DRAFT TECHNICAL MEMORANDUM
To:
Tom Moore and Lee Gribovicz, WRAP
From:
Chris Lindhjem, Lynsey Parker, and Alison Pollack
Date:
March 3, 2009
Subject:
WRAP PRP18b commercial marine emission inventory updates
INTRODUCTION
In the WRAP PRP18a emissions inventory, commercial marine emissions estimates were held
constant at 2002 levels. Despite expected significant activity growth for this sector, emissions
projections (with growth and controls) were not generated for PRP18a in part because of
significant uncertainties in the expected activity growth for commercial marine vessels, and in
part because the California Air Resources Board (CARB) was not ready to provide expected
reductions from emissions controls that varied by region within California. In the last couple of
years, there has been regulatory activity for the commercial marine sector.
This memo discusses recent regulatory activity, and estimates projection factors to estimate 2018
commercial marine emissions for PRP18b modeling. The projection factors for California were
developed based on analyses that both CARB and ENVIRON have performed, and discussion
with and inputs from CARB staff. These projections were developed for the large commercial
marine vessels commonly referred to as ocean-going vessels (OGV), which have draft typically
more than 14 feet, and do not include tugs, ferries or other vessels.
In addition, we provide here a brief review of emission inventory activities being conducted at
west coast ports outside California.
COMMERCIAL MARINE ENGINE EMISSION STANDARDS
Commercial marine engine air pollution emission standards have been promulgated under
international treaties, Federal, and California state regulations. International standards apply to
all vessels; Federal rules apply to US vessels; and California rules apply only within California
waters.
International standards have been evolving over the past 10 years including those finalized in
2008. The emission standards affecting air quality include fuel and engine emission standards.
Federal EPA emission standards apply to marine engines in U.S. flagged vessels, and focus
primarily on new engine emission standards.
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The California Air Resources Board (ARB) has promulgated a series of emission standards and
is investigating others that may reach the regulation stage. These include:





Low sulfur fuel in auxiliary engines (within 24 nautical miles [nm] from shore)
Low sulfur fuel in main engine and boilers (within 24 nm from shore)
Shoreside power
Harbor craft emissions rule
Vessel speed reduction (VSR) (under consideration)
The international, federal, and California regulations considered are outlined in Table 1.
International Standards
The international emission standards for air pollution regulations are generally referred to as the
MARPOL regulations (called ‘International Convention for the Prevention of Pollution from
Ships [MARPOL] Annex VI,’ MARPOL, 2008). These were developed under the aegis of the
International Maritime Organization (IMO) and apply to all commercial marine engines above
130 kW.
A revised Annex VI was adopted October 2008 that codifies a progressive reduction in sulfur
oxide (SOx) emissions from ships with the global fuel sulfur cap as shown below (MARPOL,
2008). A review of the 2020 global fuel sulfur standard will be completed by 2018 to determine
the availability of fuel oil to comply with the fuel oil standard. The 2012 sulfur cap would not
make a significant change to 2018 emission forecasts because EPA has assumed that the average
sulfur level for fuel used by large vessels in North America is 2.7%.
Global Fuel Sulfur Cap



4.50% m/m prior to 1 January 2012;
3.50% m/m on and after 1 January 2012; and
0.50% m/m on and after 1 January 2020.
In addition, if an Emission Control Area (ECA) were to be declared for any part of the region,
the fuel sulfur levels would be lowered from 1.5% currently to levels comparable to the CARB
regulations starting with 0.5% sulfur in 2010 and 0.1% in 2015, or a few years later than the
CARB regulations. The ECA for North America had yet to be finalized at the time of this
writing.
Emission Control Area Fuel Sulfur Cap



1.50% m/m prior to 1 July 2010;
1.00% m/m on and after 1 July 2010; and
0.10% m/m on and after 1 January 2015.
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Table 1. Summary of the air pollution emission regulations for commercial marine engines.
