DEPARTMENT OF NAVY

EMISSIONS GROWTH INCREMENT 

REQUEST FOR THE SAN DIEGO 

AIR POLLUTION CONTROL 

DISTRICT

Prepared for

Naval Facilities Engineering Command Southwest

and

Marine Corps Installations West

San Diego, California 

24 May 2011

2020 East First Street, Suite 400

Santa Ana, California 92705
DoN SIP Emissions Growth Increment

May 2011 i

TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS..................................................................................... III

EXECUTIVE SUMMARY ............................................................................................................ 1

1. INTRODUCTION ........................................................................................................... 1-1

2. MARINE CORPS ANTICIPATED ACTIONS AND ESTIMATED EMISSIONS....... 2-1

2.1 GROUND AND TACTICAL SUPPORT EQUIPMENT.................................................... 2-1

2.1.1 HMMWV Replacement with the JLTV................................................... 2-1

2.1.2 Alternative Fuels...................................................................................... 2-2

2.1.3 AAV Replacement/Upgrade .................................................................... 2-3

2.1.4 Vehicle Operations Due to the Possible Relocation of OCONUS 

Operations to San Diego County ............................................................. 2-3

2.2 AIRCRAFT ............................................................................................................. 2-4

2.2.1 CH-53E Helicopter Upgrade to CH-53K................................................. 2-4

2.2.2 Aircraft Emissions due to the Possible Relocation of Marine Corps 

OCONUS Operations to San Diego County............................................ 2-5

2.3 UTILITIES .............................................................................................................. 2-5

2.3.1 Utility Emissions due to the Possible Relocation of Marine Corps 

OCONUS Operations to San Diego County............................................ 2-5

3. NAVY ANTICIPATED ACTIONS AND ESTIMATED EMISSIONS......................... 3-1

3.1 LITTORAL COMBAT SHIPS (LCS-1 AND LCS-2).................................................... 3-1

3.2 GERALD R. FORD CLASS (CVN-78) ..................................................................... 3-2

3.3 AMPHIBIOUS TRANSPORT DOCK (LPD-17) SAN ANTONIO CLASS ........................ 3-3

3.4 AEGIS GUIDED-MISSILE DESTROYER (DDG-51) FLIGHT IIA ARLEIGH BURKE 

CLASS ................................................................................................................... 3-4

3.5 AEGIS GUIDED-MISSILE DESTROYER (DDG-51) FLIGHT III................................. 3-4

4. COAST GUARD ANTICIPATED ACTIONS AND ESTIMATED EMISSIONS........ 4-1

4.1 NATIONAL SECURITY CUTTER (NSC)................................................................... 4-1

5. CONCLUSION................................................................................................................ 5-1
DoN SIP Emissions Growth Increment

TABLE OF CONTENTS (CONTINUED)

May 2011 ii

TABLES

Table ES-1. Total DoN Emissions Growth Requested by Year With Additional 20% 

Growth .................................................................................................................................2

Table ES-2. Total DoN Emissions Growth Requested by Year and Source Category With 

Additional 20% Growth.......................................................................................................3

Table 2-1. HMMWV Replacement with JLTV ........................................................................... 2-2

Table 2-2. Alternative Fuel Replacement Program ..................................................................... 2-2

Table 2-3. AAV Replacement/Upgrade...................................................................................... 2-3

Table 2-4. Additional Vehicle Emissions from Possible OCONUS Relocation ......................... 2-4

Table 2-5. CH-53E Helicopter Upgrade to CH-53K ................................................................... 2-4

Table 2-6. OCONUS Aircraft Emissions..................................................................................... 2-5

Table 2-7. OCONUS Utilities Emissions .................................................................................... 2-6

Table 3-1. LCS-2 Projected Emissions....................................................................................... 3-1

Table 3-2. CVN-78, 79, 80 Projected Emissions....................................................................... 3-3

Table 3-3. LPD-17 Projected Emissions.................................................................................... 3-3

Table 3-4. DDG-51 Flight IIA Projected Emissions ................................................................... 3-4

Table 3-5. DDG-51 Flight III Projected Emissions..................................................................... 3-5

Table 4-1. United States Coast Guard National Security Cutter ............................................... 4-1

APPENDIX 

Appendix A: Emission Calculation Backup Documentation (Provided Electronically on the 

Enclosed CD)
DoN SIP Emissions Growth Increment

May 2011 iii

ACRONYMS AND ABBREVIATIONS

AAAV Advanced Amphibious Assault Vehicle

AAV Amphibious Assault Vehicle

ACV Amphibious Combat Vehicle

AESO Aircraft Environmental Support Office

bhp break horse power

DoN Department of the Navy

EFV Expeditionary Fighting Vehicle

EPA Environmental Protection Agency

g/bhp/hr gram per break horsepower per hour

GE General Electric

GSE ground support equipment

HMMWV High Mobility Multipurpose Wheeled Vehicle

JLTV Joint Light Tactical Vehicle

LCS Littoral Combat Ship

MPC Marine Personnel Carrier

NEPA National Environmental Protection Act

NOx Oxides of Nitrogen

NSC National Security Cutter

OCONUS outside the contiguous United States

SDAB San Diego Air Basin

shp shaft horsepower

SIP State Implementation Plan

tpy tons per year

TSE tactical support equipment

VOC Volatile Organic Compounds

WHEC High Efficiency Cutters
DoN SIP Emissions Growth Increment

May 2011 ES-1

EXECUTIVE SUMMARY

Navy Region Southwest (NRSW) and the Marine Corps Installations West (MCIWEST) have 

initiated an effort to estimate emission increases from potential operational changes through Year 

