Comment Log Display

October 18, 2021


California Air Resources Board
Liane M. Randolph, Chair
1001 I Street
Sacramento, CA  95814

Electronically submitted at
https://www.arb.ca.gov/lispub/comm/bcsubform.php?listname=2020moblesourcestrat&comm_period=N


SUBJECT:	Comments on the 2020 Mobile Source Strategy

Dear Chair Randolph:

Thank you for the opportunity to review and comment on the
California Air Resources Board (CARB) 2020 Mobile Source Strategy. 
As the governmental local air agency responsible for regulating air
emissions in Ventura County, we wish to submit the following
comments.

Ventura County is classified as a serious nonattainment area for
the 2015 National Ambient Air Quality Standard (NAAQS) for Ozone
and as a nonattainment area for the California Ambient Air Quality
Standard for Ozone.  In order to attain the state and federal
standards and realize the public health benefits those standards
provide, reductions in emissions of the ozone precursors reactive
organic compounds (ROC) and nitrogen oxides (NOx) are required. 
While the Ventura County Air Pollution Control District (VCAPCD) is
responsible for regulation of stationary sources of air pollution
in its jurisdiction, VCAPCD relies on our partners at CARB and the
United States Environmental Protection Agency to regulate and
reduce emissions of ozone precursors from mobile sources.  

As a coastal community, a large portion of the emissions of NOx
from mobile sources is attributed to ocean-going vessels (OGV) that
transit the nearshore waters off the Ventura County coastline,
including those OGV visiting the Port of Hueneme.  VCAPCD has no
authority to regulate OGV emissions.  However, the 2020 Mobile
Source Strategy under consideration by CARB does consider OGV
emissions and CARB has demonstrated authority to regulate emissions
from OGV in the California coastal waters by adopting the
regulation "Fuel Sulfur and Other Operational Requirements for
Ocean-Going Vessels within California Waters and 24 Nautical Miles
of the California Baseline" on July 24, 2008.  

CARB is currently reviewing and revising the OGV emissions
inventory and VCAPCD supports that effort to improve the
understanding of OGV emissions off the California coast.  This will
help VCAPCD understand the impact of OGV emissions on its air
quality and the importance of reducing emissions from this source.

VCAPCD requests CARB consider additional actions to reduce
emissions from OGV.  VCAPCD was encouraged by CARB's adoption of a
Control Measure for Ocean-Going Vessels At Berth that expands the
regulation to include additional vessel types and visits, as well
as additional ports and terminals.  However, more must be done.

Many OGV, especially container ships and those carrying mobile
equipment such as cars, trucks and off-road equipment (roll-on,
roll-off or RoRo vessels), travel at speeds in excess of 15 knots
through the Santa Barbara Channel and in the western approach to
the San Pedro Bay ports of Long Beach and Los Angeles.  Prevailing
winds carry NOx emissions from OGV onshore in Ventura County as
well as other coastal communities including Los Angeles and Orange
Counties, which are classified as an extreme nonattainment area for
the 2015 ozone NAAQS.

VCAPCD is a founding member of the Protecting Blue Whales and Blue
Skies (PBWBS) partnership providing incentives to ships to reduce
speeds while traveling in the near-shore areas in Southern
California and the San Francisco Bay area.  Reducing ship speeds to
10 knots or less greatly reduces emissions due to the reduced power
needed to overcome drag.  While this incentive program has been
very successful at reducing OGV speeds and emissions, the incentive
program does not have reliable funding and is therefore not a
reliable source of future emissions reductions.

The PBWBS program has demonstrated that OGV owners and operators
will slow down for modest incentives and ozone precursor emissions
from transiting OGV can be reduced in a cost-effective manner. 
Data from the PBWBS program indicate container and RoRo vessels
traveled a total of 304,572 nautical miles (nm) in the PBWBS
Southern California vessel speed reduction (VSR) zone during the
program period from May 15, 2020 through November 15, 2020.  OGV
participating in the PBWBS program traveled 151,267 nm at reduced
speeds in the VSR zone, resulting in reductions of 3.37 tons of NOx
per day.  If all container and RoRo vessels reduced speeds to 10
knots or less in the VSR zone, estimated NOx reductions would be
approximately 6.5 tons of NOx per day.  If all other OGV, such as
bulk carriers and tankers, also reduced speeds NOx emissions would
be reduced even more.

VCAPCD considers the implementation of OGV speed restrictions in
California coastal waters a reasonably available control measure
(RACM) as described in the federal Clean Air Act (CAA).  According
to the CAA, a potential control measure is considered "reasonably
available" and must be implemented if it would advance attainment
by at least one year, either alone or in combination with other
reasonably available control measures.  For the 2008 ozone NAAQS,
NOx reductions of two tons per day were considered sufficient to
advance attainment by one year.  For the 2015 ozone NAAQS, the
incremental NOx reduction needed to advance attainment in Ventura
County by one year has not yet been determined.  However, based on
the data collected during PBWBS incentive program, NOx emission
reductions from OGV of 6.5 tons per day will likely be sufficient
to advance attainment in Ventura County by at least one year.

While the cost-effectiveness of OGV speed restrictions is yet to be
determined, please note that the cost-effectiveness of the PBWBS
incentive program in 2020 was approximately $500 per ton of NOx
reduced.

VCAPCD recommends CARB consider a speed limit of 10 knots for OGV
as a RACM for Ventura County.  Speed restrictions are technically
and economically feasible as demonstrated by the PBWBS incentive
program.  Photochemical modeling will undoubtedly show the
resulting reduction in NOx emissions will advance attainment of the
2015 ozone NAAQS in Ventura County by at least one year.  Staff
believes that CARB has the authority as demonstrated by the
successful implementation of the OGV Fuel Regulation.  As RACM,
such a control measure must be implemented per the federal CAA.  It
is also clear that reducing the speed of OGV is the only realistic
method of obtaining near-term emissions reductions from this source
category.

I appreciate your consideration of these comments.  Our agency is
available to help CARB staff evaluate the proposed measures.  If
you have any questions, you may reach me at 805-303-4005.

Sincerely,



DR. LAKI TISOPULOS, P.E.
Air Pollution Control Officer