TECHNICAL SUPPORT DOCUMENT: 

INITIAL STATEMENT OF REASONS FOR THE PROPOSED 

RULEMAKING

Regulations to Reduce Emissions from Diesel Auxiliary 

Engines on Ocean-Going Vessels while At-Berth at a 

California Port 

Stationary Source Division 

Project Assessment Branch 

October 2007 

State of California 

AIR RESOURCES BOARD 

TECHNICAL SUPPORT DOCUMENT: 

INITIAL STATEMENT OF REASONS 

FOR THE PROPOSED RULEMAKING 

Public Hearing to Consider 

ADOPTION OF PROPOSED REGULATIONS TO REDUCE EMISSIONS FROM 

DIESEL AUXILIARY ENGINES ON OCEAN-GOING VESSELS WHILE 

AT-BERTH AT A CALIFORNIA PORT 

To be considered by the Air Resources Board on December 6 and 7, 2007, at: 

Air Resources Board 

Auditorium 

9530 Telstar Avenue 

El Monte, California 91731 

Stationary Source Division

Robert Fletcher, Chief 

Robert Barham, Ph.D., Assistant Chief 

Project Assessment Branch

Michael Tollstrup, Chief 

Health and Exposure Assessment Branch (RD)

Linda Smith, Ph.D., Chief 

Technical Analysis Section

Peggy Taricco, Manager 

Health and Ecosystems Assessment Section (RD)

Hien Tran, Ph.D., Manager 

Project Assessment Section

Michael Waugh, Manager 

Regulatory Support Section (PTSD)

Todd Sax, D. Env. Manager 

This report has been prepared by the staff of the Air Resources Board. 

Publication does not signify that the contents reflect the views and policies of the 

Air Resources Board, nor does mention of trade names or commercial products 

constitute endorsement or recommendation for use. 

State of California 

AIR RESOURCES BOARD 

PROPOSED REGULATIONS TO REDUCE EMISSIONS FROM DIESEL 

AUXILIARY ENGINES ON OCEAN-GOING VESSELS WHILE AT-BERTH AT A 

CALIFORNIA 

Contributing Authors

Andrew Alexis 

Alvaro Alvarado, Ph.D. 

Raymond Asregadoo, P.E. 

Joe Calavita 

Grant Chin 

Pingkuan Di, Ph.D., P.E. 

Reza Mahdavi, Ph.D. 

Lori Miyasato, Ph.D. 

Brad Penick 

Marcelle Surovik 

Kelly Weatherford 

Legal Counsel

Floyd Vergara, P.E., Office of Legal Affairs 

Supporting Divisions

Planning and Technical Support Division (PTSD) 

Research Division (RD) 

Acknowledgements

This report was prepared with the assistance and support from the other 

divisions and offices of the Air Resources Board. In addition, we would like to 

acknowledge the assistance and cooperation that we have received from many 

individuals and organizations. 

i 

TABLE OF CONTENTS 

Contents Page

I. Introduction........................................................................... I-1 

A. Overview..........................................................................

B. Need for Proposed Regulation..............................................

C. Regulatory Authority........................................................... 

D. Summary of Proposed Regulation......................................... 

E. Public Outreach and Environmental Justice............................. 

I-1 

I-2 

I-5 

I-6 

I-7 

II. Preliminary Results of the 2006 Draft Cold-Ironing Evaluation 

Report.................................................................................. II-1 

III. General Description of Ocean-Going Ship Categories and California 

Ports.................................................................................... III-1 

A. Ship Categories................................................................. 

B. California Ports.................................................................. 

III-1 

III-8 

IV. Current Port Shore Power Activities at West Coast Ports................ 

A. Shore Power Plans at California Ports.................................... 

B. Installed Shore Power Infrastructures.....................................

C. Shore Power Equipped Ships............................................... 

D. Future Ship Retrofits and New Builds..................................... 

IV-1 

IV-1 

IV-4 

IV-10 

IV-13 

V. Emissions, Potential Exposures, and Risk.................................... V-1 

A. Estimated Hotelling Emissions from Ocean-Going Vessels......... 

B. Potential Health Impacts of Hotelling Emissions...................... 

C. Estimating Potential Cancer Impacts near California Ports.......... 

D. Estimating Potential Non-Cancer Impact of Emissions from AtBerth Ocean-Going Vessel Auxiliary Engines.........................

E. Assumptions and Limitations of Health Impacts Assessment.......

V-1 

V-5 

V-7 

V-11 

V-13 

VI. Summary of the Proposed Regulation.........................................

A. Overview of the Proposed Regulation.................................... 

B. Purpose........................................................................... 

C. Applicability...................................................................... 

D. Exemptions.......................................................................

E. Limited Auxiliary Engine Operation........................................

F. Emissions Reduction Option................................................

G. Test Methods....................................................................

H. Recordkeeping and Reporting Requirements...........................

I. Violations......................................................................... 

J. Regulatory Alternatives ......................................................

VI-1 

VI-1 

VI-2 

VI-2 

VI-2 

VI-3 

VI-6 

VI-8 

VI-8 

VI-11 

VI-11 
ii 

TABLE OF CONTENTS (cont.) 

Contents Page

VII. Feasibility of Proposed Regulatory Requirements..........................

A. Shutting Off Engines and Connecting to Grid-Supplied Shore 

Power.............................................................................. 

B. Reducing Fleet Hotelling Emissions Using Alternative Sources of 

Power and Engine Emission Control Technologies....................

C. In-Use Experience with Marine Engine Emission Control 

Strategies........................................................................

VII-1 

VII-1 

VII-5 

VII-9 

VIII. Environmental Impacts............................................................

A. Legal Requirements........................................................... 

B. Effects on Air Quality.......................................................... 

C. Health Benefit Analysis....................................................... 

D. Reasonably Foreseeable Environmental Impacts as a Result of 

Potential Compliance Methods.............................................

E. Reasonably Foreseeable Mitigation Measures......................... 

F. Reasonably Foreseeable Alternative Means of Compliance with 

the Proposed Regulation..................................................... 

VIII-1 

VIII-1 

VIII-2 

VIII-5 

VIII-12 

VIII-18 

VIII-18 

IX. Shore Power as a Greenhouse Gas Emission Reduction Measure...

A. Climate Change and California............................................ 

B. Carbon Dioxide Emission Factors.......................................... 

C. Emission Reduction Calculations..........................................

D. Conclusions......................................................................

E. Impact of Alternative Technologies on Carbon Dioxide Emissions 

Reductions....................................................................... 

IX-1 

IX-1 

IX-2 

IX-7 

IX-8 

IX-9 

X. Economic Impacts...................................................................... X-1 

A. Legal Requirements............................................................

B. Summary of the Economic Impacts........................................

C. Methodology for Estimating Costs Associated with

Implementation..................................................................

D. Potential Costs and Impacts to Businesses..............................

E. Potential Costs to Local and State Agencies............................

F. Summary of Total Capital Costs for Compliance with the 

Proposed Regulation..........................................................

G. Cost-Effectiveness............................................................. 

H. Availability of Incentive Funding............................................ 

I. Analysis of Alternative Regulatory Approaches........................

X-1 

X-2 

X-3 

X-12 

X-17 

X-19 

X-19 

X-23 

X-24 
iii 

TABLE OF CONTENTS (cont.) 

APPENDICES Page

Appendix A: Proposed Regulations...................................................

Appendix B: Emission Inventory Methodology.......................................

Appendix C: LA/LB Risk Assessment..................................................

Appendix D: Non-Cancer Health Impacts Analysis................................. 

Appendix E: Cost-Effectiveness Methodology.......................................

Appendix F: Technology Evaluation....................................................

A-1 

B-1 

C-1 

D-1 

E-1 

F-1 
iv 

TABLE OF CONTENTS (cont.)

List of Tables Page

Table I-1: Workshop/Outreach Meeting Locations and Times............... I-10 

Table III-1: Port Ranking by Ship Visits in 2006................................... 

Table III-2: Number of Terminals and Berths per Ship Category for Each 

 California Port .............................................................. 

Table III-3: Ship Visits to California Ports in 2006, by Ship Category........

III-8 

III-9 

III-10 

Table IV-1: Ships with Shore Power Capability.................................... IV-11 

Table V-1: Estimated 2006 Hotelling Emissions by Ship Category.......... 

Table V-2: Estimated 2006 Hotelling Emissions for All Ship Categories 

 by Port (Tons per Day)...................................................

Table V-3: Projected 2014 and 2020 Hotelling Emission Estimates for 

Container Ships, Passenger Ships, and Reefer Ships........... 

Table V-4: Summary of Area Impacted and Population Affected by Risk 

 Levels from Hotelling Emissions from Ocean-Going Vessel 

 Auxiliary Engines (Emission Inventory Based on 2006 Port 

 Calls)...........................................................................

V-3 

V-4 

V-5 

V-9 

Table VI-1: Percentage of Vessel Fleets Subject to the Proposed 

 Regulation (2006 Wharfinger Date)................................... 

Table VI-2: Schedule of Compliance Dates and Fleet Plans for Vessel 

 Operators for Each Regulatory Compliance Option............... 

Table VI-3: Schedule for Initial Submittal of Annual Statements of 

 Compliance for Each Compliance Option...........................

VI-6 

VI-9 

VI-10 

Table VII-1: Estimated Peak Load and Annual Power Consumption by 

 2020 for Shore Power.....................................................

Table VII-2: Emission Control Strategies for Diesel Marine Engines.........

VII-4 

VII-7 
v 

TABLE OF CONTENTS (cont.) 

List of Tables Page

Table VIII-1: Projected 2014 and 2020 Hotelling Emissions with Proposed 

Regulation Implementation (Tons per Day)......................... 

Table VIII-2: Projected Statewide Diesel PM Emissions Benefits of the 

Proposed Regulation...................................................... 

Table VIII-3: Projected Statewide NOx Emissions Benefits of the Proposed 

 Regulation................................................................... 

Table VIII-4: Emission Benefits from Implementation of the Proposed 

Regulation................................................................... 

Table VIII-5: Total Health Benefits Associated with Reductions in Hotelling 

 Emissions from Container Ships, Passenger Ships, Reefer 

 Ships (2009-2020).........................................................

Table VIII-6: Undiscounted Unit Values for Health Effects (at various 

 income levels in 2006 dollars)..........................................

VIII-3 

VIII-3 

VIII-3 

VIII-4 

VIII-9 

VIII-11 

Table IX-1: Carbon Dioxide Emission Factors for Electrical Generation by 

Utility Company (Pounds per Megawatt-Hour).....................

Table IX-2: Carbon Dioxide Emission Factors for Electrical Generation 

(Pounds per Megawatt-Hour)........................................... 

Table IX-3: Estimated Electricity Demand in 2020 for Shore Power.........

Table IX-4: Estimated Statewide Carbon Dioxide Emissions Reductions 

Using Average Portfolio Emission Factors...........................

IX-6 

IX-6 

IX-7 

IX-8 

Table X-1: Growth Factors Used in Cost-Effectiveness Analysis............

Table X-2: Major Assumptions Used In Cost-Effectiveness Analysis....... 

Table X-3: Distribution of Total Costs for Private Companies................. 

Table X-4: Some Companies Affected by the Proposed Regulation........ 

Table X-5: Summary of Annualized Costs for Public Agencies’ 

Compliance with the Proposed Regulation.......................... 

Table X-6: Total Costs for Compliance with the Proposed Regulation......

Table X-7: Summary of Cost-Effectiveness for Shore-Power Based on 

 Full Regulatory Compliance.............................................

Table X-8: Summary of Cost-Effectiveness for Shore-Power for 

 Complying With 2014 Requirement................................... 

X-9 

X-11 

X-15 

X-16 

X-18 

X-19 

X-21 

X-23 
vi 

TABLE OF CONTENTS (cont.)

List of Figures Page

Figure IV-1: 

Figure IV-2: 

Figure IV-3: 

Figure IV-4: 

Figure IV-5: 

Figure IV-6: 

Figure IV-7: 

Figure IV-8: 

Figure IV-9: 

Figure IV-10: 

Figure IV-11: 

Figure IV-12: 

Figure IV-13: 

Figure IV-14: 

Figure IV-15: 

Figure V-1: 

Figure V-2: 

Figure V-3: 

Shore Power Provided via a Barge at China Shipping..... 

Cable Connections on a China Shipping Vessel.............

Steel Gantry Festooning System at Juneau, Alaska........ 

Cables Entering a Princess Cruises Ship......................

Cables Connected to an Electrical Cabinet on a Princess 

Cruises Ship.......................................................... 

Power cables at the Princess Cruises Terminal at the 

Port of Seattle.........................................................

Shore-Side Power Connection at the USS POSCO 

Facility in Pittsburg, CA............................................. 

Shore Power Connection on the Pacific Success at the 

USS POSCO Facility................................................

Navy Ships’ Shore-Power Connection System...............

Plugs Stored at a Substation at the San Diego Naval

Station..................................................................

Shore-Power Connection on a Navy Ship.....................

Cable Reel Onboard the Ever Steady............................... 

Plugs Extended from the Ever Steady.......................... 

The NYK Atlas Docked at POLA.................................

Shore Power Connection Using a Container Box............ 

2006 NOx Emissions Distributions for All Ship 

Categories............................................................. 

2006 Diesel PM Emission Distributions for All Ship 

Categories............................................................. 

Estimated Diesel PM Cancer Risk from 2006 Hotelling

Emissions at the POLA and POLB..............................

IV-5 

IV-5 

IV-6 

IV-7 

IV-7 

IV-8 

IV-8 

IV-8 

IV-9 

IV-10 

IV-10 

IV-11 

IV-11 

IV-12 

IV-14 

V-3 

V-4 

V-8 

Figure VIII-1: 

Figure VIII-2: 

Figure VIII-3: 

Figure VIII-4: 

Figure VIII-5: 

Figure VIII-6: 

Projected Diesel PM Emissions With and Without the 

Proposed Regulation................................................

Projected NOx Emissions With and Without the 

Proposed Regulation................................................

Projected Residential Areas Impacted by Hotelling 

Emissions at POLA/POLB by 2014.............................. 

Projected Numbers of Population Affected by Hotelling 

Emissions at POLA/POLB by 2014.............................. 

Projected Residential Areas Impacted by Hotelling 

Emissions at POLA/POLB by 2020.............................. 

Projected Numbers of Population Affected by Hotelling 

Emissions at POLA/POLB by 2020.............................. 

VIII-4 

VIII-4 

VIII-6 

VIII-7 

VIII-7 

VIII-8 
I - 1 

I. INTRODUCTION 

A. Overview 

The mission of the California Air Resources Board (ARB or Board) is to protect 

public health, welfare, and ecological resources through the effective and 

efficient reduction of air pollutants, while recognizing and considering the effects 

on the economy of the State. The ARB’s vision is that all individuals in California, 

especially children and the elderly, can live, work, and play in a healthful 

environment—free from harmful exposure to air pollution. To achieve this, ARB 

has adopted numerous regulations to control emissions from many different 

sources, including diesel engines. Diesel engine exhaust is a health concern 

because it is a source of unhealthful air pollutants including gaseous and 

particulate-phase toxic air contaminants (TAC), particulate matter (PM), oxides of 

nitrogen (NOx), carbon monoxide, and hydrocarbons. 

Staff is proposing a regulation to reduce emissions of diesel particulate matter 

(PM) and nitrogen oxides (NOx) from diesel-fueled auxiliary engines used aboard 

ocean-going ships while docked at a California port. Auxiliary engines are run to 

power lighting, ventilation, pumps, communication, and other onboard equipment 

while a ship is docked at a berth, or “hotelled.” The proposed regulation would 

require operators of vessels meeting specified criteria to turn off their auxiliary 

engines for most of their stay in port. We anticipate that such vessels would then 

receive their electrical power from shore, or would use an alternative, but equally 

effective, means of emissions reductions. This process of shutting off engines 

and connecting to power on shore is sometimes referred to as “shore power” or 

“cold-ironing.” The term “cold-ironing” is derived from the metal aboard the ships 

“going cold” when combustion equipment is shut down. 

Staff also estimates the reduction of carbon dioxide (CO2)—a greenhouse gas 

(GHG) responsible for much of the global climate change—that the proposed 

regulation is expected to achieve. 

This technical support document (TSD) is an addendum to the Staff Report: 

Initial Statement of Reasons (Staff Report) and provides more detailed 

information supporting the development of the proposed regulatory action. As 

noted in the Staff Report, the proposal consists of two essentially identical 

regulations, one a regulation developed pursuant to ARB’s authority under Health 

and Safety Code (HSC) sections 43013(b) and 43018, and the other an airborne 

toxic control measure (ATCM) pursuant to HSC section 39666. Because of this, 

both regulations will be collectively referred to hereinafter as the “regulation” or 

“proposed regulation.” 
I - 2 

The TSD includes the following chapters: 

• Need for the regulation, legal authority, and public outreach (Chapter I); 

• Preliminary Results of ARB’s Draft 2006 Cold-Ironing Evaluation Report 

(Chapter II); 

• Discussion of ocean-going ship categories and California ports (Chapter III); 

• Discussion of current shore power activities (Chapter IV); 

• Emissions from auxiliary engines on ships idling at berth and associated 

potential health risks (Chapter V); 

• Summary of the proposed regulation and a discuss of the regulatory 

alternatives that were considered (Chapter VI); 

• Discussion of the feasibility of the regulatory requirements and alternative 

control technologies for marine auxiliary engines (Chapter VII); 

• Environmental impacts of the proposed regulation (Chapter VIII); 

• Discussion of Shore Power as a greenhouse gas emission reduction measure 

(Chapter IX): and 

• Economic impacts of the proposed regulation (Chapter X) 

The text of the proposed regulation and other supporting information are found in 

the Appendices. 

B. Need for Proposed Regulation 

The proposed regulation to reduce emissions from hotelling vessels in 

California’s ports will help meet several health-related goals of the Board, 

including reducing diesel PM, reducing emissions from goods-movement 

activities, achieving and maintaining ambient air quality standards, and reducing 

GHG emissions to mitigate the effects of global climate change. 

 Control of Criteria Air Pollutants

Health and Safety Code (HSC) sections 43013 and 43018 direct ARB to adopt 

standards and regulations that the Board has found to be necessary, costeffective, and technologically feasible for various mobile source categories, 

including off-road diesel engines and equipment such as marine vessels, through 

the setting of emission control requirements. Specifically, HSC section 43013(b) 

directs ARB to adopt such standards and regulations for marine vessels to the 

extent permitted by federal law. 

 Control of Toxic Air Contaminants

In 1998, the Board identified diesel PM as a TAC with no Board-specified 

threshold exposure level, pursuant to Health and Safety Code (HSC) sections 

39650 through 39675. A needs assessment for diesel PM was conducted 

between 1998 and 2000 pursuant to HSC sections 39658, 39665, and 39666. 

This resulted in ARB staff developing and the Board approving the Risk 
I - 3 

Reduction Plan to Reduce Particulate Matter Emissions from Diesel-Fueled 

Engines and Vehicles (Diesel RRP) in 2000. 

The Diesel RRP presented information on the available options for reducing 

diesel PM and recommended regulations to achieve these reductions. The 

Diesel RRP’s scope was broad, addressing all categories of mobile and 

stationary engines. It included control measures for all off-road diesel sources, 

such as those covered by the proposed regulation. The ultimate goal of the 

Diesel RRP is to reduce, by 2020, California’s diesel PM emissions and 

associated cancer risks by 85 percent from the 2000 levels. The proposed 

regulation would reduce diesel PM emissions and the local health impacts from 

ships docked in California’s ports and would assist the Board with meeting the 

2020 Diesel RRP goal. 

 Control of Emissions from Goods Movement-related Activities

In April 2006, the Board approved the Emission Reduction Plan for the Ports and 

Goods Movement in California (GMERP). The GMERP identifies strategies for 

reducing emissions created from the movement of goods through California ports 

and into other regions of the State. The GMERP is part of the broader Goods 

Movement Action Plan (GMAP) being jointly carried out by the California 

Environmental Protection Agency and the Business, Transportation, and Housing 

Agency. Phase I of the GMAP was released in September 2005 and highlighted 

the air pollution impacts of goods movement and the urgent need to mitigate 

localized health risk in affected communities. The final GMAP was released in 

January 2007 and includes a framework that identifies the key contributors to 

goods movement-related emissions. 

The GMERP identifies numerous strategies for reducing emissions from all 

significant emission sources involved in goods movement, including ocean-going 

vessels, harbor craft, cargo handling equipment, locomotives, and trucks. The 

GMERP identifies several strategies for reducing emissions from ocean-going 

vessels. Specific to hotelling emissions, the GMERP establishes a goal of 

utilizing shore power for 20 percent of the ship visits to California ports by 2010, 

60 percent of visits by 2015, and 80 percent of visits by 2020. The proposed 

regulation would represent a significant first step toward satisfying the GMERP 

goals by requiring specific vessel types to shut down their engines while docked. 

Shutting an engine down is a necessary condition for using shore power; the 

proposed regulation makes it possible for 50 percent of a fleet’s visits to a port to 

be electrified by 2014, which rises to 80 percent of visits by 2020. Furthermore, 

emission reductions would begin in 2010 for vessel owners or operators 

choosing an alternative emission control technology to reduce their hotelling 

emissions.
I - 4 

 Attainment of Ambient Air Quality Standards 

The federal Clean Air Act (CAA) requires the United States Environmental 

Protection Agency (U.S. EPA) to establish National Ambient Air Quality 

Standards (national standards) for pollutants considered harmful to public health, 

including fine particulate matter (PM2.5) and ozone. Set to protect public health, 

the national standards are adopted based on a review of health studies by 

experts and a public process. The South Coast Air Basin (Air Basin), which is 

home to the two largest ports in California, the Ports of Los Angeles and Long 

Beach, exceeds the national standards for both ozone and PM2.5. Consequently, 

a State Implementation Plan (SIP) is required for the Air Basin that outlines how 

and when the region will attain the national standards. The U.S. EPA requires 

the Air Basin to meet the PM2.5 standards by 2015, but the emission reductions 

must be in place by 2014. 

Significant reductions of NOx are crucial to meet the federal standards. For 

example, at this time, the strategy to achieve attainment of the PM2.5 standards in 

the South Coast Air Basin includes staff estimates that a 55 percent reduction in 

NOx emissions from 2006 levels (i.e., a total reduction of hundreds of tons per 

day) and a 15 percent reduction in direct PM2.5 emissions from 2006 baseline 

levels will be necessary for attainment of the PM2.5 standards in the South Coast 

Air Basin. The proposed regulation would reduce hotelling NOx emissions from 

container ships, passenger ships, and refrigerated cargo ships by 50 percent 

relative to levels expected to be emitted in 2014 and nearly 75 percent relative to 

levels expected to be emitted in 2020. Consequently, the emission reductions 

from the proposed regulation would play an essential role in assisting the South 

Coast Air Basin with meeting its 2014 PM2.5 deadline as well as its future ozone 

deadlines. 

The federal Clean Air Act permits states to adopt more stringent air quality 

standards, and California has set standards for particulate matter and ozone that 

are more protective of public health than respective federal standards. The Bay 

Area, South Coast, and San Diego areas are nonattainment for the State 

standards for ozone and PM2.5. Health and Safety Code (HSC) section 40911 

requires the local air districts to submit plans to the Board for attaining the State 

ambient air quality standards, and HSC section 40924 requires triennial updates 

of those plans. The NOx and PM2.5 emission reductions from the proposed 

regulation would also assist the local air districts in achieving attainment of the 

State ambient air quality standards. 

 The California Global Warming Solutions Act of 2006

In June 2005, Governor Arnold Schwarzenegger signed Executive Order S-3-05, 

which established targets for reducing greenhouse gas (GHG) emissions in 

California: roll back GHG emissions to 2000 levels by 2010, to 1990 levels by 

2020, and finally to 80 percent below 1990 levels by 2050. In 2006, the 
I - 5 

Governor signed Assembly Bill 32 (AB 32) (Stats. 2006, ch. 488), which 

established the 2020 GHG emission reduction goal in State law (HSC § 38500 et 

seq.) and made the ARB responsible for monitoring and reducing GHG 

emissions. 

AB 32 requires the Board, by January 1, 2009, to design and adopt an overall 

plan to reduce GHG emissions to 1990 levels by 2020. The Board has until 

January 1, 2011, to adopt the necessary regulations to implement that plan. 

Implementation begins no later than January 1, 2012, and the emission reduction 

target must be fully achieved by January 1, 2020. AB 32 also required the Board 

to identify a list of discrete early action GHG reduction measures by June 30, 

2007. AB 32 defines discrete early action measures as regulations that are to be 

adopted by the Board and be enforceable by January 1, 2010. 

In April 2007, ARB staff released a report identifying 37 proposed early action 

items the Board could undertake to mitigate GHG emissions in California. Port 

electrification was identified as a GHG emission reduction measure in this report. 

In September 2007, ARB staff recommended reclassifying port electrification 

(now called Green Ports) from an early action measure to a discrete early action 

measure. Staff’s recommended reclassifications will be considered by the Board 

at its October 2007 hearing. 

The proposed regulation, while primarily aimed at reducing diesel PM and NOx 

emissions, will also reduce CO2 emissions as a co-benefit of requiring cleaner 

electrical generation for ocean-going vessels that “plug in” while docked. These 

CO2 emission reductions will help California meet its 2020 greenhouse gas 

emission reduction goal. 

C. Regulatory Authority 

Under State and federal law, ARB can regulate both criteria pollutant and toxic 

diesel PM emissions from marine vessels. The ARB has authority under 

California law to adopt the proposed regulations. H&SC sections 43013(b) and 

43018 provide broad authority for ARB to adopt emission standards and other 

regulations to reduce emissions from new and in-use vehicular, nonvehicular and 

other mobile sources. Under H&SC sections 43013(b) and 43018, ARB is 

directly authorized to adopt emission standards and other regulations for marine 

vessels, as expeditiously as possible and to the extent permitted by federal law, 

to meet State standards. The ARB is further mandated by California law under 

H&SC section 39666 to adopt Air Toxic Control Measures (ATCMs) for new and 

in-use nonvehicular sources, including marine vessels such as ocean-going 

vessels, for identified TACs such as diesel PM. 

In addition, H&SC section 38500 requires the ARB to adopt rules and regulations 

that are technologically feasible and cost-effective to achieve the GHG emissions 

reduction goals of the California Global Warming Solutions Act of 2006 (AB 32). 
I - 6 

D. Summary of Proposed Regulation 

The proposed regulation would reduce hotelling emissions from diesel-fueled 

auxiliary engines on at-berth ocean-going vessels. The regulation would apply to 

any person who owns, operates, charters, rents, or leases any container ship, 

passenger ship, or refrigerated cargo ship that visits a California port, or any 

person who owns or operates a port or terminal located at a port where 

container, passenger, or refrigerated cargo(reefer) ships visit. These ports 

would include Los Angeles, Long Beach, Oakland, San Diego, San Francisco, 

and Hueneme. 

 

The proposed regulation allows for two main options to reduce hotelling 

emissions. First, ship operators can shut down their auxiliary engines while in 

port, except for three or five permissible hours of total operation per visit (“limited 

engine use” option). Alternatively, operators can implement a fleet-based option 

to reduce the emissions from the auxiliary engines in the fleet by specified 

percentages while docked (“emissions reduction option”). 

The “limited engine use” option requires that the operators of container ships, 

passenger ships, and reefers that visit California ports shut down their auxiliary 

engines for most of their stay while hotelling. Auxiliary engines would be allowed 

to run for three or five hours per visit. Specifically, these auxiliary engines must 

be shut down for at least 50 percent of a fleet’s total visits to a California port in 

2014 and at least 80 percent of the fleet’s total visits to a port in 2020. While 

auxiliary engines are shut down, the ship’s onboard electrical needs must be 

satisfied by some other source of power, presumably the region’s electrical grid. 

An alternative compliance option is the “emissions reduction option,” in which 

ship operators would be required to reduce their fleet’s auxiliary engine 

emissions at a port by specific percentages and by specific dates. The specified 

percent reductions apply to the fleet’s engines, rather than to individual engines. 

The compliance dates for this option vary based on the emission reduction 

technique applied to the fleets. 

The emission reduction techniques that could be applied to a fleet include: 

1) using selected vessels for grid-supplied power based on potential auxiliary 

engine emission reductions rather than fleet visit percentages; 2) using 

distributed generation equipment to provide power to a vessel; 3) using 

alternative emission controls onboard a vessel or located adjacent to the vessel; 

and 4) using a combination of these techniques. 
I - 7 

E. Public Outreach and Environmental Justice 

 Environmental Justice

ARB is committed to integrating environmental justice in all of its activities. On 

December 13, 2001, the Board approved Environmental Justice Policies and 

Actions, which formally established a framework for incorporating environmental 

justice into the ARB's programs, consistent with the directives of California State 

law. Environmental Justice is defined as the fair treatment of people of all races, 

cultures, and incomes with respect to the development, adoption, 

implementation, and enforcement of environmental laws, regulations, and 

policies. The environmental justice policies apply to all communities in California, 

but recognize that environmental justice issues have been raised more in the 

context of low-income and minority communities. 

The environmental justice policies are intended to promote the fair treatment of 

all Californians and cover the full spectrum of ARB activities. Underlying these 

policies is a recognition that we need to engage community members in a 

meaningful way as we carry out our activities. People should have the best 

possible information about the air they breathe and what is being done to reduce 

unhealthful air pollution in their communities. The ARB recognizes its obligation 

to work closely with all stakeholders—communities, environmental and public 

health organizations, industry, business owners, other agencies, and all other 

interested parties—to successfully implement these Policies.

The proposed regulation is consistent with the environmental justice policy to 

reduce health risks in all communities, including those with low-income and 

minority populations. The regulation will achieve the most significant emission 

reductions in communities adjacent to the ports of Los Angeles, Long Beach, and 

Oakland, where the greatest shipping activity occurs. It would also result in 

emissions and health risk reductions in communities surrounding the ports of 

Hueneme, San Diego, and San Francisco. 

During the regulatory development process, ARB staff searched for opportunities 

to present information about the proposed regulation at places and times 

convenient to stakeholders to encourage public participation. These efforts 

involved conducting meetings during evening hours and at California ports. In 

addition, ARB staff attended community meetings in Los Angeles and Oakland to 

educate and receive input from local community members during the 

development of the regulation. 

 Outreach Efforts

ARB’s outreach efforts for the proposed regulation began during the 

development of its draft cold-ironing feasibility report (Evaluation Report). This 

report is discussed in more detail in Chapter II. ARB staff first discussed a plan 
I - 8 

for analyzing the cost effectiveness of cold-ironing ocean-going vessels at a 

public consultation meeting on November 9, 2004. 

Staff discussed preliminary concepts for the analysis at the May 14, 2005, 

Maritime Workgroup Meeting. This workgroup was comprised of ARB staff, local 

air district staff, representatives of the ports, shipping companies, environmental 

groups, and other interested members of the public.

During the Evaluation Report’s development, staff visited four ports in California: 

Los Angeles, Long Beach, Oakland, and San Diego. Staff also visited three 

cold-ironing applications in the State: a ship utilizing shore power at the 

USS POSCO steel plant in Pittsburg, a ship utilizing shore power at the China 

Shipping Terminal at the Port of Los Angeles, and a Navy ship cold-ironing at the 

Naval Station in San Diego. During these visits, staff observed the configuration 

of the ports, terminals, and berths and gained an understanding of the logistics 

involved in bringing power to the terminals and individual berths. 

Staff also held conference calls or met with shipping companies, utility 

companies, environmental groups, and other organizations interested in 

cold-ironing applications. These meetings gave staff the opportunity to hear from 

proponents of cold-ironing as well as hear the concerns from those entities that 

would be involved with bringing power to the terminals and retrofitting ships for 

cold-ironing. Staff also held conference calls with South Coast Air Quality 

Management District (SCAQMD) staff to obtain their input during the 

development of the Evaluation Report. 

ARB staff solicited public input on the Evaluation Report when it was released in 

March 2006 and considered the comments received when they began 

developing draft concepts for a shore power regulation. Staff discussed a 

regulatory approach to controlling hotelling emissions at the September 12, 2006, 

Maritime Working Group Meeting. 

Staff also coordinated with the Ports of Los Angeles and Long Beach in the 

development of the San Pedro Bay Ports Clean Air Action Plan (CAAP), which 

was released in November 2006. The CAAP identifies shore power as a 

measure to control hotelling emissions and identifies specific terminals and 

berths that will be equipped with shore power capability and the expected 

completion dates for these projects. ARB staff considered the CAAP’s shore 

power requirements as we began our development of the proposed regulation 

with a goal of developing a proposed measure that would be consistent with the 

CAAP and complementary to the ports’ ongoing emissions reduction efforts. 

ARB staff and interested parties formed a workgroup in early 2007 to assist staff 

with developing a shore power regulation. Many of the stakeholders that 

assisted ARB staff with developing the Evaluation Report were also members of 

the workgroup. ARB staff created a shore power electronic list server and 
I - 9 

webpage to notify interested parties of the workgroups and to post drafts of the 

regulation before they were discussed at the meetings. Over 2000 individuals or 

companies have subscribed to the shore power list server. 

Five shore power workgroup meetings were held between January and August 

2007. The majority of these meetings were accessible via webcast and 

teleconference in order to accommodate participants who were unable to attend 

in person. At the end of that process, ARB staff decided that it was appropriate 

to transition from the workgroup process to a more formal rulemaking process. 

Subsequently, staff held four public workshops in September 2007 to discuss the 

draft proposed regulation. Two of these workshops were evening meetings held 

in community centers near ports, where staff could seek input from those 

communities most impacted by hotelling emissions. A listing of ARB’s public 

workgroup meetings, workshops, and community outreach meetings held during 

the development of the proposed regulation is presented in Table I-1. 
I - 10 

Table I-1: Workshop/Outreach Meeting Locations and Times 

Date Meeting Type Location 

November 9, 2004 Public Workshop Conference Call Cal/EPA Building, 

Sacramento 

May 14, 2005 Maritime AQ Technical 

Working Group 

Toll-Free 

Conference Call 

Cal/EPA Building, 

Sacramento 

September 12, 2006 Maritime AQ Technical 

Working Group 

Toll-Free 

Conference Call 

Cal/EPA Building, 

Sacramento 

January 11, 2007 Public Workgroup Webcast/Toll-Free 

Conference Call 

Cal/EPA Building, 

Sacramento 

March 20, 2007 Public Workgroup Toll-Free 

Conference Call Port of Long Beach 

June 1, 2007 Public Workgroup Webcast/Toll-Free 

Conference Call 

Cal/EPA Building, 

Sacramento 

July 9, 2007 Community Outreach Conference Call 

Presentation Q&A

POLA PCAC AQS, 

Los Angeles 

July 12, 2007 Public Workgroup Toll-Free 

Conference Call 

Cal/EPA Building, 

Sacramento 

August 1, 2007 Community Outreach Meeting 

Seaport Operations 

and Air Quality 

community workshop 

Port of Oakland 

August 28, 2007 Public Workgroup Webcast/Toll-Free 

Conference Call 

Cal/EPA Building, 

Sacramento 

September 24, 2007 Public Workshop Webcast/Toll-Free 

Conference Call 

Cal/EPA Building, 

Sacramento 

September 25, 2007 Public Workshop Meeting Port of Los Angeles 

September 25, 2007

Public 

Workshop/Community 

Outreach 

Meeting Wilmington Senior 

Center 

September 27, 2007

Public 

Workshop/Community 

Outreach 

Meeting West Oakland Senior 

Center 

In addition to the workgroup and workshop meetings, staff’s outreach efforts also 

included hundreds of personal contacts via telephone and electronic mail; 

numerous individual meetings with interested parties, including port 

representatives, environmental groups, utility representatives, and shipping 

representatives; and informational visits to ports. Staff visited the Port of 

Hueneme in early 2007, where staff had the opportunity to observe refrigerated 
I - 11 

cargo ships carrying break-bulk products and discuss regulation development 

with port staff. ARB staff also toured a containerized refrigerated cargo ship at 

the Port of San Diego. At the Port of Oakland, ARB staff toured a container ship 

that was equipped with shore power capability and observed a demonstration of 

a portable distributed generation power source for powering container ships while 

in port. 
I - 12 

REFERENCES:

California Air Resources Board. Emission Reduction Plan for Ports and Goods 

Movement in California; April 2006. 

http://www.arb.ca.gov/planning/gmerp/march21plan/march22_plan.pdf

California Air Resources Board. Evaluation of Cold-Ironing Ocean-Going 

Vessels at California Ports; March 2006. 

http://www.arb.ca.gov/ports/shorepower/report.pdf 

California Air Resources Board. Expanded List of Early Action Measures to 

Reduce Greenhouse Gas Emissions in California Recommended for Board 

Consideration, October 2007. 

California Air Resources Board. Policies and Actions for Environmental Justice; 

December 2001. 

California Air Resources Board. Proposed Early Actions to Mitigate Climate 

Change in California, April 2007. 