2027 for the Department of the Navy (DoN) installations in San Diego County. This information 

is submitted to the San Diego Air Pollution Control District (SDAPCD) to be included in the 

2012 8-hr Ozone Attainment Plan for the San Diego Air Basin (SDAB). The inclusion of the 

projected military emissions growth in the Attainment Plan would proactively address the 

Environmental Protection Agency (EPA) General Conformity requirements for federal actions in 

San Diego County. In addition to the anticipated DoN projects, this emissions growth 

assessment also includes emissions growth from potential upcoming Coast Guard projects.

The data presented in this document represent the best available information for potential federal 

actions and their associated emissions at the time of this submission. URS and the DoN will 

communicate closely with SDAPCD during the Attainment Plan preparation process to refine the 

data presented here based on SDCAPCD comments, any further refinements in calculations, and 

updated information obtained. However, no significant changes to the information presented here 

are currently anticipated.

The DoN emphasizes that all growth information regarding proposed projects and emission 

estimates are notional for all potential new weapons systems, and as such, are best estimates at 

this time and subject to change. Further, the DoN must comply with the provisions of the 

National Environmental Policy Act (NEPA) and other laws and regulations that prohibit predecisional actions. Final decisions about specific projects or actions for new weapons systems 

cannot be made until NEPA and other applicable requirements are met.

After analyzing the potential upcoming DoN and Coast Guard projects, emissions growth is 

expected for the two ozone precursor criteria pollutants (i.e., oxides of nitrogen (NOx) and

volatile organic compounds (VOC)). Therefore, the DoN and Coast Guard request that 

emissions growth allowances for NOx and VOC be included in the Attainment Plan as Military 

Growth Increment line items, expressed in tons per day.

Detailed descriptions of potential projects, emissions, and operational assumptions are presented 

in the following sections. In addition to the known potential projects, an additional 20% 

emissions growth allowance is requested to account for the currently unanticipated DoN and 

Coast Guard actions, currently unknown new weapon systems or training operations, unknown 

large-scale construction projects or other operational changes that may occur through 2027. 
DoN SIP Emissions Growth Increment

May 2011 ES-2

Table ES-1 shows a summary of the requested growth increment by year, including the

additional 20% growth. Based on the information currently available for potential operational 

changes, the years 2022 through 2025 yielded a negative emission change for VOC emissions. 

The negative values were removed from the emissions growth totals by year. Table ES-2 

presents the emissions by year and by source category, with additional 20% growth included.

In summary, the DoN and Coast Guard request that 1,616 tons per year of NOx (4.43 tons per 

day) and 356.2 tons per year of VOC (approximately 1 ton per day) be incorporated in the 

upcoming Attainment Plan for San Diego County, with the understanding that the DoN and 

Coast Guard may use the allowable growth as needed, at any time during the term of the Plan. 

TABLE ES-1. TOTAL DON EMISSIONS GROWTH REQUESTED BY YEAR WITH 

ADDITIONAL 20% GROWTH

Year Annual Emissions Change, tpy

NOX VOC

2011 0.0 3.1

2012 91.0 14.3

2013 67.6 23.3

2014 67.6 1.6

2015 279.4 87.3

2016 127.5 13.5

2017 117.7 13.7

2018 117.7 13.7

2019 117.5 13.8

2020 117.4 13.9

2021 19.8 2.0

2022 86.8 --

2023 86.8 --

2024 86.8 --

2025 192.2 155.7

2026 19.8 0.1

2027 19.8 0.1

Total 1,615.7 356.2

 Note: 

 tpy: tons per year

“-- “: Indicates that net emission change resulted in a negative value for the year. This negative value 

was removed from the emissions growth totals. 
DoN SIP Emissions Growth Increment

