This page lists activities from the years up to and including 2007. See other links above for more recent activities.
Marine Shipping Related Actions by District Board
|November 2, 1994||Board approves 1994 Clean Air Plan, which identifies marine shipping as large source of emissions of nitrogen oxides (NOx).|
|January 26, 1995||Board approves letter to U.S. Environmental Protection Agency (EPA) urging action on marine shipping.|
|October 21, 1999||Board approves letter to EPA calling on the agency to take a leadership role with the International Maritime Organization (IMO) to urge the IMO to pursue emission reductions from marine vessles.|
|July 2001||Board approves international marine vessel resolution, see Board letter.|
|November 2001||Board adopts 2001 Clean Air Plan (download from this page; see Chapter 6).|
|February 2002||Board receives update on marine shipping emissions.See Board letter.|
|April 2002||Board receives update on District efforts to reduce emissions from marine shipping activities.See Board letter.|
|June 2002||Board receives update on the Marine Shipping Retrofit Project (MSRP) and comments on EPA marine engine rulemaking. See comment letter.|
|January 2003||Board Chair signs letters to the Chair and Ranking Member of the U.S. Senate Foreign Relations Committee urging ratification of IMO Annex VI, see Board letter.|
|October 2003||Board receives update on MSRP efforts and approves $100k for MSRP, see Board letter.|
|December 2004||Board adopts 2004 Clean Air Plan (view and download from this page on this site, see Chapter 6 for information on marine shipping emissions).|
|August 2006||Board approves District role as collector and distributor of emissions testing funds for a project demonstrating emission control retrofit technologies on an ocean-going vessel. See Board letter.|
|October 2006||Board authorizes the District Director to execute agreements for the in-use emission testing of an ocean-going vessel retrofitted with emissions control technologies using partner contributions and up to $22,500 of District Innovative Technology Group funds. See Board letter.|
|March 2007||Board adopted a resolution recognizing the magnitude of, and the projected growth in, international marine vessel emissions, and directed the Air Pollution Control Officer to take necessary actions to mitigate emissions from this source. Download letter and resolution (PDF file).|
|August 2007||Board adopts 2007 Clean Air Plan (view and download from this page, see Chapter 6).|
|October 2007||Board approves letter to U.S. Environmental Protection Agency (EPA) filing notice of intent to sue over EPA’s failure to regulate large ships.|
|December 2007||Board directs the Air Pollution Control Officer and APCD Counsel to sue EPA for failure to adopt standards regulating air pollution from Category 3 marine vessels.|
- December 21, 2007, letter to EPA in support of of the United States position on proposed amendments to the air pollution regulations in Annex VI of the MARPOL convention. (Letter is from Twenty Members of the United States West Coast Collaborative Marine Vessel and Ports Sector, including APCD.)
- November 28, 2007 letter to Senator Barbara Boxer, in support of HR 802, Marine Pollution Prevention Act
- November 28, 2007 letter to Senator Dianne Feinstein, in support of HR 802, Marine Pollution Prevention Act
- November 28, 2007 letter to Representative Lois Capps, in support of HR 802, Marine Pollution Prevention Act
- October 18, 2007 letter to U.S. Environmental Protection Agency filing notice of intent to sue EPA.
- May 25, 2007 letter to Senator Barbara Boxer, in support of the Marine Vessel Emissions Reduction Act of 2007.
- May 25, 2007 letter to Congresswoman Hilda Solis, in support of the Marine Vessel Emissions Reduction Act of 2007.
- May 8, 2007 letter to EPA with comments on EPA Change in regulatory deadline for rulemaking on marine engines.
- May 4, 2007 letter from CAPCOA (California Air Pollution Control Officers Association) to EPA with comments on EPA Change in regulatory deadline for rulemaking on marine engines.
- March 23, 2007 letter to Alan Lowenthal, California State Senate in support of Senate Bill 974 – Financing of Port Congestion Relief and Port Mitigation Relief.
- November 9, 2006 to California Air Resources Board on the Alternative Compliance Plan included as part of the auxiliary engine Air Toxic Control Measure developed by Air Resources Board.
- May 9, 2006 to Senator Commerce Committee to support favorable and expeditious processing of the implementation language required for US ratification of Annex VI, “Prevention of Air Pollution from Ships” of the International Maritime Organization (IMO) MARPOL.
- November 18, 2005 letter to ARB on effort to consider the adoption of proposed regulations to reduce emissions from auxiliary diesel engines and diesel-electric engines operated on ocean-going vessels within California waters and 24 nautical miles of the California baseline.
- November 4, 2005 letter to Governor Schwarzenegger re: Goods Movement
- August 24, 2004 APCD comments to the USEPA regarding Advanced Notice of Proposed Rulemaking: Control of Emissions of Air Pollution from New Locomotive Engines and New Marine Compression-Ignition Engines Less Than 30 Liters per Cylinder.
- August 19, 2004 Comments on California Resource Agency’s draft “California Ocean Resources Management: A Strategy for Action”
- Letter of June 6, 2002, from APCD to USEPA with comments on the draft rule addressing large ship engines.