Rule
MARPOL Annex VI;
2000 Tier I NOx
standard
MARPOL Annex VI
Global Sulfur Caps
MARPOL Annex VI
SOx Emissions
Control Area (SECA)
for North America
Agency
Description
International
Maritime
Organization
(US Coast
Guard lead)
Any engine > 130kW installed on a vessel
constructed on or after 1/1/2000 and any
engine that undergoes a major conversion on
or after 1/1/2000. Vessels constructed
between 1990 and 2000 would be retrofit to
this standard.
International The global sulfur cap reduced initially to 3.5%
Maritime
(from the current 4.5%) effective from 1
Organization January 2012; then progressively to 0.5%,
(US Coast
effective from 1 January 2020
Guard lead)
US
US application for a SECA. Sulfur levels
Designated capped at 1.5%, 1.0% after July 1 2010, and
(EPA/ARB
0.1% on or after 2015.
lead)
Enforcement
Compliance
Status
Entity
Dates
US Coast
May 2005,
Ship builders generally complied with
Guard
(Voluntary in 2000) this standard back to 2000.
US Coast
Guard
January 2020 for
final sulfur
standards
Adopted on 10 October 2008
US Coast
Guard
2000 1.5% S
2010 1.0% S
2015 for 0.1% S
US preparing justification and other
background materials but may apply
potentially out 200 nm from shore as
defined by Exclusive Economic Area
(EEA)
Adopted on 10 October 2008
Ongoing negotiations from a US
delegation (including EPA) for
amendments to MARPOL, Annex VI)
2011 for all new
vessels
2016 for all new
vessels when
operating in certain
areas
Tier 1, 2, 3, 4
Feb 28, 2003 (Tier 1 and 2)
emission standards March 2008 (Tier 3 and 4)
below 30 liters per
cylinder.
MARPOL Annex VI
Tier II and Tier III
exhaust emission
standards
International Tier II standards for vessels 2011 and later;
Maritime
Tier III for vessels 2016 and later while
Organization operating in an ECA.
(US Coast
Guard lead)
US Coast
Guard
Marine compressionignition (diesel)
engine rule
EPA
EPA
Harbor Craft engines below 30 liters per
cylinder
National exhaust emission standards for new
engines at or above 30 liters per cylinder
(“category 3” marine diesel engines)
Auxiliary engine low
sulfur fuel rule
ARB
Requires low sulfur fuel for use with auxiliary
engines. Effective 2007 within 24 nm of coast;
marine fuel must be Marine Gas Oil or Marine
Diesel Oil containing less than 0.5% sulfur
(must be Marine Gas Oil containing less than
0.1% sulfur starting in 2010)
ARB
Comply with
international rules
for above 30
l/cylinder
January 1, 2007
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In place – and currently enforced –
under litigation 2007 and 2010 phasein period.
The proposed regulation would apply
to diesel main and auxiliary engines,
and auxiliary boilers on ocean-going
vessels. As discussed below, this
regulation is expected to become
legally effective in 2009
Page 4
Rule
Agency
Main engine and
boiler low sulfur fuel
rule
At-Berth OceanGoing Vessels
Regulation
Vessel Speed
Reduction (VSR)
Clean Ship program
ARB
Commercial Harbor
Craft
ARB
ARB
ARB
ARB
Description
Requires low sulfur fuel use in main engines
and boilers similar to auxiliary engine
requirements.
Control hoteling emissions via one of several
possible methods
Evaluating need for VSR measure at major
ports and along coastline.
Evaluating measure or incentive program to
require cleaner or retrofitted vessels in
CA ports
Accelerated turnover (scrappage) of older
engines and vessels
Enforcement
Compliance
Entity
Dates
ARB
July 24, 2008
Board Approval
Early 2009
ARB
January 2, 2009
In place. Phase in 2010-2020
ARB
TBD
Under evaluation for mid 2008
ARB
TBD
Under development for late 2008.
