Drayage Truck Replacement Programs
Improve Air Quality in the Mid-Atlantic
£%	United States
Environmental Protect

Drayage Truck Replacement Programs
Improve Air Quality in the Mid-Atlantic
Air Program
U.S. EPA Region 3
Transportation and Climate Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
United States
Environmental Protection
February 2020

Creating this case study would not have been possible without the enthusiastic cooperation and
participation of several organizations and individuals. EPA would like to thank the Mid-Atlantic
Regional Air Management Association (MARAMA), Maryland Environmental Services (MES), the
Clean Air Council, EcoLogix Group, and the Virginia Department of Environmental Quality (DEQ)
for providing invaluable first-hand information and perspectives for this case study. EPA would
also like to thank the following individuals for participating in interviews: Debbie Thomas of
MARAMA, Ted Kluga of MES, Eric Cheung of the Clean Air Council, and Susan Stephenson of
Table of Contents
Overview	2
History of Dray Truck Replacement Programs	2
Improving Air Quality	3
Key Lessons Learned	5
Successful Outreach in Virginia	5
Outreach Challenges in Philadelphia	5
Scrappage	6
Diesel Particulate Filters	7
Looking Forward	7
Funding Availability	8
New Technologies	8
VW Settlement Impacts	8
Conclusion	9

Since 2008, four key ports in the Mid-Atlantic region—Philadelphia, Wilmington, Baltimore, and
Virginia —have implemented programs to replace aging drayage (or dray) trucks. Dray trucks play a
critical role in transporting cargo from ships to
other modes of transportation and warehouses.
However, dray trucks often can release significant
emissions as they make frequent trips throughout
the port and idle while awaiting cargo. Many dray
trucks are former long-haul trucks with high
mileage, and these older engines tend to emit
more pollutants than newer engines manufactured
to meet stricter EPA regulations. Through a
combination of national and state Diesel Emission
Reduction Act (DERA) grant funding administered
through various agencies and programs, the ports
have collectively replaced over 270 dray trucks in
the past 10 years. This case study looks at the air
quality impacts of the replacements, identifies key
lessons learned, and discusses possibilities for the future of the programs.
History of Dray Truck Replacement Programs
When EPA first distributed funds in 2008 through the DERA National Grant Program, local
stakeholders welcomed the opportunity to implement large-scale vehicle replacement projects.
Communities with environmental justice concerns near the Ports of Philadelphia, Wilmington, and
Baltimore were adversely impacted by emissions from port-related activities. Local demand for
improved air quality and EPA encouragement led nonprofits and state agencies to set up
mechanisms to help interested groups apply for the DERA grants. Throughout the region, MARAMA,
MES, the Clean Air Council, EcoLogix Group, and the Virginia DEQ served as grant project
coordinators and worked with ports and truck operators to publicize the grant opportunity and
administer funding. Over time, truck operators provided feedback to grant project coordinators,
which helped EPA modify funding mechanisms to better meet truckers' needs. Within the original
framework, some DERA grants provided direct funding to cover up to 25 percent of the cost of a
new truck, and truck owners often had to apply for loans to make up the rest of the cost. However,
many truck operators did not have adequate credit, and they received loans with steep interest
rates. Truck operators met with grant project coordinators and expressed their preference for
Port of
Port of
Port of I
Port of
Map of EPA Region 3 within part of Mid-Atlantic
United States with relevant ports.

Truck driver in Delaware poses with new
vehicle that his company, Bay Shippers,
purchased through the dray truck replacement
receiving more money upfront in an accelerated
timeframe, because missing a truck for longer than a
week could hurt their business.
In response to the feedback, EPA now offers up to 50
percent of the cost of a truck replacement. Moreover,
to address concerns about the time and staff capacity
needed to fill out the grant application, grant project
coordinators simplified the process and now provide
technical assistance and support to potential applicants.
MES created an online portal to help truck drivers easily
fill out the grant application, streamline paperwork, and
address frequently asked questions. Truck operators
have largely reacted positively to these changes.
Improving Air Quality
EPA identifies ports as potential contributors to health risks associated with diesel emissions. Long-
and short-term exposure to high levels of ozone and particle pollutants, which are byproducts of
diesel exhaust, increase instances of asthma and heart attacks and can lead to other health
Prior to 2008, the Ports of Philadelphia, Wilmington,
and Baltimore were in EPA nonattainment areas for
ozone and particulate matter and are surrounded by
densely populated areas. These areas are all currently in
nonattainment for ozone. Farther south, the Norfolk-
Virginia Beach-Newport News (Hampton Roads) region
that surrounds the Port of Virginia was in a
nonattainment area for ozone in 1997, but it reached
attainment by 2008.
3.3 million people live in the four
counties bordering the Ports of
Philadelphia and Wilmington