May 2011 ES-3

 TABLE ES-2. TOTAL DON EMISSIONS GROWTH REQUESTED BY YEAR AND 

SOURCE CATEGORY WITH ADDITIONAL 20% GROWTH 

Year Annual Emissions Change, tpy

NOX VOC

GSE/TSE

2011 0.0 0.0

2012 2.1 0.0

2013 2.1 0.0

2014 2.1 0.0

2015 107.5 23.2

2016 97.9 12.0

2017 97.9 12.0

2018 97.9 12.0

2019 97.6 12.0

2020 97.6 12.0

2021 0.0 0.0

2022 0.0 0.0

2023 0.0 0.0

2024 0.0 0.0

2025 105.4 180.2

2026 0.0 0.0

2027 0.0 0.0

Total 708.1 263.4

Aircraft

2011 0.0 0.0

2012 0.0 0.0

2013 0.0 0.0

2014 0.0 0.0

2015 48.1 55.0

2016 0.0 0.0

2017 0.0 0.0

2018 0.0 0.0

2019 0.0 0.0

2020 0.0 0.0

2021 0.0 0.0

2022 67.0 -26.8

2023 67.0 -26.8

2024 67.0 -26.8

2025 67.0 -26.8

2026 0.0 0.0

2027 0.0 0.0

Total 316.1 -52.3

Ship

2011 0.0 0.0

2012 88.9 3.5

2013 65.5 0.9

2014 65.5 0.9
DoN SIP Emissions Growth Increment

May 2011 ES-4

 TABLE ES-2. TOTAL DON EMISSIONS GROWTH REQUESTED BY YEAR AND 

SOURCE CATEGORY WITH ADDITIONAL 20% GROWTH 

Year Annual Emissions Change, tpy

NOX VOC

2015 29.6 0.1

2016 29.6 0.1

2017 19.8 0.1

2018 19.8 0.1

2019 19.8 0.1

2020 19.8 0.1

2021 19.8 0.1

2022 19.8 0.1

2023 19.8 0.1

2024 19.8 0.1

2025 19.8 0.1

2026 19.8 0.1

2027 19.8 0.1

Total 497.3 6.9

Utilities

2011 0.0 3.1

2012 0.0 10.8

2013 0.0 22.4

2014 0.0 0.7

2015 94.2 9.0

2016 0.0 1.3

2017 0.0 1.6

2018 0.0 1.6

2019 0.0 1.7

2020 0.0 1.8

2021 0.0 1.9

2022 0.0 1.9

2023 0.0 2.0

2024 0.0 2.0

2025 0.0 2.2

2026 0.0 0.0

2027 0.0 0.0

Total 94.2 64.1

 Notes:

 GSE: Ground Support Equipment 

 TSE: Tactical Support Equipment

 tpy: tons per year
DoN SIP Emissions Growth Increment

May 2011 1-1

1. INTRODUCTION

The DoN and Coast Guard are requesting an emissions growth allowance in the upcoming San 

Diego County 8-hr Ozone Attainment Plan to proactively address the EPA General Conformity 

requirements. San Diego is the largest Pacific port of the Department of the Navy (DoN, 

including both the Navy and Marine Corps) and is home to many of the soldiers and civilians 

that serve the nation’s military. The DoN takes great pride in the efforts undertaken to help

improve the air quality for the service members, their families, and the rest of the population 

living in San Diego. As such, the continuous improvement of air quality remains one of the 

DoN’s top priorities. The emissions growth allowance requested for this Attainment Plan will 

allow the DoN and Coast Guard to proactively plan potential changes to their operations while 

meeting all the applicable regulatory requirements.

The DoN and Coast Guard have evaluated upcoming potential actions that would create a net 

change in emissions over the next 16 years. These projects consist of the addition of ground and 

tactical support vehicles, new aircraft, ships, and utilities.

The data presented in this document represent the best available information for growth emission 

estimates available at the time of this submission. URS, the DoN, and the Coast Guard will 

communicate closely with SDCAPCD during the SIP preparation process to refine the data 

presented here based on SDCAPCD comments. Any further refinements in calculations, and 

updated information will be obtained. However, no significant changes to the information 

presented here are currently anticipated.

The DoN and Coast Guard emphasize that all growth information regarding proposed projects 

and emission estimates are notional for all potential new weapons systems, and as such, are best 

estimates at this time and subject to change. Further, the DoN and Coast Guard must comply 

with the provisions of the National Environmental Policy Act (NEPA) and other laws and 

regulations that prohibit pre-decisional actions. Final decisions about specific projects or actions 

for new weapons systems cannot be made until NEPA and other applicable requirements are 

met.

Detailed descriptions of projects, emissions, and operational assumptions are presented in the 

following sections. The remainder of this report is organized as follows:

 Section 2.0 – Marine Corps Anticipated Actions and Estimated Emissions 

 Section 3.0 – Navy Anticipated Actions and Estimated Emissions

 Section 4.0 – Coast Guard Anticipated Actions and Estimated Emissions 

 Section 5.0 – Conclusion
DoN SIP Emissions Growth Increment

May 2011 2-1

2. MARINE CORPS ANTICIPATED ACTIONS AND ESTIMATED EMISSIONS

The anticipated Marine Corps actions consist of projects categorized under the following source 

types:

 Ground and Tactical Support Equipment

 Aircraft

 Utilities

2.1 GROUND AND TACTICAL SUPPORT EQUIPMENT

The projects identified in the ground and tactical support equipment source category include the 

High-Mobility Multi-Purpose Wheeled Vehicle (HMMWV) replacement with the Joint Light 

Tactical Vehicle (JLTV), the vehicle alternative fuels’ goals, the Amphibious Assault Vehicle 

(AAV) replacement/upgrade, and vehicle operations associated with the possible relocation of 

the Marine Corps Outside the Contiguous United States (OCONUS) operations to San Diego 

County.

The following subsections provide the details regarding the overall projects, assumptions, 

emission factor references, and emissions calculated for this emissions growth assessment. 