The District was a party in two lawsuits challenging the EPA’s failure to adopt standards for the control of air pollution from Category 3 marine vessel diesel engines pursuant to Section 213 of the federal Clean Air Act.
The first lawsuit was filed in District Court for the District of Columbia and charged that EPA had failed to take “final action” to adopt standards for Category 3 marine vessels by the April 23, 2007 deadline. The District’s suit was consolidated with similar suits filed by the South Coast Air Quality Management District and the Friends of the Earth. EPA’s defense was to claim that it did take final action when it adopted a rule extending its deadline to December 17, 2009 (“Deferral Rule”). EPA argued the Deferral Rule rendered this suit moot and urged it be dismissed. Oral argument was heard on EPA’s motion to dismiss by Judge Collier on April 2, 2008. In light of the Court of Appeal proceedings (see below), however, Judge Collier issued a Stay Order, stating that regardless of what decision she might reach on this case, the ultimate decision was up to the Court of Appeal.
The same 3 parties also filed individual lawsuits in the Court of Appeals for the District of Columbia. These suits had to be filed no later than January 31, 2008 because the statute of limitations would have otherwise barred any challenge to the Deferral Rule. The three suits were consolidated by the Court of Appeal and ran parallel to the District Court action. This case challenges EPA’s adoption of the Deferral Rule as an abuse of discretion by charging the EPA had no authority to give itself more time to meet a deadline set by Congress. This suit also charges that EPA’s decision was not supported by evidence in the record.
Download February 22, 2008 filing in U.S. District Court (PDF file) by the District, Friends of the Earth, and South Coast Air Quality Management District .
- September 12, 2006 presentation by Tom Murphy to the Maritime Air Quality Working Group at the Port of Long Beach.
- July 18, 2006 presentation by Tom Murphy to Channel Islands Naturalist Corps (large file, @ 5.6 MB).
- November 22, 2005 presentation by Tom Murphy to Ventura County Air Pollution Control District.
- September 21, 2005 presentation on Marine Shipping Emissions by Tom Murphy to the local chapter of the Air & Waste Management Association.
- April 21 and 22, 2004 presentation by Tom Murphy at the West Coast Region Conference on Marine Port Air Quality Impacts, Seattle, Washington.
- “Air Pollution Grows as Vessel Regulations Flounder,” by Terry Dressler, in the Santa Barbara Independent May 17, 2007.
- “Next Challenge on the Horizon: Air Pollution Emissions from Ships,” by Terry Dressler, Tom Murphy, and Anthony Fournier, August 2006.
- “Controlling Air Emissions from Marine Vessels: Problems and Opportunities,” by Anthony Fournier, and supported by the University of California Institute for Global Conflict and Cooperation.
- “The Need to Reduce Marine Shipping Emissions: A Santa Barbara County Case Study,” by Tom Murphy, Ray McCaffrey, and Kathy Patton for the 2003 Air & Waste Management Association Conference.
- Articles in District’s On the Air Newsletter (see July 2001, January 2002, July 2002, and Fall 2003).
- Briefing paper for January 2002 meetings with EPA and U.S. Maritime Administration officials, in connection with Workshop on Maritime Energy and Clean Emissions conference sponsored by the USEPA, the U.S. Maritime Administration, and the U.S. Department of Energy.
- Fact sheet on the Marine Shipping Retrofit Program
Note: Because of equipment malfunctions, emissions testing conducted in 2007 did not provide reliable results.
The Maritime Working Group, formed by the California Air Resources Board (CARB) to discuss maritime air quality issues, developed a marine shipping retrofit program. Participants in the working group includes representatives from the District and other California air districts, the United States Environmental Protection Agency (EPA), the U.S. Department of Transportation’s Maritime Administration (MARAD), environmental organizations, port authorities, ship owner-operators, large engine manufacturers, and emission-control technology companies.
The District and several other members of the group began with a goal of developing a fund with an initial target of $1 million to implement and test retrofit strategies and technologies on vessels that operate in California waters. The immediate objective was to reduce emissions from two or three ships transiting the area, using cost-effective emission reduction technologies that can be adapted for use by other ships. In October of 2003, The District’s Board approved allocating $100,000 towards the retrofit program (download the Board letter here). The long-term goal was to document the emission reduction technologies and other information gained from the implementation phase in order to promote additional programs, projects, and potential incentives to reduce marine shipping emissions.
The five principal objectives of the program were as follows:
- Develop an understanding of ship activities and emissions.
- Evaluate potential control technologies.
- Develop partnerships and funding mechanisms.
- Implement retrofit technologies.
- Document results.