2 million people live in the three
subdivisions closest to the Port of
Baltimore (2018).2
1.6 million people live in the
Hampton Roads region
surrounding the Port of Virginia
1	Office of Transportation and Air Quality, U.S. Environmental Protection Agency, Clean Diesel Funding Assistance
Program, EPA-OAR-OTAQ-17-04, September 2016.
2	Office of Transportation and Air Quality, U.S. Environmental Protection Agency, Clean Diesel Funding Assistance
Program FY2018, EPA-OAR-OTAQ-18-03, June 2018.
3	https://www.epa.gov/sites/production/files/2016-01/documents/hractionplan.pdf
4	http://hero.epa.gov/index.cfm/reference/download/reference id/42866

Throughout the Mid-Atlantic region, completed dray truck replacement projects have prevented
nearly 3,000 tons of pollutants from entering the air each year. Furthermore, by taking old trucks
out of service, the dray truck replacement programs will collectively prevent over 23,000 tons of
pollutants that can contribute to significant health problems from being emitted (see table below)
Summary of Replacement Projects and
Associated Emission Reductions by Port
Annual Emission Reductions (Tons)
Philadelphia & Wilmington
Philadelphia, Wilmington &
Lifetime Emission Reductions
Philadelphia & Wilmington
Philadelphia, Wilmington
& Virginia
This table summarizes all dray truck replacements to date in the Mid-Atlantic through EPA Region 3
projects. The number of trucks replaced includes ongoing projects, but ongoing projects are not
included in the emission reduction counts, as these benefits have not been fully realized yet. While
most grants are awarded to a specific port, one grant was awarded to the Ports of Philadelphia,
Wilmington, and Virginia, and the emission benefits were recorded on a regional level.

Although the ports have made significant progress replacing aging dray trucks, many old trucks remain:
in 2016, roughly 2,000 dray trucks served the Port of Philadelphia each day. As former long-haul trucks
are repurposed into dray operations, new opportunities for replacements continuously arise. All ports
reported that many eligible trucks remain, and there is usually a waiting list for truck owners to
participate in the replacement program.
Key Lessons Learned
Throughout the region, grant project coordinators have identified three key lessons learned for
ensuring successful dray truck replacement programs: engaging stakeholders and responding to
local concerns, fostering relationships and clearly communicating with scrap yards, and working
with vendors to make sure replacement trucks and their diesel particulate filters (DPFs) have been
properly maintained.
Successful Outreach in Virginia
The Port of Virginia's Green Operator Program exemplifies
the importance of garnering support and buy-in from port
operators and stakeholders and surrounding communities
at the beginning of a project. From the onset, local trucking
associations were active in the area and had good
relationships with the port authority. Through conversations
with port operators and other stakeholders, grant project
coordinators reached out to a few larger trucking
companies that eventually became early participants in the
program. Some smaller truck operators initially hesitated to
join the program, because they would have to give up their
trucks before receiving new ones and potentially be unable
to work for several days. However, seeing involvement from
larger companies and port leadership helped small
operators embrace the program. To them, another benefit
was the opportunity to own more trucks, because they
generally owned a portion of their fleet and leased the rest.
Although the grants specifically prohibit fleet expansion, DERA makes it possible in some cases for
operators to maintain their fleets by owning vehicles instead of leasing them. Moreover, many
truck drivers working in the Port of Virginia region live in communities adjacent to the ports and
have a vested interest in improving air quality.
Outreach Challenges in Philadelphia
In 2008, the Clean Air Council began working on a replacement program in Philadelphia. Although
the port authority and the port terminal owners engaged in talks with EPA and the Clean Air
Council, some challenges arose, and the program was unable to progress. Ultimately, the grant
project coordinators determined that the most efficient way to move forward was to work with
truck drivers directly.
N)OT 1780612j
In 2019, MARAMA created a decal for
participants who complete the dray
truck replacement program in
Philadelphia or Wilmington to place
on their new vehicles.

