399 75,376,724 4,071 Note: CDP stands for Census Designated Place. These are established unincorporated communities for which the U.S. Census Bureau provides statistics about population and housing.
128 Exhausting Our Air
Methodology for Building Database of Large Warehouses
The methodology used in this report for estimating employment in large warehouses shown in Chapter 2, is as follows: 1) Employment for ALL warehouse industry workers is estimated from the U.S. Census’ 5-Year American Community Survey 2020 PUMS data. Data were filtered by:
• NAICS Industry (NAICSP) 493 (TRN-Warehouse and Storage) • Employment Status Recode (ESR) is limited to “Civilian Employed, at Work” • Total person's earnings (PERNP, adj. to 2020 dollars) at least $500 annually • Class of worker (COW) = Employee of a private for-profit business ('1') County
Employed Warehouse
Industry Workers, ALL
Warehouses (A)
Percent of Warehouse
Workers (ACS PUMS)
(B)
Los Angeles County 36,349 39%
Orange County 5,410 6%
Riverside County 18,973 20%
San Bernardino County 32,539 35%
Region Total 93,271 100%
Dataset: US Census. American Community survey (ACS) 5-Year Estimates Public Use Microdata Sample (PUMS), 2016-2020.

These county-level employment estimate for ALL warehouse industry workers is used as the denominator for creating county-level ratios of square feet of warehouse per warehouse-industry employee. 2) Square footage of ALL Warehouses by county comes from the Southern California Association of Governments (SCAG) 2018 report "Industrial Warehousing in the SCAG Region," Table 2.1 from the "Inventory" section of the report. These data were updated to 2023 by using a warehouse square feet growth factor of 23.96%, calculated from the increase in large warehouse properties the Economic Roundtable analyzed in databases for this study:

County
Total Occupied
Space (SF), ALL
Warehouses (2014)
(C)
Total Occupied
Space (SF), ALL
Warehouses in
2023 (D)
Square Feet of
Warehouse per
Employee Ratio
(E=D/A)
Los Angeles County 568,958,384 705,284,271 19,403
Orange County 134,440,969 166,653,842 30,805
Riverside County 116,588,283 144,523,544 7,617
San Bernardino County 280,317,848 347,483,708 10,679
Region Total 1,100,305,484 1,363,945,366 14,623
Dataset: Southern California Association of Governments (SCAG) 2018 report "Industrial Warehousing in the SCAG Region," Table 2.1 from the "Inventory" section of the report.

The ratio derived from data about ALL warehouses (column E) is then applied to the data about LARGE warehouses:

Exhausting Our Air 129
County
No. of Large
Warehouses
(2023) (F)
SF of Large
Warehouses
(G)
Employment
Estimate
(H)
Percent of
Employment
(I)
Los Angeles County 1,626 314,911,990 19,686 29%
Orange County 389 74,175,185 4,071 6%
Riverside County 402 131,212,586 17,238 26%
San Bernardino County 876 283,029,002 26,570 39%
Region Total 3,293 803,328,763 67,565 100%
Our employment estimate (column H) adds up to 67,565 warehouse industry workers employed in properties of 100,000 square feet or more, spread across various occupations discussed in Chapter 2, “Occupations and Wages of Warehouse Workers,” and in Chapter 5, “Occupations of Frontline Warehouse Workers.”
Methodology for Calculating Annual Truck Trips and Mileage In Chapter 4, we estimate the number of trucks trips bringing goods to and from each large warehouse in the four-county region – trips to and from seaports, intermodal facilities, cargo airports, other warehouses, and retail stores – based upon the based upon the square footage of each warehouse.

We then adjust our estimates using the 2021-22 Gate Move Analysis data from the Port of Los Angeles’ and Long Beach’s Clean Truck Program, to account for the portion of the trips between large warehouses and these seaports.

This portion of truck trips, adding up to 4,579,934 over 12 months, accounts for 34 percent of the total truck trips to and from large warehouses. (See Figure 24: Distribution of Truck Trips between Warehouses and Other Logistics Nodes, and endnote 33, referencing the South Coast Air Quality Management District (SCAQMD) warehouse survey.) We use the Seaports’ Gate Move Analysis data in proportion to the overall distribution of warehouses’ truck trip origin and destinations, as follows:

Percent Trips
Seaports Combined..................34%.......................................4,579,934 Port of Long Beach ..............17%.......................................2,321,687 Port of Los Angeles...............17%.......................................2,258,248 SoCal Cargo Airports.................3%..........................................408,938 Rail Intermodal Yards..............27%.......................................3,654,122 Other Warehouses...................22%.......................................2,967,689 Retail Stores (4-Co) .................14%.......................................1,929,900 Local Total ............................ 100%..................................... 13,540,583 Based on this estimation method, 13,540,583 annual truck trips to and from all warehouses in four-county region occur annuals. The portion of these trips to and from the region’s large warehouses is 84.90 percent of those total – based upon our earlier comparison of total to large warehouse occupied square footage and employment. This yields an estimated 130 Exhausting Our Air
11,495,607 annual truck trips to and from large warehouses in four-county region.