Likely phase in from 2010-2020
ARB
January 1, 2009
In place with phase-in from 2009 2022
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Status
Page 5
The first NOx regulations for marine engines were written in 1997, even though the treaty had
not yet been ratified. These regulations required that engines be tested at three different loads and
use a weighted averaged to compare with an overall emission standard. The emission standard,
for new vessels constructed after January 1, 2000, was related to the rated engine speed through
the relationship shown below. This requirement has been labeled as the Tier I standard with the
2008 amendments.
International Tier I NOx Emission Standard
(Starting with new engines in 2000, and retrofit for engines back to 1990)
Engine Speed <130 rpm; 17.0 g/kW-hr
130 rpm  Engine Speed ‘n’ < 2,000 rpm; 45 * n(-0.2) g/kW-hr
Engine Speed  2,000 rpm; 9.8 g/kW-hr
However, the 2008 amendments to the MARPOL (2008) Annex VI regulations reduce NOx
emissions from engines beginning in 2011 with the emission standard of 14.4 g/kW-hr (Tier II
standard). In addition, a Tier III NOx standard was set at 3.4 g/kW-hr when the vessel operates
in an Emission Control Area starting with vessels constructed in 2016. The NOx standards will
be subject to a feasibility review to be completed no later than 2013. The more detailed Tier II
and Tier III standards, shown below, lower the emission standard for higher speed (measured in
rpm) engines.
International Tier II NOx Emission Standard
(New engines beginning in 2011)
14.4 g/kWh when engine speed ‘n’ is less than 130 rpm;
44* n(-0.23) g/kWh when n is 130 or more but less than 2,000 rpm;
7.7 g/kWh when n is 2,000 rpm or more.
International Tier III NOx Emission Standard
(2016 and later ship operating in an Emission Control Area)
3.4 g/kWh when n is less than 130 rpm;
9* n(-0.2) g/kWh when n is 130 or more but less than 2,000 rpm; and
2.0 g/kWh when n is 2,000 rpm or more
Nation states may petition to declare an ECA in their waters under the MARPOL treaty if the
nations can justify the need and extent of the ECA. The ECA may extend to the Exclusive
Economic Area (EEA), which is nominally up to 200 nm from the shore except when another
nation’s waters interfere with this limit. The geographical limits for the U.S. ECA have yet to be
determined.
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U.S. Federal Standards
The U.S. EPA set emission standards for commercial marine diesel engines such that the Tier 1
standard is the same as the Tier I international standard. EPA (2003) instituted Tier 2 regulations
for new commercial marine engines as shown in Table 2, and EPA (2008) promulgated Tier 3
and 4 standards shown in Tables 3 and 4. For the most part, these regulations affect the harbor
craft category of marine vessels that include tugs, ferries, excursion vessels, dredges, fishing
vessels, and other similar general-purpose commercial marine vessels. Recreational marine
diesel engines are also affected but have different implementation dates. Large vessels with U.S.
flags would be included but only their auxiliary engines fall under the engine size limits covered
by these regulations.
Table 2. EPA primary exhaust emission standards for US flagged vessels (g/kW-hr).
