First Name | Kaity |
---|---|
Last Name | Arsoniadis-Stein |
Email Address | kaity@kaitystein.com |
Affiliation | |
Subject | California Code of Regulations Title 13, Section 2299.2 |
Comment | March 23, 2009 Chairman Mary D. Nichols, Air Resources Board 1001 “I” Street, 23rd Floor Sacramento California, 95814 Dear Madam Chairman, Re: California Code of Regulations Title 13, Section 2299.2-- Regulations on fuel sulphur content and other operational requirements for ocean going vessels within California waters and 24 nautical miles of the California base line. On behalf of the International Shipowners Alliance of Canada Inc. (ISAC), we wish to provide you with our comments regarding CCR Title 13, Section 2299.2. We note and endorse in full, the comments posted on line from Capt. Stephen Brown of the Chamber of Shipping of British Columbia as well as those of Joseph Angelo of INTERTANKO. We wish to highlight our concern regarding safety and the fact that there is a lack of operational expertise for operating auxiliary boilers on MDO/MGO for long periods of time. Our members have been advised that for main and auxiliary engines, low sulphur distillate fuel will most certainly cause problems with pump failures, seizures and other wear related issues, thus creating serious navigational and safety issues if vessels lose power or propulsion in confined waters near the port. The comments submitted by INTERTANKO clearly set out the technical challenges. The request of use of MGO/DMA grade is possible, but there are significant engine modifications required making it challenging to have all vessels compliant by July 1st, 2009. Finally, we are aware that suppliers are unable to provide MDO in a timely manner, an issue of great concern to our industry. We thank you for the opportunity to comment and trust that our input will be seriously considered. Yours sincerely, Kaity Arsoniadis-Stein LLB, LLM President & Secretary-General International Ship-Owners Alliance of Canada Inc. cc. Cpt. Stephen Brown, Chamber of Shipping, British Columbia cc: Joe Angelo, INTERTANKO |
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Date and Time Comment Was Submitted | 2009-03-23 11:27:39 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.