California Air Resources Board. Risk Reduction Plan to Reduce Particulate 

Matter Emissions from Diesel-Fueled Engines and Vehicles; October 2000. 

http://www.arb.ca.gov/diesel/documents/rrpapp.htm

Port of Los Angeles and Port of Long Beach. San Pedro Bay Ports Clean Air 

Action Plan; November 2006. 

http://www.portoflosangeles.org/DOC/CAAP_Tech_Report_Final.pdf and/or 

http://www.polb.com/civica/filebank/blobdload.asp?BlobID=3451 

Schwarzenegger, Arnold, “Executive Order S-3-05.” June 1, 2005. 
II - 1 

II. PRELIMINARY RESULTS OF THE 2006 DRAFT COLD-IRONING 

EVALUATION REPORT 

Staff is proposing to initially regulate hotelling emissions from three out of the six 

categories of ocean-going vessels that visit California ports and to address the 

hotelling emissions from the other three categories at a later date. This 

bifurcation was based on information presented in an earlier ARB report, 

Evaluation of Cold-ironing Ocean-Going Vessels at California Ports (Evaluation 

Report), which was released as a draft in March 2006. The purpose of the 

Evaluation Report was to present an analysis of the feasibility and 

cost-effectiveness of requiring ships to shut off auxiliary engines while in port and 

connect to power provided at the berth as a potential emission control measure. 

While not finalized, the results of the Evaluation Report nevertheless formed a 

good basis for ARB’s further development of the proposed regulation. 

ARB staff solicited comments on the draft Evaluation Report when it was 

released. A number of comments on the draft report were received, but instead 

of incorporating the comments and suggested changes into a final revised report, 

staff decided to move forward with developing a shore power regulation while 

considering the comments received. 

This chapter will discuss the draft Evaluation Report. The results of the 

Evaluation Report formed a basis for ARB’s development of the proposed 

regulation; therefore, a discussion of the preliminary results of the draft report is 

essential to understanding the development of the proposed regulation. 

In the Evaluation Report, ARB staff calculated, for screening purposes, the costeffectiveness of shore power as an emission reduction strategy using three major 

sets of variables: ship categories, ship power loads, and pollutants reduced. 

 Ship Categories

To begin the analysis, ARB staff divided the ocean-going vessels visiting 

California ports in 2004 into six categories: container ships, passenger ships, 

refrigerated cargo ships, tankers, bulk/cargo ships, and vehicle carriers. For 

each ship category, the cost-effectiveness analysis consisted of two parts: an 

analysis where both the shore-side infrastructure and ship retrofits are 

considered, and an analysis considering the incremental cost for cold-ironing a 

ship if the ports have already installed the necessary shore-side infrastructure. 

For the infrastructure/ship analysis, staff analyzed the following three scenarios: 

1) all ships being cold-ironed at all California ports; 2) cold-ironing ships that 

made at least three visits per year to a California port; 3) and cold-ironing ships 

that made at least six visits per year to a California port. In addition, the 

cost-effectiveness scenarios considered whether the necessary electrical 

transformers are constructed at the port (shore-side) or on the ships (ship-side). 
II - 2 

 Ship Power Loads 

The power load of the ships had to be considered as well when analyzing the 

cost-effectiveness. Ocean-going vessels typically fall into two categories: lowvoltage and high-voltage. Except for passenger ships, high-voltage is nominally 

6.6 kilovolts (kV), and low-voltage is around 440 volts (V). For passenger ships, 

high-voltage is 11.0 kV, while low-voltage is 6.6 kV. Due to these varying power 

requirements, transformers are needed to supply the proper voltage to nearly all 

of the ships. These transformers either have to be located within the port 

infrastructure or on the ships. ARB looked at both of these scenarios. 

 Pollutants Reduced

ARB staff calculated cost effectiveness using three approaches for air pollutants 

reduced: (1) “all pollutants” emissions reductions (NOx, PM, volatile organic 

compounds [VOC], and oxides of sulfur [SOx]); (2) NOx emissions reductions 

only; and (3) PM emissions reductions only. 

The all-pollutants case recognizes that cold-ironing reduces multiple pollutants. 

For the all-pollutants case, the cost effectiveness was determined by dividing the 

total annualized costs for cold-ironing by the total annual emissions reduced for 

the four major pollutants (NOx, PM, VOC, and SOx). 

The NOx-only case allowed for comparison to other NOx measures adopted in 

the State. For the NOx-only case, the cost effectiveness was determined by 

dividing the total annualized cold-ironing costs by the annual NOx emissions 

reduced. 

The diesel-PM-only case recognizes the importance of reducing diesel PM in 

California. Overall, diesel engine emissions are responsible for the majority of 

California's potential airborne cancer risk from combustion sources. For the 

diesel-PM-only case, the cost effectiveness was determined by dividing the total 

annualized cold-ironing costs by the annual diesel PM emissions reduced. 

At the time the Evaluation Report was developed, most ocean-going vessels 

were using residual fuel with their auxiliary engines. However, in December 

2005, the Board adopted an Ocean-Going Vessel Auxiliary Engine Fuel 

Regulation (see title 13, California Code of Regulations (CCR), section 2299.1 

and title 17, CCR, section 93118). That regulation requires that most of these 

ships use cleaner distillate fuel when in California waters beginning in January 

2007. Because of this requirement, ARB staff calculated cost-effectiveness 

values based on the use of distillate fuel only. 
II - 3 

 Conclusions 

Based on the screening analysis noted above, the Evaluation Report concluded 

that the most attractive vessel candidates for cold-ironing at this time are 

container ships, refrigerated cargo (reefer) ships, and passenger ships, and the 

most likely locations for cold-ironing in California are the Ports of Los Angeles, 

Long Beach, Oakland, San Diego, San Francisco, and Hueneme. The most 

attractive ship candidates were found to be those ships that make frequent visits 

to a California port, spend a sufficient number of hours at berth, and have an 

ample power demand while hotelled. These findings formed the foundation on 

which the proposed rulemaking was based. 

Of the three remaining types of vessels that visit California, the Evaluation Report 

showed that it was not as cost-effective at this time to cold-iron bulk and general 

cargo ships and vehicle carriers, relative to container ships, passenger ships and 

reefers, because the former categories generally have a low number of repeat 

visits to any single port and lower power loads. Further, crude-oil tankers were 

found to have higher average cost-effectiveness values because there are only a 

handful of diesel-electric tankers that visit California, and only two are expected 

to visit frequently. Indeed, most crude-oil tankers use steam turbines to drive 

their cargo pumps. These cargo pumps represent the majority of the power 

needed by tankers when they are berthed. The rest of the ship’s power needs 

are modest. Finally, product tankers make few visits to California ports, and their 

berthing times are short, making them a much less attractive candidate for coldironing. 

The proposed regulation specifically addresses hotelling emission reduction 

requirements for categories of ships that were found at this time to be attractive 

candidates for shore power in the Evaluation Report—container ships, passenger 

ships, reefer ships— and the California ports where these ships frequently visit. 

As noted earlier, staff is proposing to develop separate requirements for other 

ship categories that were not considered to be good candidates at this time for 

shore power -- bulk ships, tankers, and vehicle carriers—at a later date. Staff 

anticipates presenting proposed hotelling emission reduction requirements for 

these other ships to the Board in late 2008. We expect that at-berth emissions 

from tugboats operating at California ports will also be addressed at that time. 
II - 4 

REFERENCES:

California Air Resources Board. Evaluation of Cold-Ironing Ocean-Going 

Vessels at California Ports; March 2006. 

http://www.arb.ca.gov/ports/shorepower/report.pdf
III - 1 

III. GENERAL DESCRIPTION OF OCEAN-GOING SHIP CATEGORIES 

AND CALIFORNIA PORTS 

In this chapter, staff will categorize each ocean-going ship category and briefly 

describe the distinguishing features of each ship type. Images of each ship type 

are included for ease of identification. The ports of California will also be 

discussed. Although not all ship categories and California ports will be affected 

by the proposed regulation, staff wanted to provide an overall perspective of 

oceangoing ship activity in California. 

A. Ship Categories 

Container Ships

Container ships are designed to carry cargo stored in standardized containers. 

Container ships can also carry some refrigerated containers, with the ship’s 

electrical power plant providing the necessary electricity for these containers. 

The size of these ships is based upon how many twenty-foot-equivalent units 

(TEUs) can be carried by the ship. The dimensions of a TEU are 20’ x 8’ x 8.5’ 

and a typical container is 40 feet long, or two TEUs. A 40-foot container fits on 

the back of an 18-wheeler, so it is common to see these containers being 

transported on the highway. Ships visiting California typically have a carrying 

capacity ranging between 1,000 to over 8,000 TEUs, with the “average” ship 

being able to carry nearly 4,000 TEUs. In general, container ships have 

increased in size over the last few years, and this trend is expected to continue in 

the future. 

Typically, container ships are propelled by a large low-speed diesel engine and 

three to five auxiliary diesel engines provide electrical power when the ship is 

moving. In some cases, a shaft generator provides the electrical power. The 

auxiliary engines range in size from 500 kW to 3 MW each, with the largest 
III - 2 

engines used on the largest container ships. In port, the electrical power is 

provided by the auxiliary engines. 

Several older ships use steam-based power plants to both propel the ship and 

provide electrical power. Unlike diesel engines that can be shut down very 

quickly, steam-based power plants take several hours to shutdown and to restart. 

For the short duration that a ship is in port, it would be impractical to shut down 

the ship’s steam-based power plant. Consequently, the steam-based power 

plant would continue to operate and emit air pollutants even if the ship is 

cold-ironed. Cold-ironing these types of ships would result in minimal emission 

reductions. 

In 2006, 585 container ships visited California ports and accounted for nearly 

46 percent of the total ship visits to California. That is, container ships visited 

California ports as much as the combined visits of other ship categories, with no 

other ship category representing more than 20 percent of the total ship visits. If 

significant emission reductions are to be achieved from cold-ironing, container 

ships must represent a significant portion of that effort. 

Container ships often make their first West Coast call at the Port of Los Angeles 

or the Port of Long Beach (POLA/POLB). Many will then stop at the Port of 

Oakland. About 60 percent of the ships that visit POLA/POLB also visit Oakland. 

Annually, POLA/POLB receive more container ship visits than Oakland, and the 

ships tend to stay much longer, unloading more containers. In 2006, 

POLA/POLB processed over one and a half times the amount of container traffic 

than Oakland: 12.9 million loaded TEUs versus 8.1 million TEUs. 

The most important shipping routes for container ships visiting California ports 

are the routes from Asia to North America. Ships that frequent this route average 

eight to nine visits annually to the ports in the Los Angeles area and six visits 

annually to the Port of Oakland. Many ships also bring goods from South and 

Central America. Another important shipping route is between Hawaii and 

California ports. Fewer ships travel these routes but, because of the shorter 

distance, call more often at California ports. 

Power needs for a container ship varies between 1 MW to 4 MW, with the high 

end of the range based upon a ship carrying a substantial number of refrigerated 

containers. Hotelling times for container ships vary between 20 to 200 hours per 

visit (average hotelling time is 55 hours per visit) to ports in the Los Angeles area 

and 10 to 50 hours per visit (average hotelling time is 21 hours per visit) to the 

Port of Oakland. 
III - 3 

Passenger Ships

The passenger-ship category is one of the smallest, with only 52 ships visiting 

California in 2006. The vast majority of the passenger ships visit the ports of San 

Francisco, Los Angeles, Long Beach, and San Diego. A few passenger ships 

visit Monterey and Catalina, but they moor offshore and do not actually berth. 

Pleasure cruises have become increasingly popular and significant growth in the 

cruise-line industry is expected to continue. As with other types of ocean-going 

vessels, the physical size and carrying capacity of passenger ships have 

increased steadily over the years.

Unlike most ship categories, passenger ships are diesel-electric. Several diesel 

engines coupled to generators typically provide propulsion. These generators 

produce electrical power that drives electric motors coupled to the vessel’s 

propellers. This arrangement provides the option to run the vessel at a slower 

speed, while operating fewer engines at their peak efficiency, as opposed to a 

single engine at low, relatively inefficient loads. The same engines that are used 

for propulsion are also used to generate auxiliary power onboard the vessel for 

lights, refrigeration, etc.

Passenger ships typically dock in the morning and set sail in the evening. The 

average time in dock ranges from nine to eleven hours. Passenger ships have 

the highest power consumption while hotelling of any vessel type: five to eleven 

megawatts. 
III - 4 

Refrigerated Cargo Ships (Reefers)

Refrigerated or reefer ships carry perishable products, such as fruit and meat, to 

and from California. The products, usually palletized, are stored in large 

cold-storage cargo holds. Additionally, containers can be stored on the deck of 

some reefer ships. Unlike container ships, most of these types of ships are 

equipped with cranes. 

Similar to container ships, a reefer ship is propelled by a large low-speed diesel 

engine and electrical power is provided by two to three auxiliary diesel engines. 

A reefer ship’s electrical load can be considerable due to refrigerating the cargo, 

supplying power to the cranes, and providing power for lights and ballast pumps. 

Reefer ships can use between 1MW to 3 MW when hotelling; the high end of the 

range includes the use of the on-board cranes. Reefers have hotelling times that 

are similar to container ships visiting the Los Angeles area, about 53 hours per 

visit. 

Sixty-five reefer ships visited California ports in 2006, representing only three 

percent of the total ship visits to California. 
III - 5 

Vehicle Carriers

Vehicle carriers are specialized ships where vehicles are driven on and off the 

ship. This category also includes other ships, referred to as “RoRos,” that are 

designed for cargo to be rolled on and rolled off. Similar to other ocean-going 

vessels, a vehicle carrier is typically propelled by a large low-speed diesel 

engine, and the electrical power is provided by two to three auxiliary diesel 

engines. Vehicle carriers require low power while in port—about 700 kW. The 

average hotelling time for these ships is approximately 20 hours. 

Tankers

Tankers are designed to carry liquid and gaseous products. The major products 

transported include crude oil, finished petroleum products, and chemicals. There 

are two types of tankers: crude-oil tankers and product tankers. Tankers visiting 
III - 6 

California ports range in size from 15,000 dead weight tons (DWT) to over 

200,000 DWT. Tankers larger than 70,000 DWT typically carry only crude oil. 

The smaller tankers, or product tankers, carry various types of finished petroleum 

products and chemicals. In 2006, 451 tankers visited California ports, accounting 

for 22 percent of the total ship calls to California. 

Most of this activity supports the operation of California’s refineries. Tankers 

bring crude oil from Alaska and the Middle East to refineries in the Bay Area and 

Los Angeles. In addition, product tankers transport needed materials from 

Northern California to Southern California and vice versa, as well as transfer 

material into and out of the State. The major ports that tankers frequent in 

California include Benicia, Carquinez, El Segundo, POLA/POLB, Martinez, and 

Richmond.

Crude-oil tankers come in many configurations. Older tankers transporting crude 

oil use steam-based power plants to both propel the ship and provide for 

electrical power, including pumping the crude oil. For a similar steam-powered 

container ship, cold-ironing one these ships would result in minimum emission 

reductions since the steam boiler would continue to operate while in port. Newer 

tankers transporting crude oil typically use a diesel engine to propel the ship, 

auxiliary diesel engines to provide power for lights and ballast pumps, and a 

boiler/steam turbine combination to drive the cargo pump. In this case, the lights 

and ballast pumps activities can be cold-ironed. Finally, five tankers transporting 

crude oil to a California port are diesel-electric, where on-board power provides 

the needed electricity for lights, ballast pumps, and cargo pumping. The entire 

load for this type of tanker can be cold-ironed. 

The majority of the power requirements for a crude-oil tanker is for pumping out 

the crude. Since the majority of ships transporting crude oil use steam 

turbine/boiler units to pump the crude, this portion of a tanker’s operation cannot 

be electrified. Consequently, except for diesel-electric tankers, the hotelling 

power requirements for crude-oil tankers will range between 50 KW to 600 kW. 

For diesel-electric tankers, where electric motors drive the cargo pumps, the 

power requirements are between 5 MW to 6 MW. 

The hotelling times for tankers transporting crude oil range between 10 to 

40 hours per visit. Tankers visiting the Port of Long Beach average 37 hours per 

visit, and tankers visiting ports in the Bay Area average 20 hours per visit. This 

hotelling time includes time necessary for the safety and operations conference, 

connecting and disconnecting from the shore piping system, and loading ballast 

as well as discharging the cargo. 

For product tankers, a diesel engine is typically used to propel the ship, while 

auxiliary diesel engines provide the ship’s electrical power needs and productpumping requirements. Many of the product pumps are either hydraulically 

driven or directly connected to the auxiliary engine. Electric motor-driven 
III - 7 

pumping systems (i.e., diesel-electric) are amenable for cold-ironing; the 

hydraulic or direct-drive pumps cannot be cold-ironed. In 2006, there were two 

diesel-electric product tankers visiting California ports. 

Product tankers are different than crude-oil tankers in one important fashion: 

products are not only pumped off but also pumped onto the ships while docked. 

On-shore pumps load the material into the product tankers. Even if the product 

pumps on the tanker were driven by electric motors, they would be shut down 

while receiving a product, which is about 40 percent of the time. As with crudeoil tankers, pumping the cargo from the ship uses significantly more power than 

general power consumption for lights and ballast pumps. Pumping requires 

1 MW to 1.5 MW of power, while general power consumption ranges between 50 

MW to 600 kW. 

The hotelling times for product tankers range from 20 hours to 130 hours per 

visit. While the hotelling times appear long, a single visit by a product tanker to 

POLA/POLB may include stops at one to three different berths. Consequently, 

the average berthing time for a product tanker more likely varies from 25 hours to 

50 hours. 

Bulk and General Cargo Ships

Bulk and general cargo ships carry material that is not easily placed into 

containers. Examples of material a bulk or general cargo ship could transport 

include rolls of steel, large machines, gypsum, and wood products. Similar to 

reefer ships, most of these types of ships are equipped with cranes or other 

equipment to load or unload the cargo. 

Similar to other ocean-going ships, bulk ships are propelled by a large low-speed 

diesel engine, and electrical several auxiliary diesel engines provide electrical 
III - 8 

power. Electrical power is needed for lights and ballast pumps, and possibly for 

cargo loading/unloading equipment, such as cranes or conveyer belts. More 

than any other vessel category, bulk and general cargo ships have very few 

frequent visitors to California ports. In 2006, bulk ships making only one visit to a 

California port accounted for half of all the total visits made by this ship category.

B. California Ports 

Each of the California ports is unique, not only in its physical size, but also in the 

types and amounts of cargo that is handled at the port. Each port can have one 

to several terminals. Each terminal can have one to several berths. Each 

terminal is usually dedicated to a certain type of ship, such as a container ship or 

passenger ship, although some terminals are multi-use. Table III-1 shows the 

number of ship visits by port based on 2006 State Lands Commission data. The 

Ports of Los Angeles and Long Beach make up the largest port complex in the 

State. The majority of ship calls in California are made to these two ports. The 

Port of Oakland has the third most ship visits in the State. All other ports account 

for 30 percent of remaining California ship visits.

Table III-1: Port Ranking by Ship Visits in 2006 

Port Number of Ship 

Visits 

Percentage of Total 

Visits to State 

Los Angeles/Long Beach 5,469 52% 

Oakland 1,939 18% 

Carquinez 745 7% 

Richmond 549 5% 

San Diego 551 5% 

San Francisco 272 3% 

Hueneme 371 4% 

El Segundo 211 2% 

Stockton 173 2% 

All Other 232 2% 

Total 10,512 100% 

The number of terminals and berths is different for each California port. The 

larger ports have a number of terminals, each with several berths. Table III-2 

shows the number of terminals and berths by ship category at each port. It 

should be noted that not all berths included in the numbers would be utilized on a 

regular bases. For example, some terminals receive only larger ships that can 

span several berths when docked. These blocked berths can not routinely 

service other ships. In addition, there are other terminals and berths at California 

ports that are used primarily for cargo storage and port services, or may not 

currently be in use. These terminals and berths were not included in Table III-2. 
III - 9 

Table III-2: Number of Terminals and Berths per Ship Category for Each California Port 

Port Container Reefer 

Vehicle 

Carrier Bulk Tanker Passenger Total 

 T B T B T B T B T B T B T B 

Avalon-Catalina no wharf 

Benicia 1 3 1 3 

Carquinez 1 1 1 3 1 2 3 6 

Crockett 1 1 1 1 

El Segundo 1 2 1 2 

Hueneme 1 3 1 2 2 5 

Humboldt 3 5 1 1 4 6 

Long Beach/ Los Angeles 18 98 2 4 3 9 19 44 15 37 2 4 59 196 

Monterey no wharf 

Oakland 10 25 10 25 

Pittsburg bulk ships at port already cold-ironed 

Redwood City 3 5 3 5 

Richmond 1 2 3 4 1 4 5 10 

Sacramento 6 6 6 6 

San Diego 1 4 1 7 2 4 3 15 

San Francisco 7 11 1 1 2 3 10 15 

Stockton 9 19 1 1 10 20 

Totals 28 123 4 11 8 24 52 98 20 47 7 12 119 315 

As can be seen in Table III-2, there are 119 terminals at California ports 

providing services to over 300 berths. Some terminals receive ships from more 

than one category. For example, at Richmond, vehicle carrier ships and bulk 

cargo ships visit the same berths. For these cases, staff assigned the terminals 

and berths to the type of ships that utilizes them the most. POLA/POLB 

combined handle ships from all categories and have the greatest number of 

terminals and berths, 59 and 196, respectively. There are very specialized ports, 
III - 10 

such as El Segundo which receives only tankers, and Crockett, Humboldt, 

Redwood City, Stockton, and Sacramento which receives predominately bulk 

deliveries. The Ports of Avalon-Catalina and Monterey do not have terminals 

because they have no wharfs. Passenger ships at these ports anchor offshore, 

and smaller boats ferry passengers to and from shore. There is only one facility 

using the port at Pittsburg, USS POSCO, and all four bulk ships that deliver to 

this facility are cold-ironed. 

From a ship perspective, container ships visit three ports: Long Beach, 

Los Angeles, and Oakland. Reefers also visit only four ports: Hueneme, 

Los Angeles, Long Beach, and San Diego. Vehicle carriers visit six ports: 

Carquinez, Hueneme, Long Beach, Los Angeles, Richmond, and San Diego. 

Passenger ships visit six ports: Hueneme, Humboldt, Long Beach, Los Angeles, 

San Diego, and San Francisco. Tankers visit seven ports: Carquinez, El 

Segundo, Long Beach, Los Angeles, Richmond, San Francisco, and Stockton. 

Bulk ships visit nearly all of the ports. 

According to the 2006 Lands Commission data, there were just over 2,000 ships 

making a total of just over 10,500 visits to California ports. Table III-3 

summarizes these ship visits by ship category. 

Table III-3: Ship Visits to California Ports in 2006, by Ship Category 

Category Total Ships Visiting 

California Total Ship Visits 

Container 585 4,783 

Passenger 52 752 

Reefer 65 298 

Tanker 451 2,111 

Vehicle Carrier 235 1,039 

Bulk 629 1,402 

Other 33 127 

Total 2,050 10,512 

While container ships comprise less than a third of the total ships visiting in 2006 

(585 of 2,050), they made nearly 50 percent of the total ship visits (4,783 of 

10,512). Tankers, vehicle carriers, and bulk ships make up almost two-thirds of 

the total ships visiting in 2006 (1,315 of 2,050); however, combined they only 

made roughly 40 percent of the total ship visits (4,552 of 10,512). Reefers, 

passenger ships, and ships categorized as other made the least ship visits in 

2006. 
III - 11 

REFERENCES:

California Air Resources Board. Evaluation of Cold-Ironing Ocean-Going 

Vessels at California Ports; March 2006. 

http://www.arb.ca.gov/ports/shorepower/report.pdf

California Lands Commission. 2006 Port Call Database. 

Marine Exchange of the San Francisco Bay Region. Golden Gate Ports 

Handbook 2004-2005. Seattle: Northwest Publishing Center, 2004. 32-53. 

Port of Hueneme Wharfinger Data. 2006 Port Call Database. 

Port of Oakland Wharfinger Data. 2006 Port Call Database. 

Port of Oakland. Maritime: Terminal Specifications; September 2007.

http://www.portofoakland.com/maritime/terminal.asp

Port of Long Beach Wharfinger Data. 2006 Port Call Database.

Port of Long Beach. Trade/Commerce: Cargo/Tenants – Containerized, Dry Bulk, 

Liquid Bulk, Break Bulk & Ro Ro; September 2007. 

http://www.polb.com/economics/cargotenant/default.asp

Port of Los Angeles Wharfinger Data. 2006 Port Call Database.

Port of Los Angeles. Facilities: Passenger Terminal, Automobile Terminal, 

Breakbulk Terminals, Container Terminals, Dry Bulk Terminals, and Liquid Bulk 

Terminals; September 2007. http://www.portoflosangeles.org/facilities.htm

Port of San Diego Wharfinger Data. 2006 Port Call Database.

Port of San Francisco Wharfinger Data. 2006 Port Call Database.

IV - 1 

IV. CURRENT SHORE POWER ACTIVITIES AT WEST COAST PORTS 

This chapter will discuss current and future shore power actions that have been 

taken on by California ports, other West Coast ports, and the shipping industry to 

help decrease emissions from onboard auxiliary engines. This chapter will also 

discuss the fact that shore power activities are proven and technically feasible. A 

few ports in California have integrated shore power at some berths. A limited 

number of ships are currently or will soon be using shore power at California 

ports. Some ports have established very specific goals for installing shore power 

while others are researching or revising plans to determine the most efficient and 

cost-effective method to do this. There have also been several ships that have 

been retrofitted for connecting to an electrified berth, but without the shore-side 

power supply, those ships cannot shut down their auxiliary engines. Despite the 

current lack of shore-side power, some shipping companies continue to move 

forward with retrofitting additional ships or incorporating shore power equipment 

on new builds in anticipation of future infrastructure at the port. 

A. Shore Power Plans at California Ports 

The process of initiating shore power plans can take two years or more due to 

the amount of time necessary to approve the Environmental Impact 

Report/Environmental Impact Statement (EIR/EIS) and to obtain the required 

permits. Many of the plans listed in this chapter require at least a three-year time 

span for a project to become operational. Once this timetable is overcome and a 

power supply is available to visiting ships, the flow of shore power can lead to 

significant emission reductions. 

The San Pedro Bay Clean Air Action Plan (CAAP)

The Port of Long Beach (POLB) and the Port of Los Angeles (POLA) are working 

jointly to reduce emissions by setting project goals in the San Pedro Bay Clean 

Air Action Plan (CAAP). Strategies to improve air quality for ocean-going vessels 

include implementing a Vessel Speed Reduction Program, using 0.2 percent 

sulfur (or lower) marine gas oil fuel in auxiliary engines, requiring diesel 

particulate and NOx control devices where practicable, and installing shore 

power capabilities. Both ports have shore-power goals for 2011, and POLB has 

additional goals for 2016. The CAAP states that all major container terminals, 

certain liquefied bulk terminals, and passenger ship terminals will be subject to 

shore power implementation. 

POLA will incorporate Alternative Maritime Power (AMP), which is the Port’s term 

for shore power, at 15 berths at a total approximate cost of $49.1 million. The 

AMP infrastructure at the China Shipping Terminal (berth 100), installed in 2004, 

also satisfies part of the CAAP’s requirement for this terminal. Yusen Terminal 

also completed an AMP installation at berth 214 to service the shore powerequipped ship, the NYK Atlas. 
IV - 2 

The CAAP requires installation of shore power infrastructure for two berths at the 

Cruise Terminal (berths 91 and 93) in 2008. In addition to this plan, Princess 

Cruises signed a shore power agreement to begin using shore power when 

docking. The Norwegian Cruise Line also signed a multi-year contract that 

includes the use of shore power technology for its ship, the Norwegian Star. 

The CAAP sets a series of goals for a number of container berths to reach an 

operational shore power status by 2009. The Evergreen Terminal 

(berths 224-236) should have AMP installed at one berth by 2008 to power the 

newly retrofitted S-class Evergreen ships. In addition to the China Shipping 

settlement requirements, electrification is planned for one more berth at the 

China Shipping Terminal by 2009. By 2009, two berths at the Trans Pacific 

Container Service Corp. (TraPac) Terminal (berths 136-147) should have shore 

power infrastructure. A Draft Environmental Impact Statement/ Draft 

Environmental Impact Report (DEIS/DEIR) for the TraPac Terminal is currently 

under public review. 

The ultimate goal at POLA is to have all planned shore-side infrastructure 

completely operational by 2011. To achieve this goal, two berths at the West 

Basin Container Terminal (berths 121-131), one berth at the Pasha Terminal 

(berths 175-181), and one berth at the Port of Los Angeles Container Terminal 

(berths 206-209) will be equipped with shore power. Also, one berth each at the 

APL Terminal (Pier 300) and the APM Terminal (Pier 400) will be electrified. At 

the APM Terminal, a liquid bulk ship berth will have a 2011 goal to reach 

completion as well. 

In addition to the CAAP, POLA has indicated that all new shore-side power 

infrastructures for container ships will include a 6.6-kV plug at the wharf. 

Transformers, connection cables, cable reels, and plugs will be expected to be 

included on the ships, not at the wharf. However, POLA is considering an 

innovative approach of housing a portable power-transfer system, which includes 

a transformer, cables, and cable reels in a container stored at the dock. When 

the ship is ready to be cold-ironed and the appropriate space onboard has been 

made, a crane lifts the container onto the ship, and electricians make the 

appropriate connections. In this manner, the transformer is not located on the 

ship or the wharf, but is managed as a container and put into service when 

needed. 

On the other side of San Pedro Bay, POLB will potentially incorporate shore 

power at 16 berths at a total approximate cost of $130 million. In the 

Fourth Quarter of 2007, the crude oil Berth T121 at the BP Terminal should be 

electrified. British Petroleum (BP) is equipping two of its new Alaskan-class 

tankers, the Alaskan Frontier and the Alaskan Navigator, with shore-power 

capabilities. The two ships are expected to be completed around the First 

Quarter of 2008. 
IV - 3 

A total of nine berths at POLB are set to be operational in 2011. This includes 

two berths at Pier C, one berth at the Middle Harbor Terminal (Piers E), three 

berths at the International Transportation Service, Inc. (ITS) container terminal 

(Pier G), and three berths at Pier S. Preparation of the electrical infrastructure 

EIR/ EIS is currently underway for Piers E and S. 

Prior to the CAAP, ITS (a K-Line subsidiary) signed a lease agreement with 

POLB to phase in shore power and other technologies to reduce NOx emissions 

by ninety percent at Piers G and J. The construction plans at Pier G were 

recently approved and completion of the project is set for spring of 2008. Matson 

Navigation Co. and SSA Marine (at Pier C) also signed a lease agreement 

requiring the same reduction in emissions as the ITS agreement. Construction of 

the shore power infrastructure is in progress for Piers C and G. 

Between 2011 and 2016, POLB hopes to coordinate with the City of Long Beach 

and terminal leaseholders to mandate shore power. The terminal leases are not 

up for renewal for another five years; therefore, this goal has been extended to a 

later date. The additional six berths include one berth at the Carnival Cruise 

Terminal, two berths at the Sea-Launch and at the Navy Mole, one berth at the 

Total Terminals International (TTI) Terminal (Pier T), and one berth each for the 

SSA Terminals at Pier A and Pier J. 

Another delay for the latter set of goals is the lack of electrical service to power 

the berths at POLB. While the Los Angeles Department of Water and Power 

(LADWP) has the existing electrical infrastructure to supply adequate power to 

POLA, Southern California Edison (Edison) will need to extend their 

infrastructure from Interstate 405 to meet shore power needs of POLB. 

Extending these trunk lines will account for approximately 50 percent 

($69.3 million of $130 million) of the total cost for the shore power infrastructure 

at POLB. 

If POLA/POLB meet the 2011 goals of the CAAP, 25 berths between the two 

ports will be electrified and operational. According to the CAAP, POLA and 

POLB should be able to accommodate a total of 1,052 vessel calls (671 at POLA 

and 381 at POLB) in 2011. The 2016 goals for POLB are based upon renewal 

lease agreements and power supply and the progress of the 2011 goals. POLA 

and POLB intend to review the progress each year and revise areas that need 

attention. The CAAP currently lists plans for 2016 as potential additions; 

however, the cost to electrify those berths is included in the overall plan cost. 

The overall estimated cost for 2011 and 2016 goals comes to $179.1 million 

($4.1 million for POLA and $130 million for POLB). 
IV - 4 

Port of Oakland

The Port of Oakland has been exploring the option of using portable distributed 

generation equipment to provide power to a docked vessel. The objective of this 

system is to eliminate emissions from onboard diesel-powered auxiliary engines 

by operating a natural-gas-fired engine to provide power to the ship. Currently, 

the system has been tested by Wittmar Engineering and Construction, Inc. at the 

Port of Oakland on the container ship the APL China. 

Port of San Diego

San Diego Gas and Electric (SDG&E) conducted a draft shore power feasibility 

study, as requested by the San Diego Unified Ports District (SDUPD). SDUPD 

assessed the Tenth Avenue Marine Terminal (TAMT) and the Cruise Ship 

Terminal (CST) for shore power through five different options. The main goal is 

to provide the appropriate amount of power to supply the shore power needs of 

reefers at the TAMT and cruise ships at the CST. 

Currently, SDUPD and SDG&E are holding discussions to make this shore power 

project even more efficient and less costly. SDUPD is looking into possibly using 

construction improvements in San Diego’s downtown area to help supply power 

needs to the TAMT and the CST. 

Port of San Francisco

The Port of San Francisco approved a shore power project at Pier 27 in March of 

2007. The Bay Area Air Quality Management District is currently considering 

contributing Carl Moyer Memorial Air Quality Standards Attainment Program 

funds to the Port of San Francisco for this project. These funds will help cover 

most of the cost of getting the power from the street to the dockside. The power 

will be supplied by either Pacific Gas & Electric (PG&E) or from Hetch Hetchy by 

way of a PG&E substation. Since a generic range was given for the cost of 

trenching a pathway for the power supply, the utility infrastructure cost is still 

unknown. Pier 27 is planned to service Princess passenger ships. The pier is 

estimated to be operational prior to ship arrivals in 2009. 

B. Installed Shore Power Infrastructures 

Currently, there are just a handful of shore power applications operating in 

California. In addition to these few ports in California, other ports outside of 

California have installed shore power infrastructure in an effort to reduce auxiliary 

engine emissions. This section will discuss shore-side infrastructures that can be 

utilized on a regular basis. It was stated earlier in this chapter that the Yusen 

Terminal, Inc. (berth 214) at the Port of Los Angeles was complete; however, it is 

not currently functional. System testing is necessary to ensure functionality and 

safety of the infrastructure before ships can regularly connect to onshore power. 
IV - 5 

China Shipping Terminal at Port of Los Angeles

The Port of Los Angeles retrofitted the China Shipping Terminal to include a 

shore power infrastructure as part of a lawsuit settlement with the Natural 

Resources Defense Council (NRDC), the Coalition for Clean Air, and local 

community groups. The settlement requires a minimum of 70 percent of ship 

calls to this berth, on an annual average, to utilize shore power. 

At this site, a substation at the edge of the property supplies 14.5 kV of 

electricity, which is stepped down by a nearby transformer to 6.6 kV. 

Underground cables transport the electricity hundreds of yards to the edge of the 

wharf. A transformer that is housed on a barge next to the ship reduces the 

power further to 440 volts (V). The barge also contains a crane, cable reels, 

switching gear, and nine cables. Figure IV-1 shows the barge supported shore 

power application at the China Shipping Terminal. 

When a ship is ready to connect to shore power, a crane lifts the cables from the 

barge to the ship, where personnel plug them into a panel at the stern of the ship. 

Figure IV-2 shows the cable connections on a China Shipping vessel. The Port 

has indicated that the barge configuration will no longer be used in future shore 

power applications because of the cost and size of the barge. 

 

Figure IV-1: Shore Power Provided via a Barge at Figure IV-2: Cable Connections on a 

China Shipping China Shipping Vessel

South Franklin St. Dock in Juneau, Alaska

Princess Cruises began cold-ironing some of its ships berthed at the 

South Franklin St. dock in Juneau in 2001. The shore power operations were 

installed in response to community concerns over the smoke emissions from 

passenger ships visiting in the summer. During the summer cruise season, the 

air is stagnant over Juneau and the emissions from the ships’ auxiliary engines 

significantly reduce visibility. 
IV - 6 

At this site, a dual-voltage transformer supplies power from the utility company. 

The transformer can step down the voltage to either 11 kV or 6.6 kV. 

Underground cables carry the power from the transformer to the dock switch, 

where four 3 1⁄2-inch diameter flexible electrical cables direct the power to the 

ship. The cables hang in a festooning pattern on a steel gantry located on the 

dock next to the ship as illustrated in Figure IV-3. The gantry system allows the 

cables to accommodate Juneau’s 20-foot tidal range as well as withstand the 

100-mph winds during the winter. 

Figure IV-3: Steel Gantry Festooning System at Juneau, Alaska 

When connecting to shore power, personnel use the festooning system to lower 

the cables to a side shell door on the ship, where the cables are pulled through 

the doorway and the 70-pound custom-made plugs are connected to the 

electrical connection cabinet on the ship. The cable connection is a male/female 

plug-and-socket system similar to what is used in the American mining industry. 

Figure IV-4 shows cables entering a ship, and Figure IV-5 shows the cable 

connection on a ship. Onboard software allows the shore power and the ship 

generator power to automatically synchronize, combine, and transfer. 