Subcategory
Liters/cylinder
Power < 37 kW
And disp. <0.9
0.9 < disp. < 1.2
1.2 < disp. < 2.5
2.5 < disp. < 5.0
5.0 < disp. < 15
15 < disp. < 20
Power <3300 kW
15 < disp. < 20
Power >3300 kW
20 < disp. < 25
25 < disp. < 30
Tier
Model
Year*
THC + NOx
g/kW-hr
CO
G/kW-hr
PM
g/kW-hr
Tier 2
2005
7.5
5.0
0.40
Tier 2
Tier 2
Tier 2
Tier 2
2004
2004
2007
2007
7.2
7.2
7.2
7.8
5.0
5.0
5.0
5.0
0.30
0.20
0.20
0.27
Tier 2
2007
8.7
5.0
0.50
Tier 2
2007
9.8
5.0
0.50
Tier 2
Tier 2
2007
2007
9.8
11.0
5.0
5.0
0.50
0.50
Table 3. EPA Tier 3 standards for Category 1 (unmarked) and Category 2 (marked) engines
(page 37246, Federal Register / Vol. 73, No. 126 / Monday, June 30, 2008 / Rules and
Regulations) (EPA, 2008)
Engine Power
<19 kW
19 to <75 kW
L / Cylinder
< 0.9
< 0.9
< 0.9
0.9 to <1.2
1.2 to <2.5
75 to <3700 kW
(kW / liter  35)
2.5 to <3.5
3.5 < 7.0
75 to <3700 kW
(kW / liter > 35)
and recreational
< 0.9
0.9 to <1.2
1.2 to <2.5
THC + NOx
g/kW-hr
7.5
7.5
4.7
5.4
5.4
5.6
5.6
5.6
5.6
5.6
5.6
5.8
5.8
5.8
5.8
5.8
5.8
PM
g/kW-hr
0.40
0.30
0.30
0.14
0.12
0.11 <600kW
0.10 <600kW
0.11 600kW
0.11 <600kW
0.10 <600kW
0.11 600kW
0.11 <600kW
0.10 <600kW
0.11 600kW
0.15
0.14
0.13
Model Year
2009+
2009 - 2013
2014+
2012+
2013
2014 - 2017
2018+
2014+
2013 – 2017
2018+
2013+
2012 – 2017
2018+
2012+
2012+
2013+
2014+
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engines
Category 2
<3700 kW
2.5 to <3.5
3.5 < 7.0
7 to <15
15 to <20
20 to <25
25 to <30
5.8
5.8
6.2
8.7
9.8
11.0
0.12
0.11
0.14
0.27
0.27
0.27
2013+
2012+
2013
2014
2014
2014
Table 4. EPA Tier 4 standards for commercial marine engines (EPA 2008).
Engine Power
> 3,700 kW <15 l/cyl.
> 3,700 kW 15 – 30 l/cyl.
> 3,700 kW all
2,000 to <3,700 kW
1,400 to <2,000 kW
600 to <1,400 kW
HC
g/kW-hr
0.19
0.19
0.19
0.19
0.19
0.19
THC + NOx
g/kW-hr
1.8
1.8
1.8
1.8
1.8
1.8
PM
g/kW-hr
0.12
0.25
0.06
0.04
0.04
0.04
Model Year
2014 – 2015
2014 – 2015
2016
2014
2016
2017
EPA assumed that all vessels and particularly US flagged vessels had complied with the
international regulations. EPA (2003) finalized regulations that mandated that U.S. flagged
vessels built after January 1, 2004 need to comply with the international protocols because at that
time the treaty had not yet been ratified. This regulation covered all U.S. flagged vessels
including the few larger OGV that are U.S. flagged.
California Regulations
The California emission regulations and proposed regulations of the end of 2008 are described
below for each type of regulation. There are fuel sulfur limits and at-berth regulations for large
ocean-going vessels, and vessel age management regulations for smaller commercial marine
vessels. In addition, California continues to investigate vessel speed reduction for large vessels,
but has not proposed a formal regulation.
Fuel Sulfur Regulations
The fuel requirements in the regulation approved on July 24, 2008 would apply to ocean-going
vessel main (propulsion) diesel engines, auxiliary diesel engines, and auxiliary boilers when
operating within 24 nautical miles of the California Coastline (defined mostly as 24 nm from
shore, but excluding the shore of several islands). Vessel owners/operators were required to use
the marine distillate fuels. The “Phase I” fuel requirement specified the use of marine gas oil up
to 1.5 percent sulfur, or marine diesel oil up to 0.5 percent sulfur. The Phase I fuel requirement
will become effective on July 1, 2009 for main engines and auxiliary boilers. For auxiliary
engines (including all diesel-electric engines), the Phase I fuel requirement would become
effective when the regulation becomes legally effective. The Phase II fuel requirement specifies
the use of marine gas oil or marine diesel oil up to 0.1 percent sulfur fuel. The Phase II
requirement would become effective on January 1, 2012, for all sources covered by this
regulation.