One fleet owner replaced four of his
twelve trucks and noticed that
cleaner trucks have made a big
difference for his employees. The
new trucks help attract new drivers
and retain existing drivers. Drivers
much prefer the new trucks because
they are better for their health and
for their communities.
- Anecdote from Debbie
Thomas, MARAMA
Despite these early challenges, the Ports of Philadelphia and Wilmington have had recent success
implementing dray truck replacement programs. This time, MARAMA connected directly with local
truck operators. A truck vendor who spoke fluent Spanish urged MARAMA to market the
replacement program in Spanish to potential Spanish-
speaking applicants. To circumvent the language barrier,
MARAMA worked with the University of Maryland
Environmental Finance Center to translate the English grant
application into Spanish While it took time for the
applicants to begin supporting the program, once they did,
they readily promoted it within their community and
encouraged their fellow truck operators to apply. To date,
the Ports of Philadelphia and Wilmington have replaced
nearly 90 trucks (see table above).
For the grant project coordinators, having a good
relationship with scrap yards is essential to running a
successful program. After truck operators are approved
to receive a new truck, they must scrap their old vehicle
before they can purchase a new one. EPA has strict
requirements for verifying scrappage, which can take
time for scrap yard operators to learn and follow.
'A scrap yard contacted us when it
suspected that one of the trucks it
received was not eligible for
replacement because it clearly had not
been in service for several years. We
investigated the case and ultimately
revoked the down payment for the
replacement truck. By working
together, we were able to prevent a
fraudulent replacement, which shows
the importance of a good working
relationship between the [scrap yards
and agencies]."
- Anecdote from Debbie Thomas,
In each state, grant project coordinators visited scrap
yards to talk to owners about the program and explain
the photo verification process. They also worked closely
with scrap yards to complete the EPA certificate that
confirms the engine was fully destroyed according to
EPA-approved procedures. Since scrap yards are
generally very cautious of accepting stolen goods, they have been largely accommodating of the
EPA documentation requirements, such as proof of regular truck use within the last year, engine
plate, and VIN number.
The scrappage process operates differently in Virginia. While grant project coordinators in
Maryland, Delaware, and Pennsylvania select eligible scrap yards, Virginia gives truck operators the
option to compare scrap yards and negotiate prices. While this process can be cost-effective, it also
adds another step for documentation. Virginia also allows truck operators to self-scrap, which
creates some challenges. Initially, the pictures from the truck operators were not of high quality, so
grant project coordinators subsequently sent a staff person to oversee the process on site.

Diesel Particulate Filters
Grant project coordinators encountered unforeseen issues with DPFs in dray trucks throughout the
region. DPFs were first widely installed on new trucks starting in the 2007 model year, and truck
operators found the 2007-2013 replacement dray trucks were experiencing premature DPF
plugging. For proper operation, periodic DPF maintenance (cleaning) is required, and the engine
duty cycle needs to meet time and temperature requirements (minimum time at elevated exhaust
temperature), achieved through extended high load and highway driving that burns off soot for DPF
regeneration. Additionally, if an engine needs service, a DPF can temporarily hide an engine
problem, but eventually the DPF will experience plugging or other problems as well. In these grant
projects, EPA Region 3 learned the shorter trip dray truck duty cycles did not meet the time and
temperature requirements for DPF regeneration which was causing DPFs to clog and the engine to
go into a reduced power mode. Clogged filters led to trucks routinely breaking down after purchase.
Because many dray truck drivers did their own maintenance, but they could not clean the DPFs
without necessary equipment, the drivers were experiencing increased maintenance costs. Drivers
began to lose interest in expensive replacement trucks as their old trucks did not have DPFs, and
they were accustomed to their prior maintenance requirements.
Similarly, EPA Region 3 learned that in EPA Region 4 (located in the southeastern United States),
dray truck operators were experiencing DPF problems in certain truck duty cycles. For example, in
Savannah, Georgia, most trucks service depots and warehouses are a few miles from the port.
Because typical routes follow surface streets without highway operation, the DPFs could not reach
operating conditions (i.e., extended higher speeds and loads) necessary to properly burn off
accumulated soot.
To address the DPF issues, MARAMA asked truck vendors to provide an initial cleaning of DPFs on
second-hand trucks being repurposed as dray trucks before releasing them to the grant recipient.
Although this process increased the price of the vehicle, it ensured that the new vehicle owner
started with a clean DPF and properly operating engine and did not incur additional maintenance
costs immediately after purchase. Some truck vendors also provided technical support to the grant
recipients if they experienced mechanical issues within the first 30 days after purchase. MARAMA
received very positive feedback from truck drivers in response.
Additionally, MARAMA encouraged warranties included in the grant funding. While warranties
increased the initial truck price and subsequent down payments, they minimized the amount of
work time grant recipients lost to repairing faulty new DPF systems. The DPF issue is becoming
increasingly less prevalent as truck drivers opt for newer trucks.
Looking Forward
While the EPA Region 3 dray truck replacement programs have successfully replaced older trucks
with newer ones, funding and new technology could influence the programs' longevity along with
improved education to vehicle operators regarding effective maintenance practices.