Synchronizing the ship and shore power is mandatory for passenger ships, 

where any disruption to passenger services is unacceptable. 
IV - 7 

 

Figure IV-4: Cables Entering a Figure IV-5: Cables Connected to 

Princess Cruises Ship an Electrical Cabinet on a 

 Princess Cruises Ship 

Port of Seattle, Washington

Princess Cruises began cold-ironing some of its shore power-equipped vessels 

at the Port of Seattle in the summer of 2005. Likewise, the Holland America Line 

has retrofitted three ships since 2006 to take advantage of the shore power 

infrastructure. This project was a collaborative effort among Princess Cruises, 

the Port of Seattle, Seattle City Light (the local utility), and the United States 

Environmental Protection Agency (U.S. EPA) to reduce emissions from ships at 

the Port's new Terminal 30 Cruise Facility, which Princess Cruises shares with 

the Holland America Line. The Port has two passenger ship terminals serving 

five passenger ship lines. 

At this site, existing utility power is brought to a custom-made step-down 

transformer, which can deliver either 11 kV or 6.6 kV, similar to the Juneau site. 

The specialized transformer provides flexibility to the Princess Cruises fleet to 

accommodate not only the larger Princess Diamond and Princess Sapphire ships 

but also the smaller Princess vessels that were originally retrofitted for Juneau. 

Similar to Juneau, four cables carry power to the ships’ electrical connection 

cabinet via a side shell door. The cables are lowered to the ship by a winch 

connected to a metal support structure located at the edge of the wharf. The 

structure can be pivoted away from the ship when not in use. Figure IV-6 shows 

the cable management system for a Princess ship at the Port of Seattle. 
IV - 8 

Figure IV-6: Power cables at the Princess 

Cruises Terminal at the Port of Seattle 

USS POSCO Industries in Pittsburg, California

Four dry-bulk ships cold-iron while docked at USS POSCO Industries' steel mill 

in Pittsburg, California. The ships, which are owned by Hyundai, Hanjin, and 

Korea Line shipping companies, were built between 1989 and 1992 and are 

equipped with Selective Catalytic Reduction (SCR) technology. Connection to 

shore power began in 1991 as a means to mitigate emissions from a facility 

expansion. At this site, two 480-volt cables are stored at the side of the dock. 

When shore power is provided, the cables are connected to a power box located 

at the edge of the dock and then pulled up the side of the ship and bolted to an 

electrical panel in an exterior room on the ship. Figure IV-7 shows the cables 

connected to the dock, and Figure IV-8 shows the cables bolted to the shore 

power connection panel on the ship. 

 

Figure IV-7: Shore-side power connection at the Figure IV-8: Shore power connection 

USS POSCO facility in Pittsburg, CA on the Pacific Success at the USS 

POSCO facility 
IV - 9 

United States Naval Station in San Diego, California

The Navy cold-irons ships while in port at bases all over the world. The Navy 

connects to shore power as a matter of routine and has done so for several 

decades. The ships are also hooked up to shoreside water, sewer, 

communication, and steam while docked. 

The Navy has developed a unique electrical cable connection system in order to 

avoid compatibility issues with different ports of call. Figure IV-9 shows a 

schematic of the Navy’s shore-power connection system. 

Figure IV-9: Navy ships’ shore-power connection system 

This system consists of power cables that are stored on the docks at the naval 

stations around the world. On either end of the power cables are “pigtails” of 

three separate cables that end in metal connection plates. Plugs with similar 

pigtails of cables and metal connectors are carried on the Navy ship as well as 

stored near the transformer/substations on the docks at the naval stations. 

When a ship docks at the Naval Station in San Diego, a crane lifts a cluster of 

power cables onto the ship. Navy personnel on the ship bolt the power cable 

pigtails to the plug pigtails stored onboard. Similarly, Navy personnel on the 

dock bolt the power cable pigtails to the plug pigtails stored near the substation. 

Then the plugs are connected to the receptacles on the substation and on the 

ship. Figure IV-10 shows the plugs stored adjacent to a substation at the San 

Diego Naval Station. Figure IV-11 shows cables connected to the receptacles on 

a Navy ship. 
 IV - 10 

Figure IV-10: Plugs stored at a substation at the Figure IV-11: Shore-Power connection 

San Diego Naval Station on a Navy ship 

 

Each cable can deliver 480 volts at 400 amps to the ship once the connection is 

complete. Having to attach plugs to power cables every time a ship cold-irons 

makes the Navy procedure more labor-intensive; however, since the Navy coldirons across the globe and has its own plugs aboard the ships and on the docks, 

there are no compatibility issues with the different ports of call. 

The transfer of power from the ships’ auxiliary generators to shore power is 

synchronized to avoid blackouts. For example, a destroyer-class ship has two 

auxiliary gas-turbine generators running in parallel when entering the port. One 

of the generators is turned off when the ship is docked and the second generator 

is ramped down during the transfer of power. It takes about 60 to 90 minutes 

after the ship is docked for personnel to connect the ship to electrical and other 

utility needs.

C. Shore Power Equipped Ships 

Staff is aware of 42 ships that are currently visit American ports that are 

equipped with shore power capabilities. These include container ships, 

passenger ships, and dry bulk ships. The ships are listed below in Table IV-1. 
 IV - 11 

Table IV-1: Ships with Shore Power Capability 

Operator Ship Type Number of Ships 

China Shipping Container 17 

Evergreen America Container 7 

Holland America Passenger 3 

MSC Container 1 

NYK Line Container 1 

POSCO Dry Bulk 4 

Princess Cruises Passenger 9 

Total Number of Ships 42 

 

China Shipping

The China Shipping settlement requires a minimum of 70 percent of ship calls to 

Berth 100, on an annual average, to utilize shore power. There are now at least 

17 China Shipping vessels that are equipped with shore power capability. In 

2006, shore power was used for 88 out of 125 ship calls to berth 100, or an 

average shore power use of 70 percent. Although an impressive start, these 

88 cold-ironed ship calls still represent a small fraction of overall container ship 

visits to the Port. In 2006, the China Shipping fleet made 125 calls (seven 

percent) of the 1,705 container-ship visits to POLA. 

Evergreen S-Class Vessels

In March 2005, Evergreen Marine Corporation announced that its new S-class 

7,024-TEU container vessels will be equipped with cold-ironing capability. Since 

2005, the Hatsu Sigma, the Hatsu Smart, the Ever Superb, and the Ever Steady 

have made their maiden calls to POLA. Figure IV-12 shows the cable reel 

aboard the Ever Steady while it was docked in 2007 at the Port of Oakland. 

Figure IV-13 shows the plugs ready to be lowered for shore-side connection. 

 

Figure IV-12: Cable Reel Onboard the Ever Steady Figure IV-13: Plugs Extended 

from the Ever Steady
 IV - 12 

In 2006, Evergreen’s entire fleet made 253 visits out of a total of 1,705 container 

ship visits to POLA, with the S-class fleet making 11 percent (28 out of 253 visits) 

of Evergreen’s total visits. Similarly, Evergreen’s fleet made 114 visits out of a 

total of 1,938 container ship visits to the Port of Oakland in 2006, with the S-class 

fleet making seven percent (8 out of 114 visits) of Evergreen’s total visits. 

Holland America 

In 2006, the Holland America Line retrofitted two passenger ships, the 

MS Oosterdam and MS Westerdam, to accommodate the shore power 

infrastructure at the Port of Seattle. In 2007, the MS Noordam was retrofitted 

with similar shore power capability. According to the 2007 Sailing Schedule for 

the Port of Seattle, 189 ship visits by 16 vessels are scheduled for 2007. Fortythree of these ship visits (or 23 percent) were made by two Holland America Line 

vessels equipped with shore power capability, the Oosterdam and the Noordam. 

NYK Atlas at Port of Los Angeles

Figure IV-14: The NYK Atlas docked at POLA 

POLA built a shore-side infrastructure at the Yusen Terminal (berth 214) to 

provide power to a container ship (NYK Atlas) when in port. The NYK Atlas, as 

shown in Figure IV-14, was equipped with shore-power capabilities when built 

and first arrived at POLA in August 2004. The ship is one of 19 NYK ships that 

visited POLA in 2006, accounting for nine of the 89 total NYK ship visits. 

At the Yusen Terminal, 6.6 kV will be provided at a plug on the wharf (a "wharf 

box"). Two cables that are housed on a cable reel on the NYK Atlas will be 

lowered down the side of the ship via a roller guide and connected to the wharf 

box. Because the NYK Atlas uses 6.6 kV, no transformer is needed for this shore 

power application. At the moment, the NYK Atlas is going through a testing 

program for its shore power set up. 
 IV - 13 

Princess Cruises Ships

According to Princess Cruises, there are currently nine ships that are equipped to 

cold-iron when at the Port of Seattle and the port in Juneau. According to the 

2007 Sailing Schedule for the Port of Seattle, 189 ship visits by 16 vessels are 

scheduled for 2007. Forty-two of these ship visits (or 22 percent) were made by 

two Princess Cruise Line vessels equipped with shore power capability, the 

Golden Princess and the Sun Princess. According to Juneau’s 2007 Cruise Ship 

Roster, 40 passenger ships should visit Juneau, including seven of Princess’s 

shore-power equipped ships. The Princess ships that will be able to use shore 

power represent 125 out of 646 total ship visits to Juneau in 2007 (or 

19 percent). 

As can be seen in this section, one NYK container ship, one MSC container ship, 

three Holland America passenger ships, four POSCO dry bulk ships, nine 

Princess Cruises passenger ships, 17 China Shipping container ships, and seven 

new S-class Evergreen container ships have been equipped with shore-power 

capabilities. It should be noted that perhaps not all of these ships will call on 

California ports in the future. 

D. Future Ship Retrofits and New Builds 

Shipping companies are continuing efforts to increase the number of shore 

powered vessels in anticipation that the ports will establish and carry out plans to 

provide shore side infrastructure. 

British Petroleum

Two BP tankers, the Alaskan Frontier and the Alaskan Navigator, are currently 

undergoing retrofits to accommodate the ship side infrastructure. As previously 

stated, these two ships are expected to be fully equipped with shore power 

capabilities around the First Quarter of 2008. 

Evergreen America

In addition to the seven S-class ships that presently have shore power capability, 

Evergreen plans to build another two ships, bringing the S-class fleet total to nine 

ships. The additional ships are the Ever Safety and Ever Salute. 

K-Line

K-Line is upgrading some of their fleet to accommodate shore power at the ITS 

terminal. Presently, K-Line is retrofitting five vessels for shore power. The five 

ships are the Chicago Bridge, Rotterdam Bridge, Genoa Bridge, Shanghai 

Bridge, and Long Beach Bridge. All five ships may be completed by 2008 or 

shortly thereafter. 
 IV - 14 

NYK Line

The NYK Line has committed to retrofitting 17 ships, starting with the NYK 

Apollo, that will use a container to house the ship-side infrastructure for shore 

power. As shown in Figure IV-15, an onboard container will house the 

infrastructure necessary to plug into the AMP outlet dockside. The power 

provided will supply the ship with 6.6 kV, which will not require a transformer. In 

addition to these retrofits, the NYK Line plans to build about 20 new ships that 

are equipped to connect to shore power. 

Figure IV-15: Shore Power Connection 

Using a Container Box

Norwegian Cruise Line

As stated previously, the Norwegian Cruise Line signed a multi-year lease 

agreement with POLA to retrofit the Norwegian Star to utilize AMP when docked. 

The terms of this contract are to take effect in 2008. 

Conclusion

As can be seen in this chapter, cold-ironing is proven and technologically 

feasible. Shore power is currently being used or planned for passenger ships, 

container ships, bulk ships, and oil tankers, as well as having been practiced 

routinely for decades at U.S. Navy ports all over the world. Cold-ironing 

strategies are currently part of some ports’ efforts to reduce public health impacts 

to the surrounding communities. The Port of Los Angeles has an active 

Alternative Maritime Power program and is installing or planning to install several 

shore power sites. Based on the CAAP, the Port of Long Beach has committed 

to adding shore power requirements to future lease conditions and already has a 

shore power berth at its BP terminal. Other ports are evaluating adding shore 

power to their terminals. The Port of San Francisco is planning to add shore 

power to its new passenger ship terminal and the Port of San Diego is planning 
 IV - 15 

to add shore power to its passenger ship terminal and refrigerated cargo 

terminal. Additionally, some container-ship, passenger-ship, and tanker 

companies are now voluntarily adding shore-power-equipped ships to their fleets. 
 IV - 16 

REFERENCES: 

Appy, Ph.D., Ralph G. NRDC VS. City of Los Angeles Amended Stipulated 

Judgment Quarterly Report – 4th Quarter 2006; March 9, 2007. 

British Petroleum. Personal communication. June 29, 2007. 

California Air Resources Board. Evaluation of Cold-Ironing Ocean-Going 

Vessels at California Ports; March 2006. 

http://www.arb.ca.gov/ports/shorepower/report.pdf

Cruise Line Agencies of Alaska. Cruise Ship Calendar for 2007; February 23, 

2007. http://www.claalaska.com/pdf/2007/2007_Juneau.pdf

Eric Caris, Port of Los Angeles. Personal communication. June 28, 2007. 

Evergreen Line. News Archive; Press Releases about S-Type Green Ships; 

October 2007. http://www.evergreenline.com/tbn1/jsp/TBN1_GreenShip_Introduction.jsp#6

Holland America Line. Holland America Line Seagoing Environmental 

Innovation; Environmental Commitment; January 2007. 

http://www.hollandamerica.com/about/environmental.do?env=standards

Hollman, Michael (MPH). “Cold ironing gathers momentum.” Germanischer 

Lloyd nonstop. Edition 2: 26-27. June 2006. http://www.glgroup.com/images/glgroup/nonstop_2006-02_E.pdf

Jay Ach, Port of San Francisco. Personal communication. August 21, 2007. 

Joe Calavita, California Air Resources Board. Personal communication. October 

1, 2007. 

Michelle White, Port of San Diego. Personal communication. September 25, 

2007. 

NYK Line. “NYK Successfully Tests Connection to New Shoreside Electric Power 

Unit.” Press Release. September 3, 2007. 

http://www.nyk.com/english/news/2007/0903/index.htm 

NYK Line. “NYK to Deploy Thirty Eight Containerships with Alternative Maritime 

Power Capability.” Press Release. April 26, 2007. 

http://www.nykline.co.jp/english/news/2007/0426_1/index.htm
 IV - 17 

Port of Long Beach. “Port Seeks Public Comment on Pier S Development 

Project.” Press Release. January 26, 2007. 

http://www.polb.com/civica/filebank/blobdload.asp?BlobID=3622

Port of Long Beach. “Port, ITS and ‘K’ Line Commit to ‘Green Policy’.” Press 

Release. July 31, 2006. 

http://www.polb.com/civica/filebank/blobdload.asp?BlobID=3057

Port of Long Beach. “Port Approves First ‘Green Lease’ Construction Contract.” 

Press Release. September 19, 2006. 

http://www.polb.com/civica/filebank/blobdload.asp?BlobID=3281

Port of Long Beach. “Port Signs Landmark Historic Agreements to Cut Pollution 

by 90%.” RE: Port. Press Release. August 21, 2006. 

http://www.polb.com/civica/filebank/blobdload.asp?BlobID=3186

 

Port of Long Beach. “Ships ‘Plug In’ to Cut Pollution.” RE: Port. Press Release. 

September 2007. 

http://www.polb.com/news/displaynews.asp?NewsID=284&targetid=18

Port of Long Beach. “’K Line’ Retrofitting Five Ships for Shore-side Power.” 

Press Release. June 11, 2007. 

http://www.polb.com/civica/filebank/blobdload.asp?BlobID=3954

Port of Los Angeles and Port of Long Beach. San Pedro Bay Ports Clean Air 

Action Plan; November 2006. 

http://www.portoflosangeles.org/DOC/CAAP_Tech_Report_Final.pdf and/or 

http://www.polb.com/civica/filebank/blobdload.asp?BlobID=3451 

Port of Los Angeles. “Princess ships will connect to shore power at the Port of 

Los Angeles in 2008.” Press Release. January 22, 2007. 

http://www.portoflosangeles.org/News/news_012207pc.htm

Port of Los Angeles. “Port of Los Angeles signs agreement with Norwegian 

Cruise Line that includes multiple environmental initiatives.” Press Release. 

January 30, 2007. http://www.portoflosangeles.org/News/news_013007ncl.htm

Port of Los Angeles. “Port extends public comment period on TraPac Container 

Terminal environmental document.” Press Release. August 6, 2007. 

http://www.portoflosangeles.org/News/news_080607trapac.htm

Port of Los Angeles. “Two of Evergreen Group’s ‘Green’ Mega Ships Call at the 

Port of Los Angeles Simultaneously.” Press Release. August 7, 2006. 

http://www.portoflosangeles.org/Press/REL_Hatsu_Smart_Sigma.pdf
 IV - 18 

Port of Los Angeles. “Evergreen Group’s First ‘Green’ Mega Ship, Ever Superb, 

Makes Her Maiden Call at the Port of Los Angeles.” Press Release. August 7, 

2006. http://www.portoflosangeles.org/Press/REL_Ever_Superb_First_Call.pdf

Port of Los Angeles. “Evergreen Group’s ‘Green’ Mega Ship, Ever Steady, 

Makes Her Maiden Call at the Port of Los Angeles.” Press Release. January 18, 

2007. http://www.portoflosangeles.org/News/news_011807es.htm

 

Port of Los Angeles Wharfinger Data. 2006 Port Call Database.

Port of Oakland Wharfinger Data. 2006 Port Call Database. 

Port of Seattle. Preliminary Sailing Schedule; Cruise Seattle 2007; March 2007. 

http://www.portseattle.org/downloads/seaport/CruiseSched200704.pdf

San Diego Gas and Electric. Cold Ironing Feasibility Study for Electrical Services 

at Cruise Ship & 10th Avenue Marine Terminals; January 2007. 

Stefan/George Associates. Personal communication. May 23, 2007. 

Stefan/George Associates. Personal communication. May 16, 2007. 

Wittmar Engineering & Construction, Inc. American President Line; DFMV Cold 

IroningTM Presentation. September 6, 2006.
V - 1 

V. EMISSIONS, POTENTIAL EXPOSURES, AND RISK 

This chapter presents estimated hotelling emissions from ocean-going vessels 

visiting California ports. As stated in Chapter II, ARB staff is proposing 

requirements for three of the six major categories of ocean-going vessels that 

visit California ports—container ships, passenger ships, and refrigerated cargo 

ships (reefers). The other ship categories will be addressed in a future 

rulemaking that is expected to be completed by late 2008. 

In this chapter, ARB staff first presents statewide 2006 hotelling emissions for all 

ship categories, then discusses in detail the three ship categories affected by the 

proposed regulation. This chapter also includes a discussion on the potential 

cancer and non-cancer health impacts due to current hotelling emissions from all 

ocean-going vessels. 

A. Estimated Hotelling Emissions from Ocean-Going Vessels 

To develop an inventory of hotelling emissions at California ports, ARB staff 

revised the 2005 methodology for calculating emissions from ocean-going 

vessels in California. The inventory update was conducted to achieve several 

goals: 

• Reflect 2006 activity 

• Merge new port specific activity data sets that provide port call specific 

information 

• Include improvements to calculation methodologies developed in recent 

port-specific inventories 

• Refine growth assumptions and methods 

• Incorporate 2005 Auxiliary Engine Regulation into emission estimates 

• Determine the potential emissions benefits of this proposed regulation. 

This emission inventory includes emissions from all ports and vessels but 

focuses on the vessel types, operating modes, and ports that would be affected 

by the proposed regulation—container ships, passenger ships, and reefers 

visiting the Ports of Los Angeles, Long Beach, Oakland, San Diego, 

San Francisco, and Hueneme. 

The inventory integrates information from multiple sources. From the 2006 

Lloyd’s Fairplay Ship Registry, staff gleaned information about the characteristics 

of individual ships, such as engine size, net registered tonnage, and other data. 

Staff used data about port calls and hotelling times from databases developed by 

the California State Lands Commission and from management organizations at 

many ports in California. We received information on engine loads from previous 

ARB surveys and inventories developed for the Ports of Los Angeles, 

Long Beach, and Oakland. Finally, staff used emission factors taken from 

available studies of ship emissions tests. 
V - 2 

We calculated emissions by estimating ship activity on a ship-by-ship and a port 

call-by-port call basis, using actual ship auxiliary engine power estimates and 

actual ship hotelling times where possible. Base year emissions were forecasted 

using a set of growth factors specific to each port and each ship type, and control 

factors reflecting the shore power regulatory scenario. The regulatory scenario 

developed for this regulation also includes emissions associated with generating 

shore power from the electric grid, assuming the use of natural-gas fired power 

plants with selective catalytic reduction, which would be used in place of auxiliary 

engines. 

A description of the methodology for developing the engine inventory and 

associated emissions and the projection for future years is provided in 

Appendix B. 

Current 2006 Hotelling Emission from Ocean-Going Vessels 

The hotelling emission estimates are associated with the use of diesel-fueled 

auxiliary engines on ocean-going ships to power the vessel’s electrical systems 

while docked. These emissions are a function of how often the ship visits a 

California port, how long the ship is at-berth, the emissions rate of the engines, 

and the typical operating load of the auxiliary engines while the ship is at-berth. 

Data used for estimating hotelling auxiliary engine emissions include: 

• Base year vessel population 

• Port call-specific hotelling time 

• Auxiliary engine power 

• Vessel type specific engine load 

• Auxiliary engine emission factors 

• Vessel type and port growth rate 

• Replacement power emission factors 

ARB staff estimates that in 2006, there were approximately 2000 ocean-going 

vessels calling at California ports, emitting about 1.8 tons per day (TPD) of 

diesel PM and 21.1 TPD of NOx from diesel-fueled auxiliary engines while atberth. 

In addition, based on a range of statewide NOx-to-PM conversion factors of 

0.3 - 0.5 g NH4NO3/g NOx, ARB staff estimates a secondary formation of PM2.5 

nitrate from NOx hotelling emissions ranges from 6.3 to 10.6 tons per day.1 

 

1

 The conversion factor for the transformation of NOx to NH4NO3 was based on an analysis of 

annual-average conversion factors for secondary formation of PM10 nitrate from NOx emissions at 

a number of urban sites in California. A more detailed description of the methodology used to 

evaluate the conversion of NOx to NH4NO3 is found in Appendix D. 
V - 3 

Estimates of 2006 NOx, and diesel PM hotelling emissions per ship category are 

presented in Table V-1. 

Table V-1: Estimated 2006 Hotelling Emissions by Ship Category 

 

2006 Emissions, Tons/Day 

Ship Category 

NOx PM 

Container 13.8 1.1 

Passenger 2.8 0.2 

Reefers 0.9 0.1 

Tanker 2.0 0.2 

Bulk/General 1.0 0.1 

Vehicle Carriers 0.6 0.1 

Totals 21.1 1.8 

Figures V-1, and V-2 show the relative share of NOx and diesel PM emitted by 

each ship category. As can be seen in these figures, the hotelling emissions 

from the three affected ship categories—container ships, passenger ships, and 

reefer ships—represent over 80 percent of total statewide hotelling emissions. 

Figure V-1: 2006 NOx Emissions Distributions for All 

Ship Categories

3% 5%

66%

13%

4%

9%

Vehicle

Bulk/General

Container

Passenger

Reefer

Tanker
V - 4 

Figure V-2: 2006 Diesel PM Emission Distributions for All 

Ship Categories

3% 5%

65%

14%

4%

9%

Vehicle

Bulk/General

Container

Passenger

Reefer

Tanker

The proposed regulation would affect ships visiting the Ports of Los Angeles and 

Long Beach (which, for the proposed regulation, is considered one port), 

Oakland, San Diego, Hueneme, and San Francisco. To provide a perspective of 

the shipping activities at these ports compared to all other ports in California, 

staff presents total hotelling emission by California port in Table V-2. 

Table V- 2: Estimated 2006 Hotelling Emissions for All Ship Categories by 

Port (Tons per Day 

Port NOx PM 

Los Angeles/Long Beach 14.3 1.2 

Oakland 2.6 0.2 

San Diego 1.1 0.1 

Hueneme 0.7 0.1 

San Francisco 0.5 0.1 

Other Ports 1.2 0.2 

Total 21.1 1.8 

As can be seen in this table, most of the shipping activities and hotelling 

emissions occur at the largest ports in California: Los Angeles and Long Beach 

followed by Oakland. The six ports affected by the proposed regulation account 

for over 90 percent of total hotelling emissions at California ports. 
V - 5 

Projected 2014 and 2020 Hotelling Emission Estimates for Container 

Ships, Passenger Ships, and Reefer Ships 

Staff developed growth factors for each ship category to project future hotelling 

emissions. In general, the growth in vessel hotelling emissions is directly 

proportional to the growth in vessel visits, ship size, berthing times, and, in the 

case of container ships, the number of refrigerated containers aboard. Details on 

the growth assumptions are provided in Appendix B. 

Hotelling emissions from ocean-going ships are predicted to increase from 2006. 

Container ship and passenger ship emissions are expected to double by 2020. 

Reefer ship emissions are expected to decline at the Ports of Long Beach and 

Los Angeles, slightly increase at the Port of Hueneme, and triple at the Port of 

San Diego by 2020. 

The projected hotelling emission estimates for container ships, passenger ships, 

and reefer ships for 2014 and 2020 are presented in Table V-3. In December 

2005, the Board adopted an auxiliary engine fuel regulation that would limit the 

sulfur content of fuel used with auxiliary engines starting in 2007. At the time this 

technical support document was published, the regulation had been challenged 

in federal district court and is undergoing appeal at the Ninth Circuit Court of 

Appeals. The future emission projections were based on the assumption that the 

auxiliary engine regulation would ultimately be upheld and the auxiliary engines 

would be operating on low-sulfur fuel. 

Table V-3: Projected 2014 and 2020 Hotelling Emission Estimates for 

Container Ships, Passenger Ships, and Reefer Ships 

Projected 2014 

Emissions 

Tons per Day 

Projected 2020 

Emissions 

Tons per Day 

Ship 

Category 

NOx PM NOx PM 

Container 21.4 0.38 30.8 0.55 

Passenger 3.6 0.07 5.2 0.09 

Reefer 1.0 0.02 1.3 0.02 

Totals 26 0.47 37.3 0.67 

B. Potential Health Impacts of Hotelling Emissions 

This section discusses the potential cancer and non-cancer health impacts due 

to current hotelling emissions from ocean-going vessels. For the analysis of 

potential cancer impacts, we used earlier analyses conducted as part of the Port 

of Los Angeles/Long Beach Health Risk Assessment (ARB, 2006a). A copy of 
V - 6 

the Diesel Particulate Matter Exposure Assessment Study for the Ports of Los 

Angeles and Long Beach is included in Appendix C. For non-cancer impacts, we 

updated work done as part of the Goods Movement Emission Reduction Plan 

(ARB, 2006b). A discussion of the non-cancer health assessment is included in 

Appendix D. 

Particulate matter (PM) and NOx are the emissions of the greatest health 

concern from hotelling emissions from ocean-going vessels. Particulate matter 

emitted from diesel-fueled engines (diesel PM) is used as the measure of the 

toxicity of diesel exhaust, which includes over 40 identified toxic air 

contaminants. The annual average concentration of diesel PM due to hotelling 

emissions is used to estimate the potential cancer risk near port communities. 

Non-cancer impacts are estimated based on the annual average concentration of 

PM. There are two sources of PM emissions from diesel-fueled auxiliary 

engines. The first source of PM is the PM directly emitted in the exhaust from 

diesel auxiliary engines. This is referred to as directly emitted diesel PM. The 

second source of PM is the PM that is formed in the atmosphere when gases 

emitted in the exhaust from diesel engines, primarily NOx and SOx, react to form 

PM. This is referred to as secondary diesel PM. 

Non-cancer impacts can also occur from exposures to NOx and hydrocarbon 

emissions from diesel-fueled engines. NOx and hydrocarbon emissions 

contribute to the formation of ozone, which also has associated non-cancer 

health impacts. 

In 1998, the Board identified PM emissions from diesel-fueled engines as a toxic 

air contaminant (TAC). The Board concluded that long-term occupational 

exposures to diesel exhaust increases the risk of developing lung cancer. The 

Board also concluded that a number of adverse long-term non-cancer effects 

have been associated with exposure, including a greater incidence of respiratory 

irritation and chronic bronchitis. 

Over the last several years, a substantial number of epidemiologic studies have 

found a strong association between exposure to elevated PM levels (of which 

diesel PM is a subset) and adverse non-cancer health effects. (ARB, 2002; 

ARB, 2006b). These non-cancer health effects include premature death, 

increased hospitalizations for respiratory and cardiovascular causes, asthma and 

lower respiratory symptoms, acute bronchitis, work loss days, and minor 

restricted activity days. Non-cancer health effects linked to exposure to elevated 

levels of ozone include: premature deaths, hospital admissions for respiratory 

diseases, minor restricted activity days, and school absence days. 
V - 7 

C. Estimating Potential Cancer Impacts near California Ports 

The increased exposure to diesel PM from hotelling emissions from diesel-fueled 

ocean-going vessel auxiliary engines may result in elevated cancer risks to 

people who live and work near California ports. 

To provide a perspective on the potential cancer risk from hotelling emissions, 

staff used an existing analysis from 2004 of diesel PM emissions from port 

related activities (including hotelling emissions) at the Port of Los Angeles and 

the Port of Long Beach and adjusted the results of that study to reflect 2006 

estimated hotelling emissions. (2006a) Estimates of potential cancer risks from 

hotelling emissions at the Ports of Los Angeles and Long Beach would represent 

the upper range of cancer risks, given the magnitude of hotelling emissions in the 

San Pedro Bay area and the proximity of the emissions to highly urbanized 

areas. Semi-quantitative estimates of the relative impact of hotelling emissions 

from ocean-going vessels for other areas can be estimated based on a 

comparison of the relative magnitude of emissions and the proximity of the 

emissions to urbanized areas. For example, using the port-specific hotelling 

emission estimates in Table V-2, one would expect that the potential cancer risk 

estimate for the Port of Oakland would be about 20 percent of the estimate for 

the Ports of Los Angeles and Long Beach, while the cancer risk estimates for the 

Port of San Diego would be about 90 percent lower. 

In addition to the risk assessment conducted for the Ports of Los Angeles and 

Long Beach, ARB staff is currently conducting a diesel PM exposure assessment 

study for the West Oakland community which includes the Port of Oakland. This 

assessment will be similar in scope as the study completed for the Ports of 

Los Angeles and Long Beach. Staff expects a draft report on the West Oakland 

study to be released in late November. 

The following section first discusses the cancer risks estimates for hotelling 

emissions in and around the ports of Los Angeles and Long Beach. This 

discussion is followed by a discussion of the methodology used to develop the 

cancer risk estimates. 

Cancer Risk Estimates

ARB staff has estimated that the hotelling emissions may result in risk impacts in 

the nearby residential areas surrounding the Ports of Los Angeles and Long 

Beach. Figure V-3 shows the risk isopleths for 2006 diesel PM hotelling 

emissions at the Ports of Los Angeles and Long Beach superimposed on a map 

that covers the ports and the nearby communities. As can be seen in this figure, 

the area in which the risks are predicted to exceed 100 in a million has been 

estimated to be about 21,000 acres. For the higher risk level of over 

200 in a million, the impacted areas have been estimated to be about 

4,100 acres. Overall, about 100 percent of the effective modeling receptor 
V - 8 

domain of 255 square miles (excluding the port property and the surrounding 

ocean area) has an estimated risk level of over 10 in a million due to hotelling 

emissions from ocean-going vessels. 

Figure V-3: Estimated Diesel PM Cancer Risk from 2006 Hotelling 

Emissions at the POLA and POLB (Wilmington Met Data, Urban 

Dispersion Coefficients, 80th Percentile Breathing Rate, Emission = 430 

TPY, Modeling Domain = 20 mi x 20 mi, Resolution = 200 m x 200 m) 

Using the U.S. Census Bureau’s year 2000 census data, we estimated the 

population within the isopleth boundaries. Table V-4 presents a summary of the 

area impacted and the population affected for the risk ranges of greater than 

10 in a million, greater than 100 in a million, greater than 200 in a million, and 

greater than 500 in a million. Over two million people live in the area around the 

ports that has predicted cancer risks of greater than 10 in a million due to 

hotelling emissions from ocean-going vessels. In other words, almost everyone 

living within the domain is exposed to a risk level of equal or greater than 

380000 385000 390000 395000 400000 405000

Easting (m) 

3725000

3730000

3735000

3740000

3745000

3750000

N

orthin

g (m)

0 1 2

miles
V - 9 

10 in a million. Note that the size of the modeling domain was limited by the 

technical capabilities of the model. However, it is clear that a significant number 

of people outside the modeling domain are exposed to potential cancer risks 

greater than 10 in a million. 

 

Table V-4: Summary of Area Impacted and Population Affected by Risk 

Levels from Hotelling Emissions from Ocean-Going Vessel 

Auxiliary Engines (Emission Inventory Based on 2006 Port 

Calls) 

Risk Level Acres Impacted Population Affected 

Risk > 500 30 750 

Risk > 200 4,100 87,500 

Risk > 100 21,000 341,000 

Risk > 10 163,435 1,978,000 

Note: The effective modeling receptor domain is about 255 square miles or 163,435 acres, and 

the total population within the domain is about 2 million. The area with predicted risks greater 

than 10 in a million extends beyond the modeling domain. As such, the actual acres impacted 

and population exposed to levels greater than 10 in a million are larger than those presented in 

Table V-4. 

Health Risk Assessment Methodology for Cancer

Because analytical tools to distinguish between ambient diesel PM emissions 

from hotelling emissions and that from other sources of diesel PM do not exist, 

we cannot measure the actual concentration of diesel PM from ocean-going 

vessels at-berth. In place of direct measurements of diesel PM, we rely on a 

health risk assessment process to estimate the potential cancer risks from 

hotelling emissions form ocean-going vessels. A health risk assessment, as 

defined under the Air Toxics "Hot Spots" Act, includes a comprehensive 

analysis of the dispersion of hazardous substances into the environment, the 

potential for human exposure, and a quantitative assessment of both individual 

and population-wide health risks associated with those levels of exposure. 

To investigate the potential risks from exposures to hotelling emissions, ARB 

staff used dispersion modeling to estimate the ambient concentration of 

diesel PM from hotelling vessels at the Ports of Los Angeles and Long Beach. 

The key variables that can impact the results of a health risk assessment for 

ocean-going vessel auxiliary engines at-berth include the diesel PM emission 

rate and release characteristics (magnitude, location, and time of day of the 

emissions), the local meteorological conditions, and the length of time a person is 

exposed to the emissions. 

Diesel PM emissions are a function of the age and horsepower of the auxiliary 

engine, the average load the engine is operated at when the vessel is at-berth, 

the emissions rate of the engine, and the annual hours the ships is at-berth. 
V - 10 

Older engines tend to have higher pollutant emission rates than newer engines, 

and the longer an engine operates, the greater the total pollutant emissions. 

Meteorological conditions can have a large impact on the modeled concentration 

of diesel PM, with higher concentrations found along the predominant wind 

direction and under lower or calm wind conditions. How close a person is to the 

emissions plume and how long they breathe the emissions (exposure duration) 

are key factors in determining potential cancer risk, with longer exposure times 

typically resulting in higher risk. 

To examine the potential cancer risks from hotelling emissions, staff used an 

existing analysis of 2002 diesel PM emissions from port related activities 

(including hotelling emissions) at the Port of Los Angles and the Port of Long 

Beach with updated 2006 estimated hotelling emissions. 

Meteorological data from Wilmington was used for this study. The Wilmington 

site is about one mile away from the ports, and the measurements were collected 

in 2001. The U.S. EPA’s Industrial Source Complex Dispersion Model (ISCST3) 

air dispersion model was used to estimate the annual average offsite 

concentration of diesel PM in the area surrounding the two ports.2 The modeling 

domain (study area) spans a 20 by 20 mile area, which includes both the ports, 

the ocean surrounding the ports, and nearby residential areas in which about two 

million people live. The land-based portion of the modeling domain, excluding 

the property of the ports, comprises about 65 percent of the modeling domain. A 

Cartesian grid receptor network (160 by 160 grids) with 200-by-200-meter 

resolution was used in this study. While grids within the ports were included in 

the receptor network, the risks within these grids were excluded from the final 

risk analyses. The elevation of each receptor within the modeling domain was 

determined from the United States Geological Service topographic data. 

The potential cancer risks were estimated using standard risk assessment 

procedures based on the annual average concentration of diesel PM predicted 

by the model and a health risk factor (referred to as a cancer potency factor) that 

correlates cancer risk to the amount of diesel PM inhaled. The methodology 

used to estimate the potential cancer risks is consistent with the Tier-1 analysis 

presented in the Office of Environmental Health Hazard Assessment (OEHHA) 

Air Toxics Hot Spots Program Risk Assessment Guidelines. (OEHHA, 2002) 

(OEHHA, 2003) Consistent with the OEHHA guidelines, we assumed that the 

most impacted individual would be exposed to modeled diesel PM concentrations 

for 70 years. This exposure duration represents an “upper-bound” of the 

possible exposure duration. The potential cancer risk was estimated by 

multiplying the inhalation dose by the cancer potency factor (CPF) of diesel PM 

(1.1 milligrams per kilogram body weight-days (mg/kg-d)-1). 

