Local Studies and Actions

Webpage Links:  Previous Vessel Speed Reduction (VSR) Programs  |  Local Studies & Actions Initiatives  |  2007 Retrofit Project

Board Actions

The District’s work to reduce marine shipping emissions started with the 1994 Clean Air Plan, which identified ships in the Santa Barbara Channel as a large source of nitrogen oxide (NOx) emissions. NOx emissions contribute to the formation of ground-level ozone. The District Board has taken multiple other actions relating to marine shipping activities, as shown in the timeline below.

Marine Shipping Related Actions by District Board
November 1994Board approves 1994 Clean Air Plan, which identifies marine shipping as a large source of emissions of nitrogen oxides (NOx).
January 1995Board approves letter to U.S. Environmental Protection Agency (EPA) urging action on marine shipping.
October 1999Board 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 vessels.
July 2001Board approves international marine vessel resolution. See Board letter.
February 2002Board receives update on marine shipping emissions. See Board letter.
April 2002Board receives update on District efforts to reduce emissions from marine shipping activities. See Board letter.
June 2002Board receives update on the Marine Shipping Retrofit Project (MSRP) and comments on EPA marine engine rulemaking. See comment letter.
January 2003Board 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 2003Board receives update on MSRP efforts and approves $100k for MSRP. See Board letter.
October 2006Board authorizes the in-use emission testing of the ocean-going vessel retrofitted with emissions control technologies using partner contributions and up to $22,500 of District funds. See Board letter.
March 2007Board 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. See Board letter.
December 2007Board 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. See “Legal Actions” section below.
October 2010Board receives an update on the U.S. Coast Guard Port Access Route Study and the California Air Resources Board Ocean-Going Vessels Fuel Regulation. See presentation.
March 2012Board receives an update on marine shipping activities at the District. See presentation.
August 2012Board receives report and provides policy direction on the District’s initiative to incentivize reduction of ship speeds off the California Coast. See Board letter,  District’s comment letter and other letters of support, and presentation.
March 2013Board receives presentation on recent marine shipping developments and authorizes chair to sign a letter of support for use of Cap-and-Trade auction funds for a vessel speed reduction incentive program along the California coast.
June 2013Received an update on a proposal by the IMO to delay implementation of nitrogen oxides (NOx) limits for new ship engines in Emission Control Areas until 2021, and authorized Chair to sign a letter encouraging vigorous efforts by the U.S. Delegation to urge the IMO to retain the original deadline of 2016.  (See memo and presentation)

Comment Letters


 Articles, Papers and Studies

Legal Actions

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.