Comment Log Display

Dear Sir and Madam,

Attached please find our comments for subject.
We strongly request that LNG fueled vessel to be exempt from this
regulation in case the vessel consume LNG surely.


Please reply once you receive this message.

1.	Implementation date
The biggest change we see between this draft and the original
proposal is the change in implementation dates (page 28-29). As
proposed, Ro-Ros would be required to comply in 2024 rather than
2025, tankers going to LA/LB in 2025 rather than 2027, and all
remaining tanker trade in 2027 rather than 2029. As far as we can
tell, CARB has offered no explanation for this revision. 
Given the current global circumstances and likely impact on the
industry, we recommend providing comments to request the original
compliance dates be maintained to allow sufficient time for fleets
to come into compliance. 


2.	Page A-11 on Attachment A
Section 93130.2. Section Summary, and Definitions.
(b)Definitions.
 (40) ˇ§IMO NOx tierˇ¨ means the NOx tier level of a vessel as
citified in the Engine International Air 
Pollution Prevention (EIAPP) Certificate. Vessel without an IMO NOx
tier are considered pre-tier I 
vessel.
What is difference in correspondence between each vessel due to
differences in tier? 
If the vessel satisfied with tier 2 or 3, is there some
preferential treatment?


3.  Page A-19 on Attachment A
   Section 93130.5. CARB Approved Emission Control Strategy
  (d) Requirement for CARB approval of an emission control
strategy.
(1) Emission reductions.
To receive CARB approval, a person must demonstrate that the
emission controls strategy achieves emission rates less than
2.8g/kW-hr for NOx, 0.03g/kW-hr for PM-2.5, and 0.1g/kW-hr for ROG
for auxiliary engines. Additionally, for strategies approved after
2020, GHG emissions from the strategy must be grid-neutral using
the grid emission rate for the year that the technology is granted
an Executive Order. Default emission rates of auxiliary engines on
ocean-going vessels are 13.8g/kW-hr for NOx, 0.17g/kW-hr for
PM-2.5, and 0.52g/kW-hr for ROG.  
It is necessary to reduce the values of NOx, PM, and ROG
respectively to the specified values, but we 
would like to know clearly the basis (reason) of these presented
values, 2.8(NOx), 0.03(PM2.5) and 
0.1(ROG).
In addition, enormous cost and time are required for measurement of
above. Therefore, implementation 
date of regulation should not be advanced, and cost assistance is
required for NOx, PM2.5 and ROG 
measurement.
Further, we should be able to refrain from using shoreside
electrical power for LNG-fueled vessel by 
reporting or verifying that LNG fuel has been used in port.


4.  Page A-56/57 on Attachment A
Section 93130.17. Innovative Concept Compliance Option.
(a)Genera; requirements for using an innovative concept compliance
option.
(1) Applicants seeking approval of an innovative concept must
submit their applications 
to the Exclusive Officer on or before the following dates in Table
5 for each vessel category:

Table 5: Innovative Concept Application Due Date
Vessel Type	Due Date
Container/Reefer	July 1, 2021
Passenger	July 1, 2021
Ro-ro	December 1, 2021
LA/LB Tankers	December 1, 2021
Other Tankers	December 1, 2021
 
(2) The proposed innovative concept must reduce NOx, PM 2.5, and
ROG emissions 
equivalent to or greater than the level that would have been
achieved by the Control 
Measure, while not increasing GHG. Emission reductions are verified
each year through annual reporting 
in section 93130.17(d) of this Control Measure
It will be necessary to issue some documents from engine
manufacturer such as the NOx Technical File, 
in order to comply with new regulation of NOx, and to describe who
will allow CARB to approve the 
test result for PM2.5 and ROG measurement. 
If CARB accept the method/equipment for reduction of NOx/PM/ROG, we
would like to request CARB 
to compensate the cost for test.


5.  Page B-4 on Attachment B
Summary of the 15-Day Changes
8)Connection time from ˇ§Ready to Workˇ¨ determination. The
Proposed Regulation adjusts the time allowed for connection to
shore power or an alternative CAECS for vessels at berth from one
hour after ˇ§Ready to Workˇ¨. This Change is expected to have a
minor impact to the emissions reductions compared to the connection
time definition listed in the ISOR. This is based on past
compliance data for the originalAt-Berth Regulation. Staff do not
connect to shore power or to an alternative CAECS. This change has
no impact on costs.
Who has responsibility for emission control violations if more than
two hours have passed since "Ready to Work" due to delays by
shore-side works and/or any other reason to connect shore power. It
should not be on vessel.


6.  Page B-4 on Attachment B
Summary of the 15-Day Changes
9)Updated non-cancer mortality. Total costs for all entities is
expected to be about $2.4 billion through 2032, with a statewide
valuation of avoided health impacts valued at $2.44 billion from
250 fewer premature deaths, 78 fewer hospital admissions, and 126
fewer emergency room visits statewide. More information on the
updates to the Health Analysis can be found in Attachment D of the
15-day package.  
Page D-3 on Attachment D
2. Updates to Regional PM2.5 Mortality and Illness Analysis for
California Air Basins: PM Mortality and Illness: Reduction in
Health Outcomes.
California Air Resource Board (CARB) staff estimated the reduction
in health outcomes from reduced emission of PM2.5 from the 15-day
change version of the Proposed Regulation. These health outcomes
include cardiopulmonary mortality, hospital admissions, and
emergency room visits. Based on the analysis,   staff estimates
that the total number of cases statewide that would be reduced due
to the implementation of the Proposed Regulation are as follows:
„«	250 premature deaths (195 to 305; 95 percent confidence interval
(Cl)).
„«	78 hospital admissions (10 to 145; 95 percent (Cl).
„«	126 emergency room visit (79 to 172; 95 percent Cl)
Updated Tables 20 through 22 show the estimated reductions in
health outcomes resulting from the Proposed Regulation summed over
1 12-year period from 2021 to 2032. The values in parentheses
represent the 95 percent confidence interval for each health
outcome.
It understands as estimated figure, however, it is not just because
of vessels. It seems to be not considered the underlying disease,
inherited diseases, lifestyle-related diseases, etc. 

Yours faithfully,