 

2

 The U.S. EPA has promulgated the AERMOD model as the preferred air dispersion model and 

ISCST3 had been phased out of use by November 2006. The ARB’s estimates of potential 

health risk associated with emissions of diesel PM at the ports of Los Angeles and Long Beach 

was completed in 2005. 
V - 11 

D. Estimating Potential Non-Cancer Impact of Emissions from At-Berth 

Ocean-Going Vessel Auxiliary Engines 

To estimate the statewide potential non-cancer health impacts from auxiliary 

engines on hotelling ships, ARB staff used the same methodology used in 

Appendix A of the Ports and Goods Movement Emission Reduction Plan (ARB, 

2006b) with an updated PM-mortality relationship based on new published data 

(Pope 2002). The following section first discusses the statewide non-cancer 

risks estimates for auxiliary engines on hotelling ships. This is followed by a 

discussion of the methodology used to develop the non-cancer risk estimates. 

Non-Cancer Risk Estimates

Staff estimates that current exposure to direct and secondary diesel PM 

emissions from at-berth ocean-going vessel auxiliary engines can be associated 

with about 61 premature deaths per year. Due to the location of the ocean-going 

vessels’ operations, their emissions were assumed to affect the population only 

within the county in which the vessels are docked. 

Using the 2006 statewide estimate of directly emitted diesel PM hotelling 

emissions and the relationship of diesel PM to PM-mortality derived from Pope’s 

work, we estimate approximately 39 premature deaths (11 – 68, 95 percent 

confidence interval (95% CI)) per year statewide due to uncontrolled, directly 

emitted diesel PM from auxiliary engines on hotelling ships. 

Using the 2006 statewide estimate of NOx hotelling emissions and the 

relationship of NOx/nitrate to PM-mortality discussed below, we estimated 

approximately 22 (6 – 36, 95% CI) premature deaths per year statewide due to 

uncontrolled, secondary diesel PM from auxiliary engines on hotelling ships. 

In addition to PM-mortality, we estimate that the 2006 estimated emissions 

(directly emitted and secondary sources) from at-berth ocean-going vessel 

auxiliary engines will result in the following non-cancer health impacts: 

• 13 hospital admissions due to respiratory causes (8 – 18, 95% CI) 

• 24 hospital admissions due to cardiovascular causes (15 – 37, 95% CI) 

• 1,800 cases of asthma-related and other lower respiratory symptoms 

(700 – 2,800, 95% CI) 

• 150 cases of acute bronchitis (0 – 320, 95% CI) 

• 11,000 work loss days (9,000 – 12,000, 95% CI) 

• 61,000 minor restricted activity days (50,000 – 72,000, 95% CI) 
V - 12 

Non-Cancer Health Effects Methodology

 Primary Diesel PM 

Consistent with U.S. EPA (EPA, 2004), ARB has been using the PM-premature 

death relationship from Pope et al. (2002) since the approval of the Ports and 

Goods Movement Emission Reduction Plan by the Board (ARB, 2006). In 1998, 

the ARB estimated a statewide population-weighted average diesel PM2.5

exposure of 1.8 μg/m3 (ARB, 1998). Using this population-weighted exposure 

estimate and the study by Pope et al. (2002), staff estimated that diesel PM 

exposure can be associated with a mean estimate of 2,200 premature deaths per 

year in California, about 10% higher than previous estimates (Lloyd and 

Cackette, 2001). The diesel PM2.5 emissions corresponding to the diesel PM2.5

concentration of 1.8 μg/m3 is 36,000 tons for the year 2000 based on the 

emission inventory developed for this rule. 

Using this information, we estimate that reducing 17 tons per year of diesel PM2.5

emissions would result in one fewer premature death. This factor is derived by 

dividing 36,000 tons of diesel PM by 2,168 deaths (unrounded number of deaths 

described above). Although a single statewide factor (tons per death) is 

discussed in this example, staff actually developed basin-specific factors for the 

health impacts assessment of emissions from the operation of auxiliary engines 

on hotelling ships. These basin-specific factors were developed using basinspecific diesel PM concentrations and emissions for the year 2000. The basinspecific factors were applied to the county where each port is located to estimate 

health impacts. 

Using these basin-specific factors and after adjusting for population changes 

between 2000 and 2006, staff estimates that 580 tons of emissions from the 

operation of auxiliary engines on hotelling ships for the year 2006 are associated 

with approximately 39 annual deaths (11 – 68, 95% CI). Estimates of other health 

impacts, such as hospitalizations and asthma symptoms, were calculated using 

basin-specific factors developed from other health studies. Details on the 

methodology used to calculate these estimates can be found in Appendix A of 

the Emission Reduction Plan for Ports and Goods Movement in California 

(ARB, 2006). 

Secondary Diesel PM 

In addition to directly emitted PM, diesel exhaust contains NOx, which is a 

precursor to nitrates, a secondary diesel-related PM formed in the atmosphere. 

Lloyd and Cackette (2001) estimated that secondary diesel PM2.5 exposures from 

NOx emissions can lead to additional health impacts beyond those associated 

with directly emitted diesel PM2.5. To quantify such impacts, staff developed 

population-weighted nitrate concentrations for each air basin using data not only 

from the statewide routine monitoring network, which was used in Lloyd and 
V - 13 

Cackette (2001), but also from special monitoring programs such as IMPROVE 

and Children’s Health Study (CHS) in the year 1998. The IMPROVE network 

provided additional information in the rural areas, while the CHS added more 

data to southern California. Staff calculated the health impacts resulting from 

exposure to these concentrations and then associated the impacts with the 

basin-specific NOx emissions to develop basin-specific factors (tons per death). 

The basin-specific factors were applied to the county where each port is located 

to estimate health impacts. Using a similar approach as that for primary diesel 

PM and adjusting for population changes between 2006 and 1998, staff 

estimates that approximately 7,000 tons of emissions from the operation of 

auxiliary engines on hotelling ships in year 2006 are associated with an 

estimated 22 annual premature deaths (6 – 36, 95% CI). Other health effects 

were also estimated as outlined above. 

E. Assumptions and Limitations of Health Impacts Assessment

Several assumptions were used in quantifying the health effects of PM exposure. 

They include the selection and applicability of the concentration-response 

functions, the exposure assessment, and the baseline incidence rates. These 

are briefly described below. 

• For premature death, calculations were based on the concentrationresponse function of Pope et al. (2002). ARB staff assumed that the 

concentration-response function for premature death in California is 

comparable to that developed by Pope and colleagues. This is supported 

by other studies (Dominici et al. 2005, Franklin et al. 2007) in California 

showing an association between PM2.5 exposure and premature death 

similar to that reported by Pope et al. (2002). In addition, the Pope et al. 

(2002) study included subjects in several metropolitan areas of California. 

The U.S. EPA has been using the Pope et al. (2002) study for its 

regulatory impact analyses since 2004. For other health endpoints, the 

selection of the concentration-response functions was based on the most 

recent and relevant scientific literature. Details are in the Emission 

Reduction Plan for Ports and Goods Movement in California (ARB, 2006). 

• ARB staff assumed the model-predicted diesel PM exposure estimates 

published in the report titled “Proposed Identification of Diesel Exhaust as 

a Toxic Air Contaminant” (ARB, 1998) could be applied to the entire 

population within each basin. That is, the entire population within the 

basin was assumed to be exposed uniformly to modeled concentration, an 

assumption typical of this type of assessment. 

• Due to the location of the ocean-going vessels’ operations, their emissions 

were assumed to affect the population only within the county in which the 

vessels are docked. 
V - 14 

• The basin-specific factors relating emissions to health effects were applied 

to the county where each port is located to estimate health benefits. That 

is, ARB staff assumed that the basin-specific factors applied to each 

county within a basin. 

• ARB staff assumed the baseline incidence rate for each health endpoint 

was uniform across each county. This assumption is consistent with 

methods used by the U.S. EPA for its regulatory impact assessment, and 

the incidence rates match those used by U.S. EPA. 

• Although the analysis illustrates that reduction in diesel PM exposure 

would confer health benefits to people living in California, we did not 

provide estimates for all endpoints for which there are C-R functions 

available. Health effects such as myocardial infarction (heart attack), 

chronic bronchitis, and onset of asthma were unquantified due to the 

potential overlap with the quantified effects such as lower respiratory 

symptoms and hospitalizations. In addition, estimates of the effects of PM 

on low birth weight and reduced lung function growth in children are not 

presented. While these endpoints are significant in an assessment of the 

public health impacts of diesel exhaust emissions, there are currently few 

published investigations on these topics, and the results of the available 

studies are not entirely consistent (ARB, 2006). In summary, because 

only a subset of the total number of health outcomes is considered here, 

the estimates should be considered an underestimate of the total public 

health impact of diesel PM exposure. 
V - 15 

REFERENCES: 

California Air Resources Board. Diesel Particulate Matter Exposure Assessment 

Study for the Ports of Los Angeles and Long Beach, April 2006. (ARB, 2006a) 

California Air Resources Board. Emission Reduction Plan for Ports and Goods 

Movement in California; April 2006. 

http://www.arb.ca.gov/planning/gmerp/march21plan/march22_plan.pdf 

(ARB, 2006b) 

California Air Resources Board. Proposed Identification of Diesel Exhaust as a 

Toxic Air Contaminant, Appendix III, Part A, Exposure Assessment, April 1998. 

(ARB, 1998) 

California Air Resources Board and Office of Environmental Health Hazard 

Assessment. Staff Report: Public Hearing to Consider Amendments to the 

Ambient Air Quality Standards for Particulate Matter and Sulfates, 2002. 

http://www.arb.ca.gov/research/aaqs/std-rs/pm-final/pm-final.htm; (ARB, 2002) 

Dominici et al. 2005. Revised analyses of the National Morbidity, Mortality, and 

Air Pollution Study: mortality among residents of 90 cities. J Toxicol Environ 

Health A. Vol. 68(13-14):1071-92. 

Franklin et al. Association between PM2.5 and all-cause and specific-cause 

mortality in 27 US communities. J Expo Sci Environ Epidemiol. Vol. 17: 279-287, 

2007. 

 

Lloyd, A.C.; Cackette, T.A.; Diesel Engines: Environmental Impact and Control; J 

Air Waste Manage. Assoc. 2001, 51: 809-847, 2001. 

http://www.arb.ca.gov/research/seminars/lloyd/AWMA2001/JAWMADieselCritical

Review.pdf (Lloyd /Cackette, 2001) 

Office of Environmental Health Hazard Assessment. The Air Toxics Hot Spot 

Program Risk Assessment Guidelines: Part II-Technical Support Document for 

Describing Available Cancer Potency Factors; 2002. (OEHHA, 2002) 

Office of Environmental Health Hazard Assessment. Air Toxics Hot Spots 

Program Risk Assessment Guidelines: The Air Toxics Hot Spots Program 

Guidance Manual for Preparation of Health Risk Assessments; 2003. 

(OEHHA, 2003) 

Pope et al. Lung cancer, cardiopulmonary mortality, and long-term exposure to 

fine particulate air pollution. Journal of the American Medical Association. Vol. 

287 (9): 1132-41, 2002. 

 (Pope, et. al., 2002) 
V - 16 

U.S. Environmental Protection Agency (EPA), Assessment and Standards 

Division, Office of Transportation and Air Quality. Final Regulatory Analysis: 

Control of Emissions from Nonroad Diesel Engines Chapter 4. EPA420-R-04-

007. May 2004. http://www.epa.gov/nonroad-diesel/2004fr/420r04007j.pdf 

(EPA, 2004) 
VI - 1 

VI. SUMMARY OF THE PROPOSED REGULATION 

In this chapter, we provide a plain English discussion of the key requirements of the 

proposed regulation for reducing emissions from ocean-going vessels while they are 

docked (or “hotelling”). This chapter begins with a general overview of the 

regulation. The remainder of the chapter follows the structure of the proposed 

regulation and provides an explanation of each major requirement of the proposal. 

This chapter is intended to satisfy the requirements of Government Code section 

11346.2, which requires that a noncontrolling “plain English” summary of the 

regulation be made available to the public. 

A. Overview of the Proposed Regulation

The proposed regulation requires that the operators of container ships, refrigerated 

cargo ships (“reefers”), and passenger ships visiting specific California ports either 

shut down their auxiliary engines for most of their visit to a port or reduce the 

emissions from those auxiliary engines by some specified percentages while 

docked. The specific California ports identified in the proposed regulation where 

these requirements would apply are the Ports of Los Angeles, Long Beach, Oakland, 

San Diego, San Francisco, and Hueneme. The Ports of Los Angeles and 

Long Beach are considered one port for purposes of this regulation. 

The “limited engine use” option requires operators of container ships, passenger 

ships, and reefers that visit California ports to shut down their auxiliary engines for 

most of their stay while hotelling. Auxiliary engines would be allowed to run for three 

or five hours per visit. Specifically, these auxiliary engines must be shut down for at 

least 50 percent of a fleet’s total visits to a California port in 2014 and at least 80 

percent of the fleet’s total visits to a port in 2020. While auxiliary engines are shut 

down, the ship’s onboard electrical requirements would need to be satisfied by some 

other source of power. The source of electrical power used instead of the auxiliary 

engines must be provided either by the grid or by another power source that meets 

specific emissions standards. 

The “emissions reduction” option requires vessel operators to reduce their fleet 

hotelling emissions by specific amounts by specific dates, depending on the types of 

emission reduction techniques that are applied to the fleet. The emission reduction 

techniques that could be applied to a fleet include: 1) using selected vessels for 

grid-based power based on potential auxiliary engine emission reductions rather 

than fleet visit percentages; 2) using distributed generation equipment to provide 

power to a vessel; 3) using alternative emission controls onboard a vessel or 

adjacent to the vessel; and 4) using a combination of these techniques. 
VI - 2 

B. Purpose 

The purpose of this proposed regulation is to reduce emissions of diesel PM and 

NOx, with a co-benefit of reducing CO2, a significant greenhouse gas (GHG). If 

adopted, the proposed regulation will achieve significant emission reductions. 

Specifically, the proposed regulation will have the following benefits: 

• diesel PM emission reductions will reduce the potential cancer risk, premature 

mortality, and other adverse health impacts from PM exposure to people who live 

in the vicinity of California’s major ports; 

• diesel PM emission reductions will reduce regional exposure to PM, and help 

continue progress toward State and federal ambient air quality standards for 

PM10 and PM2.5; 

• NOx emission reductions will reduce the formation of regional ozone and 

secondary nitrate PM; and

• CO2 emission reductions will reduce overall GHG emissions and help mitigate 

the effect of GHGs on global climate change.

C. Applicability 

The regulation would apply to any person who owns, operates, charters, rents, or 

leases any container ship, passenger ship, or refrigerated cargo ship that visits a 

California port, or any person who owns or operates a port or terminal located at a 

port where container, passenger, or refrigerated cargo (also known as “reefer”) ships 

visit. These ports include Los Angeles, Long Beach, Oakland, San Diego, San 

Francisco, and Hueneme. For purposes of complying with the proposed regulation, 

the ports of Los Angeles and Long Beach are considered as one port. 

The regulations apply to both U.S.-flagged vessels and foreign-flagged vessels. 

Foreign-flagged vessels are vessels registered under the flag of a country other than 

the United States. 

D. Exemptions 

The proposed regulation contains general and specific exemptions. Under the 

general exemptions, vessels in “innocent passage”; vessels owned or operated by 

local, state, federal or foreign governments in government non-commercial service; 

steamships; and auxiliary engines using natural gas are exempt from the regulation. 

“Innocent passage” generally means travel within the 24 nautical miles boundary off 

California’s coastline without stopping or anchoring, except in limited situations such 

as when the vessel is in distress or must stop to comply with U.S. Coast Guard 

regulations.
VI - 3 

Military ships used for purposes of national defense and safety would not be affected 

by the proposed regulation. The military operates numerous vessels and the Navy 

has a long tradition of using shore-side services, including electricity, when vessels 

are in port. ARB staff is unaware of any local or state entity that operates an 

ocean-going vessel. 

A steamship is an ocean-going vessel whose primary propulsion and electrical 

power are provided by steam boilers. Unlike engines, boilers must be shutdown and 

started up over many hours making it infeasible to shutdown these boilers for the 

typical port visit. Additionally, there are less then ten steamships currently visiting 

California ports. These ships are all container vessels that are 40 years old and 

represent only two percent of the total container vessels that visited California ports 

during 2006. 

Although staff is not aware of any vessels using natural gas in their auxiliary 

engines, we provided an exemption for vessel operators who may choose to switch 

fuels to natural gas. As with shore-based engines used in distributed generation 

applications, switching to natural gas reduces NOx emissions by 85 percent and 

eliminates diesel PM emissions. 

There are also particular exemptions from specified portions of the regulation for 

emergency events and delays caused by federal agency inspections and a de 

minimus exemption for small fleets, which will be discussed later in this chapter.

As noted earlier in this report, vessel categories that are not attractive candidates for 

shore power—bulk and general cargo ships, tankers, and vehicle carriers—are 

excluded from the proposed regulation; however, staff proposes to address the 

auxiliary engine emissions from these vessels in a subsequent rulemaking.

E. Limited Auxiliary Engine Operation 

 General Requirements

The proposed regulation allows for two options for reducing a fleet’s hotelling 

emissions: 1) ship operators can either shut down their auxiliary engines during most 

of their stay while in port; or 2) ship operators can reduce the emissions from those 

auxiliary engines while in port by applying one or several emission-reduction 

techniques to their fleet’s vessels. Each option would have different compliance 

dates. 

The “limited engine use” option in the proposed regulation requires that the 

operators of container ships, passenger ships, and reefers that visit California ports 

shut down their auxiliary engines during most of their stay while hotelling. 

Specifically, these auxiliary engines must be shut down for at least 50 percent of a 

fleet’s total visits to a California port in 2014 and at least 80 percent of the fleet’s 
VI - 4 

total visits to a port in 2020. While auxiliary engines are shut down, the ship’s 

onboard electrical needs must be satisfied by some other source of power. The 

source of electrical power used instead of the auxiliary engines must be provided 

either by the grid or by another power source that meets specified emission 

standards. 

Staff recognizes that sufficient time must be allowed to connect and disconnect 

electrical lines for shore power, so the proposed regulation allows the auxiliary 

engines to operate for up to three hours total during a visit on vessels using 

synchronous power transfer, or five hours total during a visit for vessel that lose 

power during the process of switching power from the vessel’s auxiliary engines to 

shore power. This time period may be extended due to circumstances beyond the 

control of the vessel operators, such as emergency events or delays resulting from 

obligations imposed by federal agencies (for example, the U.S. Coast Guard or 

some other branch of the Department of Homeland Security). 

The regulation defines “fleet” as vessels operated under the direct control of a 

person or a company. Direct control includes the operation of vessels that are under 

a contract, lease agreement, or other arrangement with a third-party to operate the 

vessels. Under of the proposed regulation, a company or person will have a 

different fleet for each California port visited. 

A “visit” is defined in the regulation as the time period between when a vessel initially 

ties its mooring lines upon arrival at a berth and when it casts off its mooring lines 

prior to departure. When a vessel visits two different berths and the time interval 

between when the mooring line is cast off at the first berth visited and when the 

mooring line is initially tied to the next berth is less than two hours, then those two 

berth visits are still considered one “visit.” This provision was added to ensure that 

ships visiting more than one berth at the ports of Los Angeles and Long Beach 

(which are treated as one port in the regulation) within a short amount of time would 

be treated as one visit. Port wharfinger data indicated that some container and 

reefer vessels do visit more than one berth in the POLA/POLB complex during a 

visit. 

 Compliance Dates for Grid-Based Shore Power

While the final requirements of the proposed regulation are consistent with the 

proposal in the Goods Movement Emission Reduction Plan (80 percent of vessel 

visits to California ports using shore power by 2020), the interim compliance dates 

and vessel visit percentage requirements in the proposed regulation are different. 

As discussed in Chapter I, the strategy for shore power contained in the Goods 

Movement Emission Reduction Plan required 20 percent of the vessel visits to 

California ports use shore power by 2010 and 60 percent of the vessel visits use 

shore power by 2015. 
VI - 5 

Staff did not propose a 2010 compliance requirement for grid-based shore power. 

Grid-based shore power implementation will require extensive modification to port 

and terminal electrical infrastructures. In some cases, a significant upgrade to the 

utility grid may be needed to bring the additional electrical power to the port. Such 

modifications are likely to require environmental review, permits, and complex 

construction—construction activity that needs to be coordinated with an operating 

terminal—which is likely to take up to five years to complete. Assuming the 

proposed regulation is effective in late 2008, the proposed regulation’s initial 

milestone of 2014 for shore power allows for five years for initial implementation. 

Although 2014 is the first compliance date for grid-based shore power in the 

proposed regulation, staff expects earlier reductions to occur from shore power 

projects already planned at some California ports. Emissions reductions from 

vessels using shore power at Long Beach and Los Angeles will occur well before 

2014 because of commitments made in the Clean Air Action Plan. If the plan is fully 

implemented, staff anticipates reductions of 1,300 tons of NOx emissions and 37 

tons of PM emissions by 2011, which represents a reduction in emissions of 15 

percent for NOx and 20 percent for PM of emissions in 2011 at the ports. The ports 

are continuing to update the Clean Air Action Plan, and it is likely both ports will 

identity additional reductions for shore power prior to 2014. In addition, to satisfy the 

2014 milestone, staff anticipates that emission reductions as a result of the 

regulation will begin in 2011 and significant reductions will occur in 2012 and 2013. 

Finally, the proposed regulation requires that 50 percent of the vessel visits connect 

to shore power in 2014 as opposed to the Goods Movement Emission Reduction 

Plan’s strategy for a shore power that requires 60 percent of the vessel visits use 

shore power by 2015. Staff proposed a compliance date one year earlier to allow 

the NOx emission reductions from the proposed regulation to be used to satisfy the 

South Coast air basin SIP for attaining the PM2.5 ambient air quality standard. By 

moving the date up one year, staff proportionally reduced the percentage of vessel 

visits from 60 percent to 50 percent. 

 De Minimus Fleet Visit Levels

Since the emission reduction requirements of the proposed regulation are based on 

fleet averages, ARB staff recognized that infrequent visitors belonging to small fleets 

should be exempt from the regulation. Those vessels are simply not cost-effective 

for shore power. Consequently, ARB staff added a de minimus limit to the proposed 

regulation for each ship category. 

For example, at the Port of San Diego in 2006, 18 vessels from 18 different 

passenger ship companies visited just once. Without a de minimus exemption, each 

of those vessels would have to retrofit to use shore power. (The regulation does 

require that if any of these ships were already equipped for shore power, it would 

have to plug into a berth that is likewise equipped with shore power capabilities.) 

There are similar cases in the container ship and reefer ship categories. 
VI - 6 

Staff chose 25 visits as the de minimus number of fleet visits for the container ships 

and reefers because the 2006 data revealed that, below that level, shore power was 

not cost-effective due to infrequent visitation of those vessels to a California port. 

Nevertheless, the capture of ship visits to California ports is extremely high, as seen 

in Table VI-1. 

Table VI-1: Percentage of Vessel Fleets Subject to the Proposed Regulation 

(2006 Wharfinger Data)

Category 

Total / 

Affected 

Fleets 

Total / 

Affected Visits

Percentage of 

Visits 

Captured 

Container 

Ships 66 / 44 4,928 / 4,737 96 % 

Passenger 

Ships 51 / 15 686 / 632 92 % 

Reefers 11 / 3 300 / 203 68% 

Total 128 / 62 5,914 / 5,572 94% 

Most of the reefer fleets are exempt from the proposed regulation; however, these 

fleets make too few visits and are seasonal in nature to be cost-effective for shore 

power. By affecting the three largest reefer fleets in California, the proposed 

regulation will capture two-thirds of the total visits by reefers. 

F. Emissions Reduction Option 

 General Requirements

An alternative to the “limited engine use” approach is the “emissions reduction” 

option, in which the ship operators reduce their fleet hotelling emissions by applying 

one or several emission-reduction techniques to their fleet’s vessels. The 

compliance dates for this approach are different than those for the limited engine 

use option. Grid-based power involves a significant lead time to install at a terminal. 

Alternative emission controls, such as distributed generation (DG) power and 

emission controls onboard a vessel or at the berth, could provide reductions in 

hotelling emissions much earlier than grid-based shore power. Consequently, staff 

is requiring earlier compliance dates for the “emission reduction option” than what is 

required for the “limited engine use.” 

The emission reduction techniques that could be applied to a fleet include: 1) ship 

operators selecting vessels for grid-based power based on potential auxiliary engine 

emission reductions rather than fleet visit percentages; 2) using distributed 

generation equipment to provide power to a vessel; 3) using alternative emission 
VI - 7 

controls onboard a vessel or adjacent to the vessel; and 4) a combination of these 

techniques. 

 Compliance Dates for Emission Reduction Option

For ship operators satisfying the emission reduction option by selecting vessels for 

grid-based power based on potential auxiliary engine emission reductions rather 

than fleet visit percentages, the NOx and PM emissions from the fleet’s auxiliary 

engines at a port must be reduced by 50 percent from the baseline fleet emissions 

by 2014 and by 80 percent by 2020. 

For ships satisfying the emission reduction option by using distributed generation 

equipment to provide power to a vessel or by using onboard or shore-side 

alternative emission controls, the NOx and PM emissions from the fleet’s auxiliary 

engines at a port must be reduced by 20 percent from the baseline fleet emissions 

by 2010, 40 percent by 2012, 60 percent by 2014, and 80 percent by 2016. 

For ships satisfying the emission reduction option by using a combination of grid 

power, distributed electrical generation, or alternative emission controls, the NOx 

and PM emissions from the fleet’s auxiliary engines at a port must be reduced by 

20 percent from the baseline fleet emissions by 2012, 50 percent by 2014, and 

80 percent by 2020. 

 Percent Emission Reduction Calculations

Percent emission reductions are calculated as a ratio between the emissions 

reduced and the baseline emissions, which are defined as the emissions that would 

have otherwise occurred if no controls had been applied. Baseline fleet emissions 

are calculated by multiplying the emission rate, average berthing time, average atberth power load, and number of visits of each ship and summing the results for 

each ship in the fleet. Post-baseline fleet emissions are calculated in a similar 

fashion with the addition of multiplying a control factor, where applicable, for each 

ship’s emission rates. 

The proposed regulation provides default values for making the percent emission 

reductions calculation, including default values for emission factors and power 

requirements. In addition, the proposed regulation provides procedures for 

determining control factors and applicable emission testing procedures. 

 Requirements for Distributed Generation (DG) Power

Sources of electrical power, other than the grid, that are used to comply with the 

emission reduction option would be required to satisfy additional requirements. 

Before January 1, 2014, distributed generation equipment must satisfy the emission 

standards applicable to a newly manufactured spark-ignited off-road engine. These 

engines are typically 85 percent cleaner than the NOx emissions from the vessel’s 
VI - 8 

auxiliary engines and do not emit any diesel PM. However, after factoring in the 

time the vessel is actually using the power from another source, the overall 

efficiency for NOx reduction will be 70 to 80 percent and diesel PM reduction will be 

85 to 95 percent. 

 

 As of January 1, 2014, all distributed generation would be subject to a more 

stringent emission standard that is equivalent to a spark-ignited engine using Best 

Available Control Technology (BACT). The application of BACT will reduce 

emissions of NOx from distributed generation by another order of magnitude (from 

two grams per kilowatt-hour to 0.2 grams per kilowatt-hour). Finally, the source of 

electrical power must emit no more CO2 (a greenhouse gas) emissions than a 

combined-cycle gas turbine—the emissions level that the California Public Utilities 

Commission recommended for unspecified sources of power. 

G. Test Methods 

The proposed regulation includes test methods to determine the emissions from the 

auxiliary engines when alternative emissions controls are applied in lieu of shutting 

off the engines while hotelling, or from engines used for distributed generation of 

electricity. Specifically, the proposed regulation requires using ARB Method 100 

testing for NOx and CO2; ISO 8178 test procedures for diesel PM; Bay Area Air 

Quality Management District Source Test Procedure ST-1B for ammonia slip from 

SCR systems; and ISO 8754 for the sulfur content of fuel. 

H. Recordkeeping and Reporting Requirements 

The proposed regulation has reporting and recordkeeping requirements affecting the 

vessel operators, terminals and ports. 

Vessel Operators

The reporting and recordkeeping requirements for vessel operators depend upon the 

compliance option selected by the vessel operator. The proposed regulation 

requires a vessel fleet plan to be submitted to the Executive Officer of the ARB in the 

year prior to the year of the fleet’s regulatory compliance dates. The regulatory 

compliance dates and the fleet plan due dates are listed in Table VI-2 below, 

according to each compliance option available to vessel operators. 
VI - 9 

 Table VI-2: Schedule of Compliance Dates and Fleet Plans for Vessel 

Operators for Each Regulatory Compliance Option 

Date 

Limited Engine 

Operation 

(Grid) 

Reduced 

Emission 

Operation 

(Grid) 

Reduced 

Emission 

Operation 

(Non-Grid) 

Reduced 

Emission 

Operation 

(Both) 

July 1, 2009 - - Fleet plan - 

January 1, 2010 - - Compliance 

date 

- 

July 1, 2011 - - Fleet plan Fleet plan 

January 1, 2012 - - Compliance 

date 

Compliance 

date 

July 1, 2013 Fleet plan Fleet plan Fleet plan Fleet plan 

January 1, 2014 Compliance 

date 

Compliance 

date 

Compliance 

date 

Compliance 

date 

July 1, 2015 - - Fleet plan - 

July 1, 2016 - - Compliance 

date - 

July 1, 2019 Fleet plan Fleet plan - Fleet plan 

January 1, 2020 Compliance 

date 

Compliance 

date - 

Compliance 

date 

In addition to the vessel fleet plans, the proposed regulation requires an annual 

statement of compliance to be submitted to the Executive Officer of the ARB 

certifying compliance with the regulatory requirements for the previous calendar 

year. As with the fleet plans, the dates for the initial submittals depend upon the 

compliance option selected by the vessel operator. The initial submittal dates for the 

annual statements of compliance are listed below in Table VI-3 according to each 

compliance option available to vessel operators. 
 VI - 10 

 Table VI-3: Schedule for Initial Submittal of Annual Statements of Compliance 

for Each Compliance Option 

Compliance Option First Regulatory 

Compliance Date 

Initial Submittal of 

Annual Statement of 

Compliance 

Limited Engine Operation 

(Grid) January 1, 2014 March 1, 2015 

Reduced Emission 

Operation (Grid) January 1, 2014 March 1, 2015 

Reduced Emission 

Operation (Non-Grid) January 1, 2010 March 1, 2011 

Reduced Emission 

Operation (Both) January 1, 2012 March 1, 2013 

The recordkeeping and reporting requirements are simpler for the limited engine use 

option because they focus on only those vessels that will comply with the 2014 and 

2020 shore power requirements. The recordkeeping and reporting requirements for 

the emission reduction option are more significant because the vessel operator must 

track the emissions of each vessel in the fleet. 

Terminal Operators

A terminal that receives more than 50 vessel visits in 2008 is required to submit a 

plan to the Executive Officer of the Air Resources Board by July 1, 2009. This plan 

is required to identify how the terminal will be upgraded to allow affected vessels to 

satisfy either the limited engine use option or the emissions reduction option. The 

terminal is also required to submit plan updates at a frequency dependant upon the 

control strategy selected by the vessel and terminal operators. The plan updates 

must include contingency measures, should the planned infrastructure modifications 

identified in the original plan prove to be infeasible by the specified target dates. 

In addition, the terminal operator is required to keep records of equipment 

breakdowns that affect a vessel’s ability to comply with the limited engine use option 

or the emission reduction option, and records of electricity usage for shore power. 

Ports 

The port is required to submit wharfinger data annually to ARB’s Executive Officer. 

The port’s report must document when each vessel visits the port, the berth that the 

vessel visited, and the dates and times that the vessel was initially tied to the berth 

and subsequently released from the berth. 
 VI - 11 

I. Violations 

The proposal specifies a violations provision that provides, among other things, that 

any violation of any part of the regulation would constitute a single, separate 

violation for each hour that the violation occurs. The exception to this would be for 

violations of the recordkeeping and reporting requirements; a violation of those 

provisions would constitute a single, separate violation for each day that the violation 

occurs. 

 

J. Regulatory Alternatives 

Staff considered two regulatory alternatives: 1) targeting the highest-emitting ships 

to obtain the necessary reductions, or 2) using best available control technology 

(BACT) on auxiliary engines while the ship is hotelling. 

Alternative 1 would target the ships that make the most visits to specific ports and 

make them use shore power or an equivalent control technology to reduce hotelling 

emissions. For example, a requirement under this regulatory alternative might state 

“container ships making more than four visits to a California port in 2014 must turn 

off their engines or use an alternative control technology.” 

Staff estimated that this regulatory alternative would be as effective as the proposed 

regulation; however, staff did not pursue this alternative because of the complexity 

and difficulty of tracking the ships that were required to reduce emissions. Many of 

these ships would be repositioned elsewhere, while other ships would replace them 

in California service, creating excessive recordkeeping requirements and practical 

enforcement challenges. 

Alternative 2 requires vessel operators to install BACT on their auxiliary engines. 

Currently, few emission-control technologies that have been used successfully on 

land-based engine applications have been demonstrated on marine engines. 

Nevertheless, for the purpose of determining a potential cost-effectiveness of this 

alternative, staff selected selective catalytic reduction (SCR) for NOx emissions 

reductions and diesel oxidation catalyst (DOC) for diesel PM emissions reductions. 

Installing this equipment on the same ships affected by the proposed regulation 

would cost less than the overall cost of the proposed regulation. However, the 

reduction of PM emissions would be considerably less with this BACT alternative 

because DOCs achieve only about 25 percent PM emission reductions. 

Furthermore, the varying load of the auxiliary engines during transiting, 

maneuvering, and hotelling would compromise the performance of the SCR, 

achieving less than 80 percent emissions reduction.
 VI - 12 

Considering the unproven application of these technologies for marine engines, 

fewer total emissions reductions, and much higher cost-effective values for diesel 

PM emissions reductions, staff did not pursue this alternative regulatory alternative. 
VII - 1 

VII. FEASIBILITY OF PROPOSED REGULATORY REQUIREMENTS 

The proposed regulation allows for two options to reduce hotelling emissions; 

ship operators can either shut down their auxiliary engines during most of their 

visit to a port (“limited engine use” option), or reduce the emissions from those 

auxiliary engines by some specified percentages while docked (“emissions 

reduction option”). 

Staff expects most ship operators to comply with the limited engine use option in 

the regulation. While the proposed regulation’s shutdown requirement does not 

require vessels, ports, or terminals to install or modify any equipment, staff 

anticipates that vessel owners, ports, and terminals will elect to install equipment 

that will allow vessels to use shore power while the auxiliary engines are shut 

down at berth. The source of the shore power is expected to be the utility grid. 

However, some ship operators may decide to reduce their fleet hotelling 

emissions by applying a number of other techniques to their fleet, including using 

alternative sources of power at the berth (e.g. distributed generation equipment), 

and using onboard or shore-based engine emission control technologies. 

This chapter will discuss the feasibility of grid-based shore power, modifications 

that would be needed to ships and terminals to make shore power a viable 

hotelling emission reduction measure, and port power demands for meeting the 

shore power requirements. Staff will also discuss possible distributed generation 

technologies that operators could use as alternative sources of shore power, 

NOx and PM emission reduction control strategies that could be used to reduce 

fleet emissions, and emission reduction demonstration projects that have been 

conducted on marine vessel engines. 

A. Shutting Off Engines and Connecting to Grid-Supplied Shore Power 

The regulation requires ship operators to shut off auxiliary engines except for 

three or five hours of total operation, during 50 percent and 80 percent of port 

visits by 2014 and 2020, respectively. To achieve this, power that would 

otherwise be supplied by the ships’ auxiliary engines must be available at the 

berth, and the ships must be able to connect to the shoreside power. 

As was demonstrated in Chapter IV, grid-supplied shore power has been proven 

and is technologically feasible. Shore power is already being used or will soon 

be used for passenger ships, container ships, bulk ships and oil tankers at 

California ports. Shore power is currently used at the China Shipping Terminal at 

the Port of Los Angeles (POLA) and at the USS POSCO facility at Pittsburg. 

Ships will soon be utilizing shore power at two other container terminals at POLA 

and at a tanker terminal at the Port of Long Beach (POLB). In addition, POLA 

and POLB have committed to adding shore power to their passenger-ship 

terminals and to several of their container-ship terminals. Several passenger 

ships that visit California ports have been retrofitted to connect to shore power, 
VII - 2 

and some container ship owners have committed to adding shore power 

equipment to their newbuilds and retrofitting some of their existing fleet with 

shore-power capabilities. 

As was illustrated in Chapter IV, modifications are needed for both terminals and 

ships to utilize grid-based shore power as a method for reducing hotelling 

emissions. The following sections discuss these modifications. 