Exhausting Our Air 131

10. Endnotes ----------------------------------------------------------------------------------------------------------------- 132 Exhausting Our Air
1 The Economic Roundtable used the list published by the South Coast Air Quality Management District (SCAQMD) for rule 2305this list as a starting point for creating an inventory of all large warehouses that fall under the rule’s jurisdiction. Warehouse property data sources used in this study include:

South Coast AQMD address list of the largest 3,321 warehouse buildings that are over 100,000 square feet in size and likely subject to Rule 2305 (Appendix C pages 144-171) across the four-county SCAQMD region. SCAQMD staff confirmed these data came from CoStar. http://www.aqmd.gov/docs/default-source/Agendas/GoverningBoard/2021/2021-May7-027.pdf?sfvrsn=10 Southern California Association of Governments’ (SCAG) 2019 Annual Land Use Dataset which includes buildings’ square footage of improvements. SCAG data is assembled from county-level assessor databases, and from municipal planning agencies.

These data are part of SCAG’s Regional Data Platform: https://scag.ca.gov/regional-dataplatform Microsoft’s open source JSON file of building footprints from all 50 U.S. states to identify *all* individual buildings greater than 100,000 SF, alongside other data sources. These data come from LandSat imagery. https://www.microsoft.com/enus/maps/building-footprints 2 Rose Institute, “San Bernardino: Two Years into Bankruptcy,” (December 1, 2014), https://roseinstitute.org/san-bernardino-two-years-bankruptcy/. 3 Paloma Esquivel, “After five long years, San Bernardino is officially out of bankruptcy.

What’s next?” Los Angeles Times, (June 22, 2017), https://www.latimes.com/local/lame-ln-san-bernardino-bankruptcy-end-20170621-htmlstory.html 4 City of Carson, General Plan (October 11, 2004),
https://ci.carson.ca.us/content/files/pdfs/planning/cityofcarsongeneralplan.pdf. 5 This estimate was derived from the Consumer Expenditure Survey, U.S. Bureau of Labor Statistics, September, 2018, Table 1203, “Income before taxes: Annual expenditure means, shares, standard errors, and coefficients of variation.” This table breaks households out into nine income groups and provides expenditure amounts for a detailed list of items purchased by households in each income group. Retail items in this list were flagged and totaled for each income group. These expenditures by income group were then applied to census-tract-level breakouts of household income, and then adjusted proportionately for each census tract so that the total for all four counties equaled the estimated total of $31,045,901,815 in retail sales in the region. 6 U.S. Census Bureau, 2020 5-Year American Community Survey (ACS) Public Use Microdata Sample (PUMS). Filtering includes NAICS Industry (NAICSP) 493 (TRNWarehouse and Storage), Employment Status Recode (ESR) is limited to “Civilian Employed, at Work” with at least $500 annual earnings.
7 Daniel Flaming and Patrick Burns, Economic Roundtable, Someone Else’s Ocean:

Dockworkers, Foreign Shippers and Economic Outcomes, (2022), p. 29, https://economicrt.org/publication/someone-elses-ocean/. 8 The profile of trucking companies is derived from a random sample of 304 trucking companies registered with the Ports of Los Angeles and Long Beach. Data about number of drivers and annual mileage is from the U.S. Department of Transportation FMCSA Safety and Fitness Electronic Records System, with data extracted for each of the 304 companies: https://safer.fmcsa.dot.gov/saferhelp.aspx#General.

Exhausting Our Air 133
9 Port of Los Angeles, “Clean Truck Program Gate Move Analysis, (June 2023), https://kentico.portoflosangeles.org/getmedia/452bad8c-4e16-490f-bab6- 155b061866bb/POLA-Monthly-Gate-Move-Analysis.
10 A. R. Ravishankara, John S. Daniel, and Robert W. Portmann, Chemical Sciences Division, Earth System Research Laboratory, National Oceanic and Atmospheric Administration, “Nitrous Oxide (N2O): The Dominant Ozone-Depleting Substance Emitted in the 21st Century,” (August 2009),
https://www.science.org/cms/asset/48f20a35-fe6d-4d0d-8bc4-fc605aea13b7/pap.pdf 11 Emissions from electric trucks were calculated based on kilowatts of electricity consumed per ton-mile of movement by heavy-duty trucks, and then identifying the emissions produced by generating a kilowatt of electricity.

Heavy-duty trucks consume 2.07 kilowatts of electricity per mile, according to the California Air Resources Board, EMFAC2021 Volume III Technical Document, (March 31, 2021), https://ww2.arb.ca.gov/sites/default/files/2021- 03/emfac2021_volume_3_technical_document.pdf).

