Comment Log Display

1. On page 8, Requirements and Compliance Schedule (d)(2)(A)
The sentence  “…Specifically, at-berth auxiliary engine emissions
must be reduced by 10 percent by January 1, 2010, 25 percent by
January 1, 2012, …”
 should be modified to read… “Specifically, at-berth emissions
must be reduced by…”, 
where the words “auxiliary engines” have been deleted.

At-berth emissions include boiler emissions, and the ACTI system
will reduce boiler emissions as well as auxiliary engine
emissions, resulting in lower total emissions than if only the
auxiliary engines were considered. Total emissions reduction
should be the criterion.

2. There will be a period of time during shore power connect and
also prior to shore power disconnect when the auxiliary engines
will be operating. This time is not accounted for.