 Terminal Modifications

Terminal operators will have to design shore-power installations based on the 

types of ships visiting the terminal. Container-ship, passenger-ship, and reefership terminals may have different shore-power designs because the ships have 

different voltage and power loads. Most ocean-going vessels, including reefers, 

are configured for 440 - 480 volts (V). Larger container ships and passenger 

ships are configured for 6.6 kilovolts (kV), although the larger, newer, passenger 

ships are configured for 11 kV. The future trend in container-ship design is to 

build larger ships that use 6.6 kV; however, some manufacturers are still building 

vessels to operate on 440 - 480 V. Since all ships do not have the same voltage 

requirements, a transformer will be needed to increase or decrease the voltage 

to a ship. The terminal operator must decide if the transformer will be provided at 

the berth or expected to be onboard visiting ships. For example, the Ports of 

Los Angeles (POLA) and Long Beach (POLB) will provide 6.6 kV power at their 

container terminals when they install future shore power projects. Ships using 

lower voltage will be expected to use an onboard transformer during shore power 

connection. However, the cruise ship terminal at the Port of Los Angeles will 

have a dual voltage transformer at the wharf to accommodate the various-sized 

passenger ships that visit the port. 

Terminal operators must also decide if power connection cables will be placed at 

the berth or onboard the visiting ships. As with transformers, POLA and POLB 

will expect visiting ships to carry the necessary connecting cables and reels 

onboard, but the passenger ship terminal at POLA will have cables and reels 

stored on-site. 

Transformers, cables, and other necessary power connection equipment can 

also be placed in a container that is permanently stored on a ship. Some 

container ship companies have indicated that they will use this configuration with 

the ships they choose to retrofit with shore power capability. 

To accommodate ships that carry cables onboard, receptacles must be provided 

at the berth into which the ships can plug and receive the power. More than one 

power receptacle may be needed at the berth to accommodate various-sized 

ships and to allow ships to tie-down to the berth on the port or starboard side. 
VII - 3 

 Ship Modifications

Shipping companies that visit shore-power equipped terminals will have to modify 

existing ships that visit the terminals or build new ships with shore power 

capabilities. As was mentioned in Chapter IV, some passenger ships have been 

retrofitted with shore power capabilities and some were built with shore power 

equipment. The same will be true with container ships. Currently no reefer ships 

have been modified or built with shore power capabilities. Typically, shipping 

companies frequently change their ships’ route of service. To reduce the number 

of ships needing to be retrofitted, ship companies may need to commit their 

shore-power equipped ships to specific routes for several years. 

 Synchronization of Power Transfer

Ship owners will also have to consider the synchronization of power transfer 

when retrofitting existing ships or for new-builds. Some vessels will lose power 

for a period of time during the process of switching power from the vessel’s 

auxiliary engines to shore power because the power transfer is not synchronized. 

However, ship side shore power equipment can be designed to synchronize 

power transfer so that the power from the shore is ramped up while the power 

from the auxiliary engines is ramped down. In this manner, there is no 

interruption to the ship’s power load demands during transfer. Passenger ships 

use synchronized power transfer when connecting to shore power because any 

interruption to power on these types of ships is unacceptable. 

 

 Standardization of Power Connection

With six ports and over 1,400 ships potentially affected over the life of the 

proposed regulation, standardization of power connections will be a concern to 

ship and terminal operators. Generally, the number of cables needed to connect 

ships to shore power is based on the voltage and power load of the ship. Ships 

with lower-power voltage would require more cables for power connection. For 

example, nine cables are used to supply 440 V of power to the ships at POLA’s 

China Shipping Terminal. The container ship, NYK Atlas, which operators at 

6.6 kV, uses two cables to connect to shore power. Four power cables are used 

to supply passenger ships (which generally have higher power loads than 

container ships) with 6.6 kV or 11 kV of power in Juneau and Seattle. 

Recognizing the importance of standardizing shore power connection at ports 

throughout the world, the International Organization of Standardization (ISO) 

formed a working group under its Technical Committee 8, Ships and Marine 

Technology, to develop a standardized shore-to-ship power system. The Port of 

Los Angeles is a member of this working group. Subcommittees have been 

formed to explore a number of issues related to developing a shore-to-ship 

power standard, including power demand, voltage, reliability, power transfer, 

equipment location, power outlets, and cable management systems. The 
VII - 4 

objective is to establish Publicly Available Specifications (PAS), which will allow 

ports and carriers to refer to an official document that provides shore-to-ship 

power specifications. 

 Additional Power Supply for Shore Power

Power demand will increase at the ports as shore power installations are added 

to the terminals. ARB staff estimated the total power demand for satisfying the 

shore power requirements by 2020. Table VII–1 presents peak load in 

megawatts (MW) and annual power consumption in megawatt-hours (MW-hr) by 

2020 for each affected ship category and port. 

Table VII-1: Estimated Peak Load and Annual Power Consumption 

by 2020 for Shore Power 

Port Ship Category Peak Load (MW) 

Annual power 

consumption 

(MW-hr) by 2020 

Los Angeles Container 40 215,000

Long Beach Container 40 168,000

Oakland Container 20 94,000

Los Angeles Passenger 30 40,000

San Diego Passenger 30 53,000

Long Beach Passenger 15 24,000

San Francisco Passenger 15 9,000

San Diego Reefer 10 24,000

Hueneme Reefer 5 16,000

Statewide totals 205 643,000

By 2020, the peak load for shore power will be approximately 205 megawatts, 

and the annual power consumption for all ship categories will be over 

640 gigawatt-hours. Not surprisingly, container ships, having the most ship visits 

to Californian ports, will have the greatest annual power consumption (about 

75 percent of the statewide total). Although there are far fewer passenger ships 

visiting California ports than container ships, passenger ships have the highest 

at-berth power loads of all three ship categories, resulting in significant annual 

power consumption. The number of reefer ships affected by the proposed 

regulation will be the fewest of the three ship categories. Considering that reefer 

ships have lower power loads, reefers are expected to make up the smallest 

portion of annual power consumption from shore power by 2020. 
VII - 5 

Based on projected power consumption information in the most recent Integrated 

Energy Policy Report from the California Energy Commission, the power demand 

for shore power in 2020 will represent less than one-quarter of one percent of the 

State’s overall annual power consumption. 

To meet this additional power demand, the ports must work with their local utility 

companies to ensure that the power can be delivered to the port. Some ports will 

be able to use the utility’s existing circuits to access the additional power, and 

others will have to rely on new substations for the power. For example, the utility 

companies for the Ports of Los Angeles and Hueneme have indicated that they 

can provide the additional power demands with their existing system. However, 

the utility for the Port of Long Beach will have to install new substations to satisfy 

the additional power demand for shore power. 

Public utilities are required, either through city charters for municipal-owned 

utilities or the Public Utilities Code for investor-owned utilities, to provide service 

to their customers upon request, although the timing and infrastructure costs are 

negotiable. 

B. Reducing Fleet Hotelling Emissions Using Alternative 

Sources of Power and Engine Emission Control Technologies 

An alternative to the limited auxiliary engine compliance approach is the 

“emissions reduction option,” in which the fleets reduce their auxiliary engine 

emissions at a port by specific percentages and by specific dates. The emission 

reduction techniques that could be applied to a fleet include: 1) using select 

vessels for grid-supplied power based on potential auxiliary engine emission 

reductions rather than fleet visit percentages; 2) using alternative sources of 

power (distributed generation equipment) to provide power to a vessel; 3) using 

alternative emission controls onboard a vessel or adjacent to the vessel; and 

4) using a combination of these techniques. 

 Alternative Sources of Shore Power

Alternative sources of power at the berth could be supplied by distributed 

electrical generation (DG) technologies, such as fuel cells, engines, and turbines. 

The proposed regulation would only allow the use of DG technologies that meet 

specific emission limits. 

Terminal operators would need to consider space constraints at the berth when 

considering using a DG technology. The size of the DG equipment would 

depend on the ship’s auxiliary engine load that it would be replacing. For 

example, if a ship generally has a one-megawatt auxiliary engine load while at 

berth, the DG technology must be able to supply an equivalent amount of power 

to the ship during its visit. Sufficient space must be available for a DG 

technology if it is installed permanently at a terminal. A more attractive option to 
VII - 6 

operators may be portable DG that could be moved from berth to berth at the 

terminal. As with connecting to grid-supplied shore power, ships would need to 

be equipped with shore power capabilities to connect to DG shore power. 

 Alternative Emission Control Technologies

Alternative emission control technologies for auxiliary engines could include 

alternative fuels and post-combustion control measures. Emission control 

equipment for auxiliary engines could be placed at the berth or onboard the 

ships. While many control technologies have been proven to reduce emissions 

of PM and NOx from land-based diesel-fueled engines, there is limited 

experience in applying these technologies to marine vessel engines. In addition, 

there are currently no emission control strategies verified by the ARB for marine 

applications. Some of these technologies have been applied to harbor craft 

engines, but those applications were on much smaller engines than the auxiliary 

engines on ocean-going vessels. 

A few demonstration projects have been conducted on auxiliary ocean-going 

vessel engines. These involved the use of portable distributed generation, a 

seawater scrubber, biodiesel fuel, an on-demand water/fuel emulsion system, 

and selective catalytic reduction. However, because these technology 

demonstrations are still at an early stage, ARB staff cannot predict at this time 

the future deployment or feasibility of these alternative technologies as effective 

emission control measures for auxiliary engines on ships at berth. 

Several factors would impact the selection of an alternative emission control 

strategy, including the engines’ duty cycles, the varying hotelling power load 

requirements of different ship types and sizes, the exhaust system configuration, 

available space for control equipment, the size and weight of the proposed 

emission control strategy, and age of the engines. In addition, any design 

modification must be approved by the U.S. Coast Guard prior to changes being 

made to a U.S.-flagged ship. 

Table VII-2 provides general descriptions of diesel NOx and PM emission 

reduction control strategies that have been used in diesel engine applications 

and includes a brief description of demonstration projects that have been applied 

in the marine environment. Most of these projects are primarily with harbor craft 

engines, but a few have been conducted on ocean-going vessels. More details 

on the various control technologies and demonstration projects are provided in 

Appendix F. 
 VII - 7 

Table VII-2: Emission Control Strategies for Diesel Marine Engines 

Potential Emission 

Control Technology Brief Description Reductions 

Diesel PM NOx

Dem

Diesel Particulate Filters 

(DPF)/Catalyzed Diesel Particulate 

Filters (CDPF) 

DPF-Removes PM through physical 

filtration usually through a ceramic 

filter. CDPF- ceramic diesel 

particulate filter along with a platinum 

catalyst to catalyze the oxidation of 

carbon-containing emissions 

85% 0% 

One pro

installed o

ferry. Emis

Diesel Oxidation Catalysts (DOC) 

After-treatment with catalytic surfaces 

that enhance the combustion of 

carbonaceous pollutants 

25% 0% 

DOCs have 

Europe with 

installation 

CA. No 

Flow-through Filters (FTF) 

Densely packed material that either 

traps PM or causes turbulent exhaust 

flow to enhance combustion of 

unburned hydrocarbons 

50–75% 0% 

One insta

400 hp D

engines. 

Selective Catalytic Reduction 

(SCR) 

Injects ammonia or urea into the 

exhaust, in the presence of a catalyst, 

to reduce NOx to nitrogen and water 

0% 50–85% 

SCR has 

European 

auxiliary en

Here in Cali

a catama

container 

indicates thi

nee

Water/Fuel Mixture 

Water absorbs heat in the combustion 

chamber. This reduces the peak 

combustion temperature and, in turn, 

reduces NOx formation 

0% 

One-to-one 

water to NOx

up to 20% 

water 

One installa

Detroit D

Emission te

demonstra

main engin

s

Humidify Intake Air/ Water Injection 

at Air Intake 

Water absorbs heat in the combustion 

chamber, reducing the peak 

combustion temperature which 

reduces NOx formation 

0% 15–25% 

Humid Air s

hydrofoil 

Water inject
 VII - 8 

Table VII-2: (cont.). Emission Control Strategies for Diesel Engines

Potential Emission Reductions Control Technology Brief Description Diesel PM NOx Dem

Alternative Fuels Impacts on emissions depend on the fuel type Fuel Dependent Fuel Dependent 

One dem

of biodie

Biodiesel

A report omajor crui

main 

Exhaust Gas Recirculation 

(EGR) 

Reduces NOx formation by diluting the 

fuel mixture in the chamber with exhaust 

gas and reducing the combustion 

temperatures 

PM disbenefit 

50-300% 15-50% 

To da

demons

with 

Sea Water Scrubber 

Sea water is pumped to a scrubber where calcium carbonate in the water absorbs all the SOx from the exhaust gas to produce harmless calcium sulphate. The majority of particulates as well as some NOx are also removed and stripped from the water prior to discharge. 

Up to 80% 5% 

One ins

MW au

Demonst

diesel g

ship i

eva

Portable Distributed 

Generation 

Uses alternative fuels such as liquefied 

natural gas (LNG) to power a generator 

mounted on a trailer which supplies 

electricity to the ship. 

 Fuel Dependent Fuel Dependent 

Demonstr

conce

Oakland 

5,100-TE

Richmo

Shore-based AfterTreatment System Captures exhaust gases from a ship’s stack and channels them to a chamber scrubber and a SCR Fuel Dependent Fuel Dependent System 

Rosevill

testing sc

the 

Fuel Cells 

Converts chemical energy to electricity 

by combining oxygen from the air with 

fuel 

100% 100% 

No fuel c

marine ap

to include 

auxiliary 
 VII - 9 

C. In-Use Experience with Marine Engine Emission Control Strategies 

Demonstration Projects

This section provides a more detained discussion of emission control 

demonstration projects that were conducted or will be conducted on marine 

engines including harbor craft and ocean-going vessels. Although there have 

been only a limited number of demonstration projects for emission control 

techniques used on ocean-going vessel engines, there has been more testing of 

emission-control techniques on harbor craft engines, specifically on ferries. 

These engines, however, are generally much smaller than those used on oceangoing ships. 

1. Diesel Particulate Filter on U.S. Navy Workboat 

In 2006, one of two DDC 12V-71 400 horsepower engines on a U.S. Navy 

workboat operating in the Suisun Bay was rebuilt with Clean Cam Technology 

(CCT) system, including combustion chamber and injector modifications and the 

addition of a turbocharger. Based on preliminary emissions tests results, the 

rebuilt engine reduced PM emissions by over 30 percent and NOx emissions by 

approximately 70 percent. A Rypos active flow-through DPF was tested on the 

engine before it was rebuilt with CCT. This filter achieved a PM reduction of 

approximately 70 percent and a small NOx reduction. Used together, the CCT 

and Rypos active DPF achieved over 80 percent PM reduction and over 

70 percent NOx reduction. Durability testing of the system was completed in late 

2006. 

This project is a prime example of the uniqueness associated with the installation 

of marine-related after-treatment controls. The DPF was engineered specifically 

for the space available below deck, the average engine load, and the size of the 

engines powering the vessel. In addition, modifications were made to the 

vessel’s exhaust system to ensure that there would be no intrusion by salt water 

into the system. 

This demonstration shows that DPFs are a technology that has the potential for 

wider marine applications if steps are taken to ensure that the control device is 

sized appropriately and any unique feature of the vessel design or operation is 

addressed in the system’s design. 

2. Selective Catalytic Reduction 

SCR systems have been used on European marine vessels to reduce NOx 

emissions since the early 1990’s. European SCR designer and manufacturer 

Munters estimates that it has delivered and installed over 200 SCR systems for 

both main and auxiliary marine engines on close to 60 vessels throughout 
 VII - 10 

Europe. (Munters, 2007) Here in the United States, marine applications of SCR 

systems are relatively new and less widespread. 

 a. Sophie Maersk Container Ship 

In 2005, a urea-based SCR was installed on auxiliary engine #5 of the container 

ship Sophie Maersk. The University of California, Riverside, CE-CERT in 

association with Maersk and CARB, conducted the testing using a partial dilution 

system conforming to ISO 8178. NOx and PM were measured at engine loads of 

25 percent, 50 percent and 75 percent on three separate dates using both heavy 

fuel oil (HFO) and marine diesel oil (MDO). 

The NOx reductions averaged 90 percent at the three test loads using HFO and 

there were no PM reductions. The NOx reductions averaged nearly 100 percent 

at the three test loads using MDO, but the ammonia slip was high at 10 to 

70 parts-per-million (ppm). The PM reductions averaged approximately 

60 percent when using MDO. (Maersk, 2007) 

 b. Vallejo Baylink Ferry 

In 2004, the Vallejo Baylink Ferry launched M/V Solano, a low-emissions ferry 

utilizing a urea-based SCR system made by Steuler GmBH. The SCR system 

was used with the two MTU/DDC 16V-4000 propulsion engines with rated power 

of 3100 hp each. The SCR system was designed to reduce NOx by 57 percent. 

(Baylink, 2006; MARAD, 2003) 

In July of 2007, engine alarms indicating high cylinder temperature activated in 

the M/V Solano’s propulsion engines. Baylink staff inspected the engine and the 

SCR unit. They found that a number of the starboard engine cylinders showed 

excessive wear as well as ring damage. Upon opening up the starboard SCR 

unit, they found extensive damage to the catalyst blocks. The catalyst block 

damage included what appeared to be salt water corrosion and excessive heat 

and mechanical impacts. The Baylink staff has published a report and continues 

to look into the potential reasons for the damage to the engine and the SCR unit. 

(Baylink, 2007) 

 c. Staten Island Ferry 

The two Caterpillar 3516 1,550-horsepower propulsion engines of the 

M/V Alice Austen were retrofitted with SCR and diesel oxidation catalyst in 2004. 

The system was designed to reduce NOx by 50 percent as well as PM by 

25 percent. (Bradley, 2006) 

The M/V Alice Austen has been operating with SCR since 2005. The vessel is in 

service during the night runs of the Staten Island Ferry system (9 p.m. to 5 a.m.). 

The route that the vessel is assigned includes two 20-minute runs and idling 
 VII - 11 

periods during passenger loading and unloading. There have been no problems 

with the SCR system. 

 d. San Francisco Bay Area Water Transit Authority Ferry 

The San Francisco Bay Area Water Transit Authority (WTA) is planning on 

building two new 149-passenger ferries to be put into service in late 2008, which 

will include exhaust after-treatment to reduce NOx emissions by at least 

85 percent beyond Tier 2 standards. The ferries are being designed to 

incorporate a compact SCR system coupled with an oxidation catalyst with the 

1410-hp Detroit Diesel propulsion engines. The inclusion of the after-treatment 

system will require about six feet to be added to the vessel’s overall length. The 

ferries’ design includes a dry exhaust with a high exhaust stack. (WTA, 2006) 

3. Water/Fuel Mixture 

a. San Francisco Bay Area Water Transit Authority Ferry 

In 2003, the San Francisco Bay Area WTA partnered with the Golden Gate 

Bridge, Highway and Transit District, to test PuriNOxTM, a water and diesel 

emulsion, on the ferry M/V Golden Gate. The 28-year-old ferry is powered by 

two 671-hp Caterpillar 3412C turbocharged and after-cooled diesel engines. Its 

fuel tanks were cleaned, and for 11 weeks it ran on PuriNOxTM fuel instead of 

conventional diesel fuel. No filter fouling was observed. The fuel emulsion 

remained stable in the fuel tanks. Because emissions testing was conducted 

during periods of passenger service, test points were limited to full cruising 

power, idle in-gear, and idle in-neutral. PM was reduced by approximately 

60 percent at high power, but increased somewhat at idle. NOx was only slightly 

reduced at high power. There were no operational implications resulting from 

lower maximum power. (MARAD, 2003a) 

 b. Container Ship APL Singapore 

In spring 2007, an on-demand water/fuel emulsion system was installed on the 

APL Singapore container ship using funding from the Carl Moyer Program 

administered by Santa Barbara County Air Pollution Control District (SBCAPCD), 

the Port of Los Angeles, Port of Long Beach, Ventura County APCD, and the 

San Luis Obispo APCD. (APL, 2007a) 

In September 2007, the water/fuel emulsification of 10 percent water was used in 

the main engine on a voyage from Hong Kong to Los Angeles with no adverse 

effects to the engine. The mixture was increased to 22 percent water on the 

subsequent trip from Los Angeles to Oakland. University of California Riverside, 

CE-CERT was responsible for baseline emissions testing and will perform postretrofit emissions testing in October 2007. (APL, 2007b) 
 VII - 12 

4. Humid Air Injection 

SCX Ferries, Inc and MARAD tested the emission reduction potential of an air 

humidification system on a hydrofoil ferry in San Diego, California. The ferry is 

powered by four high-speed Detroit Diesel 12V92 diesel-fueled engines, each 

rated at 1050 hp driving two water jets. The water injection (fumigation) system 

reduces NOx by reducing peak combustion temperatures. The system was able 

to reduce NOx by about 16 percent. (MARAD, 2003) 

5. Alternative Fuels 

a. Blue and Gold Fleet Ferry 

In 2002, Blue and Gold Fleet and the San Francisco Bay Area WTA released the 

results of emission testing conducted on the 400-passenger ferry M/V OSKI. The 

OSKI is powered by twin two-stroke, 12V-71, Detroit Diesel engines. The testing 

established NOx and PM emissions for baseline operation with low-sulfur diesel 

fuel, for a 20-percent blend of biodiesel, for 100-percent biodiesel, and for a 

continuous water injection system with both low-sulfur diesel and 100-percent 

biodiesel fuel.

The biodiesel fuel was a soy-based methyl-ester type. Biodiesel is a renewable 

energy source that reduces greenhouse gases and particulate matter. However, 

biodiesel often increases NOx emissions. In order to reduce NOx, a continuous 

water injection system was installed to inject finely atomized water droplets in the 

engine’s intake air system. Water injection reduces maximum combustion 

temperatures and, consequently, reduces NOx emissions.

At the data points tested, B20 produced a NOx increase ranging from 

2 to 11 percent, and the B100 increase ranged from 5 to 20 percent. The water 

injection system, which was only operated at higher powers, reduced NOx by 

averages greater than 20 percent. B100 generally reduced PM emissions by 

over 50 percent.

Formal fuel performance tests were not conducted, but the operator stated there 

was no noticeable change in consumption when the continuous water injection 

system was applied.

Blue and Gold, a ferry operator in San Francisco Bay, managed the project with 

MARAD as a co-sponsor. The water injection equipment was purchased from 

MA Turbo/Engine Ltd. of Vancouver, British Columbia. The biodiesel fuel was 

purchased from World Energy, Inc. Testing and test reports were by Walther 

Engineering. (MARAD, 2003b)
 VII - 13 

 b. Royal Caribbean Cruise Lines 

In 2007 Royal Caribbean Cruises, Ltd. began to use biodiesel in its ships 

equipped with gas turbines, (Royal, 2006) and in August 2007 entered into a 

5-year contract with a biodiesel producer to purchase a minimum of 15 million 

gallons of B100 fuel in 2007 and a minimum of 18 million gallons each year 

thereafter. (GreenCar, 2007) 

6. Sea Water Scrubber 

Holland America Line is conducting a seawater scrubber feasibility project 

aboard the MS Zaandam in 2007-08 with the assistance of EPA/West Coast 

Collaborative and Puget Sound Clean Air Agency grants. 

The sea water scrubber system was scheduled to be installed in April 2007 with 

operation and testing of the system from May 2007 to October 2008. Results are 

scheduled to be reported in October 2008. (Holland, 2007a) 

The same company that manufactured the sea water scrubber system for the 

MS Zaandam also installed a similar system on the ferry M/V Pride of Kent in the 

United Kingdom in 2005. (Holland, 2007) 

7. Shore-Based After-Treatment System 

The Advanced Cleanup Technologies, Inc. (ACTI) system was tested on a 

locomotive engine at the Roseville, CA rail yard in the summer of 2006. 

Emissions testing data is available. The same system is scheduled to be fitted to 

a dock-side crane for testing on at a bulk ship terminal at the Port of Long Beach 

in the late fall 2007. (ACTI, 2006) 

8. Combined Technologies 

In 2006, Cleaire worked with Blue and Gold Ferries in San Francisco to install an 

after-treatment control system on a ferry. The system installed consisted of a 

DPF and a lean NOx catalyst element. The lean NOx catalyst element was a 

diesel fuel injector located down-stream of the DPF. The diesel fuel served as a 

catalyst to reduce NOx. 

The after-treatment control system was sized and installed on the ferry based on 

a successful demonstration in on-road bus Detroit Diesel 4 stroke engines. The 

engines on the ferry were identical to those on the bus. During the course of 

emission testing the system on simulated ferry runs, the diesel fuel injector in the 

lean NOx catalyst element was thermally destroyed. After several attempts to 

resolve that issue, the demonstration and emission testing was discontinued. It 

is assumed that the failure was due to the difference in a ferries engine load and 

cycle when compared to that of an on-road bus. 
 VII - 14 

9. Foss Tugboat with Hybrid System 

The Foss Tug Company of Seattle, Washington recently “laid keel” on a Dolphinclass hybrid tug boat. The tug boat will be a stern-drive vessel used primarily for 

harbor assist services. The tug boat’s electric drive units will be powered by two 

670-horsepower battery packs coupled with two 335-horsepower diesel-fueled 

generators. Although the main engines will have lower horsepower than those 

found in the existing Dolphin-class tug boats, the total horsepower of the hybrid 

tug boat will be equal to that of the existing Dolphin-class tug boats—about 

5,000 hp. 

Foss anticipates a number of benefits from the use of hybrid technology. These 

benefits include over a 40-percent reduction in emissions of PM and NOx, lower 

fuel consumption, and a reduction in the noise associated with the operation of 

the vessel. It is anticipated that the vessel will begin operations in 2008. (Foss, 

2007) 

10. Portable Distributed Generation 

In July 2007, Wittmar Engineering and Construction, Inc. (Wittmar), with financial 

support from the Port of Oakland, the Bay Area Air Quality Management District 

(BAAQMD) and Pacific Gas & Electric (PG&E), conducted a proof-of-concept test 

of its portable distributed generation system on the 5,100-TEU APL China

container ship at the Port of Oakland. The liquefied natural gas (LNG) powered 

generator supplemented one of the ship’s auxiliary engines and provided partial 

power to the ship for an 18-hour test period. Another proof-of-concept test is 

planned at the Port of Richmond. (APL, 2007) 
 VII - 15 

REFERENCES:

Advanced Cleanup Technologies, Inc. ACTI When Experience Counts; 

Informational Brochure 2006. 

Alimchandani, Jai K.; A.P. Moeller – Maersk Group; Regulatory Affairs Technical 

Organization. “Maersk Pilot Fuel Switch Initiative”. July 26, 2007. 

http://www.arb.ca.gov/ports/marinevess/presentations/072407/072407maepres.p

df 

American Presidents Line Maritime Ltd. “APL announces breakthrough plan to 

reduce emissions.” Press Release. June 13, 2007. 

American Presidents Line Maritime Ltd. Draft Emissions Testing Protocol: In-use 

Emissions Testing of an Ocean-going Vessel Retrofitted with Emissions Control 

Technologies (2006/2007) APL-Singapore Container Ship; May 01, 2007. 

Baylink Ferry. SCR Project-M/V Solano. June 30, 2007. 

California Air Resources Board. Evaluation of Cold-Ironing Ocean-Going 

Vessels at California Ports; March 2006. 

http://www.arb.ca.gov/ports/shorepower/report.pdf

California Energy Commission. Integrated Energy Policy Report; 

November 2005. http://www.energy.ca.gov/2005publications/CEC-100-2005-

007/CEC-100-2005-007-CMF.PDF

DieselNet. http://dieselnet.com/tech/engine_adv.html (DieselNet, 2002a) 

Foss Maritime Company. “World’s First True Hybrid Tug to be Built by Foss 

Maritime.” Press Release. March 7, 2007. 

http://www.foss.com/press/Press_Release_030207.html

Frank Angelacci, American Presidents Line Maritime Ltd. Personal 

communication. September 10, 2007. 

Green Car Congress, “Royal Caribbean Cruises Signs Long-Term Biodiesel 

Contract with Imperium Renewables.” August 7, 2007. 

http://www.greencarcongress.com/2007/08/royal-caribbean.html 

Holland America Line. Holland America Line - MS Zaandam Sea Water Scrubber 

Technology Demonstration Project Environmental Impact Assessment (EIA) 

Plan; August 10, 2007. 
 VII - 16 

Joseph Calavita, California Air Resources Board. Personal communication. 

October 5-6, 2006. 

Los Angeles Department of Water and Power. Personal communication. 

September 14, 2007. 

M.J. Bradley and Associates. Staten Island Ferry: Alice Austen Vessel SCR 

Demonstration Project Final Report. August 2006. 

Martin Robbins, Baylink Ferry. Personal communication. October 24, 2006. 

Munters Europe AB. DEC SCR Converter System. April 26, 2007. 

Port of Los Angeles and Port of Long Beach. San Pedro Bay Ports Clean Air 

Action Plan; November 2006. 

http://www.portoflosangeles.org/DOC/CAAP_Tech_Report_Final.pdf and/or 

http://www.polb.com/civica/filebank/blobdload.asp?BlobID=3451

Public Utilities Commission (PUC). Chapter 3, Article 1, Section 451-467; Public 

Utilities Code. Date accessed: October 9, 2007. http://www.leginfo.ca.gov/cgibin/displaycode?section=puc&group=00001-01000&file=451-467

Royal Caribbean Cruises Ltd. “Royal Caribbean Reports Second Quarter 2006 

Earnings.” Press Release. July 27, 2006. 

San Francisco Bay Area Water Transit Authority. “The SF Bay Area Water 

Transit Authority is Building Boats.” Press Release. May 9, 2006. 

http://www.watertransit.org/pressreleases/pressRelease050906.pdf

Sea to Sky Pollution Solutions. WiFE on Demand; September 5, 2007. 

http://www.seatoskypollutionsolutions.com/solution-wife.php 

Tina Stotz, Holland America Line, Inc. Personal communication. 

September 14, 2007. 

U.S. Department of Transportation Maritime Administration Office of Shipbuilding 

and Marine Technology. Energy Technologies. Newsletter No. 04; Winter 2003-

2004. 

http://www.marad.dot.gov/nmrec/energy_technologies/images/ETNo4Winter0304

.htm Date accessed: August 9, 2006. 

U.S. Department of Transportation Maritime Administration Office of Shipbuilding 

and Marine Technology. Energy Technologies. Newsletter No. 3; Spring 2003. 

http://marad.dot.gov/NMREC/energy_technologies/images/ETNo3Spring03.htm

Date accessed: August 12, 2007. 
 VII - 17 

U.S. Department of Transportation Maritime Administration Office of Shipbuilding 

and Marine Technology. Energy Technologies. Newsletter No. 2; Fall 2002. 

http://marad.dot.gov/NMREC/energy_technologies/images/ETNo2Fall2002.htm

Date accessed: August 12, 2007. 
 
 VIII - 1 

VIII. ENVIRONMENTAL IMPACTS 

The proposed regulation is intended to protect the health of California’s citizens 

by reducing auxiliary diesel engine emissions from ocean-going vessels while atberth in a California port. This chapter describes the potential environmental 

impacts of the proposed regulation, including potential impacts on air quality, 

wastewater treatment, and hazardous waste disposal. Based upon available 

information, the ARB staff has determined that no significant adverse 

environmental impacts should occur as the result of adopting the proposed 

regulation. 

A. Legal Requirements 

The California Environmental Quality Act (CEQA) and ARB policy require an 

analysis to determine the potential environmental impacts of proposed 

regulations. Because the ARB's program involving the adoption of regulations 

has been certified by the Secretary of Resources pursuant to Public Resources 

Code section 21080.5, the CEQA environmental analysis requirements may be 

included in the Initial Statement of Reasons (ISOR) for this rulemaking. In the 

ISOR, ARB must include a “functionally equivalent” document, rather than 

adhering to the format described in CEQA of an Initial Study, a Negative 

Declaration, and an Environmental Impact Report. In addition, staff will respond, 

in the Final Statement of Reasons for the regulation, to all significant 

environmental issues raised by the public during the public review period or at 

the Board public hearing. 

Public Resources Code section 21159 requires that the environmental impact 

analysis conducted by ARB include the following: 

• An analysis of reasonably foreseeable environmental impacts of the 

methods of compliance; 

• An analysis of reasonably foreseeable feasible mitigation measures; 

and 

• An analysis of reasonably foreseeable alternative means of 

compliance with the regulation. 

Compliance with the proposed regulation is expected to directly affect air quality 

and potentially affect other environmental media as well. Our analysis of the 

reasonable foreseeable environmental impacts of the methods of compliance is 

presented in the next section. 

Regarding mitigation measures, CEQA requires an agency to identify and adopt 

feasible mitigation measures that would minimize any significant adverse 

environmental impacts described in the environmental analysis. As mentioned 

earlier, based upon available information, the ARB staff has determined that no 
 VIII - 2 

significant adverse environmental impacts should occur as the result of adopting 

the proposed regulation. 

The proposed regulation is needed to reduce the risk from exposures to diesel 

PM as required by Health and Safety Code (HSC) section 39666 and 39667, to 

help fulfill the goals of the October 2000 Diesel Risk Reduction Plan 

(ARB, 2000), and to help meet the goals of the Goods Movement Emission 

Reduction Plan (ARB, 2006). The regulation is also necessary to fulfill ARB’s 

obligations under HSC 43013 and 43018 to achieve the maximum feasible and 

cost effective emission reductions from all mobile source categories, including 

marine engines. The emission reductions from the proposed regulation in 

ambient levels of PM, and NOx will help make progress in meeting the State and 

Federal ambient air quality standards for ozone and PM in non-attainment areas 

of the State. 

Regarding alternative mean of compliance with the regulation, alternatives to the 

proposed regulation were discussed in the Chapter VI. ARB staff has concluded 

that there are no feasible alternative mitigation methods that would achieve 

similar diesel PM and NOx emission reductions at a lower cost. 

B. Effects on Air Quality 

The proposed regulation will provide diesel PM and NOx, emission reductions 

throughout California, especially in communities surrounding California’s major 

ports, areas which, in most cases, are non-attainment for federal ambient air 

quality standards for ozone, PM10, and PM2.5. The regulation would also have 

a co-benefit of reducing CO2 emissions. A more detailed discussion of the CO2

emission reduction benefits expected from the proposed regulation is included in 

Chapter IX. 

The projected controlled hotelling emissions from ocean-going vessels from the 

three ship categories affected by the proposed regulation are presented in Table 

VIII-1. 
 VIII - 3 

Table VIII-1: Projected 2014 and 2020 Hotelling Emissions with Proposed 

Regulation Implementation (Tons per Day) 

Category Current 2006 

Emissions 

2014 Controlled 

Emissions 

2020 Controlled 

Emissions 

PM NOx PM NOx PM NOx

Container ships 1.12 13.8 0.19 10.6 0.13 7.4 

Passenger ships 0.24 2.5 0.03 1.7 0.03 1.6 

Refrigerated 

cargo ships 0.07 0.9 0.01 0.5 0.01 0.5 

Totals 1.42 17.2 0.23 12.8 0.17 9.5 

Note: Sums may not be exact due to rounding. 

The reductions due specifically to the regulation are summarized in Table VIII-2, 

and Table VIII-3. As can be determined from the information provided in the 

tables, PM and NOx emissions will be 50 percent lower in 2014 and 75 percent 

lower in 2020 than they would be without the regulation. 

Table VIII-2: Projected Statewide Diesel PM Emissions Benefits of the Proposed 

Regulation 

Year 

PM Emissions 

without 

Regulation 

(tons/day) 

PM Emissions 

with 

Regulation 

(tons/day) 

Emission 

Reductions 

(tons/day) 

% Emission 

Reductions 

2014 0.47 0.23 0.24 51 

2020 0.67 0.17 0.50 75 

Table VIII-3: Projected Statewide NOx Emissions Benefits of the Proposed Regulation 

Year 

NOx 

Emissions 

without 

Regulation 

(tons/day) 

NOx 

Emissions 

with 

Regulation 

(tons/day) 

Emission 

Reductions 

(tons/day) 

% Emission 

Reductions 

2014 26.1 12.8 13.3 51 

2020 37.3 9.5 27.8 74 

Figures VIII-1 and III-2 show the projected diesel PM and NOx hotelling 

emissions for container ships, passenger ships, and reefer ships, with and 

without implementation of the proposed regulation. The uncontrolled projections 
 VIII - 4 

assume emissions from implementation of ARB’s auxiliary engine fuel 

regulation.3

 

Figure VIII-1: Projected Diesel PM Emissions With and Without the 

Proposed Regulation

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

2006 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Year

Emissions (Tons/Day)

Uncontrolled PM

Controlled PM

Figure VIII-2: Projected NOx Emissions With and Without the Proposed 

Regulation

0.0

5.0

10.0

15.0

20.0

25.0

30.0

35.0

40.0

2006 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Year

Emissions (Tons/Day)

Uncontrolled NOx

Controlled NOx

 

3

 See title 13 CCR § 2299.1 and title 17 CCR § 93118. At the time this Technical Support 

Document (TSD) was published, those regulations had been challenged in federal district court 

and undergoing appeal at the Ninth Circuit Court of Appeals. Pacific Merchant Shipping Ass'n v. 