The group evaluated several control technologies, and worked with ship owners/ operators to assess the possibility of retrofitting a ship(s) with emission control technologies. The group worked with APL to demonstrate the feasibility of retrofitting the ocean-going vessel the APL SINGAPORE. Below is information on: vessel specifics, the emission control technologies, funding, and the 12/4/06 APL media event, as well as links to the project partner’s websites.
|Vessel Name||APL Singapore|
|Ship type||Post-Panamax Container ship|
|TEU Capacity||5,108 TEU|
|Length/Breadth/Depth||863′ / 131′ / 66′|
The APL SINGAPORE at that time operated on APL’s PS2 (Asia to North America) route. The eastbound and westbound routes are shown below. For more information on APL routes see: http://www.apl.com/routes/
Two emission control technologies wereinstalled on the main engine of the APL SINGAPORE for use on California calls: a fuel/ water emulsion system and slide-valves. Water in fuel emulsion is the process of introducing water into the fuel prior to injection into the combustion cylinder. Introducing water into the combustion cylinder reduces the maximum peak combustion temperature and the formation of nitrogen oxides (NOx). The in-cylinder evaporation of the water also improves the atomization of the fuel causing it to burn more completely. This system was installed and connected to the ship’s main engine and was expected to yield a 1% reduction in NOx for every 1% concentration of water in the emulsion. Different concentrations of water were tested to determine the emulsion level that best reduces emissions. NOx reductions up to 25% are expected from this control technology.
Particulate Matter (PM) is a product of incomplete combustion, and un-burnt fuel; therefore the optimization of the fuel injection system was expected to result in the reduction of fuel consumption and a reduction of PM emissions. Slide valves were installed on the vessel’s main engine and differ from conventional valves in their spray patterns that are designed to reduce the dripping of fuel from the injector into the combustion zone post injection. The slide valves were expected to reduce PM emissions by about 25%.
The funding for this project came from a number of different agencies. In 2005, the District supported an application by the Bay Area Air Quality Management District (BAAQMD) for funding from the CARB Multi-district Carl Moyer funding program. The application was successful in securing grant funds that, when combined with the EPA contribution covered the purchase and installation of the control technology, allowing the other funds to be used to cover the emissions testing costs. In an effort to expedite the testing coordination process, District staff volunteered to accept funding from project partners and contract with the emissions testing contractors selected for the project. The Ports of Los Angeles and Long Beach in addition to the Ventura County, San Luis Obispo County and Santa Barbara County air districts contributed funds towards the testing portion of the project. The installation of the emulsification equipment was completed in early 2007 and the emissions testing will begin in March/April 2007.
Speaker panel for the APL media event (from left to right): Eric Hutchingame – Sea to Sky Pollution Solutions; John Bowe – President of APL (Americas); Wayne Nastri – US EPA Region 9 Regional Administrator; Mike Zampa – APL Director of Corporate Communications (Americas); Jean Roggenkamp – BAAQMD Deputy APCO; and Dr. Wayne Miller – UC Riverside, Emissions and Fuels Manager.
View from the bridge of the APL SINGAPORE
On October 15, 2007 Tom Murphy, Ron Tan and Anthony Fournier from the District visited the APL SINGAPORE at the Port of Los Angeles. The vessel had just returned from its voyage across the Pacific. On this voyage, an emissions testing crew studied the emissions characteristics of the vessel’s main engine and auxiliary engine under different conditions (including the use of emulsified fuels in the main engine).
During the visit to the ship District staff witnessed the installation of some of the slide valves that were purchased as part of the demonstration project to reduce emissions. The emission testing was to continue as the vessel departed Los Angeles for Oakland, at which point the emissions testing crew would depart the vessel. See below for pictures from the visit. Emissions test results were not finalized; because of equipment malfunctions, emissions testing conducted in 2007 did not provide reliable results
Ron Tan and Tom Murphy on the top floor of three floors of the APL Singapore’s main engine
Inspecting the water emulsification control unit
Old fuel injector removed New slide valve fuel injector installed
Photos below from emissions testing setup on the exhaust stack of the APL Singapore’s main engine
For more information…
View December 4, 2006 presentation by Eric Hutchingame of Sea to Sky Pollution Solutions here.
Selected articles on the project (not a complete listing)
Los Angeles Times, December 5, 2006, “Shipper to Test System to Cut Emissions” on the paper’s website here.
Wall Street Journal, December 2006, “Shipper APL Adapts Fuel Use For California Ports” online here.
Sustainable Shipping website, December 5, 2006, “APL turns to technology to reduce emissions,” online, here.
MarineLink, December 5, 2006, “APL Aims to Cut Emissions,” online here.
California air districts
Bay Area AQMD – http://www.baaqmd.gov
Ventura County APCD – http://www.vcapcd.org
San Luis Obispo County APCD – http://www.slocleanair.org
Santa Barbara County APCD – http://www.ourair.org
Port of Los Angeles – http://www.portoflosangeles.org
Port of Long Beach – http://www.polb.com
California Air Resources Board – http://www.arb.ca.gov
Maritime Administration of the U.S. Department of Transportation – http://www.marad.dot.gov
U.S. Environmental Protection Agency – http://www.epa.gov
APL – http://www.apl.com
Emissions testing contractors and vendors
MAN Diesel – http://marine.man.eu/
University of California at Riverside, Center for Environmental Research & Technology (C-CERT) – http://www.cert.ucr.edu
Sea to Sky Pollution Solutions – http://www.wifeondemand.com