Given that the average load of trucks moving cargo from the ports is 19 tons, 0.11 kilowatts of electricity are consumed per ton-mile.

The U.S. Energy Information Administration identified the following pounds of emissions per kilowatt of electricity generated by electric utilities:

Sulfur dioxide 0.0006
Nitrogen oxide 0.0007
Carbon dioxide 0.8856
Annual Electric Generator Report, (2021),
https://www.eia.gov/electricity/state/unitedstates/state_tables.php 12 Center for Disease Control, Agency for Toxic Substances and Disease Registry, (April 2002), https://www.atsdr.cdc.gov/toxfaqs/tfacts175.pdf. 13 California Air Resources Board, Carbon Monoxide and Health, https://ww2.arb.ca.gov/resources/carbon-monoxide-and-health. 14 United States Environmental Protection Agency, “Health and Environmental Effects of Particulate Matter (PM),” https://www.epa.gov/pm-pollution/health-and-environmentaleffects-particulate-matter-pm. 15 National Park Service, Sulfur Dioxide Effects on Health, (February 27, 2023), https://www.nps.gov/subjects/air/humanhealth-sulfur.htm. 16 U.S. Department of Transportation, Federal Railroad Administration, “Railroad Energy Intensity and Criteria Air Pollutant Emissions,” (October 2018), https://railroads.dot.gov/sites/fra.dot.gov/files/fra_net/18212/Railroad%20Energy%20Inte nsity%20and%20Criteria%20Pollutant%20Emissions.pdf.
17 Port of Los Angeles, “Clean Truck Program (CTP) Gate Move Analysis,” (November 2022), https://kentico.portoflosangeles.org/getmedia/452bad8c-4e16-490f-bab6- 155b061866bb/POLA-Monthly-Gate-Move-Analysis. Only 84.9 percent of truck trips at the ports are estimated to linked to large warehouses; other trips include small warehouses. This estimate of trip origins and destinations is based on the South Coast Air Quality Management District’s “Warehouse Truck Trip Origin and Destination Data,” (2014), https://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysishandbook/high-cube-warehouse. 18 TransportPolicy.net, "US Heavy-duty Emissions Transport Policy,” https://www.transportpolicy.net/standard/us-heavy-duty-emissions/. 134 Exhausting Our Air
19 California Air Resources Board, Emissions Inventory, South Coast AQMD (2023), https://arb.ca.gov/emfac/emissionsinventory/28ffaed607e86fec45648960f1f041ede7baa441. 20 David Austin, Congressional Budget Office, Pricing Freight Transport to Account for External Costs, (March 2015), https://www.cbo.gov/publication/50049. 21 California Air Resources Board, “Advanced Clean Fleets Regulation Summary,” https://ww2.arb.ca.gov/resources/fact-sheets/advanced-clean-fleets-regulation-summary. 22 John Kingston, “19 states target EPA waiver for California’s Advanced Clean Trucks rule,” Freight Waves, (June 8, 2023), https://www.freightwaves.com/news/19-statestarget-epa-waiver-for-californias-advanced-clean-trucks-rule. 23 South Coast Air Quality Management District, Agenda Item 27, Board Meeting May 7, 2021, http://www.aqmd.gov/docs/default-source/Agendas/Governing-Board/2021/2021- May7-027.pdf?sfvrsn=10.
24 Latham & Watkins LLP, “US Warehouse Regulation Lawsuit Reaches Critical Stage,” (April 21, 2023) https://www.jdsupra.com/legalnews/us-warehouse-regulation-lawsuitreaches-3820942/#. 25 The availability of these trucks was documented through site visits by the Economic Roundtable to truck dealerships and also by: Gladstein, Neandross & Associates, 2021 Feasibility Assessment for Drayage Trucks, (February 2023), https://www.gladstein.org/research/2021-feasibility-assessment-for-drayage-trucks/. 26 California Air Resources Board, “Battery-Electric Truck and Bus Energy Efficiency Compared to Conventional Diesel Vehicles,” (May 2018),
https://ww2.arb.ca.gov/resources/documents/battery-electric-truck-and-bus-energyefficiency-compared-conventional-diesel. 27 Port of Los Angeles, “Port of Los Angeles Awards $6 Million to Fund 22 ZeroEmission Trucks,” (December 20, 2022), https://www.portoflosangeles.org/references/2022-newsreleases/news_122022_ze_truck_grants. 28 California Air Resources Board, Proposed Fiscal Year 2022-23 Funding Plan for Clean Transportation Incentives, (October 12, 2022),
https://ww2.arb.ca.gov/sites/default/files/2022-
10/proposed_fy2022_23_funding_plan_final.pdf.
29 South Coast Air Quality Management District, “Incentives,” https://www.aqmd.gov/home/air-quality/clean-air-plans/air-quality-mgt-plan/facilitybased-mobile-source-measures/incentives. 30 Evconnect, “SCE Ready Charge Program,” https://www.evconnect.com/charge-ready2. 31 Southern California Edison, “Electric Vehicle (EV) Infrastructure Rule 29,” https://www.sce.com/sites/default/files/2022-
07/EV%20Rule%2029%20Fact%20Sheet%200622_WCAG%20(V2).pdf. 32 Southern California Edison, “Southern California Edison Comments on California Energy Commission Interconnection Workshops,” (May 23, 2023), https://www.energy.ca.gov/event/workshop/2023-05/commissioner-workshop-cleanenergy-interconnection-electric-distribution Exhausting Our Air 135
33 Method for estimating truck trip miles is drawn from the South Coast Air Quality Management District’s “High Cube Warehouse Trip Rate Study for Air Quality Analysis” survey project, carried out 2012-14. The truck trips to and from a sample of high cube warehouses in SCAQMD region were identified by their origin/destination:

Local Origin Destination O-D Avg. Local Share
Sea Ports (POLA/POLB) 52% 5% 29% 34%
Port of Long Beach 27% 3% 15% 17%
Port of Los Angeles 26% 3% 14% 17%
SoCal Cargo Airports 0% 5% 3% 3%
Rail Intermodal Yards 9% 37% 23% 27%
Other Warehouses 27% 10% 19% 22%
Local Stores (SoCal) 2% 22% 12% 14%
Local Total 100%
Non-local
Out of state 10% 13% 11%
Non-local stores (non-SoCal) 0% 8% 4%
Port of San Diego 0% 0% 0%
Port of Hueneme 0% 0% 0%
Local + Non-Local Total 100%
Source: South Coast Air Quality Management District (SCAQMD). 2014. High Cube Warehouse Trip Rate Study for Air Quality Analysis https://www.aqmd.gov/home/rulescompliance/ceqa/air-quality-analysis-handbook/high-cube-warehouse 34 The distance from large warehouses to their nearest intermodal freight rail facility was calculated, to / from the following:
• Intermodal Container Transfer Facility (ICTF), Long Beach, CA 90810 • LA Transportation Center – Union Pacific, Los Angeles, CA 90031 • East LA Intermodal Facility – Union Pacific, City of Commerce, CA 90023 • Hobart Yard – Burlington Northern Santa Fe, Los Angeles, CA 90023 • Pacific Harbor Line (PHL) On-Dock Intermodal Facility, Wilmington, CA 90744
• City of Industry Intermodal Terminal – Union Pacific, Industry, CA 91748 • San Bernadino Intermodal Facility – Burlington Northern Santa Fe, San Bernardino, CA 92411
35 The distance from large warehouses to their nearest cargo airport was calculated, to / from the following:
• John Wayne Airport (SNA), Santa Ana, CA 92707
• Long Beach Airport Daugherty Field (LGB), Long Beach, CA 90806 • Los Angeles International Airport (LAX), Los Angeles, CA 90045 • Ontario International Airport (ONT) , Ontario, CA 91761 • San Bernardino International Airport (SBD), San Bernardino, CA 92408 • Hollywood Burbank Airport (BUR), Burbank, CA 91505
• March Air Reserve Base (RIV), Riverside, CA 92518
36 Non-local destinations, such as retail stores outside of Southern California and outside of the state, are also among the destinations of truck from large warehouses, but are omitted in this analysis because the length of those trips are unknown and most of their diesel emission impacts are non-local.
37 The average contents weight of a loaded 40-foot container is 13.15083383 tons, based upon the U.S. DoT Maritime Administration’s data on waterborne containers by U.S.

Customs Port. For the pre-pandemic year 2017, our estimate converts TEU’s to 40-foot 136 Exhausting Our Air
container equivalents, and Metric Tons to US Tons, in order to get an average import tons per 40-foot container. We blend the average weight of 40-foot containers entering the ports of Long Beach (13.79593112) and Los Angeles (12.61791991) to get the weight of containers’ contents driven to and from large warehouses in the 4- county region.

Imports in
Twenty-Foot
Equivalent
Units (TEUs),
2017
Imports in 40'
Container Units
(TEUs/2), 2017
Imports
(in Metric
Tons) 2017
Imports
(in US
Tons) 2017
Import
Tons per
40'
Container
2017
Port of LB, CA 3,792,165 1,896,083 23,730,349 26,158,224 13.8 Port of LA, CA 4,590,451 2,295,226 26,272,961 28,960,974 12.6 Sum / Average 8,382,617 4,191,308 50,003,310 55,119,198 13.2 Source: U.S. Department of Transportation, Maritime Administration, 2000 - 2017 U.S.