Cackette, (E.D.Cal. Oct 05, 2007) 2007 WL 2914961 (No. Civ. S-06-2791-WBS-KJM). The 

analysis presented in this portion of the TSD assumes those auxiliary engine regulations will 

ultimately be upheld on appeal. 
 VIII - 5 

As summarized in Table VIII-4 below, staff estimates that approximately 

1,100 tons of diesel PM and 61,700 tons of NOx will be removed from California's 

air between 2006 and 2020 due to the implementation of the proposed 

regulation. 

Table VIII-4: Emission Benefits from Implementation of the Proposed 

Regulation 

PM NOx

Total Emission Reductions 

 2006 to 2020 (Tons) 1,100* 61,700* 

Annual Average Reductions 

(Tons per Year) 85 4,700 

* For the container-ship category, the regulatory period is 

 2009 – 2030 to account for ship turnover. Total emissions 

reductions to 2030 are 2,600 tons of diesel PM and 140,000 tons 

of NOx. 

C. Health Benefits Analysis 

Reduced Ambient Particulate Matter Levels

A substantial number of epidemiologic studies have found a strong association 

between exposure to ambient particulate matter (PM) and adverse health effects. 

(ARB, 2002) For this report, ARB staff evaluated the impacts the proposed 

regulation would have on potential cancer risks and conducted a quantitative 

analysis of seven potential non-cancer health impacts associated with exposures 

to ambient levels of directly emitted diesel PM. 

1. Reduction in Potential Cancer Risks 

The reductions in diesel PM emissions that will result from implementation of the 

proposed regulation will reduce the public’s exposures to diesel PM emissions 

and the potential cancer risks associated with those exposures. The ARB staff 

used the air dispersion model and model inputs developed for the Port of 

Los Angeles (POLA) and Port of Long Beach (POLB) health risk assessment to 

estimate the reductions in potential cancer risk that would result from 

implementation of the proposed regulation in the area surrounding the two ports. 

Staff believes that the results from this analysis provide quantitative results for 

exposures around POLA/POLB and are generally applicable to other ports in 

California, providing a semi-quantitative estimate for those areas. 
 VIII - 6 

To investigate the reductions in potential risks commensurate with the reductions 

in hotelling emissions from container ships, passenger ships, and reefer ships, 

ARB staff used dispersion modeling and the projected emissions inventories for 

2014 and 2020. Staff estimated the ambient concentrations of diesel PM from 

hotelling emissions at POLA/POLB in those two years. 

The auxiliary engine fuel regulation, adopted by the Board in December 2005, 

reduces diesel PM from hotelling ships by about 70 percent. Because of the 

expected growth in ship visits to California ports, however, the potential exposure 

of diesel PM to nearby residents will increase from 2007 to 2020 without further 

control. Staff estimates that the proposed regulation will reduce diesel PM by 

75 percent in 2020. These emission reductions will more than offset the 

emissions increases from the growth in ship activity, thereby reducing the 

potential exposure to nearby residents. 

As shown in Figures VIII-3 through VIII-6, we expect a significant decline in the 

number of people exposed to elevated risk levels from hotelling emissions and 

the acres impacted as the auxiliary engine regulation is implemented. In addition 

to this reduction, the proposed at-berth ocean-going vessel regulation will reduce 

the number of residential acres and population exposed to diesel PM 

concentrations greater than 10 per million an additional 50 percent by 2014 and 

70 percent by 2020. More importantly, all higher risk levels of greater than 100 in 

a million are eliminated due to implementation of the proposed regulation. 

 

Figure VIII-3: Projected Residential Areas Impacted by Hotelling 

Emissions at POLA/POLB by 2014 

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

Residential Area (Acres)

2014 without Control

2014 with Auxi Reg

2014 with Auxi + Cold

2014 without Control 163,435 48,146 11,653 761

2014 with Auxi Reg 113,016 939 0 0

2014 with Auxi + Cold 57,269 0 0 0

Risk > 10 Risk > 100 Risk > 200 Risk > 500
 VIII - 7 

Figure VIII-4: Projected Numbers of Population Affected by Hotelling 

Emissions at POLA/POLB by 2014 

Figure VIII-5: Projected Residential Areas Impacted by Hotelling 

Emissions at POLA/POLB by 2020 

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

Number of Persons

2014 without Control

2014 with Auxi Reg

2014 with Auxi + Cold

2014 without Control 1,977,764 631,799 206,577 17,917

2014 with Auxi Reg 1,339,600 20,800 0 0

2014 with Auxi + Cold 736,000 0 0 0

Risk > 10 Risk > 100 Risk > 200 Risk > 500

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

Residential Area (Acres)

2020 without Control

2020 with Auxi Reg

2020 with Auxi + Cold

2020 without Control 163,435 80,457 23,979 2,540

2020 with Auxi Reg 134,820 2,955 119 0

2020 with Auxi + Cold 33,517 0 0 0

Risk > 10 Risk > 100 Risk > 200 Risk > 500
 VIII - 8 

Figure VIII-6: Projected Numbers of Population Affected by Hotelling 

Emissions at POLA/POLB by 2020 

2. Non-Cancer Health Impacts and Valuations 

To determine the impacts from the proposed regulation on non-cancer health 

endpoints, ARB staff used the methodology described previously in Chapter V to 

evaluate the change in ambient PM levels that are expected due to 

implementation of the proposed regulation. A discussion of the non–cancer 

health impacts assessment is included in Appendix D. 

This analysis shows that the statewide cumulative impacts of the emissions 

reduced through this regulation from year 2009 through 2020 are approximately: 

• 280 premature deaths (78 to 480, 95% confidence interval (CI)) 

• 60 hospital admissions due to respiratory causes (38 to 83, 95% CI) 

• 110 hospital admissions due to cardiovascular causes (70 to 170, 95% CI) 

• 8,200 cases of asthma-related and other lower respiratory symptoms 

(3,200 to 13,000, 95% CI) 

• 680 cases of acute bronchitis (0 to 1,400, 95% CI)

• 49,000 work loss days (42,000 to 57,000, 95% CI) 

• 280,000 minor restricted activity days (230,000 to 330,000, 95% CI) 

Table VIII-5 lists the impacts associated with primary and secondary diesel 

emissions separately. The methodology for estimating these health impacts is 

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

Number of Persons

2020 without Control

2020 with Auxi Reg

2020 with Auxi + Cold

2020 without Control 1,977,765 1,009,250 381,870 57,600

2020 with Auxi Reg 1,644,856 65,856 6,180 0

2020 with Auxi + Cold 485,000 0 0 0

Risk > 10 Risk > 100 Risk > 200 Risk > 500
 VIII - 9 

outlined below and details can be found in Appendix A of the Emission Reduction 

Plan for Ports and Goods Movement in California (ARB, 2006) 4

. 

Table VIII-5: Estimated Total Health Benefits Associated with Reductions 

in Hotelling Emissions from Container Ships, Passenger 

Ships, and Reefer Ships (2009-2020)* 

Endpoint Pollutant

# of Cases 

95% C.I. 

(Low) 

# of Cases 

(Mean) 

# of Cases 

95% C.I. 

(High) 

PM 22 80 140

Premature Death NOx 56 200 340

Total 78 280 480

PM 11 17 24

NOx 27 43 59

Hospital 

admissions 

(Respiratory) Total 38 60 80

PM 20 31 49

NOx 50 79 120

Hospital 

admissions 

(Cardiovascular) Total 70 110 170

PM 910 2,400 3,800

NOx 2,300 5,900 9,300

Asthma & Lower 

Respiratory 

Symptoms Total 3,200 8,200 13,000

PM 0 200 430

Acute Bronchitis NOx 0 480 1,000

Total 0 680 1,400

PM 12,000 14,000 16,000

Work Loss Days NOx 30,000 35,000 41,000

Total 42,000 49,000 57,000

PM 66,000 81,000 96,000

NOx 160,000 200,000 240,000 Minor Restricted 

Activity Days 

Total 230,000 280,000 330,000

*

Health effects from primary and secondary PM are labeled PM and NOx, respectively. The 

sum of PM and NOx impacts may not equal the total given due to rounding. 

3. Economic Valuation of Non-Cancer Health Effects 

This section describes the methodology for monetizing the value of avoiding 

adverse health impacts. 

The U.S. EPA has established $4.8 million in 1990 dollars at the 1990 income 

level as the mean value of avoiding one premature death (U.S. EPA, 1999). This 

value is the mean estimate from five contingent valuation studies and 17 wagerisk studies. Contingent valuation and wage-risk studies examine the willingness 

to pay (or accept payment) for a minor decrease (or increase) in the risk of 

 

4

 http://www.arb.ca.gov/planning/gmerp/march21plan/appendix_a.pdf 
 VIII - 10 

premature death. For example, if individuals are willing to pay $800 to reduce 

their risk of mortality by 1/10,000, then collectively they are willing to pay 

$8 million to avoid one death. This is also known as the “value of a statistical life” 

or VSL.5

As real income increases, people are willing to pay more to prevent premature 

death. U.S. EPA adjusts the 1990 value of avoiding a premature death by a 

factor of 1.2016 to account for real income growth from 1990 through 2020, (U.S. 

EPA, 2004). Assuming that real income grows at a constant rate from 1990 until 

2020, we adjusted VSL for real income growth, increasing it at a rate of 

approximately 0.6% per year. We also updated the value to 2006 dollars. After 

these adjustments, the value of avoiding one premature death is $8.2 million in 

2007, $8.3 million in 2009 and $8.9 million in 2020, all expressed in 2006 dollars. 

The U.S. EPA also uses the willingness-to-pay (WTP) methodology for some 

non-fatal health endpoints, including lower respiratory symptoms, acute 

bronchitis and minor restricted activity days. WTP values for these minor 

illnesses are also adjusted for anticipated income growth through 2020, although 

at a lower rate (about 0.2% per year in lieu of 0.6% per year). 

For work-loss days, the U.S. EPA uses an estimate of an individual’s lost wages, 

(U.S. EPA, 2004), which CARB adjusts for projected real income growth, at a 

rate of approximately 1.5% per year. 

“The Economic Value of Respiratory and Cardiovascular Hospitalizations,” (ARB, 

2003), calculated the cost of both respiratory and cardiovascular hospital 

admissions in California as the cost of illness (COI) plus associated costs such 

as loss of time for work, recreation and household production. When adjusting 

these COI values for inflation, CARB uses the Consumer Price Index (CPI) for 

medical care rather than the CPI for all items. 

Table VII-6 lists the valuation of avoiding various health effects, compiled from 

ARB and U.S. EPA publications—updated to 2006 dollars. The valuations based 

on WTP, as well as those based on wages, are adjusted for anticipated growth in 

real income. 

 

5

 U.S. EPA’s most recent regulatory impact analyses, (U.S. EPA 2004, 2005), apply a different 

VSL estimate ($5.5 million in 1999 dollars, with a 95 percent confidence interval between 

$1 million and $10 million). This revised value is based on more recent meta-analytical literature, 

and has not been endorsed by the Environmental Economics Advisory Committee (EEAC) of 

U.S. EPA’s Science Advisory Board (SAB). Until U.S. EPA’s SAB endorses a revised estimate, 

ARB staff continues to use the last VSL estimate endorsed by the SAB, i.e., $4.8 million in 1990 

dollars. 

6

 U.S. EPA’s real income growth adjustment factor for premature death incorporates an elasticity 

estimate of 0.4. 
 VIII - 11 

Table VIII-6: Undiscounted Unit Values for Health Effects 

 (at various income levels in 2006 dollars) A 

Health Endpoint 2006 2015 2025 References 

Mortality

Premature death ($ million) 8.2 8.6 9.2 U.S. EPA (1999, p. 70-72, 

2000, (2004, p. 9-121) 

Hospital Admissions 

Cardiovascular ($ thousands) 43 48 54 ARB (2003), p. 63 

Respiratory ($ thousands) 35 39 44 ARB (2003), p. 63 

Minor Illnesses 

Acute Bronchitis 451 459 469 U.S. EPA (2004), 9-158

Lower Respiratory Symptoms 20 20 21 U.S. EPA (2004), 9-158 

Work loss day 189 217 252 2002 California wage data, 

U.S. Department of Labor 

Minor restricted activity day (MRAD) 64 65 66 U.S. EPA (2004), 9-159 

A The value for premature death is adjusted for projected real income growth, net of 

0.4 elasticity. Wage-based values (Work Loss Days) are adjusted for projected real income 

growth, as are WTP-derived values (Lower Respiratory Symptoms, Acute Bronchitis, and 

MRADs). Health endpoint values based on cost-of-illness (Cardiovascular and Respiratory 

Hospitalizations) are adjusted for the amount by which projected CPI for Medical Care 

(hospitalization) exceeds all-item CPI. 

Benefits from the proposed rule on the operation of auxiliary engines on at-berth 

ocean-going vessels are substantial. ARB staff estimates cumulative benefits 

over the period from 2009 to 2020 to be nearly $1.9 billion using a 3% discount 

rate or $1.3 billion using a 7% discount rate7. A large proportion of the 

monetized benefits results from avoiding premature death. The estimated 

benefits from avoided morbidity are approximately $28 million with a 3% discount 

rate and nearly $20 million with a 7% discount rate. Approximately 72% of the 

benefits are associated with reduced PM from NOx emissions, and the remaining 

28% from direct PM emissions. 

Reduced Ambient Ozone Levels

Emissions of NOx and ROG are precursors to the formation of ozone in the lower 

atmosphere. Exhaust from diesel engines contributes a substantial fraction of 

ozone precursors in any metropolitan area. Therefore, reductions in NOx and 

ROG from diesel engines would make a considerable contribution to reducing 

 

7

 ARB follows U.S. EPA practice in reporting results using both 3% and 7% discount rates. 
 VIII - 12 

exposures to ambient ozone. Controlling emissions of ozone precursors would 

reduce the prevalence of the types of respiratory problems associated with ozone 

exposure and would reduce hospital admissions and emergency visits for 

respiratory problems. 

D. Reasonably Foreseeable Environmental Impacts as a Result of 

Potential Compliance Methods 

The primary compliance strategy proposed in the regulation is turning off the 

auxiliary engines and plugging in to shore power. ARB staff anticipates that the 

majority of affected ship companies will choose to comply with the requirements 

of the proposed regulation by using shore power. ARB staff does not foresee 

any negative environmental impacts associated with the use of shore power as a 

primary strategy. 

ARB staff recognizes that there are emissions associated with the generation of 

electricity used for shore power (i.e., emissions from power plants that supply 

electricity to the grid). When calculating the emission reduction benefits of the 

proposed regulation, ARB staff considered the net benefits, subtracting the 

emissions associated with the grid. 

One compliance option with potential adverse environmental impacts is the use 

of diesel emission control strategies. To date, there are no ARB verified aftertreatment controls for marine engines. As such, the ARB is encouraging the use 

of non-verified after-treatment control devices in the hopes of achieving some 

reductions of diesel PM associated with ocean going vessels due to the 

installation of after-treatment controls. The ARB staff does not anticipate 

significant reductions of diesel PM from ocean going vessels attributable to aftertreatment controls until such time as those technologies are proven to be 

effective and durable when used in the marine environment. The ARB continues 

to support projects that utilize after-treatment controls in the hopes that those 

technologies will become verified in the future. 

The ARB has identified potential adverse environmental impacts from the use of 

diesel oxidation catalysts (DOCs), diesel particulate filters (DPFs), selective 

catalytic reduction (SCR), alternative fuels, exhaust gas recirculation (EGR), 

seawater scrubbers, and shore-based after-treatment systems. These include a 

potential increase in sulfate PM, a potential increase in NO2 from some DPFs, 

and the potential for creating hazardous wastes. As described below, options 

are available to mitigate these potential adverse impacts. 

Diesel Oxidation Catalyst (DOC)

Two potential adverse environmental impacts of the use of diesel oxidation 

catalysts have been identified. First, as is the case with most processes that 

incorporate catalytic oxidation, the formation of sulfates increases at higher 
 VIII - 13 

temperatures. Depending on the exhaust temperature and sulfur content of the 

fuel, the increase in sulfate particles may offset the reductions in soluble organic 

fraction emissions. 

Second, a DOC could be considered a “hazardous waste” at the end of its useful 

life depending on the materials used in the catalytic coating. Because catalytic 

converters have been used on gasoline powered on-road vehicles for many 

years, there is a very well-established market for these items (see, for example, 

http://pacific.recycle.net – an Internet posting of buyers and sellers of various 

scrap materials). In the recycling process, the converters are broken down, and 

the metal is added to the scrap-metal stream for recycling, while the catalysts 

(one or a combination of the platinum group metals) are extracted and reused. 

Because of platinum’s high activity as an oxidation catalyst, it is the predominant 

platinum group metal used in the production of diesel oxidation catalysts. There 

is a very active market for reclaimed platinum for use in new catalytic converters, 

jewelry, fuel cells, cathode ray tube screens, catalysts used during petroleum 

refining operations, dental alloys, oxygen sensors, platinum electrode spark 

plugs, medical equipment, and platinum-based drugs for cancer treatment, to 

name a few. (Kendall, 2002) (Kendall, 2003) 

Catalyzed Diesel Particulate Filters

These devices are composed of a ceramic diesel particulate filter along with a 

platinum catalyst to catalyze the oxidation of carbon-containing emissions and 

significantly reduce diesel PM emissions. This is an obvious positive 

environmental impact. 

However, there are also inorganic solid particles present in diesel exhaust, which 

are captured by diesel particulate filters. These inorganic materials are metals 

derived from engine oil, diesel fuel, or engine wear and tear. While the PM filter 

is capable of capturing inorganic materials, these materials are not oxidized into 

a gaseous form and expelled. 

Because these materials would otherwise be released into the air, the filters are 

benefiting the environment by capturing these metallic particles, known as “ash.” 

However, the ash that is collected in the PM filter must be removed from the filter 

periodically to maintain the filter’s effectiveness. 

Ash collected from a diesel engine using a typical lubrication oil and no fuel 

additives has been analyzed and is primarily composed of oxides of the following 

elements: calcium, zinc, phosphorus, silicon, sulfur, and iron. Zinc is the element 

of primary concern because, if present in high enough concentration, it can make 

a waste a hazardous waste. Title 22, CCR, section 66261.24 establishes two 

limits for zinc in a waste: 250 milligrams per liter for the Soluble Threshold Limit 

Concentration and 5,000 milligrams per kilogram for the Total Threshold Limit 
 VIII - 14 

Concentration. The presence of zinc at or above these levels would cause a 

sample of ash to be characterized as a hazardous waste. 

Under California law, it is the generator's responsibility to determine whether their 

waste is hazardous or not. Applicable hazardous waste laws are found in the 

HSC, division 20; title 22, CCR, division 4.5; and title 40 of the Code of Federal 

Regulations. Staff recommends owners that install a diesel particulate filter on 

an engine to contact both the manufacturer of the diesel emission control system 

and the California Department of Toxic Substances Control (DTSC) for advice on 

proper waste management. 

Additionally, the technology exists to reclaim zinc from waste. For example, the 

Swedish company MEAB has developed processes for extracting zinc and 

cadmium from various effluents and industrial waste streams. Whether 

reclamation for reuse will be economically beneficial remains to be seen. 

(MEAB, 2003) 

Because of the time and costs associated with filter maintenance, there are also 

efforts by industry to reduce the amount of ash formed. Most of the ash is 

formed from the inorganic materials in engine oil, particularly from zinc-containing 

additives necessary to control acidification of engine oil – due in part to sulfuric 

acid derived from sulfur in diesel fuel. As the sulfur content of diesel fuel is 

decreased, the need for acid neutralizing additives in engine oil should also 

decrease. A number of technical programs are ongoing to determine the impact 

of changes in oil ash content and other characteristics of engine oil on exhaust 

emission control technologies and engine wear and performance. 

It may also be possible to reduce the ash level in diesel exhaust by reducing oil 

consumption from diesel engines. Diesel engine manufacturers over the years 

have reduced engine oil consumption in order to reduce PM emissions and to 

reduce operating costs for engine owners. Further improvements in oil 

consumption may be possible in order to reduce ash accumulation rates in diesel 

particulate filters. 

In addition, measurements of NOx emissions for heavy-duty diesel vehicles 

equipped with passive catalyzed filters have shown an increase in the NO2

portion of total NOx emissions, although the total NOx emissions remain 

approximately the same. In some applications, passive catalyzed filters can 

promote the conversion of nitrogen oxide (NO) emissions to NO2 during filter 

regeneration. More NO2 is created than is actually being used in the 

regeneration process; and the excess is emitted. The NO2 to NOx ratios could 

range from 20 to 70 percent, depending on factors such as the diesel particulate 

filter systems, the sulfur level in the diesel fuel, and the duty cycle. 

(DaMassa, 2002) 
 VIII - 15 

Formation of NO2 is a concern because it irritates the lungs and lowers 

resistance to respiratory infections. Individuals with respiratory problems, such 

as asthma, are more susceptible to the effects. In young children, nitrogen 

dioxide may also impair lung development. In addition, a higher NO2/NOx ratio in 

the exhaust could potentially result in higher initial NO2 concentrations in the 

atmosphere, which, in turn, could result in higher ozone concentrations. 

Model simulations have shown that a NO2 to NOX emission ratio of approximately 

20 percent would nearly eliminate any impact of increased NO2 emissions. 

(DaMassa, 2002). According to the model, at the NO2 to NOx ratio of 20 percent, 

there will be a decrease of the 24-hour ozone exposure (greater than 90 parts 

per billion) by two percent while an increase of the peak 1-hour NO2 by six 

percent (which is still within the NO2 standard). 

The health benefits derived from the use of PM filters are immediate and offset 

the possible adverse effects of increases in NO2 emissions. For this reason, a 

cap of 20 percent NO2 to NOx emission ratio was established for all diesel 

emission control systems through ARB’s Verification Procedure. 

Selective Catalytic Reduction (SCR)

The heart of the SRC system is the catalyst. The reaction converting NOx to 

nitrogen and water occurs on the surface of the catalyst. NOx compounds must 

come into contact with the catalyst in order to be converted. Modern catalysts 

are usually made in the form of honeycomb structures. 

Many catalysts materials contain heavy metal oxides that are hazardous to 

human health. Vanadium pentoxide, for example, is on the U.S. EPA’s 

Extremely Hazardous Substances. In California, spent catalyst from SCR is 

considered to be hazardous waste and the volume of waste from SCR is large. 

The disposal of catalyst is expensive, but some catalyst manufacturers provide 

for disposal and/or recycling of the catalyst. In Japan, for example, titanium from 

titanium dioxide spent catalyst is used for paint pigment. An advantage of 

precious metal catalysts is that they do not produce as much hazardous waste, 

and they have a salvage value at the end of their useful life, but the initial cost is 

higher. 

Ammonia or urea is necessary for the chemical reactions in SCR to work. Urea 

is less expensive and less hazardous than ammonia, so almost all systems use 

urea. Urea comes in the form of powder that is dissolved with water and then 

injected into the exhaust stream. The urea breaks down to form nitrogen and 

hydrogen compounds that will react with nitrogen oxide. The temperature range 

for efficient NOx reduction with urea is higher than the exhaust temperature of 

some engines (minimum of approximately 270°C), so u rea injection is limited to 

systems where there is either ample exhaust temperature or supplemental firing 

applied to the exhaust stream. (Munters, 2007) 
 VIII - 16 

In the unlikely event ammonia is used in place of urea, there could be some 

environmental impacts. Ammonia (in lieu of urea) is necessary for the chemical 

reactions in SCR to work. Unfortunately, ammonia is also a hazardous 

substance. Ammonia is on the U.S. EPA’s list of extremely hazardous 

substances under Title III, Section 302 of the Superfund Amendments and 

Reauthorization Act of 1986 (SARA). Ammonia is immediately dangerous to life 

and health (IDLH) at only 500 ppm. It has a time weighted average (TWA) 

exposure limit (the maximum allowable exposure limit in a 10 hour day in a 40 

hour week) of 25 ppm. Ammonia has a pungent, suffocating odor. Exposure to 

ammonia causes eye, nose, and throat irritation, and it will burn the skin. 

If used, ammonia is released from an SCR system because excess ammonia is 

required for efficient conversion of NOx to nitrogen. Excess ammonia is required 

because of imperfect distribution of the chemical. In theory, if the ammonia could 

be perfectly distributed so that the reactants could come into contact, no 

ammonia would be released, but under real world conditions this is not possible. 

This is also analogous to the necessity for excess air required for combustion. 

Excess air is required since all the oxygen molecules can’t find all the fuel 

molecules to react with during the short period of time of combustion due to 

imperfect mixing of fuel and air. 

The molar ratio of nitrogen oxide (NO) to ammonia in the SCR reaction is 1.0 

(i.e., 1 ft3

 of ammonia is required to convert 1 ft3 of NOx), and the molar ratio of 

ammonia to nitrogen dioxide (NO2) is 2.0. Over 80 percent of the NOx 

compounds in the exhaust are nitrogen oxide, so the SCR system is usually run 

with a ratio of ammonia to NOx around 1.0. Further increases of this ratio will 

reduce NOx emissions, but emissions of ammonia will also increase. 

In an SCR unit, it is critical that the ammonia is injected and thoroughly 

distributed throughout the flue gas stream. This is done with the ammonia 

injected grid located upstream of the catalyst. Ammonia is drawn out of a 

storage tank and evaporated with an electrically- or steam-heated vaporizer. The 

vapor is then mixed with a carrier gas, which is usually compressed air or steam. 

The carrier gas provides the momentum to deliver the gas into the exhaust 

stream. 

The storage of ammonia is usually considered to be a greater potential hazard 

than the ammonia slip from the exhaust stack. Emitted levels of ammonia slip 

are far below the odor and health hazard thresholds of the chemical. Because 

ammonia is water soluble, it doesn’t remain very long in the atmosphere. 

Ammonia for an SCR unit is stored in a tank, and a relatively large volume of 

storage is required. Accidental release from storage could pose problems to 

communities surrounding a vessel or facility equipped with SCR. Aqueous and 

anhydrous ammonia are the two types of ammonia used for ammonia injection. 

The aqueous form is favored in that the stored ammonia concentration can be 
 VIII - 17 

limited and the volatilization rate is reduced, so it is generally safer. The 

aqueous form is used in more heavily populated areas. 

In summary, we do not believe the use of SCR, to the extent that it is used, will 

result in significant adverse environmental impacts because: (1) urea is safer and 

cheaper than ammonia, so urea is much more likely to be used, (2) ammonia is 

water soluble, so its persistence in the atmosphere is relatively short, and (3) use 

of the aqueous ammonia is generally safer and is the preferred form in heavily 

populated areas, such as the areas surrounding the ports where the regulated 

vessels will visit. In addition, to the extent SCR is used on land-based engines 

that will provide alternative means of shore power to affected vessels, such landbased engines will be subject to already stringent local air district permitting and 

emissions control requirements, as well as the applicable requirements specified 

in the proposed regulation. Thus, we believe the use of SCR, if any, will result in 

no significant adverse environmental impacts. 

Alternative Fuels

As discussed in Appendix F, a number of alternative fuels and alternative diesel 

fuels show great promise in their potential to reduce diesel PM emissions. These 

include alternative diesel fuels such as biodiesel, emulsified diesel fuel, and 

Fischer-Tropsch fuels, and alternative fuels such as natural gas. No significant 

negative environmental impacts have been determined from the use of 

alternative fuels. With respect to alternative diesel fuels, there may be an 

increase in NOx emissions as a result of biodiesel use. (Hofman/Solseng, 2002) 

Exhaust Gas Recirculation (EGR)

Exhaust gas recirculation (EGR) lowers combustion temperatures thereby 

reducing NOx formation. By reducing combustion temperatures and available air 

for combustion, EGR may cause incomplete combustion, increases in HC, CO, 

and PM emissions, and decreased fuel economy. (DieselNet, 2006). 

Sea Water Scrubber (SWS)

Seawater scrubbing utilizes the water surrounding the ship, whether it is 

seawater, coastal water or harbor water, as an exhaust gas-washing medium. 

The scrubbing equipment uses this water to scrub out and neutralize the sulfur 

oxides (SOx) from the exhaust of marine main and auxiliary engines. Calcium 

carbonate in the seawater absorbs the SOx from the exhaust gas and produces 

calcium sulphate. SOx are also readily soluble in seawater where they form 

sulfuric acid. The natural alkalinity of the seawater then neutralizes this and 

other acids formed during scrubbing. In addition SWS also removes up to 

80 percent of the PM and up to five percent of the NOx as well as other 

unburned/partially burned hydrocarbon derived from fuel and lubricants, ash, and 

other incombustible materials, such as metals, in the exhaust gas. SWS systems 
 VIII - 18 

should be designed to ensure that the contaminants removed from exhaust gas 

stream are subsequently removed from the wash water prior to the wash water 

being discharged. (Holland, 2007) 

Although concentrations of these compounds within the wash water are generally 

extremely low, even in the absence of any wash water treatment system, the 

accumulation of these compounds over time in the marine ecosystem must be 

considered. The removal and storage or proper disposal of wash water 

contaminants as a neutralized sludge ensures that the accumulation affect in the 

marine environment does not occur. 

E. Reasonably Foreseeable Mitigation Measures

ARB staff has concluded that no significant adverse environmental impacts 

should occur from the adoption of and compliance with the proposed regulation. 

Therefore, no mitigation measures would be necessary. 

F. Reasonably Foreseeable Alternative Means of Compliance with the 

Proposed Regulation 

Alternative means to comply with the proposed regulation are provided through 

the use of emission control strategies to achieve the same fleet-wide emission 

reductions that would be achieved through utilizing shore power. Alternatives to 

the proposed regulation are discussed in Chapter VI of this report. ARB staff has 

concluded that the proposed regulation provides the most effective and least 

burdensome approach to reducing children’s and the general public’s exposure 

to diesel PM and other air pollutants emitted from the diesel auxiliary engines on 

ocean-going vessels while at berth. 

Although there are issues associated with the use of alternative diesel emission 

control strategies to achieve reductions of emissions of NOx and diesel PM from 

ocean going vessels, the ARB staff believes that there are ways to address and 

mitigate any adverse environmental impacts associated with a specific emission 

control strategy. 

The alternative compliance strategies described above and in Chapter VI provide 

benefits associated with the reduction of NOx and diesel PM from ocean-going 

vessels. In addition to providing flexibility to the regulated community, these 

compliance options also promote the development of cleaner retrofit and 

emission control technologies for ocean-going vessels. 
 VIII - 19 

REFERENCES: 

California Air Resources Board. Emission Reduction Plan for Ports and Goods 

Movement in California; April 2006. (ARB, 2006) 

California Air Resources Board. Final Research Report: The Economic Value of 

Respiratory and Cardiovascular Hospitalizations; May 2003. 

ftp://ftp.arb.ca.gov/carbis/research/apr/past/99-329.pdf (ARB, 2003) 

California Air Resources Board. Risk Reduction Plan to Reduce Particulate 

Matter Emissions from Diesel-Fueled Engines and Vehicles; October 2000. 

http://www.arb.ca.gov/diesel/documents/rrpapp.htm (ARB, 2000) 

California Air Resources Board and Office of Environmental Health Hazard 

Assessment. Public Hearing to Consider Amendments to the Ambient Air Quality 

Standards for Particulate Matter and Sulfates, Staff Report; May 2002. 

http://www.arb.ca.gov/research/aaqs/std-rs/pm-final/pm-final.htm (ARB, 2002) 

DaMassa, John. California Air Resources Board. Presentation: Air Quality 

Effects of Trap-Related Emissions (Updated); February 6, 2002. (DaMassa, 

2002) 

DieselNet. Engine Design for Low Emissions: Water in Diesel Combustion;

DieselNet Technology Guide. September 29, 2006. 

http://www.dieselnet.com/tech/engine_water.html (DieselNet, 2006) 

Holland America Line. Holland America Line - MS Zaandam Sea Water Scrubber 

Technology Demonstration Project Environmental Impact Assessment (EIA) 

Plan; August 10, 2007. (Holland, 2007)

 

Kendall, Tom; Johnson Matthey. Platinum 2002; May 2002. 

http://www.platinum.matthey.com/publications/1051543656.html (Kendall, 2002) 

Kendall, Tom; Johnson Matthey. Platinum 2003; May 2003. 

http://www.platinum.matthey.com/publications/1059138410.html (Kendall, 2003) 

Metallextraktion AB (MEAB). August 2003. http://www.meab-mx.se/en/index.htm

(MEAB, 2003) 

Munters Europe AB. DEC SCR Converter System. April 26, 2007. (Munters, 

2007) 

United States Environmental Protection Agency. Clean Air Interstate Rule: 

Regulatory Impact Analysis; March 2005. 

http://www.epa.gov/interstateairquality/pdfs/finaltech08.pdf (EPA, 2005)
 VIII - 20 

United States Environmental Protection Agency, Guidelines for Preparing 

Economic Analyses. EPA240-R-00-003. September 2000. 

http://www.epa.gov/opei/pubsinfo.htm (EPA, 2000) 

United States Environmental Protection Agency. The Benefits and Costs of the 

Clean Air Act 1990 to 2010. EPA-410-R-99-001. November 1999. 

http://www.epa.gov/air/sect812/copy99.html (EPA, 1999) 

United States Environmental Protection Agency, Assessment and Standards 

Division, Office of Transportation and Air Quality. Draft Regulatory Impact 

Analysis: Control of Emissions of Air Pollution from Nonroad Diesel Engines and 

Fuel. EPA420-R-03-008. CD-ROM. Research Triangle Park, North Carolina. April 

2003http://www.epa.gov/otaq/cleaner-nonroad/r03008.pdf (EPA, 2003) 

U.S. Environmental Protection Agency (EPA), Assessment and Standards 

Division, Office of Transportation and Air Quality. Final Regulatory Analysis: 

Control of Emissions from Nonroad Diesel Engines Chapter 4. EPA420-R-04-

007. May 2004. 

http://www.epa.gov/otaq/regs/nonroad/equip-hd/2004fr.htm#ria (EPA, 2004) 
 IX - 1 

IX. SHORE POWER AS A GREENHOUSE GAS EMISSION REDUCTION 

MEASURE 

The focus of the proposed regulation is to require reductions in oxides of nitrogen 

and diesel particulate matter from ocean-going vessels while hotelling. However, 

as a co-benefit, it is also expected to result in a significant reduction in the 

emissions of carbon dioxide (CO2), a greenhouse gas (GHG). This chapter 

discusses the proposed regulation as a measure to reduce GHG emissions. 

A. Climate Change and California 

Climate change poses a serious threat to the economic well-being, public health, 

natural resources, and the environment of California. California is vulnerable to 

the impacts of climate change through the reduction in the quality and supply of 

water to the state from the Sierra snow pack; the exacerbation of California's air 

quality problems; the adverse impact on human health by increasing heat stress 

and related deaths, incidence of infectious disease, and risk of asthma, 

respiratory and other health problems; the rise in sea level along the 1,100 miles 

of coastline; and detrimental impacts to agriculture due to increased 

temperatures, diminished water supply and changes in the abundance and 

distribution of pests. 

National and international actions are necessary to fully address the issue of 

global warming; however, action taken by California to reduce emissions of 

greenhouse gases will have far-reaching effects by encouraging other states, the 

federal government, and other countries to act. Taking a leadership role, 

Governor Arnold Schwarzenegger signed Executive Order S-3-05 in June 2005, 

which established targets for reducing GHG emissions in California: roll back 

GHG emissions to 2000 levels by 2010, to 1990 levels by 2020, and finally to 

80 percent below 1990 levels by 2050. 

In 2006, the Governor signed Assembly Bill 32 (AB 32) (Stats. 2006, ch.488), 

which established the 2020 GHG emission reduction goal in State law 

(HSC § 38500 et seq.) and made the ARB responsible for monitoring and 

reducing GHG emissions. AB 32 requires the Board, by January 1, 2009, to 

design and adopt an overall plan to reduce GHG emissions to 1990 levels by 

2020. The Board has until January 1, 2011, to adopt the necessary regulations 

to implement that plan. Implementation begins no later than January 1, 2012, 

and the emission reduction target must be fully achieved by January 1, 2020. 

AB 32 also required the Board to identify a list of discrete early action GHG 

reduction measures by June 30, 2007. AB 32 defines discrete early action 

measure as regulations adopted by the Board and enforceable by 

January 1, 2010. 

In April 2007, ARB staff released a report identifying 37 proposed early action 

items the Board could undertake to mitigate GHG emissions in California. Port 

electrification was identified as a GHG emission reduction measure in this report. 

In September 2007, ARB staff, for the purpose of GHG emission reductions, 
 IX - 2 

renamed the shore electrification measure “Green Ports” and recommended 

reclassifying it from an early action measure to a discrete early action measure. 

Staff’s recommended reclassifications will be considered by the Board at its 

October 2007 hearing. 

AB 32 requires that all GHG reduction regulations adopted and implemented by 

the Board be technologically feasible and cost-effective. As mentioned earlier, 

ARB staff has developed the proposed regulation to reduce NOx and diesel PM, 

and has identified GHG emissions reductions as a co-benefit of the regulation; 

therefore, there are no additional costs for the reduction of CO2 associated with 

the proposed regulation. 