2.1.1 HMMWV Replacement with the JLTV

The High-Mobility Multi-Purpose Wheeled Vehicle (HMMWV) will be replaced by the Joint 

Light Tactical Vehicle (JLTV), which is a U.S. Army and Marine Corps joint effort. Currently, 

the Marine Corps is set to purchase 5,500 units, with full production projected by 2015. The 

JLTV program will include a greater payload, additional armor, and a larger engine, as compared 

to the HMMWV.

Emission factors for the HMMWV and JLTV were obtained from the U.S. Army Fuels and 

Lubricants Research Facility’s Interim Report Number 376, Emissions from a 6.5L HMMWV

Engine on Low Sulfur Diesel Fuel and JP-8, published in 2004 The emissions were based on 

assumptions that one third (1/3) of the JLTVs will be located in San Diego, each JLTV will 

operate 500 hours per year, and the emission factors for the HMMWV and JLTV, in units of 

grams per brake horse power per hour (g/bhp-hr), are equivalent. Table 2-1 presents the 

emissions from the HMMWV replacement with JLTV.
DoN SIP Emissions Growth Increment

May 2011 2-2

TABLE 2-1. HMMWV REPLACEMENT WITH JLTV

Year

HMMWV 

Average 

Engine 

Size (bhp)

Joint Light 

Tactical Vehicle 

Engine Size 

(bhp)

Number of 

Vehicles 

Replaced

Annual 

Hours 

Per 

HMMWV

Emission Factor Per 

HMMWV and JLTV 

(g/bhp-hr)

Annual Emissions Change 

(tpy)

NOX VOC NOX VOC

2015 170 322 306 500 2.90 0.36 74.34 9.23

2016 170 322 306 500 2.90 0.36 74.34 9.23

2017 170 322 306 500 2.90 0.36 74.34 9.23

2018 170 322 306 500 2.90 0.36 74.34 9.23

2019 170 322 305 500 2.90 0.36 74.10 9.20

2020 170 322 305 500 2.90 0.36 74.10 9.20

Total 445.57 55.31

Notes:

g/bhp-hr: gram per break horsepower per hour

bhp: break horse power

tpy: tons per year

2.1.2 Alternative Fuels

The Secretary of the Navy has set a goal to use 50% of alternative fuels for military applications 

by 2020. To help reach this 50% benchmark, fleet vehicles may be required to use B100 (i.e., 

100% biofuel) on all fleet vehicles that currently use B20 (i.e., 20% biofuel). However, the use 

of B100 is known to decrease fuel efficiency by approximately eight percent and increase NOx

emissions by an additional eight percent as compared to B20.

To estimate this increase in NOx emissions, the 2009 actual NOx emissions from all Marine 

Corps ground support and tactical support equipment was multiplied by 16% (i.e., 8% increase 

from additional fuel and 8% additional NOx emissions. This showed that the use of B100 would 

increase the NOx emissions by approximately 16 tons. Table 2-2 presents the emissions from the 

alternative fuel replacement program.

TABLE 2-2. ALTERNATIVE FUEL REPLACEMENT PROGRAM

Year

Current NOx Emissions Fleet 

On- and Off-Road Vehicles 

using B20 (tpy)

Percent Additional Fuel 

Required for 

Switching From 

B20 To B100

Increase in NOx Emissions for 

Switching From 

B20 to B100

B20 and B100 

Net Increase in 

NOx Emissions 

(tpy)

2012 10.5 8.05% 8.00% 1.745

2013 10.5 8.05% 8.00% 1.745

2014 10.5 8.05% 8.00% 1.745

2015 10.5 8.05% 8.00% 1.745

2016 10.5 8.05% 8.00% 1.745

2017 10.5 8.05% 8.00% 1.745

2018 10.5 8.05% 8.00% 1.745
DoN SIP Emissions Growth Increment

May 2011 2-3

TABLE 2-2. ALTERNATIVE FUEL REPLACEMENT PROGRAM

Year

Current NOx Emissions Fleet 

On- and Off-Road Vehicles 

using B20 (tpy)

Percent Additional Fuel 

Required for 

Switching From 

B20 To B100

Increase in NOx Emissions for 

Switching From 

B20 to B100

B20 and B100 

Net Increase in 

NOx Emissions 

(tpy)

2019 10.5 8.05% 8.00% 1.745

2020 10.5 8.05% 8.00% 1.745

Total 94.1 8.05% 8.00% 15.705

Note:

tpy: tons per year

2.1.3 AAV Replacement/Upgrade

The Marine Corps had planned to replace the aging Amphibious Assault Vehicle (AAV) with the 

Expeditionary Fighting Vehicle (EFV). However, on 6 January 2011, Secretary of Defense 

Robert Gates announced that the EFV program will be cancelled. Replacement programs such 

as upgrading the existing AAV, creating new Amphibious Combat Vehicles (ACVs), and Marine 

Personnel Carriers (MPCs) are being considered. Since these replacement vehicles are early in 

the planning stages, vehicle-specific emissions data are not available. Therefore, it was assumed 

that the AAV replacement vehicle emissions will be equivalent to the Advanced Amphibious 

Assault Vehicle (AAAV) emission as described in the Environmental Impact Statement for the 

Advanced Amphibious Assault Vehicle Marine Corps Base Camp Pendleton, published in 2003. 

