Comment Log Display

I live in Point Richmond - roughly a half mile from Chevron's wharf
where 400 tankers a year idle with their engines on. The amount of
PM in Richmond is visibly greater than in say San Francisco. (I've
lived in both cities). And I'm sure you know that Richmond has very
high asthma and chronic respiratory health problems. Speaking
frankly, it is astonishing to me that the State of California has
been so unconcerned and passive about reducing PM where it can be
easily reduced. Truck PM is a tough regulatory problem requiring
long lead times and complex economic changes - marine vehicle PM is
far less difficult.

Chevron's Richmond refinery is the biggest on the west coast - if
they were forced to put a wet scrubber on their primary cracking
unit and hook their tankers up to shore power, Richmond residents
would experience a HUGE improvement in quality of life. These 2
things could have and should have been required ten or even twenty
years ago. The installation of a wet scrubber might legitimately
require 5 years lead time, but it is very difficult to understand
why bringing electricity to the wharf should take even five years
much less the ten that you are proposing.

From the documents you provided, a few facts stood out to me:

1) Tankers generate three times as much PM as container ships!
2) Richmond tankers (Chevron) generate more PM and DPM than is
generated by the much larger Port of Oakland!
3) DPM can be reduced by 70% in Richmond and PM 2.5 by 30% (we need
the wet scrubber to increase this number!)

PLEASE, re-draft this rule to implement the requirement to use
shore power at Chevron's Richmond wharf within 2 or 3 years. And
make sure that any regulation with a slower implementation schedule
is fully justified by actual required lead times rather than simply
Chevron's preferences. 

Thank you for addressing this area of major possible improvement.

Jeff Kilbreth
Richmond Planning Commission 2015-2016