B. Carbon Dioxide Emission Factors 

Staff estimated the CO2 emissions reductions to be achieved under the proposed 

regulation. Since we expect both main compliance options under the regulation 

to be associated with the use of shore-based electricity, we calculated the CO2

emission reductions by multiplying the CO2 emissions rate associated with each 

of the sources of power (in pounds per megawatt-hour) by the total amount of 

power to be transferred from the shore to the ships (in megawatt-hours). 

 Auxiliary Engines

For the onboard auxiliary engines burning marine gas oil, ARB staff used a CO2

emission factor of 690 grams per kilowatt-hour (1520 pounds per megawatthour). This figure is based on work done by Entec using Lloyd’s of London and 

IVL Swedish Environmental Institute data that related emissions to engine speed 

and the type of fuel used (Entec 2002). 

 The Electrical Grid

The utility companies generate or purchase electricity from a variety of sources: 

hydroelectric dams, gas-fired power plants, coal-fired power plants, wind 

turbines, photoelectric cells, nuclear plants, and distributed generation sources 

using landfill and digester biogas or biomass, such as wood chips or agricultural 

wastes. Each of these sources has its own CO2 emissions profile. The utility 

companies typically generate and distribute their electricity in a manner called 

economic dispatch. That is, they generate electricity that is the least expensive 

to produce first, then the next least expensive next, and so on. A notable 

exception to this concept of economic dispatch includes producing electricity 

from renewable sources as required by State law, which may be among the most 

expensive generated. 

ARB staff took three different approaches to estimate the CO2 emissions from 

grid electricity. The first two are based on the generation of marginal power, 
 IX - 3 

while the third is based on current power-supply portfolios of the utility companies 

that would provide power to the six affected ports.

By presenting several options, staff recognizes the current work by others to 

quantify CO2 emissions associated with California’s electrical grid and provides a 

range of CO2 emissions reductions possible through the adoption and 

implementation of the proposed regulation. Under any of these options, ARB 

staff expects the GHG benefits from using grid-based shore power will increase 

with time, as AB 32 and other energy programs produce cleaner sources of 

electricity. 

1. Marginal Electricity 

Electricity used for shore power will be a new load for California utilities—it will be 

additional power generated over and above baseline electrical needs and 

marginal loads. ARB staff believes that the best approach for estimating the 

emissions from shore power is to use the emission profile for marginal power. 

The utility companies providing the power to the six ports affected by the 

proposed regulation indicated that marginal electricity production is typically 

generated at a natural gas-fired power plant utilizing a combined-cycle gas 

turbine (CCGT). 

A CCGT generates electricity by combusting the natural gas in a large turbine, 

which drives a generator, then taking the exhaust heat from that turbine to 

produce steam, which drives another turbine attached to another generator for 

additional electricity. The overall efficiency of a CCGT can be about 55 percent, 

which is higher than large simple-cycle turbines (40 percent) and internalcombustion engines (30 to 38 percent), although their overall efficiency can be 

improved by utilizing their waste heat in other processes. This is called 

combined-heat-and-power (CHP). The exhaust heat can be used to heat water, 

make steam, heat or cool buildings, or supplement industrial processes. 

When considering CO2 emissions from marginal power, staff considered two 

sources: 1) the CO2 emissions value that the California Energy Commission 

(CEC) and the California Public Utilities Commission (CPUC) recommended for 

unspecified sources of electricity; and 2) an emissions estimate that the Climate 

Action Team (CAT) Economics Subgroup developed. 

a. California Energy Commission and the California Public Utilities 

Commission Values for CCGT Emissions 

The estimated CO2 emissions from a CCGT vary, and staff used values based on 

work being conducted to satisfy the requirements of SB 1368 (Stats. 2006, 

ch. 598) and AB 32. SB 1368 requires the California Energy Commission (CEC), 

in consultation with the California Public Utilities Commission (CPUC) and the 

ARB, to establish a greenhouse gases emission performance standard for all 
 IX - 4 

baseload generation of local publicly owned electric utilities that is no higher than 

the rate of emissions of greenhouse gases for combined-cycle natural gas 

baseload generation. SB 1368 also requires that the greenhouse gases 

emission performance standard established by the CEC be consistent with the 

standard adopted by the CPUC. 

In the second quarter of 2007, the CPUC and the CEC adopted an emission 

performance standard of 1,100 pounds of CO2 per megawatt hour of electricity 

(lbs CO2/MW-hr). Although this standard of performance is higher than that of a 

new CCGT using best available control technology (BACT), the CPUC and CEC 

set the standard so that new, clean units in adverse conditions such as high 

altitude or hot temperatures would not be crowded out by a standard that was too 

restrictive (CEC, March 2007). 

In another joint effort between the CPUC and the CEC, the commissions 

recommended in September 2007 that ARB, as part of its AB 32 obligations, 

adopt a reporting and verification regulation for GHG emissions from the 

electricity sector based upon the commissions’ proposed model rule 

(CEC/CPUC, September 2007). Of particular interest is the recommendation 

that, when the source of a power purchase is not identified, ARB use a regional 

default emission factor of 1,100 lbs CO2/MW-hr. The commissions 

recommended that this value be used for purchases from both in-state and outof-state unspecified sources, and should be in effect until a regional tracking 

system for GHG emissions from electricity is implemented. 

b. Climate Action Team Economics Subgroup Macroeconomic 

Analysis 

When Governor Schwarzenegger signed Executive Order S-3-05 in June 2005, 

he created a Climate Action Team (CAT) to implement global warming emission 

reduction programs and report on the progress made toward meeting the 

statewide greenhouse gas targets that were established in the Executive Order 

(Schwarzenegger, 2005). The CAT, under the guidance of the California 

Environmental Protection Agency (Cal/EPA), was comprised of representatives 

from the ARB, the Business, Transportation and Housing Agency, the 

Department of Food and Agriculture, the Resources Agency, the CPUC, and the 

CEC. 

The CAT created an Economics Subgroup to examine the economic impacts of 

achieving the State’s climate goals. The subgroup presented preliminary findings 

to the Governor in March 2006 as part of an overall CAT Report. As described in 

the 2006 CAT Report, the macroeconomic impact assessment available at that 

time was preliminary, and would benefit from updated cost and savings estimates 

for the strategies as well as a refined analysis. Consequently, the Economics 

Subgroup committed to providing an updated analysis. 
 IX - 5 

In September 2007, the Economics Subgroup presented a draft updated 

macroeconomic analysis (CAT Economics Subgroup, 2007). The goals of the 

updated analysis were to ensure consistent methods for estimating emissions, 

costs, and savings for the GHG emissions reductions measures identified by the 

CAT; identify and address potential double counting, identify and address cobenefits; and provide documentation and transparency. 

One key element of the economic analysis was to determine the GHG impact of 

generating electricity. For that analysis, the subgroup estimated the GHG 

emissions related to electricity production, examining both “avoided fossil-fuel 

generation” and “avoided renewable generation.” 

The subgroup defined “avoided fossil-fuel generation” as electricity from a 

combined-cycle gas turbine with a heat rate of 7,000 Btus per kilowatt-hour. It 

considered this level of performance as a reasonable representation of a new 

power plant whose construction may be avoided due to reduced electricity 

demand, and the subgroup estimated the emissions from this representative 

plant to be 815 lbs CO2/MW-hr. 

By 2020, renewable generation is expected to be at least 20 percent of electric 

supply. The investor-owned utilities are committed to achieving this level of 

renewables by 2010, and the municipal utilities are expected to achieve this level 

prior to 2020. Therefore, reductions in electricity demand in 2020 will reduce 

generation from the entire mix of generating assets, including renewable 

generation. While some renewable electric supply has zero direct GHG 

emissions (e.g., wind), data provided by the CPUC indicate that geothermal 

sources may have emissions on the order of 50 lbs CO2/MW-hr. Based on 

recent CEC staff scenario analysis showing that geothermal sources may 

account for about one-third of renewable energy production, the subgroup 

estimated emissions from the renewable portion of electric power generation to 

be 17 lbs CO2/MW-hr. 

The subgroup also considered transmission losses. Based on CPUC data, it 

estimated that losses from in-state generation are about 4.5% and losses from 

out-of-state generation are about 7.5%. Furthermore, the subgroup assumed 

that 80 percent of the new generation would come from in-state sources, with the 

remainder coming from out-of-state sources (similar to the current supply ratio). 

Using these assumptions about marginal electricity production, renewables, 

transmission losses, and sources of the electricity, the subgroup estimated the 

emission factor for avoided electricity to be 690 lbs CO2/MW-hr. 
 IX - 6 

2. Average Utility Portfolio Values 

As mentioned above, the utility companies generate or purchase electricity from 

a variety of sources: hydroelectric dams, gas-fired power plants, coal-fired power 

plants, wind turbines, photoelectric cells, nuclear plants, and distributed 

generation sources. Because the utility companies have different portfolios of 

generated and purchased power, the CO2 emissions associated with those 

portfolios varies. 

Table IX-1 shows the emission factor that staff estimated for the utility companies 

that would provide power to the ports affected by the proposed regulation using 

the 2005 CEC power mix and power content labels (CEC, 2006). 

Table IX-1: Carbon Dioxide Emission Factors for Electrical Generation by 

Utility Company (Pounds per Megawatt-Hour) 

Port(s) Utility Estimated Average 

Emission Factor 

Los Angeles Los Angeles Department of 

Water and Power 1,300 

Long Beach, Hueneme Southern California Edison 700 

Oakland, San Francisco Pacific Gas & Electric* 450 

San Diego San Diego Gas & Electric 750 

* The Port of Oakland receives its power from the Western Area Power Administration 

(WAPA), and the Port of San Francisco receives its power from Hetch Hetchy Water & 

Power. PG&E is used as a surrogate here. The actual emission factor may be lower due to 

the hydroelectric sources of electricity from these two utilities. 

The portfolio of the Los Angeles Department of Water and Power (LADWP) 

contains electricity generated by out-of-state coal-fired power plants, so its 

average GHG emission factor is considerably higher than the other utility 

companies. The requirements of SB 1368 and AB 32, and the requirements for 

achieving specified targets of renewables within portfolios, will reduce this 

emission factor and probably all of the emission factors, as the grid gets “cleaner” 

between now and 2020. 

Based upon the discussion above, the emissions factors for calculating GHG 

emissions reduction are presented in Table IX-2. 

Table IX-2: Carbon Dioxide Emission Factors for Electrical Generation 

(Pounds per Megawatt-Hour) 

Onboard Auxiliary 

Engines

Marginal Electricity from 

the Grid Average Utility Portfolios 

1,518 690 – 1,100 450 – 1,300 
 IX - 7 

C. Emission Reduction Calculations 

The estimated electricity shifted from the auxiliary engines to the grid is 

presented in Table IX-3. (See Chapter VII for discussion on California grid 

impacts of proposed regulation.) 

Table IX-3: Estimated Electricity Demand in 2020 for Shore Power 

PORT PEAK LOAD (MW) ANNUAL USAGE 

(GW-HRS) 

Hueneme 5 16 

Long Beach 55 192 

Los Angeles 70 255 

Oakland 20 94 

San Diego 40 77 

San Francisco 15 9 

TOTAL 205 643 

To estimate the CO2 emissions reductions achieved by the proposed regulation, 

staff multiplied the difference between the auxiliary engine emission factor and 

the electrical grid factor(s) by the shift in total load from the ships to the grid. 

For example: 

(1,518 – 690) lbs/MW-hr x 643,000 MW-hr in 2020 ÷ 2,200 lbs/metric ton = 

 242,000 metric tons of CO2 reduced in 2020 

This example assumes that the marginal electricity supplied by the grid for shore 

power resembles that estimated by the CAT Economics Subgroup. If the 

CPUC/CEC figure of 1,100 lbs CO2/MW-hr is used, the estimated statewide CO2

emissions reductions drops to 122,000 metric tons of CO2 reduced in 2020. 

Using the current portfolios of the specific utility companies, the estimated 

statewide CO2 emissions reductions are shown in Table IX-4. 
 IX - 8 

Table IX-4: Estimated Statewide Carbon Dioxide Emissions Reductions 

Using Average Portfolio Emission Factors 

Port Annual Usage 

(GW-hrs) 

Estimated CO2 Emission 

Reductions (Metric Tons) 

Hueneme 16 5,500 

Long Beach 192 71,000 

Los Angeles 255 25,000 

Oakland 94 46,000 

San Diego 77 27,000 

San Francisco 9 4,000 

TOTAL 715 179,000* 

* If 100 percent hydroelectric generation is assumed for the Bay Area ports, the total 

reductions would be 197,000 metric tons of CO2. 

Therefore, the estimated statewide CO2 emissions reductions achieved by the 

proposed regulation in 2020 are 122,000 – 242,000 metric tons. 

These reductions are less than the 500,000 metric tons of CO2 originally 

estimated for the CAT for two significant reasons: 

• ARB staff revised downward the growth factors for the ocean-going 

vessels, especially the passenger ships, since the original estimate; 

and 

• Based on wharfinger data supplied by the ports for the development of 

the proposed regulation, the average berthing times of the ships are 

shorter than what staff used in the original estimate in 2006. 

D. Conclusions 

ARB staff considered the co-benefit of the proposed regulation on CO2 emission 

reductions and reached the following conclusions: 

1. In all scenarios—whether considering the generation of marginal 

power or using the emissions associated with specific utility 

portfolios—shore power will achieve CO2 reduction benefits. 

2. ARB staff believes that the most likely source of electricity for shore 

power will be a mix of marginal sources of power with an mid-range 

emission factor of about 900 lbs/MW-hr. 
 IX - 9 

3. With the above assumption, the proposed regulation would reduce 

GHG emissions in 2020 by 181,000 metric tons, a 40 percent 

reduction for the affected ships. 

4. The GHG benefits of using grid-based shore power will increase 

with time, as AB 32 and other energy programs produce cleaner 

sources of electricity. 

E. Impact of Alternative Technologies on Carbon Dioxide Emissions 

Reductions 

The proposed regulation will allow the use of alternative technologies to achieve 

required emission reductions. These alternatives may include ship-side 

technologies, such as post-combustion devices, alternative fuels, or cleaner 

engines; or shore-side technologies, including distributed generation or emissioncapture-and-treatment devices (so-called “bonnet” systems). These 

technologies—although attractive for early deployment for NOx and diesel PM 

reductions—will most likely be less effective in reducing GHG emissions when 

compared to grid-based shore power, but they are permitted as specified in the 

proposal. 

For example, one of the alternative technologies being considered is providing 

power to the ship via a portable generator driven by an engine fueled with liquid 

natural gas (LNG). Assuming an engine efficiency of 36 percent, which is not 

unusual for a large spark-ignited engine, this alternative technology would emit 

about 1,090 lbs CO2/MW-hr, which is essentially the same as the recommended 

CPUC/CEC value for combined-cycle gas turbines, although it is certainly higher 

than a CCGT using BACT or many of the average values associated with the 

individual utility company portfolios. 

For sources of electricity other than the grid for providing shore power to the 

ships, the proposed regulation limits the CO2 emissions to 500 grams per 

kilowatt-hour (1,100 lbs CO2/MW-hr). This emission standard will prohibit the use 

of electrical generation technologies that emit much higher levels of CO2, such as 

diesel engines and less efficient spark-ignited engines. 

The post-combustion technologies—selective catalytic reduction (SCR), diesel 

particulate filters (DPFs), and diesel oxidation catalysts (DOCs)—tend to 

increase CO2 emissions due to increased fuel use. However, the DPFs and 

DOCs remove black carbon, a component of diesel PM and a likely contributor to 

global warming. 

For the emission-capture-and-treatment devices (e.g., Advanced Cleanup 

Technologies’ “bonnet” system), there would be a much larger CO2 penalty 

because there is an auxiliary burner on the treatment unit for reheating the stack 

gases so that the SCR operates effectively. In addition, a vessel would use a 

bonnet system to allow the continued operation of the onboard auxiliary engines. 
 IX - 10 

Thus, the auxiliary engines aboard the ships would still be operating, along with 

the treatment unit’s burner. On the other hand, this alternative technology would 

capture and treat the NOx and PM emissions from the boilers on the ships—

something that shore power would not do—so the increase in CO2 emissions 

would need to be balanced against the additional NOx and PM emission 

reductions. 

Most of these technologies are at the proof-of-concept stage, and ARB staff 

cannot at this time predict with certainty the extent of their deployment in the 

future. Therefore, we are unable to project the impact of such alternatives on 

overall CO2 emission reductions under this program. 
 IX - 11 

REFERENCES: 

California Air Resources Board. Proposed Early Actions to Mitigate Climate 

Change in California, April 2007. 

California Air Resources Board. Expanded List of Early Action Measures to 

Reduce Greenhouse Gas Emissions in California Recommended for Board 

Consideration, October 2007. 

California Energy Commission. Initial Study/Proposed Negative Declaration for 

Regulations Establishing and Implementing a Greenhouse Gases Emission 

Performance Standard for Local Publicly Owned Electric Utilities, 

CEC-700-2007-006, March 2007. 

California Energy Commission. Net System Power: A Small Share of California’s 

Power Mix in 2005, CEC-300-2006-009-F, April 2006. 

California Energy Commission. Reporting and Verification of Greenhouse Gas 

Emissions in the Electricity Sector,” California Public Utilities Commission, CPUC 

Rulemaking 06-04-009, Decision # 07-09-017, September 6, 2007, California 

Energy Commission, Docket 07-OIIP-1, September 12, 2007. 

California Environmental Protection Agency. Climate Action Team Report to 

Governor Schwarzenegger and the Legislature, March 2006. 

Climate Action Team Economics Subgroup. Updated Macroeconomic Analysis 

of Climate Strategies Presented in the March 2006 Climate Action Team Report, 

Public Review Draft, September 7, 2007. 

Entec UK Limited. Quantification of Emissions from Ships Associated 

with Ship Movements between Ports in the European Community, July 2002. 

Los Angeles Department of Water and Power. “ Power Content Label, Annual 

Report of Actual Electricity Purchases for LADWP, Calendar Year 2006.” 

May 2007. http://www.ladwp.com/ladwp/cms/ladwp006643.pdf

Pacific Gas and Electric Company. “July 2006 Bill Inserts.” 2006 

http://www.pge.com/customer_service/bill_inserts/2006/july.html

San Diego Gas and Electric. “Power Content Label.” 

http://www.sdge.com/tariff/inserts/FINAL0730070_PowerLabel_3.pdf

Southern California Edison. “Power Content Label.” 2006. 

http://www.sce.com/NR/rdonlyres/145E4E27-36CF-43FE-8E84-

38D7FFE84A30/0/Insert_PCL_Q3_0606.pdf
 IX - 12 

Schwarzenegger, Arnold, “Executive Order S-3-05.” June 1, 2005.
X - 1 

X. ECONOMIC IMPACTS 

In this chapter, we present the estimated costs and economic impacts associated 

with the implementation of the proposed regulation. The estimated capital and 

recurring costs are presented, as well as an analysis of the cost-effectiveness. 

The economic impacts associated with the costs of the proposed regulation are 

presented for private companies, as well as for governmental agencies. 

A. Legal Requirements 

In this chapter, we will also address certain legal requirements that must be 

satisfied in analyzing the economic impacts of the proposal. 

Section 11346.3 of the Government Code requires State agencies to assess the 

potential for adverse economic impacts on California business enterprises and 

individuals when proposing to adopt or amend any administrative regulation. The 

assessment shall include a consideration of the impact of the proposed 

regulation on California jobs, business expansion, elimination or creation, and the 

ability of California businesses to compete with businesses in other states. 

In addition, the ARB is required under section 43013(b) of the Health and Safety 

Code (H&SC) to adopt standards and regulations, consistent with H&SC section 

43013(a), for marine vessels to the extent permitted by federal law. Health and 

Safety Code section 43013(a) authorizes ARB to adopt and implement “motor 

vehicle emission standards, in-use performance standards, and motor vehicle 

fuel specifications...which the State board has found to be necessary, costeffective, and technologically feasible...” 

A literal reading of H&SC section 43013(a) would lead one to conclude that the 

criteria “necessary, cost-effective, and technologically feasible” do not apply to a 

marine vessel regulation because marine vessels are non-vehicular by definition. 

(See H&SC section 39039.) However, because the Legislature placed the 

authorization to regulate marine vessels in H&SC section 43013(b), we will infer 

a legislative intent to require ARB to determine that its proposed regulations on 

marine vessels are “necessary, cost-effective, and technologically feasible.” 

Also, State agencies are required to estimate the cost or savings to any State or 

local agency and school district in accordance with instructions adopted by the 

Department of Finance (DOF). The estimate shall include any non-discretionary 

cost or savings to local agencies and the cost or savings in federal funding to the 

State. 

Finally, H&SC section 57005 requires the Air Resources Board to perform an 

economic impact analysis of submitted alternative regulatory approaches to a 

proposed regulation before adopting any major regulation. A major regulation is 

defined as a regulation that will have a potential cost to California business 
X - 2 

enterprises in an amount exceeding ten million dollars in any single year. The 

estimated cost of the proposed regulation does exceed ten million dollars in a 

single year, although much of the cost will be borne by businesses based outside 

of California. Nevertheless, we have conducted an economic impact analysis of 

submitted alternative regulatory approaches to the proposal. 

The following is a description of the methodology used to estimate costs as well 

as ARB staff’s analysis of the economic impacts on California businesses and 

State and local agencies. 

B. Summary of the Economic Impacts 

Although not required, staff assumes that the most widely deployed technique for 

meeting the requirements of the proposed regulation will be grid-based shore 

power. This approach satisfies the “limited engine use” option and will probably 

be the technique of choice for the emissions reduction option. Consequently, 

staff’s economic analysis addressed the use of grid-based shore power only. 

Staff estimates the statewide total regulatory costs for affected businesses and 

port authorities to comply with the proposed regulation to be approximately 

$1.8 billion, discounted to 2006 dollars. Annually, the costs are expected to vary 

from $30 million to $137 million. The low end of the range represents a year 

when the only major capital expenditures are for retrofitting container ships due 

to repositioning, and the high end of the range represents a year when capital 

expenditures are being made for shoreside infrastructure and for retrofitting a 

considerable number of ships to meet the 2020 milestone. The total statewide 

annual costs to private business include recovery of capital expenditures, both 

aboard the ships and at the ports, and operating costs, which are labor costs and 

net energy costs, if any. 

Since 25 of the 35 vessel fleets affected by the proposed regulation are 

container-ship fleets, for the purposes of this proposed regulation, the typical ship 

company refers to a company operating container ships. The total costs to a 

typical ship company complying with the proposed regulation, including capital 

and ongoing costs, are estimated to be about $34 million. This cost would be 

distributed over the years 2009 to 2030. Annual costs would vary between 

$600,000 and $3 million per year, with the average cost of $1.5 million per year 

over this time period. The low end of the range represents a year when no major 

capital expenditures are made, and the high end of the range represents a year 

where capital expenditures are made for both new ships as well as replacement 

ships that are rerouted. 

 For the other ship categories, the total costs for a typical ship company to 

comply with the proposed regulation, including capital and ongoing costs, are 

estimated to be about $3.2 million. This cost would be distributed over a 12-year 

period, from 2009 to 2020. Annual costs would vary between $150,000 and 
X - 3 

$500,000 per year, with the average cost of $260,000 per year over this time 

period 

Similarly, the total costs to a typical terminal operator complying with the 

proposed regulation, including capital and ongoing costs, are estimated to be 

about $11 million. About 20 percent of the cost is attributed to labor costs and 

the other 80 percent for capital costs. This cost would be distributed over a 12-

year period, from 2009 to 2020. Annual costs would vary between $500,000 and 

$1.1 million per year, with the average cost of $1 million per year over this time 

period. The low end of the range represents a year where no major capital 

expenditures are made, and the high end of the range represents a year where 

capital expenditures are made for shore-side improvements. With 31 terminals 

and 35 vessel fleets affected by the proposed regulation, the cost to a typical 

business would be $26 million. 

Ship companies, terminals, and ports would have additional recurring costs 

associated with recordkeeping and reporting. For a ship company, the costs 

associated with reporting and recordkeeping will vary between $600 and $12,000 

annually. The higher cost for reporting and recordkeeping is based upon the ship 

company complying with the emission reduction option of the proposed 

regulation, and the lower end of the range is the costs for ship companies 

complying with the limited engine use option. Similarly, for the terminal operator, 

the costs associated with reporting and recordkeeping is about $800 annually. 

Staff estimated that the overall cost effectiveness of the proposed regulation is 

about $12,800 per ton of NOx emissions reduced, assuming all costs are 

allocated to NOx reduction. For diesel PM, staff estimated an overall costeffectiveness of $690,000 per ton, assuming all costs are allocated to PM 

reduction. 

ARB staff considers the CO2 emissions reductions achieved by this proposed 

regulation to be a co-benefit; therefore, there are no costs associated with CO2. 

C. Methodology for Estimating Costs Associated with Implementation 

This section provides the general methodology and assumptions used to 

estimate the costs associated with the proposed regulation. 

1. Compliance Options 

The proposed regulation has two basic approaches for achieving emissions 

reductions: 1) the limited engine use option, and 2) the emissions reduction 

option. (See Chapter VI for a complete description of the requirements of the 

proposed regulation.) 
X - 4 

The limited engine use option requires certain container ships, passenger ships, 

and refrigerated cargo ships (reefers) to turn off their auxiliary engines when they 

dock, or “hotel,” at a California port. For 2014, at least 50 percent of the ship 

visits from these three categories of ships must turn off their auxiliary engines. In 

2020, at least 80 percent of the ship visits must do this. The assumption is that 

these ships will receive their electrical needs from on-shore through electrical 

cables. 

The alternative regulatory approach—the emissions reduction option—would 

require these ships to reduce their auxiliary engine hotelling emissions by 

specific amounts by certain dates, depending on the control technologies 

chosen. For example, if the vessel fleet operator chooses shore power, that fleet 

must reduce its hotelling emissions by at least 50 percent by 2014 and 

80 percent by 2020. If the vessel fleet operator chooses to use an alternative 

control technology, that fleet must reduce its hotelling emissions by 20 percent in 

2010, increasing another 20 percent every two years until the fleet has reduced 

its emissions by at least 80 percent by 2016. Finally, someone choosing a 

combination of these two approaches has emission-reduction targets of 

20 percent in 2012, 40 percent in 2014, and 80 percent in 2020. 

Staff believes that the most widely deployed technique for meeting the 

requirements of the proposed regulation will be grid-based shore power. This 

approach satisfies the limited engine use requirement and will probably be the 

technique of choice for the emissions reduction option. Consequently, the 

economic analysis below will address the use of grid-based shore power. Staff 

will provide a general discussion of alternative control technologies, citing costs 

where available. 

2. Capital Cost Assumptions 

The sections below discuss the capital cost assumptions used in the costeffectiveness analysis. Appendix E contains additional information regarding the 

information used to establish the assumptions and also contains an example 

cost-effectiveness calculation. 

Ships

For shore power to be implemented, ships need to be equipped to receive power 

from an outside source. Existing ships usually need to be retrofitted with specific 

electrical equipment—wiring, connectors, transformers, and switch gear—while 

many new ships are being built with this equipment as part of their naval 

architecture. 

Based on previous shore-power projects, the cost to modify a ship to receive 

shore power ranges from $500,000 to $2 million. The less expensive ship 

retrofits have occurred with passenger ships, the more expensive retrofits with 
X - 5 

container ships. To date, no reefers have been retrofitted for shore power. (See 

Chapter IV for a complete discussion of current shore power activities, including 

specific ship retrofit costs.) 

For the purpose of estimating total costs and calculating cost effectiveness, staff 

used $1.5 million per ship. This represents a conservative estimate, as it is 

toward the higher end of the cost spectrum, and staff expects the cost per ship to 

decrease as new ships are built with shore-power capability instead of retrofitting 

existing ships. Staff estimates that as many as 1,450 ships will need to be 

equipped for shore power over the lifetime of this proposed regulation. 

 Terminals

Just as the ships need to be equipped to receive shore power, the berths at the 

terminals must be capable of providing that power. The necessary shoreside 

infrastructure may include cables, plugs, underground wiring, substations, 

transformers, and switch gear. Based upon information provided by various 

ports, staff estimates that the cost to modify each berth at a terminal will be about 

$5 million. Staff estimates that 78 berths will have to provide shore power to 

visiting ships in 2020. 

 Electrical Infrastructure Outside Ports

Electrical infrastructure, such as distribution lines and substations, may be 

required on the part of the local utility company to supply the ports with sufficient 

electricity for shore power projects. The Ports of Los Angeles and Hueneme are 

not expected to need significant additional outside electrical infrastructure; 

however, several other ports will require upgraded electrical service. For 

example, the Port of Long Beach has estimated that to bring sufficient power to 

the port, an additional $15 million needs to be invested. The Port of San Diego 

may require as much as $32 million of additional investment, although recent 

reconfigurations should lower that estimate considerably. (SDG&E 2007) 

For the purpose of estimating total capital costs and the cost effectiveness of the 

proposed regulation, staff used $15 million for the Ports of Long Beach, Oakland, 

and San Francisco, $30 million for the San Diego, and no additional significant 

costs for Los Angeles and Hueneme. Some of these capital costs may be borne 

by the local utility, since the customers (the terminals) will be paying higher utility 

bills for increased electricity usage; however, the ports, terminals, and utility 

companies ultimately negotiate these arrangements. 
X - 6 

3. Operating Cost Assumptions 

Energy Costs

Shore power shifts electrical generation from a ship’s onboard generators, driven 

by auxiliary engines, to a source on shore, usually the electrical grid. 

Consequently, the ship must purchase electricity, but it saves fuel by shutting 

down its auxiliary engines. 

Electrical tariff schedules vary among utilities, but they all typically include 

monthly fees, demand charges, time-of-use charges, and seasonal adjustments. 

Overall, the cost of electricity from the grid depends upon how much capacity is 

needed (i.e., the “demand,” the maximum number of megawatts needed at any 

one time) and how much electricity is used annually. 

The most expensive average electrical rates occur if the electrical demand is 

high (a lot of megawatts are needed, as with passenger ships), but the actual 

usage is low (few ships using shore power infrequently). In this case, the 

demand charges, which can be substantial and are paid whether one is using 

electricity or not, dominate the total electricity costs. Conversely, for most tariff 

schedules, the more continually the electricity is used, the lower the average 

electrical rate. In this case, the monthly fees and the demand charges are 

diluted by the energy costs, which can be relatively low (8 cents per kilowatthour). 

Staff used actual utility tariff schedules to estimate electrical costs for shore 

power with one exception. The Los Angeles Department of Water and Power 

(LADWP), which serves the Port of Los Angeles, is proposing a special AMP 

(Alternative Maritime Power) tariff schedule that will be based on an interruptible 

schedule and will cost about 13 cents per kilowatt-hour ($0.13/kW-hr). Southern 

California Edison (SCE), who serves the Port of Long Beach, is discussing a 

similar approach. For container ships, which are expected to consume threequarters of the electricity required for shore power, staff assumed that the cost of 

electricity would be $0.13/kW-hr. 

Passenger ships use a considerable amount of electricity while hotelling—up to 

12 megawatts—and they normally hotel during the day when rates are the 

highest, so their cost for electricity is considerably greater than that for container 

ships. (ARB, 2005a) Therefore, for passenger ships, staff used actual utility 

tariff schedules to estimate electrical costs for shore power. (PG&E, 2005) 

(SDG&E, 2005) (SCE, 2005) These electricity costs ranged from $0.13/kW-hr to 

$0.29/kW-hr. 

Staff also used tariff schedules for the reefers. (SDG&E, 2005) (SCE, 2005) 

Although their overall usage is low, their rates are more affected by demand 

charges, raising their average cost for electricity per kilowatt-hour. The electricity 
X - 7 

rate for reefers at San Diego remained near $0.13/kW-hr, but the Hueneme rates 

were $0.23 – 0.26/kW-hr. 

For fuel costs, staff assumed that the ships were burning distillate fuel in their 

auxiliary engines, pursuant to the requirements of the auxiliary engine fuel 

regulation adopted by the Board in December 2005. Although there has been a 

legal challenge to that regulation, staff assumes that distillate will continue to be 

used at dockside. Based on published costs for fuels in the spot-fuel market in 

the summer of 2007, staff estimated distillate fuel to cost $550 per metric ton. 

Using the energy content of these fuels, and an average internal-combustionengine efficiency of 35 percent, these market values correspond to about 

$0.13/kW-hr. Therefore, staff assumed for the container ships the cost of 

distillate fuel used in the auxiliary engines would offset each other, thereby 

resulting in no net cost to the ships that use shore power. For the other two ship 

categories, staff compared actual electricity rates from the tariff schedules to the 

price of fuel, resulting in a net energy cost to the ships for shore power. 

 

Labor

For all ship categories, staff included the cost of using union electricians to both 

connect and disconnect electrical power for these ships. Staff assumes that 

three electricians are necessary to perform this function at a compensation rate 

of $100/hour, or $600 per ship visit. However, if electricians are not already on 

duty, costs could be much higher, as labor contracts require that workers, once 

called, be paid for an entire shift. Assuming that electricians were paid an entire 

shift to connect a ship and again to disconnect a ship, the labor costs for a ship 

visit could be as high as $4800. For the purpose of calculating total operating 

costs and overall cost-effectiveness, staff used $4800 per visit. In the case of 

passenger ships, staff assumed that two electricians would connect and 

disconnect electrical power. All other assumptions regarding labor costs are the 

same. 

 Maintenance

ARB staff assumed that additional maintenance costs incurred with shorepower—mostly associated with shore-side electrical equipment—would be offset 

by reduced maintenance costs for the ship’s auxiliary engines, which would 

accrue fewer hours of operation. Therefore, maintenance was not included in the 

cost-effectiveness analysis. 

 Recordkeeping and Reporting Requirements

The proposed regulation has reporting and recordkeeping requirements affecting 

the ship companies, terminals, and ports. 
X - 8 

The reporting and recordkeeping requirements for ship companies depend upon 

the compliance option selected by the vessel owner or operator and terminal. 

The proposed regulation requires a vessel fleet plan to be submitted to the 

Executive Officer of the ARB in the years prior to the fleet’s regulatory 

compliance dates. In addition to the vessel fleet plans, the proposal requires an 

annual statement of compliance to be submitted to the Executive Officer of the 

ARB certifying compliance with the regulatory requirements for the previous 

calendar year. 

The recordkeeping and reporting requirements are simpler for the limited engine 

use option because the vessel owner or operator choosing that option must track 

only those vessels that will comply with the 2014 and 2020 shore power 

requirements. The recordkeeping and reporting requirements for the emission 

reduction option are more significant because the vessel owner or operator 

choosing that option must track the emissions of each vessel in the fleet. 

Staff estimates that, for the ship companies that choose the limited engine use 

option, eight hours would be expended to complete the vessel fleet plan, and 

16 hours would be used to complete the annual compliance report. Based upon 

these estimates, the cost to prepare the vessel fleet plan is about $300, and each 

ship company is expected to expend about $600 annually to prepare the 

compliance report. Finally, staff anticipates that the ship companies would use 

existing resources to satisfy the proposed regulation’s reporting requirements. 

Similarly, for a ship company using the emission reduction option, the reporting 

and recordkeeping costs associated with these requirements are about $800 for 

the vessel fleet plan and about $8,000 annually to prepare the compliance report. 

Finally, staff estimates that the recordkeeping for this option would cost about 

$4,000 annually. 

A terminal that receives more than 50 vessel visits in 2008 is required to submit a 

plan to the Executive Officer of the Air Resources Board by July 1, 2009. This 

plan is required to identify how the terminal will be upgraded to allow vessels to 

satisfy either the limited engine use option or the emissions reduction option. 

The terminal is also required to submit plan updates at a frequency that depends 

on the control strategy selected by the vessel fleet owner or operator and the 

terminal. 

Staff estimates that a company will use one person-month to develop the plan 

and use three days to prepare each of the plan updates required by the proposed 

regulation. Furthermore, staff anticipates that existing resources would be used 

to satisfy the proposed regulation’s reporting requirements. Overall, the cost to 

develop the plan is estimated to be about $7,000 with another $1,000 to be 

expended by terminal staff for each update to the plan. 
X - 9 

The port is required to submit wharfinger data annually to ARB’s Executive 

Officer. The port’s written submittal must document when each vessel visits the 

port, the berth that the vessel visited, and the dates and times that the vessel 

was initially tied to the berth and subsequently released from the berth. In 

addition, the terminal operator is required to keep records of electricity usage for 

shore power and equipment breakdowns that affect a vessel’s ability to comply 

with the limited engine use option or the emission reduction option. 

Staff anticipates that each port will use eight hours of staff time to prepare the 

wharfinger data and one hour a month for recordkeeping. Overall, the annual 

cost for the ports is expected to cost about $800 annually. 

4. Ship Assumptions 

Number of Ships Affected

ARB staff developed a 2006 baseline for the number of ships potentially affected 

by this proposed regulation, then applied the growth factors in Table X-1 to 

estimate activity levels in 2014 and 2020. The 2006 baseline is based upon 

wharfinger information provided by the ports. For all ships that visited a specific 

port, the wharfinger information provides the berth that the ship visited and its 

date and time of arrival and departure. 

