Comment Log Display

The Santa Barbara County Air Pollution Control District is pleased
to provide input on use of Cap-and-Trade auction funds, and
recommends that some funds be used as an incentive to reduce speeds
of large ships along the California coast.

This action addresses the goals of AB 32 immediately and directly.
Reducing ship speeds down to 12 knots along the California coast
from the current speeds of approximately 20 knots would produce a
50% reduction of greenhouse gases (GHG). 12 knots appears to be a
feasible lower limit. Approximately 1.4 million metric tons of GHG
reductions would be achieved statewide. This amounts to nearly half
of the entire reductions expected from Cap and Trade on a yearly
basis. 

This action also provides significant public health and business
benefits. Particulates (including black carbon), air toxics, and
nitrogen oxide emissions would also be reduced by vessel speed
reduction, significantly benefiting public health. In addition,
coastal communities, and the businesses located in these
communities, would be assisted in efforts to attain health-based
standards for particulate matter and ozone. 

This action supports the state’s economy, and furthers a long-term
transformative effort to develop a clean-energy economy.  Shipping
companies docking in California already have to comply with the
state’s fuel rule and the International Maritime Organization’s
rules associated with the North American Emission Control Area. An
incentive-based program avoids the need for mandatory ship speed
reduction, which is under evaluation by the California Air
Resources Board, and the National Oceanic and Atmospheric
Administration (NOAA). NOAA has implemented mandatory
speed-reduction measures along the East Coast, and has been
petitioned to regulate speeds on the West Coast, for protection of
endangered whales. 

Providing incentives to shipping companies would avoid potential
costs to the industry of scheduling adjustments, and would support
the continued economic health of the ports, an economic engine for
all of California.  The auction revenue incentives would initially
offset increases in scheduling and crew costs, and then substantial
annual savings in fuel costs would kick in over the next few years,
providing a sustainable incentive for speed reduction. 
                                                                   
                                                          
The action provides other important environmental benefits. Reduced
ship speeds would reduce the risk and severity of ship strikes on
endangered blue, fin and humpback whales. NOAA supports this action
for its benefits to these whale populations. Slower ships are also
quieter ships, reducing ocean noise pollution that negatively
affects marine mammals. 
 
The action could be implemented based on an existing model. The
Ports of Long Beach and LA already have implemented successful
programs that reward shipping operators with incentives for
voluntarily reducing ship speeds when approaching the ports. These
programs have been in effect for several years, and compliance
rates have been very high. 
 
The emission reductions are verifiable and measureable.   A network
of monitors along the California coast currently tracks ship
position and speed. This data can be obtained on a daily basis to
ensure ships speeds are in compliance.  Additionally, ship fuel
consumption data could be reviewed.