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The ARB approved the Ship Auxiliary Engine Regulation in 2005, and enforcement of the
requirements began on January 1, 2007. However, ARB stopped enforcing this regulation
pursuant to an injunction issued by a federal district court. The court order may be dissolved if
the ARB receives an authorization from the United States Environmental Protection Agency to
enforce the regulation. For more details, refer to the following advisory:
http://www.arb.ca.gov/ports/marinevess/documents/Auxenforce050708.pdf.
The ARB’s regulation for propulsion engine fuel on ocean-going vessels was designed so that it
would not require an authorization from U.S. EPA.
At-Berth Ocean-Going Vessels Regulation
California has instituted an at-berth regulation that would reduce the auxiliary engine emissions
while in port. The primary method to accomplish this would be to use shoreside power, but
other methods could be used to mitigate the emissions while in port. A summary of the rule and
expected benefits is shown in Table 5.
Table 5. CARB at-berth ocean-going vessels emission controls.
Date
Jan. 1, 2010
Jan. 1, 2012
Jan. 1, 2014
Jan. 1, 2017
Jan. 1, 2020
Reduced Onboard Power Generation Option
Shore-power equipped ships must use shore
power if available at berth
Shore-power equipped ships must use shore
power if available at berth
50% shore-power visits and power reduction
70% shore-power visits and power reduction
80% shore-power visits and power reduction
Equivalent Emissions
Reduction Option
10% Emission Reduction
25% Emission Reduction
50% Emission Reduction
70% Emission Reduction
80% Emission Reduction
Vessel Speed Reduction for Ocean-going Vessels
By the end of 2008, the ARB was considering a regulation mandating vessel speed reduction
while in California Waters. The suggested approach would consider a 12-knot speed limit within
either 24 nm or 40 nm from shore, or consider such speed reductions at major ports and along
busy shipping channels. The benefit of vessel speed reduction results from the fact that the
average load on the vessels engines is related to the cube of the vessel speed, so emission
reductions can be realized from slower vessel speeds.
Commercial Harbor Craft Regulation
The commercial harbor craft regulation was approved by the ARB in Nov. 2007, and became
effective Jan. 1, 2009. The regulation affects various commercial marine vessels including:




Ferries
Excursion vessels
Tugboats and towboats
Crew and supply vessels
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




Commercial fishing
Charter fishing boats
Pilot boats
Work boats
Other vessels
The regulation affects harbor craft statewide, and in the South Coast the compliance dates are
generally sooner than those statewide. The rule mandates accelerated fleet turnover (also called
scrappage) of older vessel engines first. The first compliance date is December 2009 and follows
the general pattern of turnover in 2009-2016 of Tier 0 engines and 2015-2022: Tier 1 engines.
There is accelerated compliance for ferry engines, and all Tier 0 engines comply by 2014. The
schedule replacement of older engines with new engines follows Table 6.
Table 6. Compliance schedule for California harbor craft (outside South Coast AQMD).
Engine Model Year Affected
1975 and earlier
1975 and earlier
1976 – 1985
1976 – 1985
1986 – 1995
1986 – 1995
Ferries Only (1996 – 1999)
Vessels Other Than Ferries
1996 – 1999
Vessels Other Than Ferries
1996 – 1999
2000
2000
1996 – 2000
1996 – 2000
2001 – 2002
2003
2004
2005
2006
2007
Total Annual Hours of Operation
≥ 1500
≥300 and < 1500
≥1500
≥ 300 and < 1500
≥ 1500
≥ 300 and < 1500
≥ 300
Compliance Date
12/31/2009
12/31/2010
12/31/2011
12/31/2012
12/31/2013
12/31/2014
12/31/2014
≥ 1500
12/31/2015
≥ 300 and < 1500
≥ 1500
≥ 300 and < 1500
≥1500
≥ 300 and < 1500
≥ 300
≥ 300
≥ 300
≥ 300
≥ 300
≥ 300
12/31/2016
12/31/2015
12/31/2016
12/31/2015
12/31/2016
12/31/2017
12/31/2018
12/31/2019
12/31/2020
12/31/2021
12/31/2022
GROWTH AND CONTROL FACTORS FOR ESTIMATING 2018 EMISSIONS
In order to forecast emissions, both activity growth and emission control need to be considered.