Table 2-3 presents the emissions for the AAV replacement/upgrade program.

TABLE 2-3. AAV REPLACEMENT/UPGRADE

Year

Annual Emission Change (in 

tpy)

NOx VOC

2016 5.50 0.78

2017 5.50 0.78

2018 5.50 0.78

2019 5.50 0.78

2020 5.50 0.78

Total 27.50 3.90

 Note:

 tpy: tons per year

2.1.4 Vehicle Operations Due to the Possible Relocation of OCONUS 

Operations to San Diego County

Due to the high risk of disruption of normal operations resulting from natural disasters (e.g., 

storm surges, earthquakes, volcanoes), the Operations Outside the Contiguous United States 

(OCONUS) program may be transferred to facilities located in San Diego County. To plan for 

this contingency, the Marine Corps would like to incorporate OCONUS vehicle emissions, as 

presented in the Final Environmental Impact Statement for the Guam and CNMI Military
DoN SIP Emissions Growth Increment

May 2011 2-4

Relocation, published in 2010. The EIS analysis included emissions from off-base vehicle 

operations. Based on the possible relocation, Marines and their dependents are estimated to 

increase off-base vehicle miles traveled from 3,535,224 to 4,160,544 by 2025. On-base vehicle 

commuter traffic and training operations for the additional Marines will also increase emissions. 

Table 2-4 presents the additional vehicle emissions due to the possible relocation of Marine 

Corps OCONUS operations to San Diego.

TABLE 2-4. ADDITIONAL VEHICLE EMISSIONS FROM POSSIBLE OCONUS RELOCATION

OCONUS Annual Operation Increase in Emissions Year

Annual Emissions 

Change, in tpy

NOX VOC

On Base Vehicle Travel 2015 13.1 9.9

Training Vehicle Operations 2015 0.3 0.2

Off-Base Vehicle Travel 2025 87.8 150.2

Total 101.20 160.30

 Note:

 tpy: tons per year

2.2 AIRCRAFT

Two potential projects were identified for the aircraft source category. These projects consist of 

the CH-53K upgrade to CH-53K and the aircraft emissions due to the possible relocation of 

OCONUS operations. 

2.2.1 CH-53E Helicopter Upgrade to CH-53K

Beginning in 2018, the Marine Corps will begin upgrading their fleet of CH-53E Super Stallions 

to the CH-53K. This upgrade will enable the aircraft to have a lift capacity and range twice that 

of its predecessor. The new aircraft will be equipped with three General Electric GE38-1B 

engines rated at 7,500 shaft horse power (shp). Since the CH-53K only recently passed Critical 

Design Review in August 2010, and has yet to go into test production, Aircraft Environmental 

Support Office (AESO) has not had the opportunity to test these new engines nor was able to 

make any recommendations on calculating emissions. Therefore, an assumption was made that 

the program emissions for the CH-53K upgrade will be equal to the MV-22 program, a similar 

program. Table 2-5 presents the emissions from the CH-53K Helicopter Upgrade.

TABLE 2-5. CH-53E HELICOPTER UPGRADE TO CH-53K

Year Annual Emissions Change, in tpy

NOX VOC

2022 55.8 -22.4

2023 55.8 -22.4

2024 55.8 -22.4

2025 55.8 -22.4
DoN SIP Emissions Growth Increment

May 2011 2-5

TABLE 2-5. CH-53E HELICOPTER UPGRADE TO CH-53K

Year Annual Emissions Change, in tpy

NOX VOC

Total 223.3 -89.4

 Note:

 tpy: tons per year

2.2.2 Aircraft Emissions due to the Possible Relocation of Marine Corps 

OCONUS Operations to San Diego County

As with the possible relocation of OCONUS vehicle operations due to the high risk of disruption 

of normal operations resulting from natural disasters; OCONUS aircraft operations may also be 

transferred to facilities located in San Diego County. To plan for this contingency, the Marine 

Corps would like to incorporate OCONUS aircraft emissions as presented in the Final 

Environmental Impact Statement for the Guam and CNMI Military Relocation, published in 

2010. The EIS includes aircraft emissions for additional based CH-53E, AH-1N, UH-1N, MV22 and F/A-18D squadrons. Table 2-6 presents the Marine Corps emissions for OCONUS 

aircraft.

TABLE 2-6. OCONUS AIRCRAFT EMISSIONS

Aircraft Year Annual Emissions Change, in tpy

NOX VOC

CH-53E 2015 3.5 3.1

AH-1N 2015 3.7 0.5

UH-1N 2015 0.8 0.3

MV-22 2015 12.1 0.1

F/A-18D 2015 20.1 41.8

Total 40.20 45.80

 Note:

 tpy: tons per year

2.3 UTILITIES

Utilities emissions due to the possible relocation of OCONUS operations to San Diego County 

were quantified in this emissions growth assessment. Details regarding the quantification of 

utilities emissions are provided below.