Waterborne Container Trade by U.S. Customs Port, columns 1 and 3. (Columns 2, 4 and 5 calculated by the Economic Roundtable.) https://www.maritime.dot.gov/datareports/data-statistics/us-waterborne-foreign-container-trade-us-customs-ports-2000- %E2%80%93-2017
38 The weight of an empty 40-foot container is 4.1336625 tons in our estimates, converted from the metric weight 3,750 kg using a 1 Kilogram = 0.00110231 US tons conversion rate. "A 40-foot container’s empty weight is 3,750 kg (4.1336625 tons, using a 1 Kilogram = 0.00110231 US tons) and can be loaded to a maximum overall weight of 29 tons (26,300kg). But the amount of cargo you can load would depend in large on possible restrictions and/or limitations of the shipping line, the nature of the cargo and specific details of the shipment. Use our cubic meter calculator and discover the exact volume of your cargo." Source: https://www.icontainers.com/help/40-foot-container/ 39 The weight of a semi-tractor cab, in which the engine sits and is separate from the trailer chassis or enclosed trailer usually attached to it, can have a range of weights. In this research, we use the weight 34,000 pounds, or 17 tons. 40 The weight of a tractor truck chassis, the base frame that holds a 40-foot container (or two 20-foot containers) and is connected to – and pulled by – the semi-tractor cab, has a tare (empty) weight of 6,600 pounds, or 3.3 tons. Source:
http://www.chassisking.com/products/40-foot-container-chassis/40-foot-straight-framecontainer-chassis/ 41 Uncompensated public costs from truck travel are costs that exceed the revenue collected from heavy-vehicle use tax, tax on tires, fuel tax, and vehicle registration fees for trucks and trailers. Austin, David (March 2015), Congressional Budget Office, “Pricing Freight Transportation to Account for External Costs,” Working Paper 2015-03, https://www.cbo.gov/publication/50049. Uncompensated public costs from truck noise are from U.S. Department of Transportation, Federal Highway Administration, (May 2000) “Addendum to the 1997 Federal Highway Cost Allocation Study Final Report,” https://www.fhwa.dot.gov/policy/hcas/addendum.cfm
42 U.S. Congressional Budget Office (May 2023) Baseline Projections: Highway Trust Fund Accounts, page 1: “The fund records inflows from revenues collected through excise taxes on the sale of motor fuels, trucks and trailers, and truck tires; taxes on the use of certain kinds of vehicles; and interest credited to the fund.” https://www.cbo.gov/system/files?file=2023-05/51300-2023-05-highwaytrustfund.pdf 43 U.S. Department of Transportation, Bureau of Transportation Statistics. 2023. State Transportation Statistics: Road Condition. Accessed April 2023:
https://www.bts.gov/road-condition
Exhausting Our Air 137
44 California Air Resources Board. 2021. EMFAC2021 v1.0.2 CA ARB Emission Factors (EMFAC) model. Notes: ARB’s Fleet Database provides data generated from the 2021 vehicle registrations. For our research, we used ARD’s Air District; Region: South Coast AQMD dataset for calendar year 2023 (Annual), and used emissions factors for EMFAC202x Categories “T7 … Class 8” trucks, a weighted average by VMT. Source:
https://arb.ca.gov/emfac/emissionsinventory/28ffaed607e86fec45648960f1f041ede7baa441 45 U.S. Environmental Protection Agency. 2023. CO-Benefits Risk Assessment Health Impacts Screening and Mapping Tool (COBRA). https://cobra.epa.gov/ Economic Roundtable estimated truck trips, ton miles were used to calculate annual tons of diesel truck emissions (PM2.5, SO2, NOx, NH3 and VOCs), using the California Air Resources Board. 2021. EMFAC2021 v1.0.2 CA ARB Emission Factors (EMFAC) model, which are the inputs to the COBRA model. The COBRA sectors selected are Highway Vehicles > Diesel Fuel > Heavy Duty trucks.
46 Employment impacts are from the 2019 IMPLAN model for California, sector 52, construction of new power and communication structures. Dollars have been adjusted to 2022 values. Based on the IMPLAN crosswalk to Census Bureau industry classifications (https://www.census.gov/construction/c30/definitions.html) sector 52 includes:
• Electric power facilities including plants, dry-waste generation, thermal, wind and solar energy facilities.
• Electrical distribution facilities including electric distribution systems, electrical substations, switch houses, transformers, and transmission lines. • Communication facilities including telephone, television, and radio, distribution and maintenance buildings and structures.
47 Share of total U.S. warehouse employment in the five largest frontline occupations:

SOC Code Title of Occupation Percent
43-5071 Shipping, Receiving, and Inventory Clerks 5%
53-7051 Industrial Truck and Tractor (Forklift) Operators 16% 53-7062 Laborers and Freight, Stock, and Material Movers, Hand 25% 53-7064 Packers and Packagers, Hand 5%
53-7065 Stock Clerks - Stockers and Order Fillers 15%
U.S. Bureau of Labor Statistics, Department of Labor, Occupational Employment Statistics (OES) Survey, (May 2019), www.bls.gov/oes.
48 Skill requirement information is from the U.S. Department of Labor, Employment and Training Administration, O*NET, which is a database of detailed job descriptions, including measurements of required levels of skills and knowledge. The first O*NET database, version 1.0, was released in 2001. Skill requirements identified in that database are compared to requirements in the most recent database, version 28.0. O*NET information can be accessed at: https://www.onetonline.org/. 49 MIT Living Wage Calculator, Counties and Metropolitan Statistical Areas in California, (accessed July 23, 2023), https://livingwage.mit.edu/states/06/locations. 50 Industry revenue and profit are from the 2019 IMPLAN model for California, sector 422, warehousing and storage. Dollars have been adjusted to 2022 values. 51 Economic Roundtable analysis; U.S. Census Bureau, 2020 Census National Redistricting Data (P.L. 94-171) Summary File, Table P1. Released 2021; U.S. Census Bureau, TIGER/Line Shapefiles. https://www.census.gov/programs-surveys/decennialcensus/about/rdo/summary-files.html 52 Definitions of a family and non-family households, from the U.S. Census Bureau’ s “American Community Survey and Puerto Rico Community Survey 2021 Subject 138 Exhausting Our Air
Definitions “ https://www.census.gov/programs-surveys/acs/technicaldocumentation/code-lists.html • “Household – A household includes all the people who occupy a housing unit. (People not living in households are classified as living in group quarters.) … The occupants may be a single family, one person living alone, two or more families living together, or any other group of related or unrelated people who share living arrangements.” Page 80.
• “Family Households – A family consists of a householder (sometimes referred to as the “head of household”) and one or more other people living in the same household who are related to the householder by birth, marriage, or adoption.

All people in a household who are related to the householder are regarded as members of his or her family.” Page 82
• “Nonfamily Household – A householder living alone or with nonrelatives only.

Unmarried couples households, whether opposite-sex or same-sex, with no relatives of the householder present are tabulated in nonfamily households.”

Page 84 ends

53 Female-headed families are defied by the U.S. Census Bureau as “Female Householder, No Spouse Present – A family with a female householder and no spouse of the householder present.” Other family household types in these data include “Male Householder, No Spouse Present” and “Married-Couple Family – A family in which the householder and his or her spouse are listed as members of the same household. … Family households and married-couple families include same-sex married couples, beginning with the 2013 data.” U.S. Census Bureau “American Community Survey and Puerto Rico Community Survey 2021 Subject Definitions “ https://www.census.gov/programs-surveys/acs/technical-documentation/code-lists.html 54 U.S. Census Bureau, 2021 American Community Survey 5-Year, Detailed Tables:

B11011 Household Type by Units in Structure. Released December 2022. Universe Occupied Households, Geography: Census Tracts.
55 The median income is that of the middle household, when all households are rankorder sorted from highest to lowest income households. 56 The Census Bureau “uses a set of money income thresholds that vary by family size and composition to determine who is in poverty. If a family’s total income is less than the family’s threshold, then that family and every individual in it is considered in poverty.

The official poverty thresholds do not vary geographically, but they are updated for inflation using the national Consumer Price Index (CPI-U). The official poverty definition uses money income before taxes and does not include capital gains or noncash benefits (such as public housing, Medicaid, and food stamps).” Read more information about How the Census Bureau Measures Poverty here:
http://www.census.gov/topics/income-poverty/poverty/guidance/poverty-measures.html Poverty Thresholds for 2022 by Size of Family and Number of Related Children < 18 (In dollars) Size of
family unit
Related children under 18 years
None One Two Three Four Five Six Seven Eight+
1 person:

Under 65 15,225
65+ 14,036
2 people:

Under 65 19,597 20,172
65+ 17,689 20,095
3 people 22,892 23,556 23,578
4 people 30,186 30,679 29,678 29,782
Exhausting Our Air 139
5 people 36,402 36,932 35,801 34,926 34,391
6 people 41,869 42,035 41,169 40,339 39,104 38,373
7 people 48,176 48,477 47,440 46,717 45,371 43,800 42,076 8 people 53,881 54,357 53,378 52,521 51,304 49,760 48,153 47,745 9 people+ 64,815 65,129 64,263 63,536 62,342 60,699 59,213 58,845 56,578 Source: U.S. Census Bureau, 2023. Note: The source of the weighted average thresholds is the 2023 Current Population Survey Annual Social and Economic Supplement (CPS ASEC). https://www.census.gov/data/tables/time-series/demo/income-poverty/historical-poverty-thresholds.html 57 Econometrica, Inc. (2007), Measuring Overcrowding in Housing, prepared for the U.S.