ARB staff provided commercial marine growth and control factors for California waters, and
ENVIRON prepared factors for areas outside California: Oregon, Washington, Mexico, and
Canada. These factors were applied to the existing 2002 commercial marine emissions to project
emissions in 2018. The 2002 emissions were generated by ENVIRON using Geographic
Information Systems (GIS), and were developed as gridded emissions files. Details of the
methods used to generate the 2018 gridded emissions from the 2002 gridded emissions and the
projection factors described below are provided in the Appendix.
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California Growth and Control Factors
ARB developed growth and control factors to project 2002 commercial marine emissions to
2018 for nine geographic areas: on shore, within 100nm, and beyond 100nm, each for northern,
central, and southern subareas. Figure 1 shows these nine regions, and the 2002->2018
projection factors for each subarea are shown in Table 7.
Figure 1. ARB subareas for estimating 2018 commercial marine emissions
Table 8. ARB growth and control percentages to apply to 2002 commercial marine emissions
by subarea to estimate 2018 emissions.
Region
Central
Central
Central
North
North
North
South
South
South
Zone_
100nm
Ocean
On Shore
100nm
Ocean
On Shore
100nm
Ocean
On Shore
CO2
192%
192%
52%
173%
194%
41%
190%
247%
42%
NOX
191%
192%
84%
171%
195%
64%
209%
247%
49%
PM10
95%
192%
14%
82%
194%
10%
60%
247%
10%
PM25
95%
192%
13%
82%
194%
10%
61%
247%
9%
SOX
79%
192%
3%
67%
194%
3%
34%
247%
3%
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Growth and Control Factors Outside California
The growth in large deep draft vessel activity was projected for EPA as shown in Table 8 (ICF,
2007). These growth factors were developed for specific regions based on recent activity trends
and other economic projections. For the northern Pacific region, a 3.3% per year growth was
estimated, so this will be used in the WRAP forecasts. For the southern Pacific region off
Mexico, 5.0% per year was estimated.
Table 8. EPA growth estimates for category 3 ocean-going vessel activity.
Region
Alaska East
Alaska West
East Coast
Gulf Coast
Great Lakes Canada
Great Lakes U.S.
Hawaii
Northern Pacific
(Lower 48)
Southern Pacific
Annualized
Growth
3.30%
3.30%
4.50%
2.90%
1.70%
1.70%
5.00%
3.30%
5.00%
The control factors could involve a number of measures, but the only emission standard in effect
for all commercial marine vessels (foreign and U.S. flagged vessels) are the Tier 1 NOx
standards. From Browning (2008), the following excerpt describes the approach that EPA used
to forecast emission reductions from this emission standard:
“Most manufacturers build engines to emit well below the standard. EPA determined the
effect of the IMO standard to be a reduction in NOx emissions of 11 percent below
engines built before 2000. Therefore for engines built in 2000 and later, a NOx factor of
0.89 is applied to the calculation of NOx emissions for both propulsion and auxiliary
engines. Since this standard only applies to diesel engines, the factor is not applied to
either steam turbines or gas turbines.”
ICF (2007) provided the rated power (a measure of the relative activity) weighted age
distribution of vessels operating in U.S. ocean waters that allow a forecast the benefit of the
MARPOL standard for 2000 and later vessels. Therefore the basic emission factors for all engine
types with and without the new emission standard (no change for gas or steam turbine vessels)
were used to compare the 2002 calendar year with the 2018 calendar year. Table 9 shows the age
distribution and engine type by model along with the applicable standard for marine engines in
that model year. The model years 1990 and later may be retrofitted to Tier I standards, but it is
uncertain that will occur during the period modeled here. If an Emission Control Area (ECA) is
declared for North American, the Tier III standards may become applicable.