2.3.1 Utility Emissions due to the Possible Relocation of Marine Corps 

OCONUS Operations to San Diego County

As with the possible relocation of OCONUS vehicle and aircraft operations, due to the high risk 

of disruption of normal operations resulting from natural disasters, OCONUS utility emissions 
DoN SIP Emissions Growth Increment

May 2011 2-6

may also be transferred to facilities located in San Diego County. To plan for this contingency, 

the Marine Corps would like to incorporate OCONUS utility emissions as presented in the Final 

Environmental Impact Statement for the Guam and CNMI Military Relocation, published in 

2010. The EIS includes utility emissions from both solid waste and power generation. Table 

2-7 presents the Marine Corps emissions for OCONUS utilities.

TABLE 2-7. OCONUS UTILITIES EMISSIONS

OCONUS Utilities Year

Annual Emissions 

Change, in tpy

NOX VOC

Waste

2011 0.0 2.6

2012 0.0 9.0

2013 0.0 18.7

2014 0.0 0.6

2015 0.0 0.9

2016 0.0 1.1

2017 0.0 1.3

2018 0.0 1.3

2019 0.0 1.4

2020 0.0 1.5

2021 0.0 1.6

2022 0.0 1.6

2023 0.0 1.7

2024 0.0 1.7

2025 0.0 1.8

Power 2015 78.5 6.6

Total 78.5 53.4

 Note:

 tpy: tons per year
DoN SIP Emissions Growth Increment

May 2011 3-1

3. NAVY ANTICIPATED ACTIONS AND ESTIMATED EMISSIONS

As with the Marine Corps, the Navy evaluated all the potential projects subject to the EPA 

General Conformity requirements. Following a review of the planned projects, the Navy 

determined that only their ship emissions will increase in the San Diego Air Basin (SDAB). 

The following subsections provide the details regarding each ship type, assumptions needed to 

estimate emissions, emission factor references, and the total emissions estimated for the project.

3.1 LITTORAL COMBAT SHIPS (LCS-1 AND LCS-2)

The distribution of LCS-1s and LCS-2s arriving at the San Diego Air Basin (SDAB) is unknown 

at this time. Since LCS-2s have a slightly higher emission profile than the LCS-1s, it was 

conservatively assumed that all LCS in the SDAB will be LCS-2 Independence Class ships.

The LCS-2 uses two 12,200-hp MTU 20V 8000M91 engines for propulsion, two 1,125-hp MTU 

8V-396 TE54 engines for power generation, and one 1,125-hp MTU 8V-396 TE54 engine for 

bow thrust, while the ship is within zero to three nautical miles offshore. Emission factors for 

the engines were estimated, assuming each engine will operate a maximum of 40 hours per year 

within zero to three nautical miles offshore, and that one trip through San Diego Harbor, out to 

three nautical miles, will take approximately 1.35 hours. The remaining data needed to derive 

the emission factors per engine is proprietary to the Navy and cannot be released to the public. 

The Navy plans to procure a total of 16 LCS ships beginning in FY 2012 through FY 2015, at a 

rate of six the first year and five the two subsequent years. All 16 ships are expected to be 

homeported within the SDAB. Table 3-1 presents the estimated emissions for the LCS-2s.

TABLE 3-1. LCS-2 PROJECTED EMISSIONS

Year Engine 

Manufacturer

Engine 

Model HP

Total No. 

of

Engines 

Operation 

Mode

No.

of 

Ships

Emission Factor 

Per Ship (tpy)

Annual Emissions 

Change (tpy)

NOX VOC NOX VOC

2012

GE LM2500 29000 2 Idle to 9000 

rpm

6 3.20 0.10 19.17 0.61

MTU 20V8000 

M91 12200 2 Idle to 1000 

rpm

MTU 8V-396 

TE54 1125 4 Idle to 40% 

power

MTU 8V-396 

TE54 1125 1 Idle to 50% 

power
DoN SIP Emissions Growth Increment

May 2011 3-2

TABLE 3-1. LCS-2 PROJECTED EMISSIONS

Year Engine 

Manufacturer

Engine 

Model HP

Total No. 

of

Engines 

Operation 

Mode

No.

of 

Ships

Emission Factor 

Per Ship (tpy)

Annual Emissions 

Change (tpy)

NOX VOC NOX VOC

2013

GE LM2500 29000 2 Idle to 9000 

rpm

5 3.20 0.10 15.98 0.51

MTU 20V8000 

M91 12200 2 Idle to 1000 

rpm

MTU 8V-396 

TE54 1125 4 Idle to 40% 

power

MTU 8V-396 

TE54 1125 1 Idle to 50% 

power

2014

GE LM2500 29000 2 Idle to 9000 

rpm

5 3.20 0.10 15.98 0.51

MTU 20V8000 

M91 12200 2 Idle to 1000 

rpm

MTU 8V-396 

TE54 1125 4 Idle to 40% 

power

MTU 8V-396 

TE54 1125 1 Idle to 50% power

Total 16 9.59 0.31 51.12 1.63

Notes:

HP: horsepower

tpy: tons per year

3.2 GERALD R. FORD CLASS (CVN-78)

The CVN-78 Gerald R. Ford Class is to be the lead ship of her class of supercarriers. The main 

propulsion and power-generating engines of this ship are driven by two A1B nuclear reactors. 

