RFI to the EPA About Reducing Carbon Footprints at the Nation's Ports...

There are multiple steps, that may be phased in, or adopted simultaneously, to attain zero or, more likely, near-zero emissions at any, or all, ports:

1. Adoption of battery electric vehicles (BEV), class 6 & 7 trucks, that are powered via battery packs behind the cab, and/or under the cargo box, create zero emission vehicles (ZEV). An electric motor mounted in close proximity to the drive axle makes the space, normally used to accommodate a drive shaft, available for batteries. Some, to all, of the cargo boxes can have solar panels on the roof to provide some battery charging capacity.

2. Adoption of Full Series Hybrid Electric Vehicle (FSHEV) technology can be used for class 8 trucks that are available for use 24/7. This type of vehicle will include an internal combustion engine (ICE) to generate electricity; charge the battery. The vehicle need not have external connection to recharge batteries, but can have attachment to provide vehicle to grid (V2G) electricity.

3. Internal combustion engines, used in FSHEV or larger, centralized electricity generation capacity, not powered by sun or wind, can be powered by: gasoline, propane or natural gas; diesel is obviated.

4. Cargo containers can also have solar panels on, or as, their roofs.

5. Train cars can use regenerative braking to assist in generating electricity for moving containers around the port. Containers can have electric motors connected to each axle, for said regenerative braking, and for assisting in the movement of the cars around the port facilities. Batteries can be mounted under the cargo container, and electrical connections can be made available to import or export electricity.

Everything needed to build the aforementioned vehicles, except batteries and solar panels, are currently produced in the USA. The ports will operate most efficiently if they are equipped with their own ability to generate electricity for it's own operation; not reliant on the local/regional electric grid.

Production of the equipment referred to above is capable of being done via modest modification of existing manufacturing infrastructure... The main problem that will be encountered is the lack of desire of existing companies to swim against the tides and currents originating in the efforts of players within the oil and gas cartel of companies.

Performance and efficiency of electric vehicles is being demonstrated by existing battery electric vehicles (BEV) now in service. Operating efficiency is largely generated by the reduction in moving parts in an electric drive train, and the reduction of energy lost to wasted heat.

All the pieces are current technology that's readily available, and only the aforementioned will within industry participants is lacking... The EPA's ability to motivate the movement to efficiency will determine the success, or lack thereof, in creating far cleaner, greener, port operations.