Department of Housing and Urban Development Office of Policy Development and Research.
58 The three categories of occupants per room are:
• Not Crowded: A rental housing unit is considered adequate or not crowded when the number of rooms per unit corresponds with or exceeds the number of people in the household (≤ 1.0 persons /room).
• Overcrowded: A rental housing unit is considered crowded when the number of people in the household corresponds with or exceeds the number of rooms per unit (1.01 - 1.50 persons/room). A 5-person household that occupies a 1- bedroom apartment with a living room and kitchen (3 rooms) is considered to be living in overcrowded conditions.
• Severely Overcrowded: This is a further threshold of overcrowding, comparable to having 3 or more occupants living in a studio apartment with a kitchen (2 rooms) and 5 or more occupants in 1-bedroom apartment with a living room and kitchen (3 rooms) (> 1.5 persons /room). A 6-person household that occupies a 1-bedroom apartment with a living room and kitchen (3 rooms) is living in severely overcrowded conditions
59 This section utilizes CalEnviroScreen and other public health data to highlight communities most affected by pollution. CalEnviroScreen data are compiled by the California Office of Environmental Health Hazard Assessment (OEHHA). Version 4.0 of CalEnviroScreen was released in November 2021. “CalEnviroScreen ranks census tracts in California based on potential exposures to pollutants, adverse environmental conditions, socioeconomic factors and the prevalence of certain health conditions. Data used in the CalEnviroScreen model come from national and state sources.” https://oehha.ca.gov/calenviroscreen
60 Zeise, Lauren (OEHHA) and Jared Blumfield (California EPA). CalEnviroScreen 4.0, October 2021. Published by OEHHA, California Environmental Protection Agency. Page

47. https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40 Further information available online at:
https://oehha.ca.gov/media/downloads/calenviroscreen/report/cireport123110.pdf 61 The CalEnviroScreen 4.0 “Pollution Burden” is calculated from the following data:

Pollution Burden: Exposure Indicators
• Air Quality: Ozone
• Air Quality: PM2.5
• Diesel Particulate Matter
• Drinking Water Contaminants
• Children’s Lead Risk from Housing
• Pesticide Use
• Toxic Releases from Facilities
• Traffic Impacts
Pollution Burden: Environmental Effects Indicators
• Cleanup Sites
• Groundwater Threats
• Hazardous Waste Generators and Facilities
• Impaired Water Bodies
• Solid Waste Sites and Facilities
• Scores for Pollution Burden
• Asthma
Source: Zeise, Lauren (OEHHA) and Jared Blumfield (California EPA).

CalEnviroScreen 4.0, October 2021. Published by OEHHA, California Environmental 140 Exhausting Our Air
Protection Agency. Page 47. https://oehha.ca.gov/calenviroscreen/report/calenviroscreen40 62 Amini, H., M. Danesh-Yazdi, Q. Di, W. Requia, Y. Wei, Y. AbuAwad, L. Shi, M.

Franklin, C.-M. Kang, J. M. Wolfson, P. James, R. Habre, Q. Zhu, J. S. Apte, Z. J.

Andersen, X. Xing, C. Hultquist, I. Kloog, F. Dominici, P. Koutrakis, and J. Schwartz. 2023. Annual Mean PM2.5 Components (EC, NH4, NO3, OC, SO4) 50m Urban and 1km Non-Urban Area Grids for Contiguous U.S., 2000-2019 v1. Palisades, New York: NASA Socioeconomic Data and Applications Center (SEDAC). https://doi.org/10.7927/7wj3- en73. Accessed March 7, 2023.

Additional methodology paper: Amini, H., M. Danesh-Yazdi, Q. Di, W. Requia, Y. Wei, Y. AbuAwad, L. Shi, M. Franklin, C.-M. Kang, J. M. Wolfson, P. James, R. Habre, Q.

Zhu, J. S. Apte, Z. J. Andersen, X. Xing, C. Hultquist, I. Kloog, F. Dominici, P.

Koutrakis, and J. Schwartz. 2022. Hyperlocal super-learned PM2.5 components across the contiguous US. Research Square. https://doi.org/10.21203/rs.3.rs-1745433/v2.