The ship will, however, carry four 6,000-hp Colt-Pielstick 16PA6B-STC diesel emergency 

generators. Emission factors for the four Colt-Pielstick engines were estimated, assuming each 

engine will operate a maximum of seven hours per year within zero to three nautical miles 

offshore, at full load. The remaining data needed to derive the emission factors per engine is 

proprietary to the Navy and cannot be released to the public.

Construction of the CVN-78 began in August 2005 and is expected to join the Navy fleet in 

2015. The CVN-79 and CVN-80 are expected to join the fleet in 2019 and 2023, respectively. 

Table 3-2 presents the estimated emissions for the three Gerald R. Ford Class supercarriers. 
DoN SIP Emissions Growth Increment

May 2011 3-3

TABLE 3-2. CVN-78, 79, 80 PROJECTED EMISSIONS 

Year Engine 

Manufacturer

Engine 

Model HP

No. 

of 

Engines 

Operation 

Mode

No. 

of Ships

Emission 

Factor Per 

Ship 

(tpy)

Annual 

Emissions 

Change

(tpy)

NOX VOC NOX VOC

2015 Colt-Pielstick 16PA6B

-STC 6,000 4 Load 1 0.02 0.00 0.02 0.00

2019 Colt-Pielstick 16PA6B

-STC 6,000 4 Load 1 0.02 0.00 0.02 0.00

2023 Colt-Pielstick 16PA6B

-STC 6,000 4 Load 1 0.02 0.00 0.02 0.00

Total 3 0.05 0.00 0.05 0.00

 Notes:

 HPL: horsepower

 tpy: tons per year

3.3 AMPHIBIOUS TRANSPORT DOCK (LPD-17) SAN ANTONIO CLASS 

The LPD-17 uses its four 10,400-hp Colt-Pielstick PC2.5STC engines for propulsion and two 

3,350-hp Caterpillar 3608 engines for power generation while the ship is within zero to three 

nautical miles offshore. Emission factors for LPD-17 were estimated assuming the ship will 

operate a maximum of 66 hours per year within three miles offshore. The four Colt-Pielstick 

engines will operate at 25% power and the two Caterpillar engines will operate at 50% power. 

The remaining data needed to derive the emission factors per engine is proprietary to the Navy 

and cannot be released to the public.

The Navy currently operates two LPD San Antonio Class ships within the SDAB. Four more 

ships are under construction and two are expected to join the Navy San Diego fleet in 2012. Only 

the emissions for the two additional ships will be included in the emissions totals of this 

conformity evaluation. Table 3-3 presents the estimated emissions for the additional two LPD17s.

TABLE 3-3. LPD-17 PROJECTED EMISSIONS 

Year Engine 

Mfr.

Engine 

Model HP

No.

of 

Engines 

Operation 

Mode

No.

of 

Ships

Emission Factor 

Per Ship (tpy)

Annual Emissions 

Change (tpy)

NOX VOC NOX VOC

2012

Caterpillar 3608 3,350 5

2 Engines 

@ 

50% power 2

4.63 0.25 9.25 0.51

ColtPielstickPC2.5

STC 10,400 4

4 Engines 

@ 

25% power

14.56 0.83 29.12 1.67

Total 2 19.19 1.09 38.38 2.18

Note:

tpy: tons per year
DoN SIP Emissions Growth Increment

May 2011 3-4

3.4 AEGIS GUIDED-MISSILE DESTROYER (DDG-51) FLIGHT IIA ARLEIGH BURKE CLASS 

The DDG-51 Flight IIA uses four 26,250-hp General Electric (GE) LM2500 engines for 

propulsion and two 3,580-hp Allison 501-K34 engines for power generation while the ship is 

within zero to three nautical miles offshore. Emission factors for the DDG-51 were estimated 

assuming the ship will operate a maximum of 40 hours per year within zero to three nautical 

miles offshore, with the engines operating at 50% power. The remaining data needed to derive 

the emission factors per engine is proprietary to the Navy and cannot be released to the public.

The Navy plans to procure six additional DDG-51 beginning FY2012-FY2015. The emissions 

estimated for this evaluation assume that all six additional ships will be homeported within the 

SDAB. Table 3-4 presents the estimated emissions for the DDG-51 Flight IIA.

TABLE 3-4. DDG-51 FLIGHT IIA PROJECTED EMISSIONS

Year Engine 

Mfr.