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Table 9. Age distribution for vessels.
Build
Year
1955
1968
1969
1971
1973
1974
1975
1977
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
Age
63
50
49
47
45
44
43
41
36
35
34
33
32
31
30
29
28
27
26
25
24
23
22
21
20
19
18
17
16
15
14
13
12
11
10
9
8
7
6
5
4
3
2
1
0
Percentage by engine type within model year
Medium
Slow
Speed
Speed
Gas
Diesel
Diesel
Turbine Steam Turbine
100.0%
0.0%
0.0%
0.0%
100.0%
0.0%
0.0%
0.0%
100.0%
0.0%
0.0%
0.0%
0.0%
0.0%
0.0%
100.0%
0.0%
0.0%
0.0%
100.0%
4.8%
0.0%
0.0%
95.2%
0.0%
0.0%
0.0%
100.0%
0.0%
0.0%
0.0%
100.0%
100.0%
0.0%
0.0%
0.0%
100.0%
0.0%
0.0%
0.0%
59.0%
41.0%
0.0%
0.0%
78.0%
0.0%
0.0%
22.0%
100.0%
0.0%
0.0%
0.0%
23.4%
72.7%
0.0%
3.9%
5.3%
92.4%
0.0%
2.3%
4.5%
45.2%
0.0%
50.3%
5.5%
85.9%
0.0%
8.6%
11.6%
61.7%
3.7%
23.1%
17.9%
75.0%
0.5%
6.7%
9.0%
86.1%
0.0%
4.9%
23.1%
75.0%
0.0%
2.0%
15.0%
74.2%
0.0%
10.8%
23.2%
65.3%
0.0%
11.6%
14.7%
85.0%
0.0%
0.2%
14.8%
85.2%
0.0%
0.0%
8.1%
91.7%
0.0%
0.1%
12.7%
87.3%
0.0%
0.0%
6.2%
93.8%
0.0%
0.0%
13.1%
86.9%
0.0%
0.0%
16.3%
83.7%
0.0%
0.0%
17.8%
82.2%
0.0%
0.0%
2.6%
97.4%
0.0%
0.0%
29.6%
70.4%
0.0%
0.0%
22.7%
77.3%
0.0%
0.0%
23.0%
77.0%
0.0%
0.0%
23.4%
75.4%
0.0%
1.2%
20.6%
79.4%
0.0%
0.1%
21.8%
78.2%
0.0%
0.0%
21.5%
78.4%
0.0%
0.1%
22.0%
78.0%
0.0%
0.0%
25.8%
74.2%
0.0%
0.0%
36.5%
63.4%
0.0%
0.1%
30.7%
65.5%
3.7%
0.1%
29.1%
64.6%
6.3%
0.0%
26.7%
70.1%
2.8%
0.4%
Percentage of All Vessels
By Age
0.0002%
0.0019%
0.1235%
0.0068%
0.0042%
0.0134%
0.0055%
0.1785%
0.0065%
0.0008%
0.0326%
0.3467%
0.0024%
0.3550%
0.6733%
0.2062%
0.3786%
0.3013%
0.5823%
1.0090%
1.2799%
1.4780%
2.0170%
1.8513%
1.5374%
1.9068%
2.9865%
3.0645%
2.2346%
2.5642%
2.8260%
2.2300%
3.0694%
3.9245%
3.4387%
5.0486%
4.2358%
5.0983%
4.6640%
6.7492%
7.6403%
6.3175%
6.8477%
9.3022%
3.4591%
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Diesel Engine
Control
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0
Tier 0 / 1
Tier 0 / 1
Tier 0 / 1
Tier 0 / 1
Tier 0 / 1
Tier 0 / 1
Tier 0 / 1
Tier 0 / 1
Tier 0 / 1
Tier 0 / 1
Tier 1
Tier 1
Tier 1
Tier 1
Tier 1
Tier 1
Tier 1
Tier 1
Tier 1
Tier 1
Tier 1
Tier 2
Tier 2
Tier 2
Tier 2
Tier 2
Tier 2 / 3
Tier 2 / 3
Tier 2 / 3
Page 13
Applying the emission factors in Table 10 along with an 11% NOx reduction for Tier I and an
additional 15.3% reduction for Tier II from Tier I (or in other words, a 24.6% reduction from
precontrolled for Tier II) to the age distribution provides the average emission rates in 2018. Gas
turbines and steam turbine driven ships are unaffected by the international rule because those
propulsion systems have emission rates below the Tier II emission standards. By comparing the
future year average with the precontrolled case, a 16.2% reduction from the precontrolled case
was calculated for both propulsion and auxiliary engines for calendar year 2018 for the Tier I
benefit only. (Note that no benefit for the Tier I emission controls had been taken for the 2002
case at the time because it was uncertain if there was any benefit to this initial rule. If the Tier I
standard had been included in the 2002 baseline inventory, then a 2% NOx reduction in 2002 is
consistent with this analysis.)