Table X-1: Growth Factors Used in Cost-Effectiveness Analysis 

Category Growth Factors 

Container Ships Container ship growth: 

• 2014: ships are 45 percent larger than in 2004 

• 2020: ships are 55 percent larger than in 2004 

Ship visits: 

• 2014: 40 percent increase in ship traffic from 2004 

• 2020: 75 percent increase in ship traffic from 2004 

Passenger Ships Ship visits: 

• 2014: 36 to 95 percent increase in ship traffic from 

2006, depending upon specific port 

• 2020: 72 to 323 percent increase in ship traffic from 

2006, depending upon specific port 

Reefers Ships Ship visits: 

• 2014: 15 to 205 percent increase in ship traffic from 

2006, depending upon specific port 

• 2020: 27 to 350 percent increase in ship traffic from 

2006, depending upon specific port 
X - 10 

To account for growth in activity for the passenger ships and reefers, staff 

developed growth factors and increased the number of ship visits accordingly. 

(See Appendix B for a discussion on the development of the ARB emissions 

inventory.) For container ships, the growth in activity (i.e., total containers 

imported and exported) will be accomplished by both larger ships and more 

visits. For this reason, staff used the growth estimates for container ships in the 

report Forecast of Container Vessel Specifications and Port Calls within San 

Pedro Bay (Mercator, 2005), which considered these two phenomena. 

Hotelling Times

Staff used port wharfinger data from 2004 – 2006 to determine hotelling times for 

the three ship categories, excluding the data for container ships visiting the Ports 

of Los Angeles or Long Beach during the second half of 2004. There was a labor 

shortage during that period, extending the hotelling times to levels that are 

considered unrepresentative. 

Hotelling times for the passenger and reefer ships are generally consistent with 

each visit. For container ships, the hotelling times are more variable, depending 

on the port visited, the carrier, and the size of the container ship. This variation 

in hotelling times was considered in the cost-effectiveness analysis. 

Power Usage

Staff estimated ship hotelling electrical requirements based upon the results of 

the 2005 ARB Ocean-Going Vessel Survey and subsequent discussions with 

ship operators. For container ships, the electrical demand includes two 

elements: 1) a basic hotelling requirement for water-pumping and general 

household requirements, and 2) the electrical load from refrigerated containers 

(reefer boxes). The 2005 survey results provided estimates of the basic hotelling 

load and some information on the load from reefer containers. Staff requested 

additional information on reefer boxes carried by container ships in the 2007 ARB 

Ocean-Going Vessel Survey and also attempted to estimate the reefer load by 

compiling U.S. Department of Commerce (DOC) data on goods imported and 

exported in California that are likely to be refrigerated.

Table X-2 presents a summation of assumptions that staff used in its estimation 

of the total cost and cost-effectiveness of the proposed regulation. 
X - 11 

Table X-2: Major Assumptions Used In Cost-Effectiveness Analysis 

Category Assumptions 

All • An annual five percent real interest rate is basis of all 

economic impacts, assuming seven percent nominal interest 

and two percent inflation 

• All costs reported in 2006 dollars 

• Ship capital costs amortized over 10 years 

• Terminal capital costs amortized over 20 years 

• Cost-effectiveness analysis period covers period beginning 

with year with first expenses and ends with year with the final 

expenses 

- 2009 through 2020 for passenger and reefer ships 

- 2009 through 2030 for container ships 

Container 

Ships 

• Average power requirements for this category vary from 1 to 

2 MW, depending upon the size of the ship 

• Hotelling times average between 8 hours to over 100 hours—

the average is about 50 hours in the POLA/POLB and 

22 hours in Oakland. The hotelling time varies depending 

upon the ship size and the carrier—the smaller ships average 

40 hours or less per visit and the largest ships average 60 to 

70 hours per visit. 

• Capital cost for retrofitting ship is assumed to be $1.5 million 

dollars 

• To address the ship re-deployment issue, staff assumed that 

twice as many ships would be equipped with shore power 

capability over the economic life of the regulation

• Labor used to connect cables and power switchover from ship 

power to shore power will be a combination of longshoremen 

and electrical union. Cost will be based upon using three 

personnel for 8 hours each—at a cost of $100/hr 

• Electrical cost are assumed to offset cost savings from not 

using distillate fuel in auxiliary engines 

Passenger 

Ships 

• Power requirements for this category vary from 7 to 15 MW 

• Hotelling times average 10-11 hours per visit 

• Capital cost for retrofitting ship is assumed to be $1.5 million 

dollars 

• Labor used to connect cables and power switchover from ship 

power to shore power will be a combination of longshoremen 

and electrical union. Cost will be based upon using two 

personnel for 8 hours each—at a cost of $100/hr 

• Staff used actual tariff schedules. Electrical rates were 

$0.13 - $0.29 per kW-hr. 
X - 12 

Category Assumptions 

Reefer Ships • Average power requirements: 3.3 MW for fully containerized 

reefer ships, 1.3 MW for break-bulk reefer ships 

• Hotelling times average between 25 hours to over100 hours. 

The average is dependent upon the product being shipped. 

For example, ships carrying bananas stay in port for about 

60 hours per visit and ships carrying melons stay in port for 

about 30 hours per visit 

• Capital cost for retrofitting ship is assumed to be $1.5 million 

dollars 

• Labor used to connect cables and power switchover from ship 

power to shore power will be a combination of longshoremen 

and electrical union. Cost will be based upon using three 

personnel for 8 hours each—at a cost of $100/hr. 

• Staff used actual tariff schedules. Electrical rates were 

$0.13 - $0.26 per kW-hr. 

Terminals • Capital cost for retrofitting each berth is assumed to be 

$5 million 

• Number of berths considered for shore power equipment 

based upon: 1) berths with more than 30 visits in 2006; 

2) historical traffic at berth; and 3) if growth exceeds historical 

traffic at the berth, staff assumed new berths are added 

Utilities • San Diego ($30 million); Long Beach, Oakland, and 

San Francisco ($15 million); Los Angeles and Hueneme 

(None) 

D. Potential Costs and Impacts to Businesses 

In this section, we estimate the costs and impacts on private companies from 

complying with the proposed regulation. The analysis estimates the overall total 

statewide cost to private businesses, as well as the cost to a typical business, 

and the total costs to different sections of the industry. 

We do not believe that the ship companies or terminal operator subject to this 

proposed regulation would qualify as small businesses due to the large capital 

and operating costs associated with vessel operation. Typical container ships 

are estimated to cost $50 to $100 million (Mercator, 2005). In addition, 

Government Code section 11342.610 excludes businesses in transportation and 

warehousing with annual gross receipts exceeding one and a half million dollars 

from its definition of “small business.” We believe that the annual gross receipts 

for a profitable vessel owner or operator would far exceed this level in order to be 

profitable. For example, a single Asia-to-U.S. West Coast voyage for a typical 

container ship costs about $2 to $3 million. (Ibid) Similarly, the terminal 

operators are generally related to the ship companies (e.g., Evergreen ships 
X - 13 

visiting an Evergreen terminal). The few terminal operators not directly related to 

ship companies are also large companies. Therefore, we do not believe there 

are any small businesses directly affected by the proposed regulation. As such, 

we have only included costs in this analysis for typical businesses. 

 Total Costs

Staff estimates that as many as 1,450 ships will need to be equipped for shore 

power over the lifetime of this proposed regulation (2009 -2030). This estimate 

includes approximately 15 reefers, 85 passenger ships, and 1,350 container 

ships. Staff estimated that the number of container ships operating at California 

ports that need to be fitted for shore power in 2020 would be 675. However, 

since the container ship fleet serving California changes with time and ships are 

redeployed to other routes worldwide, staff doubled the number of retrofits/new 

installations needed to account for repositioning of ships from California service. 

Although historically some carriers have redeployed container ships at a higher 

rate, staff believes that this method is reasonable: the ships that will call on 

California ports and be subject to this proposed regulation will require capital 

investments that may result in longer use of these ships in California ports. 

Furthermore, staff believes that using $1.5 million per ship is likely overestimates 

the average cost; staff expects that new builds and later retrofits will be less 

expensive. 

Staff estimates that 78 berths will have to be equipped provide shore power to 

visiting ships in 2020, including five reefer berths, six passenger berths, and 67 

container berths. The additional capital costs identified above for bringing power 

to several of the ports add $75 million to total shoreside infrastructure costs. 

Staff estimates the statewide total regulatory costs for affected businesses and 

port authorities to comply with the proposed regulation to be approximately 

$1.8 billion, discounted to 2006 dollars. Annually, the costs are expected to vary 

from $30 million to $137 million. The low end of the range represents a year 

when the only major capital expenditures are for retrofitting container ships due 

to repositioning, and the high end of the range represents a year when capital 

expenditures are being made for shoreside infrastructure and for retrofitting a 

considerable number of ships to meet the 2020 milestone. The total statewide 

annual costs to private business include recovery of capital expenditures, both 

aboard the ships and at the ports, and operating costs, which are labor costs and 

net energy costs, if any. 

 Costs to Ship Companies and Terminal Operators

Staff prepared costs for a typical ship company and a typical terminal operator 

complying with the proposed regulation. For this example, both the ship 

company and terminal operator are in the container shipping business. For the 

ship company, the costs are distributed over a 22-year period (2009 - 2030), and 
X - 14 

for the terminal operator, the costs are distributed over an 11-year period (2009 - 

2020). The longer analysis period for the ship company is required for the full 

recovery of the capital expenditures related to the second round of retrofits due 

to the repositioning of ships as discussed above. 

The total costs to a typical ship company complying with the proposed regulation, 

including capital and ongoing costs, are estimated to be about $34 million, 

assuming an average fleet size of 20 ships. This cost would be distributed over a 

22-year period, from 2009 to 2030. About 40 percent of the cost is associated 

with modifying additional ships to replace ships that have been re-deployed away 

from California ports. Annual costs would vary between $600,000 and $3 million 

per year, with the average cost of $1.5 million per year over this time period. The 

low end of the range represents a year when no major capital expenditures are 

made, and the high end of the range represents a year where capital 

expenditures are made for both new ships as well as replacement ships that are 

rerouted. 

 For the other ship categories, the total costs for a typical ship company to 

comply with the proposed regulation, including capital and ongoing costs, are 

estimated to be about $3.2 million. This cost would be distributed over a 12-year 

period, from 2009 to 2020. Annual costs would vary between $150,000 and 

$500,000 per year, with the average cost of $260,000 per year over this time 

period. 

Similarly, the total costs to a typical terminal operator complying with the 

proposed regulation, including capital and ongoing costs, are estimated to be 

about $11 million. About 20 percent of the cost is attributed to labor costs and 

the other 80 percent for capital costs. This cost would be distributed over an 11-

year period, from 2009 to 2020. Annual costs would vary between $500,000 and 

$1.1 million per year, with the average cost of $1 million per year over this time 

period. The low end of the range represents a year where no major capital 

expenditures are made and the high end of the range represents a year where 

capital expenditures are made for shore-side improvements. 

Both companies would have additional recurring costs associated with 

recordkeeping and reporting. For the ship company, the costs associated with 

reporting and recordkeeping will vary between $600 and $12,000 annually. The 

higher cost for reporting and recordkeeping is based upon the ship company 

complying with the emission reduction option of the proposed regulation, and the 

lower end of the range is the costs for ship companies complying with the limited 

engine use option. Similarly, for the terminal operator, the costs associated with 

reporting and recordkeeping is about $800 annually.
X - 15 

 Costs and Impacts to Various Industry Sectors

ARB staff categorized the private businesses into three groups: ship companies, 

terminal operators, and utilities. The costs by industry sector are given in 

Table X-3. The total costs to private businesses are expected to be about 

$1.8 billion over the life of the regulation. Sixty-seven percent of the total costs of 

complying with the proposed regulation will be in the ship company category. As 

discussed above, about half the cost attributed to the ship company category is 

for replacement ships as ships are re-routed to other shipping routes. This cost 

can be substantially reduced if the ship companies elect to dedicate ships 

equipped with shore-power equipment to visiting California ports. 

Table X-3: Distribution of Total Costs for Private Companies 

Business Category Estimated Total Statewide Costs 

Ship companies $1.2 billion 

Terminal Operators $540 million 

Utility Companies $60 million 

The methodology used to estimate the costs in Table X-3 is the same used to 

estimate the total statewide costs of the proposed regulation, except that the 

individual industry sectors are analyzed separately. The total statewide costs for 

ship companies include costs for capital and electricity, and the total statewide 

costs for the terminal operators include costs for capital and additional labor. 

Staff assumes that the costs to the local utilities will be fully recovered through 

the additional sale of electricity and possibly tariff rate modifications. 

Potential Business Impact

In this section, we analyze the potential impacts of the estimated costs of the 

proposed regulation on business enterprises. Section 11346.3 of the 

Government Code requires that, in proposing to adopt or amend any 

administrative regulation, State agencies shall assess the potential for adverse 

economic impact on California businesses to compete with businesses in other 

states, the impact on California jobs, and the impact on California business 

expansion, elimination, or creation. 

The companies likely affected by the proposed regulation are not Californiabased businesses. Nearly all the affected businesses are foreign owned 

enterprises, sometimes involving complicated ownership arrangements involving 

consortiums of investors. Additionally, these businesses subject to this proposed 

regulation are large companies generating billions of dollars in annual sales and 

employing thousands of people. A list of some of the affected companies is 

given in Table X-4. Consequently, the proposed regulation is not expected to 

impose a significant cost burden on these companies. 
X - 16 

Table X-4: Some Companies Affected by the Proposed Regulation 

Company 

American President Lines 

Carnival Cruise Lines 

China Shipping Container Lines 

Dole 

Hanjin Shipping 

Maersk Line 

Nippon Yusen Kaisha (NYK) Line 

SSA Marine 

 Comparison of the Costs of the Proposed Regulation

Staff compared the costs based upon the commodity being affected. For 

container ships, the costs ranges from $25 to $40 per container moved. This 

estimated is based upon the containers moved through the ports of Long Beach, 

Los Angeles, and Oakland for 2006 and assuming that by 2020 the amount of 

containers moved through these ports will either double (high end of range) or 

triple (low end of range). This cost represents less than five percent of the typical 

costs to ship a container. For the passenger ship category, the cost for 

complying with the proposed regulation represents about 15 percent of the cost 

of a cabin for a typical three-day or seven-day cruise. Overall, this proposed 

regulation is not expected to have a major impact on the cost for operating these 

vessels 

 Potential Impact on Business Competitiveness

The businesses affected by the proposed regulation are primarily based in 

foreign countries. Therefore, the proposed regulation is not expected to affect 

the ability of California businesses to complete with businesses located outside 

the state. 

The proposed regulation could potentially affect the ability of California ports and 

California based vessel operators to compete with ports and vessel operators 

outside California due to the slight increase in operating costs. However, we do 

not believe that the added costs of the proposed regulation are high enough for 

vessel operators to consider alternative ports outside California. 

There are several reasons for this. First, many vessel operators utilize California 

ports because there is already a local market for their goods within California, or 

because California exporters choose to utilize California ports to transport their 

goods overseas. Second, other vessel operators find that the overall cost of 

transporting goods to their final destination beyond California is lowest by using 
X - 17 

California ports because of the ports’ existing and well established infrastructure, 

including road and rail access. Third, in some cases, vessel operators would 

have to factor in the added costs of fuel and other costs of traveling greater 

distances to non-California ports. Finally, as stated previously, the 

added costs resulting from the proposed regulation are a small fraction of the 

costs to move these commodities, and as discussed above, these costs are not 

expected to result in a significant adverse impact on the profitability of typical 

companies. 

Most of the affected businesses that operate vessels are large businesses and 

can either absorb or pass-through the increased costs associated with the 

proposed regulation with no significant impact on their ability to compete with 

non-California businesses. Based on these reasons, we do not believe the 

relatively low costs of this proposed regulation are high enough to significantly 

affect the competitiveness of those businesses that are integrally linked to the 

movement of goods through California ports.

 Potential Impact on Employment, Business Creation, Elimination or 

Expansion

As noted, we do not expect the proposal to have a significant adverse economic 

impact on businesses. Therefore, the proposed regulation is not expected to 

have a noticeable impact on employment, or business creation, elimination, or 

expansion. The proposed regulation may lead to an increase or modification of 

job duties, leading to no net change in the number of jobs. For example, existing 

longshoreman or electrical labor may be used to connect the vessel to shore 

power. To the extent that electrical equipment, emission control equipment or 

distributed generation equipment are manufactured in California, some jobs may 

also be created to make, install, repair or operate these systems. 

E. Potential Costs to Local and State Agencies 

Local Agencies

In this section, we estimate the total costs to governmental agencies. The 

governmental agencies affected by the proposed regulation are the port 

authorities, which are departments under the applicable cities. The ports 

affected by the proposed regulation are the Ports of Hueneme, Long Beach, 

Los Angeles, Oakland, San Diego, and San Francisco. Additionally, the cruise 

terminal at the Port of Long Beach is owned by the City of Long Beach. 

The Ports of Long Beach, Los Angeles, and Oakland are landlord ports that have 

long-term agreements with their tenants. Staff assumes that the landlord ports 

will work with their tenants, the terminal lessees, to provide the shoreside 

infrastructure necessary to meet the requirements of the proposed regulation. 

Furthermore, staff assumes that the landlord ports will eventually recover their 
X - 18 

capital costs through modifications to terminal leases, while the non-landlord 

ports will recover their capital costs through fees collected from the carriers. 

Table X-4 provides the costs associated with satisfying the requirements of the 

proposed regulation, both the fiscal impact—defined as the costs incurred to the 

local agencies in the three fiscal years starting with the 2007/2008 fiscal year—

and the total capital costs. Staff anticipates that there would be no fiscal impact 

until the second year. At this time, staff anticipates that the port authorities would 

begin to make payments during fiscal year 2008/2009 and 2009/2010 for the 

necessary shore-power equipment to satisfy the 2014 milestone. For this 

analysis, the capital costs were amortized over a 20-year period at a five percent 

real interest rate. The fiscal costs range from $600,000 to $7.4 million for the 

fiscal years 2007/2008 and 2009/2010. 

In addition, Table X-5 shows the total costs to be expended by the port 

authorities to add shore-power equipment to their facilities. This cost ranges 

between $4 million to $86 million for the affected ports. 

Table X-5: Summary of Annualized Costs for Public Agencies’ 

Compliance with the Proposed Regulation 

Port Total Fiscal Impact Total Costs 

Long Beach $7 million $79 million 

Los Angeles $7 million $86 million 

Oakland $7 million $80 million 

Hueneme $2 million $12 million 

San Diego $2 million $12 million 

San Francisco $620,000 $4 million 

 State Agencies

We do not expect any significant fiscal impacts on State agencies. The ARB will 

need to expend resources to enforce the proposed regulation. However, these 

enforcement activities can be conducted with existing resources in the short 

term. Eventually, additional resources will be needed as the implementation of 

this and other port-related measures occur.

 Federal Agencies

We are not aware of any impacts on federal agencies. Military and other 

government owned or operated vessels in government , non-commercial service 

are exempted from the requirements of the proposed regulation. 
X - 19 

F. Summary of Total Costs for Compliance with the Proposed 

Regulation 

Under this section, the total cost of the proposed regulation to both private and 

governmental agencies is estimated. As shown in Table X-6, nearly all of the 

cost is expected to be borne by private companies, including costs for shore-side 

infrastructure at Los Angeles, Long Beach, and Oakland. Staff assumes that 

these ports are likely to pass the cost of any shore-power project to the terminal 

operator. The other affected ports, including Hueneme, San Diego, and San 

Francisco, are not likely to be able to pass the costs to their tenants. Since these 

ports operate as a unit under the jurisdiction of the city where port is located, the 

anticipated costs for these ports are included in the city category for Table X-6. 

Table X-6: Total Capital Costs for Compliance with the Proposed 

Regulation 

Category Total Costs 

Private $1.8 billion 

City $27 million 

Total $1.8 billion 

G. Cost-Effectiveness 

This section discusses the cost-effectiveness of the proposed regulation. Cost 

effectiveness is expressed in terms of control costs (dollars) per unit of air 

emissions reduced (ton). As described below, the cost-effectiveness for the 

proposed regulation is determined by dividing the total cost of the proposed 

regulation by the total tons of air pollutants reduced from 2009 to 2020. (As 

mentioned previously, for the container-ship category, the regulatory period is 

2009 - 2030 to allow for the full recovery of the capital expenditures related to the 

second round of retrofits due to the repositioning of ships.) 

Staff calculated cost-effectiveness values for each terminal affected by the 

proposed regulation. For each terminal, staff considered the shoreside 

infrastructure costs (including any additional utility infrastructure costs that may 

apply outside the port); the infrastructure costs aboard the ships that visited the 

terminal; the net energy costs, if any, while the ship hotelled; and the labor costs 

to connect and disconnect the power to the ships. 

Allocation of Capital Costs for Ships

A ship may visit multiple ports in California—for example, a container ship visiting 

the Port of Long Beach and the Port of Oakland. To avoid counting the capital 

costs of retrofitting that ship for shore power multiple times, ARB staff assigned 

the capital costs to the port that the ship visited most frequently during 2006. In 

the rare case where the ship visited two or more ports the same number of times, 

staff used total berthing hours at each port as a tie-breaker. 
X - 20 

 Phase-In of Capital Costs

For grid-based shore power, for which staff conducted these cost-effectiveness 

analyses, the first regulatory milestone is 2014. At that time, a vessel fleet calling 

on a port must shut off on-board auxiliary engines for at least 50 percent of its 

total port calls and presumably connect to shore power. Staff assumed that the 

ship companies, in order to minimize the number of affected ships, would initially 

modify the ships that make the most frequent visits to California ports. Based 

upon this approach, most ship companies would typically need to modify about 

25 - 35 percent of their ships with shore-power equipment to satisfy the 

50 percent requirement. This would represent about 300 ships. 

Similarly, the terminal operator will also need to update one to two berths at their 

terminals by 2014, as required by the proposed regulation, to handle the ships 

equipped with shore-power equipment. Overall, statewide, 44 berths would need 

to be equipped with shore-power infrastructure to satisfy the 2014 milestone. 

For the 2020 regulatory milestone—80 percent of port calls by a vessel fleet 

using shore power—again staff assumed that ship companies would modify the 

ships that make the most frequent visits to California ports. Most ship companies 

would typically need to modify 50 - 60 percent of the ships, or an additional 20 - 

25 percent, in order to satisfy the 80 percent criteria. Coupled with the expected 

increase in goods movement, which results in additional container ship activity, 

ship companies will need to equip more ships with shore-power equipment than 

was done to satisfy the 2014 milestone. Overall, satisfying the 2020 milestone 

would result in 450 additional ships equipped with shore-power capability. 

As mentioned earlier, because of the historical repositioning of container ships to 

different shipping lanes, staff assumed in the cost-effectiveness analyses that 

over a 15-year period, beginning in 2016, operators of container-ship fleets would 

need to replace the entire fleet with other ships equipped with shore-power 

equipment, or another 700 container ships. 

The terminal operators will need to modify additional berths at their terminals to 

handle the additional ships now equipped with shore-power equipment. Staff 

estimates an additional 31 berths would be modified to satisfy the 2020 

milestone. 

 Cost-Effectiveness Results

Using the assumptions described above, staff estimated that the overall cost 

effectiveness of the proposed regulation is about $12,800 per ton of NOx 

emissions reduced, assuming all costs are allocated to NOx reduction. For 

diesel PM, staff estimated an overall cost-effectiveness of $690,000 per ton, 

assuming all costs are allocated to PM reduction. 
X - 21 

Since the proposed regulation reduces both pollutants, Table X-7 presents the 

cost-effectiveness values in several formats: 1) the total costs are borne by NOx 

emissions reduction only; 2) the total costs are borne by diesel PM emissions 

reduction only; and 3) the total costs are split between NOx emissions reductions 

and diesel PM emissions reductions. The range of values represents the 

variation in cost-effectiveness among all the terminals analyzed. 

Table X-7: Summary of Cost-Effectiveness for Shore-Power Based on Full 

Regulatory Compliance in 2020 

 All Costs for 

NOx Only 

All Costs for 

PM Only 

Half Costs for 

NOx 

Half Costs for 

PM 

(Dollars per Ton of Pollutant Reduced) 

Container 

Ships—

POLA/POLB 

$11,000 to 

$32,000 

$400,000 to 

$1.1 million 

$5,500 to 

$16,000 

$200,000 to 

$550,000 

Container 

Ships--

Oakland 

$11,500 to 

$71,000 

$400,000 to 

$2.5 million 

$5,800 to 

$36,000 

$200,000 to 

$1.2 million 

Passenger 

Ships 

$13,000 to 

$47,000 

$440,000 to 

$1.6 million 

$6,400 to 

$23,000 

$220,000 to 

$810,000 

Reefer Ships $16,000 to 

$30,000 

$600,000 to 

$1 million 

$7,900 to 

$15,000 

$300,000 to 

$510,000 

The cost-effectiveness values for PM emissions reductions are elevated because 

a previously adopted ARB regulation (Regulation for Auxiliary Diesel Engines 

and Diesel-Electric Engines Operated on Ocean-Going Vessels within California 

Waters and 24 Nautical Miles off the California Coastline) reduced diesel PM 

emissions from hotelling ships by 70 percent, leaving 30 percent available to be 

further reduced by the proposed regulation. 

Typically, the longer a ship stays in berth, the more cost-effective shore power is 

for that ship: more emissions are reduced for the same capital investment and 

labor costs. Yet despite shorter hotelling times for container ships visiting 

Oakland—an average of 21 hours, as compared to 50 hours for POLA/POLB—

the cost-effectiveness values for Oakland are reduced because the capital costs 

associated with the ships visiting Oakland have been allocated to POLA/POLB. 

In other words, many of the container ships visiting Oakland would not incur 

additional capital costs. The cost of a shore power project at Oakland will largely 

be the cost of providing the shoreside infrastructure only. 

The better cost-effective values represent terminals that receive numerous ship 

calls—again more emissions reductions for the investment. Conversely, the 

higher values represent terminals who must invest in shoreside infrastructure 

with fewer ship calls to achieve emissions reductions. 
X - 22 

For perspective, the cost-effectiveness values of the proposed regulation are 

compared to that for other regulations recently adopted by the Board. For 

example, the Heavy Duty Urban Bus Engines and Fleet Rule for Transit 

Agencies, approved by the Board in September 2005, estimated a costeffectiveness of nearly $68,000 per ton of NOx reduced, assuming all of the 

costs go toward NOx emissions reductions. The average cost-effectiveness of 

the proposed regulation is below this value, as are the calculations for the 

individual terminals, with the exception of one terminal at Oakland, which is 

slightly above this cost-effectiveness level. 

The highest cost-effective values for regulations adopted by the Board to reduce 

PM emissions was about $320,000 per ton of PM reduced for the Diesel 

Particulate Control Measure for On-Road Heavy-Duty Diesel-Fueled Vehicles 

Owned or Operated by Public Agencies and Utilities. If the total costs of the 

proposed regulation are split between NOx emissions reductions and diesel PM 

reductions, then about half of the terminals are below this cost-effectiveness 

threshold. Again, the auxiliary engine fuel regulation already has reduced 

hotelling diesel PM emissions by 70 percent. 

Table X-8 provides cost-effectiveness values for 2014, when the interim 

milestone becomes effective. The calculation method is different than that used 

to determine the overall cost-effectiveness of a proposed regulation. To 

determine cost-effectiveness for an interim date within the regulatory period, staff 

must add the annualized capital recovery costs to the operating costs for that 

year and divide by the emissions reductions for that year. In general, the costeffectiveness values for 2014 are consistent with the overall cost-effectiveness 

values for the proposed regulation. In the few cases where the 2014 values were 

significantly higher than the overall cost-effectiveness values, the terminals in 

question either had a disproportionately greater number of ships affected by the 

2014 milestone than the other terminals, or had fewer ships visiting the terminal. 
X - 23 

Table X-8: Summary of Cost-Effectiveness for Shore-Power for Complying 

With 2014 Requirement 

 All Costs for 

NOx Only 

All Costs for 

PM Only 

Half Costs for 

NOx 

Half Costs for 

PC 

(Dollars per Ton of Pollutant Reduced) 

Container 

Ships—

POLA/POLB 

$10,000 to 

$49,000 

$360,000 to 

$1.7 million 

$5,000 to 

$25,000 

$180,000 to 

$850,000 

Container 

Ships--

Oakland 

$18,000 to 

$63,000 

$620,000 to 

$2.2 million 

$9,000 to 

$32,000 

$310,000 to 

$1.1 million 

Passenger 

Ships 

$10,000 to 

$30,000 

$350,000 to 

$1 million 

$5,000 to 

$15,000 

$170,000 to 

$500,000 

Reefer Ships $9,900 to 

$29,000 

$170,000 to 

$500,000 

$5,000 to 

$14,000 

$86,000 to 

$250,000 

In conclusion, staff considers the proposed regulation to be cost-effective for 

NOx emissions reductions and marginally cost effective for diesel PM emissions 

reductions. In its cost-effectiveness calculations, staff used conservative 

estimates. For example, staff assumed an overall cost of $1.5 million per ship to 

add shore-power equipment. One carrier, NYK, has announced that it will deploy 

38 container ships with shore power capability at a total cost of $22 million, or a 

cost of $600,000 per ship. This cost is based upon placing the necessary shorepower equipment (transformer, switchgear, and associated controls) in a 

container at the berth that can be placed on each ship equipped to use this 

shore-power container. With this approach, the necessary equipment can be 

moved from ship to ship on an as-needed basis instead of fully retrofitting each 

ship with the necessary electrical equipment. Since the cost to modify the ships 

represents about 80 percent of the capital costs for shore power, reducing the 

ship-side costs can significantly improve the cost effectiveness of the regulation. 

Finally, as was discussed in Chapter IX, staff allocated no costs to the reduction 

of CO2, a greenhouse gas (GHG). Staff considers these reductions to be a cobenefit of the proposed regulation; however, if staff allocated costs to these GHG 

emission reductions, the cost-effective values for the proposed regulation would 

be even less. 

H. Availability of Incentive Funding 

The Proposition 1B: Goods Movement Emission Reduction Program (Prop 1B 

Bond) and the Carl Moyer Air Quality Standards Attainment Program (Carl Moyer 

Program) are two distinct state incentive programs that could potentially help 

fund shore power projects. The Prop 1B Bond, approved by voters in 2006, will 

provide $1 billion in funding over four years beginning in 2008 to reduce 

emissions and health risk from activities associated with freight movement in 
X - 24 

California’s trade corridors. ARB was appropriated $250 for this program in fiscal 

year 2007/2008. The Carl Moyer Program provides up to $140 million annually 

for projects that reduce emissions from diesel engines, vehicles, and equipment. 

Both state programs seek to leverage non-state funds, and are required by 

statute to reduce emissions beyond what would otherwise occur though 

regulation or other legal mandate. 

The Prop 1B Bond program is a new incentive program. Implementing legislation 

was passed in August 2007 that requires ARB to adopt program guidelines by 

the end of 2007. ARB is now holding public workshops regarding minimum 

requirements of shore power projects and other Prop 1B Bond projects. Staff 

believes project criteria for shore power projects funded through the $1B Bond 

Program and the Carl Moyer Program should be complementary to ensure the 

programs aren’t competing for the same group of applicants. 

While no shore power projects have been funded through the Carl Moyer 

Program to date, interest in program funding for this source category is 

increasing. Staff intends to include specific criteria for Carl Moyer Program 

funding of shore power projects in its updated program guidelines, scheduled to 

be considered by the Board in February 2008. Shore power projects will have to 

meet all Carl Moyer Program requirements to receive program funding. For 

example, projects must be operational at least three years before required by 

regulation, and project life used for evaluating project cost-effectiveness may not 

extend beyond an applicable rule compliance date. All Carl Moyer program 

projects must also achieve real, surplus, quantifiable, and enforceable emission 

reductions, and cost no more than $14,300 per weighted ton of emissions 

reduced.8

 ARB shall hold a workshop on preliminary draft Carl Moyer Program 

criteria for all project categories in November 2007 and release draft guideline 

revisions for public comment in early 2008. 

I. Analysis of Alternative Regulatory Approaches 

In this section, staff compares the cost-effectiveness of the proposed regulation 

to two alternative regulatory approaches: 1) targeting the highest-emitting ships 

to obtain the necessary reductions, or 2) using best available control technology 

(BACT) on auxiliary engines while the ship is hotelling. 

Staff originally considered approach 1 before choosing the “visits or emissions 

reduction” approach contained in the proposed regulation. Approach 1 would 

“tag” the ships that make the most visits to specific ports and make them use 

shore power or an equivalent control technology to reduce hotelling emissions. 

For example, a requirement under this regulatory approach might state 

 

8

 Cost effectiveness is calculated as cost per ton of NOx + ROG + 20*PM emissions reduced. 

The $14,300 per weighted ton cost-effectiveness cap will likely rise to reflect an increase in the 

Consumer Price Index when the Guidelines are revised. 
X - 25 

“container ships making more than four visits to a California port in 2014 must 

turn off their engines or use an alternative control technology.” 

Staff estimated that this regulatory approach would be as effective as the 

proposed regulation. An advantage to this approach is that it would identify the 

most cost-effective ships from which to reduce emissions; however, staff 

abandoned this approach because of the complexity and difficulty of tracking the 

ships that were required to reduce emissions. Many of these ships would be 

repositioned elsewhere, while other ships would replace them in California 

service, creating excessive recordkeeping requirements and practical 

enforcement challenges. 

The second alternative that ARB staff considered is requiring ship companies to 

install BACT on their auxiliary engines. Currently, few emission-control 

technologies that have been used successfully on land-based engine 

applications have been demonstrated on marine engines. Nevertheless, for the 

purpose of determining a potential cost-effectiveness of this approach, staff 

selected selective catalytic reduction (SCR) for NOx emissions reductions and 

diesel oxidation catalyst (DOC) for diesel PM emissions reductions. 

Staff estimated that the cost to install SCR and DOC on auxiliary engines would 

be $155 per horsepower per engine ($130 for SCR and $25 for DOC). Installing 

this equipment on the same ships affected by the proposed regulation would cost 

$1.2 billion dollars, which is less than the overall cost of the proposed regulation. 

The PM emission reductions would be considerably less with this BACT 

approach because DOCs achieve only about 25 percent PM emission 

reductions. Furthermore, the NOx emissions reductions typically achieved by 

SCR systems on land (80 percent or higher) would more than likely be less 

because of the varying load of the auxiliary engines during transiting, 

maneuvering, and hotelling. SCR systems work more effectively under constant 

load conditions. 

Staff estimated the average cost-effectiveness for NOx reductions using SCR to 

range from $11,000 to $21,000 per ton reduced, which may be considered 

comparable to the $12,800 per ton achieved by the proposed regulation. The 

cost-effectiveness for diesel PM reductions using this approach, estimated at 

$1.7 million per ton, is more than twice as high as the $690,000 per ton of diesel 

PM emissions achieved with the proposed regulation.

Considering the unproven application of these technologies for marine engines, 

fewer total emissions reductions, and much higher cost-effective values for diesel 

PM emissions reductions, staff did not pursue this alternative regulatory 

approach. 
X - 26 

REFERENCES: 

California Air Resources Board. 2005 Oceangoing Vessel Survey of Results; 

2005. http://www.arb.ca.gov/regact/marine2005/appc.pdf. 

California Air Resources Board. Emission Reduction Plan for Ports and Goods 

Movement in California; April 2006. 

http://www.arb.ca.gov/planning/gmerp/march21plan/march22_plan.pdf

California Air Resources Board. Proposed Amendments to the Exhaust 

Emission Standards for 2007-2009 Model-Year Heavy Duty Urban Bus Engines 

and the Fleet Rule for Transit Agencies; September 2005. (ARB, 2005c) 

California Air Resources Board. Proposed Diesel Particulate Matter Control 

Measure for On-Road Heavy-Duty Diesel-Fueled Vehicles Owned or Operated 

by Public Agencies and Utilities; October 2005. (ARB, 2005b) 

California Air Resources Board. Proposed Diesel Particulate Matter Control 

Measure for On-Road Heavy-Duty Residential and Commercial Solid Waste 

Collection Vehicles; September 2003. 

California Air Resources Board. Proposed Regulation for In-Use Off-Road Diesel 

Vehicles; April 2007. 

Mercator Transport Group. Forecast of Container Vessel Specifications and Port 

Calls Within San Pedro Bay; February 2005. 

Pacific Gas and Electric Company. “Tariff Book.” Pacific Gas and Electric 

Company. July 2005. http://www.pge.com/tariffs/ERS.SHTML#ERS (PG&E, 

2005) 

San Diego Gas and Electric. Cold Ironing Feasibility Study for Electrical Services 

at Cruise Ship & 10th Avenue Marine Terminals; January 2007. (SDG&E, 2007) 

San Diego Gas and Electric. “Electric Tariff Book - Commercial/Industrial Rates.” 

San Diego Gas and Electric. July 2005. 

http://www.sdge.com/regulatory/tariff/elec_commercial.shtml (SDG&E, 2005) 

Southern California Edison. “Regulatory – SCE Tariff Books, General Service – 

Industrial Rate Schedules.” Southern California Edison. July 2005. 

http://www.sce.com/AboutSCE/Regulatory/tariffbooks/ratespricing/businessrates.

htm (SCE, 2005)