Engine 

Model HP

No. 

of 

Engines

Operation 

Mode

No. 

of 

Ships

Emission Factor 

Per Ship (tpy)

Annual Emissions 

Change (tpy)

NOX VOC NOX VOC

2012

GE LM2500 26,250 4 4 Engines @ 

50% power 1

14.26 0.10 14.26 0.10

Allison 501-K34 3,580 3 2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2013

GE LM2500 26,250 4 4 Engines @ 

50% power

2

14.26 0.10 28.53 0.21

Allison 501-K34 3580 3 2 Engines @ 

50% power 2.26 0.00 4.52 0.01

2014

GE LM2500 26250 4 4 Engines @ 

50% power

2

14.26 0.10 28.53 0.21

Allison 501-K34 3580 3 2 Engines @ 

50% power 2.26 0.00 4.52 0.01

2015

GE LM2500 26250 4 4 Engines @ 

50% power

1

14.26 0.10 14.26 0.10

Allison 501-K34 3580 3 2 Engines @ 

50% power 2.26 0.00 2.26 0.00

Total 6 66.10 0.42 99.15 0.63

Note:

tpy: tons per year

3.5 AEGIS GUIDED-MISSILE DESTROYER (DDG-51) FLIGHT III

Since the Navy’s FY2011 budget proposed terminating the CG(X) program, the Navy is 

proposing to build an improved version of the DDG-51, called the Flight III version. The Navy 

plans call for procuring 24 Flight III DDG-51s between FY 2016 and FY 2031. With detailed 
DoN SIP Emissions Growth Increment

May 2011 3-5

design work scheduled to begin in FY2012 or FY2013, information regarding the type of engines 

and emissions generated from this ship are unavailable. Therefore, it is assumed that the 

emissions from this ship will be equal to that of its predecessor, the DDG-51 Flight IIA. The 

homeports of this ship have also not been identified by the Navy. Therefore, it is assumed that 

half of the 24 ships will be homeported within the SDAB and will be produced at a rate of one 

ship per year from FY2016 through FY2027. Table 3-5 presents the estimated emissions for the 

DDG-51 Flight III.

TABLE 3-5. DDG-51 FLIGHT III PROJECTED EMISSIONS

Year Engine 

Manufacturer

Engine 

Model HP No. of 

Engines 

Operation 

Mode No. of 

Ships

Emission Factor Per 

Ship (tons/year)

Annual Emissions 

Change (tpy)

NOX VOC NOX VOC

2016 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2017 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2018 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2019 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2020 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2021 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2022 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2023 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00
DoN SIP Emissions Growth Increment

May 2011 3-6

TABLE 3-5. DDG-51 FLIGHT III PROJECTED EMISSIONS

Year Engine 

Manufacturer

Engine 

Model HP No. of 

Engines 

Operation 

Mode No. of 

Ships

Emission Factor Per 

Ship (tons/year)

Annual Emissions 

Change (tpy)

NOX VOC NOX VOC

2024 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2025 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2026 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

2027 GE LM2500 26250 4

4 Engines @ 

50% power 1 14.26 0.10 14.26 0.10

Allison 501-K34 3580 3

2 Engines @ 

50% power 2.26 0.00 2.26 0.00

Total 12 198.31 1.27 198.31 1.27

Note:

tpy: tons per year 
DoN SIP Emissions Growth Increment

May 2011 4-1

4. COAST GUARD ANTICIPATED ACTIONS AND ESTIMATED EMISSIONS

The Coast Guard evaluated all the potential projects subject to the EPA General Conformity 

requirements. Following a review of the planned projects, the Coast Guard determined that only 

one ship will be introduced to the San Diego Air Basin (SDAB). 

The following subsection provides the details regarding the ship type, assumptions needed to 

estimate emissions, emission factor references, and the total emissions estimated for the project.

4.1 NATIONAL SECURITY CUTTER (NSC)

The National Security Cutter (NSC) is the flagship of the Coast Guard fleet. The ship uses a 

30,565-hp, gas-powered turbine engine for propulsion and two 9,655-hp internal combustion 

engines for power generation. At this time, four NSCs are expected to arrive, at a rate of one per 

year, beginning in 2013. Shortly after the first two arrive, two smaller existing high efficiency 

cutters (WHEC) will be relocated outside the SDAB. The net difference in emissions from the 

addition of the 4 NSCs and the relocation of the WHECs outside SDAB was included in this

evaluation. Emissions data for each ship was provided by Yvan Le of the Coast Guard and is 

presented in Table 4-1. 

TABLE 4-1. UNITED STATES COAST GUARD NATIONAL SECURITY CUTTER 

Year

No. of 

Ships

NSC (tpy) WHEC (tpy) Annual Emission Change (tpy)

NOX VOC NOX VOC NOX VOC

2013 1 8.143 -- -2.573 -- 5.57 --

2014 1 8.143 -- -2.573 -- 5.57 --

2015 1 8.143 -- -- -- 8.143 --

2016 1 8.143 -- -- -- 8.143 --

Total 32.57 -- -5.15 -- 27.43 --

Notes:

"--": value not quantified

tpy: tons per year 
DoN SIP Emissions Growth Increment

May 2011 5-1

5. CONCLUSION

In summary, the DoN and Coast Guard request that 1,616 tons per year of NOx (4.43 tons per 

day) and 356.2 tons per year of VOC (approximately 1 ton per day) be incorporated in the 

upcoming Attainment Plan for San Diego County as Military Growth Increment line items, 

expressed in tons per day, with the understanding that the DoN and Coast Guard may use the 

allowable growth as needed, at any time during the term of the Plan.
Appendix A

Emission Calculation Backup Documentation (Provided Electronically on the 

Enclosed CD)