Elemental Carbon (EC) data come from the 2019 National Urban Dataset for All PM2.5 Components (EC, OC, Nitrate, Sulfate and Ammonium), extracted for Southern California and shared by Sina Hasheminassab, Ph.D., Science Systems Engineer, Jet Propulsion Laboratory, California Institute of Technology. Sincere thanks to Heresh and Sina for their time sharing access to, and insights into, these newly available and high spatiotemporal resolution data.
63 Concerning pre-existing Chronic Obstructive Pulmonary Disease (COPD) conditions which are aggravated by harmful diesel emissions, “[t]he main cause of COPD in developed countries is tobacco smoking. In the developing world, COPD often occurs in people exposed to fumes from burning fuel for cooking and heating in poorly ventilated homes. Only some chronic smokers develop clinically apparent COPD, although many smokers with long smoking histories may develop reduced lung function. Some smokers develop less common lung conditions. They may be misdiagnosed as having COPD until a more thorough evaluation is performed.” Source: Mayo Clinic. 2023. Diseases & Conditions: COPD. https://www.mayoclinic.org/diseases-conditions/copd/symptomscauses/syc-20353679 Accessed online July 13, 2023. 64 U.S. Department of Health & Human Services, National Center for Environmental Health. 2023. Most Recent Asthma State or Territory (2021): Adult Prevalence / Mortality: California. https://www.cdc.gov/asthma/most_recent_data_states.htm Accessed online July 13, 2023.
65 Wolstein, Joelle, PhD, MPP, MA, Ying-Ying Meng, DrPH, Susan H. Babey, PhD. 2010. Policy Research Report: Income Disparities in Asthma Burden and Care in California. UCLA Fielding School of Public Health, Center for Health Policy Research. https://healthpolicy.ucla.edu/publications/search/pages/detail.aspx?PubID=45 Accessed online July 14, 2023.
66 Babey SH, Meng YY, Brown ER, Hastert TA. Nearly six million Californians suffer from asthma symptoms or asthma-like breathing problems. Policy Brief UCLA Cent Health Policy Res. 2006 Oct;(PB2006-5):1-7. PMID: 17051690. https://pubmed.ncbi.nlm.nih.gov/17051690/
67 U.S. Energy Information Administration. 2021. Today in Energy: Warehouses were the most common U.S. commercial building type as of 2018. Released November 30, 2021. https://www.eia.gov/todayinenergy/detail.php?id=50496 Accessed online August 1, 2023.
68 Energy consumption data is for non-refrigerated warehouses.

Exhausting Our Air 141
69 U.S. Energy Information Administration. Commercial Buildings Energy Consumption Survey (CBECS) Table C22. “Electricity consumption totals and conditional intensities by building activity subcategories, 2018.” (December 2022), https://www.eia.gov/consumption/commercial/reports/2012/water/ 70 CA Energy Commission. “2009-2021 Total System Electric Generation (Spreadsheet)” https://www.energy.ca.gov/data-reports/energy-almanac/california-electricity-data/2021- total-system-electric-generation
71 U.S. Environmental Protection Agency. 2023. “Sources of Greenhouse Gas Emissions:

Overview” https://www.epa.gov/ghgemissions/sources-greenhouse-gas-emissions 72 U.S. Environmental Protection Agency. 2023. “Sources of Greenhouse Gas Emissions:

Electric Power Sector Emissions” https://www.epa.gov/ghgemissions/sourcesgreenhouse-gas-emissions 73 U.S. Energy Information Administration. Commercial Buildings Energy Consumption Survey (CBECS) Public Use Microdata, 2018. Note: Buildings can use 1+ types of energy.

US Energy Administration 2018 CBECS commercial building microdata: Energy Sources of Warehouses vs all Buildings, by Census Region. https://www.eia.gov/consumption/commercial/data/2018/
74 U.S. Environmental Protection Agency. 1998. AP 42, Compilation of Air Pollutant Emission Factors: Section 1.4 Natural Gas, Final Section - Supplement D, July 1998. https://www.epa.gov/sites/production/files/2020-
09/documents/1.4_natural_gas_combustion.pdf
75 California Air Resources Board (CARB). 2023. “Resources: Inhalable Particulate Matter and Health (PM2.5 and PM10).” https://ww2.arb.ca.gov/resources/inhalableparticulate-matter-and-health Accessed on July 31, 2023. 76 U.S. Environmental Protection Agency. 1998. AP 42, Compilation of Air Pollutant Emission Factors: Section 1.4 Natural Gas, Final Section - Supplement D, July 1998. See page 3. https://www.epa.gov/sites/production/files/2020- 09/documents/1.4_natural_gas_combustion.pdf
77 U.S. Energy Information Administration. 2017. Commercial Buildings Energy Consumption Survey (CBECS). Table W1. Water consumption in large commercial buildings, 2012. https://www.eia.gov/consumption/commercial/reports/2012/water/ 78 California Natural Resources Agency, California Environmental Protection Agency. 2022. “Press Release: State Enlists Commercial, Industrial Sector in Water Conservation Efforts” https://calepa.ca.gov/2022/06/07/press-release-state-enlists-commercialindustrial-sector-in-water-conservation-efforts-6-7-2022/

Mayor and City CouncilOctober 7, 2026

Mayor and City Council
October 7, 2026