Funding Availability
DERA grant funds support drayage truck projects through
both the DERA program's national competitive program
as well as its state-level program. Replacement programs
are popular among many truck operators, and the
number of interested applicants and eligible trucks
exceeds the funding available in each grant cycle. In
Baltimore, there is a continuous waitlist as many truckers
are eager to replace their trucks. Continued funding levels
would ensure that the maximum number of trucks could be replaced, but there is uncertainty
around sustained funding. Some grant project coordinators also suggested that additional funding
dedicated to outreach would be beneficial to their programs and could strengthen educational
opportunities for truck operators.
Newer, less conventional technologies also pose a potential funding concern: alternative fuel and
zero-emission vehicles are more expensive than standard diesel engines. If the cost of each vehicle
increases, fewer replacements would occur with the same amount of money.
New Technologies
Although stakeholders ranging from truck operators to
environmental groups have expressed a growing interest in
zero-emission vehicles and alternative fuels, EPA Region 3
grant project coordinators have found that few are feasible
or cost-effective options for dray trucks as of 2020. While
electrification is gaining popularity for light duty passenger
cars, there are fewer zero emission truck offerings from manufacturers. Nevertheless, the Port of
Los Angeles, located in EPA Region 9, is building, testing, and evaluating several class-8, heavy-duty,
on-road, zero-emission vehicles. If this technology proves to be successful at the Port of Los
Angeles, other port operators in the U.S. may become interested in adopting it (and thus help to
create an economy of scale).
Compressed natural gas (CNG) is a potential alternative fuel option. At one point, MARAMA
researched the prospect of replacing diesel-powered trucks with those fueled with CNG, but
ultimately decided that it would be cost-prohibitive.
VW Settlement Impacts
The 2016 Volkswagen Clean Air Act Civil Settlement (VW Settlement) has been highly publicized,
which has helped increase public awareness that funding is available for vehicle upgrades. Across
the region, truck operators are starting to ask about VW Settlement funding options. VW
Settlement funding varies from state to state, and each state has its own plan to determine how to
spend the funds (e.g., Maryland's share of the VW Settlement is $75.7 million, with $2 million set
aside for dray trucks, while Virginia received $93.6 million with no specific allocation for dray
"Individual owner-operators view any
opportunity to get a new truck as a
great opportunity, so there has been
no problem getting truckers to
- Ted Kluga, Maryland
Environmental Service
/	\
"Everyone needs to do their
part...buying a greener vehicle; it
- William Thomas, Truck
Driver at the Port of Baltimore

trucks). Throughout the region, DERA grant project coordinators and VW Settlement state
administrators couid find opportunities for collaboration.
The EPA Region 3 dray truck replacement programs
demonstrate that with effective community outreach,
clear communication with scrap yards, and proactively
addressing maintenance issues, grant project
coordinators can replace large numbers of dray trucks
in a relatively short timeframe and reduce emissions
in port areas. Program participants have provided
positive feedback about the replacements, and with
many eligible dray trucks remaining, interest in the
programs will likely continue. Innovative technologies
and additional funding sources could provide new
opportunities and directions for the program to grow.
EPA Region 3 is proud of the progress
we and our partners have made in
replacing older, dirtier dray age fleets
serving major port facilities in the Mid-
Atlantic. We remain committed to
continuing work to improve the health of
near-port communities by reducing diesel
exhaust pollution related to port truck
- Cosmo Servidio,
Regional Administrator
Ports of Philadelphia and Wilmington
Port of Baltimore
https://efc.umd.edu/de patruckreDlacement.html
Port of Virginia