Comment Log Display

Dear CARB personnel,

I am somewhat confused how EJAC intends to add intrastate marine
fuels to a deficit generating status. I was unable to listen past
around 5:30PM this evening, so may have missed further discussion
of this point. My apologies if so. 

My understanding is travel through the North American ECA, in which
California Regulated Waters are a part, already requires the use of
0.1% sulfur (or less) marine fuel, almost always in the form of
marine gasoil (MGO), a distillate product that burns far cleaner
than heavy residual fuel oil or the like. I only bring this up
because the EJAC slide shows a bulker with a stream of black smoke
emitting from its stacks. This does not occur with use of MGO. 

Given provisions in the Commercial Harbor Craft (CHC) legislation
that went into effect this year, there should be increasing use of
shore-based electrical power available to moored vessels so they
don't have to operate their shipboard generators, which will help
in reducing port emissions. Required 99-100% renewable diesel use
by CHC was also mandated, so there should not, theoretically, be
any deficits generated by CHC since they are running in RD. CHC
fuel use therefore should not be an issue here.

What fuels does EJAC then propose to add as deficit generators?
Fuels sold in California for use in personal watercraft? Bunker
fuel sold to vessels at California ports to ocean-going vessels
(OGV)? Such bunker fuel would have to be limited to that used
during intrastate voyages only, and I would guess most of the
bunker is delivered to vessels performing either 1) interstate
voyages, or 2) international voyages. The fuel consumed would also
need to only be MGO, as heavy fuel oil (HFO) or very low sulfur
fuel oil (VLSFO) is not allowed to be combusted in California
Regulated Waters (CRW) or the North American ECA anyhow. I would
also guess much of the MGO sold in California is consumed outside
CRW as well. Unlike intrastate jet travel, where there is one fuel
type consumed on one aircraft with guarantee of use in California
airspace, no such simple scenario exists for marine fuels, for the
most part. And for those able to be monitored and assumed to be
operating exclusively in CRW, the commercial harbor craft, their
emissions are attempting to be regulated already as through the CHC
legislation.

Thank you for the opportunity to comment, and for your time.

Sincerely,
Josh Kehoe