Continuation of Board Hearing

November 15, 2007

California Environmental Protection Agency

Air Resources Board

Regulation for 

Commercial Harbor Craft 

2

Overview

♦ Proposed Harbor Craft Regulation

♦ Questions and staff analysis

♦ Summary of staff analysis
3

Proposed Commercial 

Harbor Craft Regulation Overview

4

Key Elements of Proposal

♦ Existing ferries, excursion vessels, 

tugboats, and towboats required to replace 

older engines with new certified engines

♦ New vessels and replacement engines 

must install new certified engines

♦ Monitoring, recordkeeping, and reporting 

requirements
5

October Board Hearing 

Questions and Staff Analysis

Should Proposal be 

Modified?

♦ Should replacement of Tier 0 engines be 

accelerated?

♦ Should replacement of ferry Tier 0 

engines be accelerated?

♦ How do we recognize early investment in 

Tier 1 engines?

♦ Is more flexibility needed for owners 

required to repower multiple vessels in 

single year?

6
7

Accelerate Replacement of 

Tier 0 Engines

♦ Three options:

– Accelerate replacement of Tier 0 engines in 

entire State to South Coast schedule

– Accelerate replacement of Tier 0 engines 

statewide, but on a slower schedule than 

South Coast

– Accelerate replacement of Tier 0 ferry 

engines

8

Factors Considered

♦ Tier 3 PM standard 50% cleaner than Tier 2

♦ Tier 3 NOx standard 20% cleaner than Tier 2

♦ Later model (1995-1999) Tier 0 engines are 

cleaner (25-30%) than older Tier 0

♦ Installation capacity for repower limited

♦ As schedule compacts, more owners have to 

repower multiple vessels in same year

♦ Recognition of early investment in Tier 1
9

Tier 3 Engines Emit 50% Less 

PM than Tier 2 

PM Emission Factors

0

0.1

0.2

0.3

0.4

0.5

0.6

Older Tier 0

1984-1994

Newer Tier 0

1995-1999

Tier 1 Tier 2 Tier 3

PM (g/bhp-hr)

NOx Emission Factors

0

2

4

6

8

10

12

14

Older Tier 0

1984-1994

Newer Tier 0

1995-1999

Tier 1 Tier 2 Tier 3

NOx (g/bhp-hr)

10

Tier 3 Engines Provide 

25% Greater PM Benefit and 

20% Greater NOx Benefit

Category 1 Engines 

(90% of All CHC engines)

0

0.05

0.1

0.15

0.2

0.25

0.3

0.35

0.4

-1 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24

Engine Life (years)

PM Emission Factor

1995-1999 Tier 0 emission level

Tier 2 emission level

Tier 3 emission level
11

Accelerate Statewide Schedule

♦ Tier 0 engines replaced by Tier 2 instead of 

Tier 3

– Lose 25% of Tier 3 PM reductions over engine life,

20% of Tier 3 NOx reductions

♦ Strains or exceeds repower capacity in 

several years

♦ More operators have to repower multiple 

vessels in same year

♦ Net benefit of rule is less

12

Accelerate Replacement of 

Tier 0 Ferry Engines

♦ Accelerate replacement of 1996-1999 MY ferry 

engines to 2014

♦ Still ensures newer Tier 0 engines will be replaced

with Tier 3 engines

♦ Maintains minimum 15 year life outside of South 

Coast

♦ Could accelerate reductions by 1 to 2 years with 

no loss of long term benefits

♦ Estimate <10 ferries impacted
13

Multiple Vessel Compliance in 

Single Year

♦ Current proposed regulation provides 

flexibility for vessels with compliance 

dates 2012 and beyond

– Alternative Control of Emissions

– Use funding options for early reductions

♦ However, vessels with early compliance 

dates (2009-2010) have little 

opportunity for using this flexibility

14

Potential Flexibility Option

♦ Allow phased compliance for fleets with 

multiple vessels requiring compliance in 

2009 and 2010

♦ Minimum of 25% each year if 2009 

compliance date

♦ Minimum 33% each year if 2010 

compliance date

♦ All repowers to be completed by 2013
15

Other Questions Posed by 

Board Members

♦ What funding opportunities are available 

for excursion vessels?

♦ What about small fleet economic 

impacts?

♦ Any new information on ferry 

aftertreatment technology?

♦ What is impact on greenhouse gas 

emissions?

16

Excursion Vessel Funding 

Opportunities

♦ Typical excursion vessel engine 

replacement qualifies under Moyer costeffectiveness criteria

♦ Moyer Program is over subscribed

♦ Ferry and tug engine replacements 

more cost-effective
17

Small Fleet Economics 

♦ Single vessel owners:

– 32% of ferries/excursion vessels

– 10% of tugboat vessels

– 37% of towboat vessels

♦ No clear size cutoff that would preserve 

most of the emission reduction 

♦ Excursion vessel likely to have greater 

economic impact than other vessels

♦ Estimate 5 to 10% increase in ticket price 

needed to cover the cost of compliance

18

Ferry Aftertreatment 

Technologies

♦ Staff re-evaluated available data

♦ European experience

– SCR on large ferries – ocean going vessel 

size

– SCR on one “fast ferry” – seeking additional 

information

♦ United States experience

– New York Staten Island Ferry – large ferry

– Blue and Gold Ferry Auxiliary Engines DPF

– New York private ferry fleet experience
19

Impact on Greenhouse Gas 

Emissions

♦ Small reduction due to accelerated engine 

replacement 

♦ Small reduction in CO2 due to improved 

efficiency of new engines without 

aftertreatment (~1% reduction)

– About 0.007 Million tons

20

Summary of Staff Analysis 

♦ Accelerating statewide schedule possible, 

but would strain capacity and forego 

emission reductions

♦ Opportunity to accelerate Tier 0 ferry 

engine replacement without loss of long 

term benefits

♦ More flexibility for multi-vessel compliance 

in first two years (2009 & 2010) is needed