Table 10. Precontrolled NOx emission factors (g/kW-hr) by engine type.
Engine
Medium Speed Diesel Medium Speed Diesel Slow Speed
Gas
Steam
Type
– Residual Fuel
– Distillate Fuel
Diesel
Turbine Turbine
Propulsion
14.0
N/A
18.1
6.1
2.1
Auxiliary
14.7
13.9
N/A
N/A
N/A
California did not account for the Tier I or Tier II emission standards in its forecasts for WRAP
because those had not been finalized at the time of the preparation of the 2018 inventory, and did
not determine the benefit of the Tier III engines given that the Emission Control Area had not yet
been declared. The 16.2% NOx reduction was incorporated into the projection factors provided
by ARB.
Also not accounted for in this forecast are the benefits of several voluntary approaches by the
ports and vessel operators inside or outside of California waters. These strategies include
voluntary fuel switching, shoreside power, and other initiatives.
2018 EMISSION INVENTORY RESULTS
ENVIRON developed the 2018 gridded commercial marine emissions inventory by forecasting
gridded 2002 emissions to account for anticipated growth and future controls. The growth and
control factors were defined for different regions as described above; the methodology used to
generate the gridded 2018 emission inventory is described in the Appendix. Table 11 shows the
resulting NOx and SO2 commercial marine emissions in 2018 in comparison with the existing
2002 emissions.
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Table 11. Summary of 2002 and 2018 commercial marine NOx and SO2 emissions.
Summary of 2018 West Coast NOx Emissions (tons per year)
Beyond
Within
100nm
100nm
Total
of Coast of Coast Onshore
California
376,878 221,292 139,842 15,744
Oregon and Washington
130,975
Canada
146,898
Mexico
250,391
Total US
507,853
Total Domain
905,143
-
Summary of 2018 West Coast SO2 Emissions (tons per year)
Beyond
Within
100nm
100nm
Total
of Coast of Coast Onshore
California
172,600 148,519
23,863
218
Oregon and Washington
88,978
Canada
98,565
Mexico
168,017
Total US
261,577
Total Domain
528,160
-
Summary of 2002 West Coast NOx Emissions (tons per year)
Beyond
Within
100nm
100nm
Total
of Coast of Coast Onshore
California
244,354 130,641
85,000 28,713
Oregon and Washington
92,969
Canada
104,272
Mexico
136,886
Total US
337,324
Total Domain
578,481
-
Summary of 2002 West Coast SO2 Emissions (tons per year)
Beyond
Within
100nm
100nm
Total
of Coast of Coast Onshore
California
120,732
73,461
40,155
7,116
Oregon and Washington
52,928
Canada
58,631
Mexico
76,970
Total US
173,660
Total Domain
309,261
-
%change of West Coast NOx Emissions 2002 -> 2018
Beyond
Within
100nm
100nm
Total
of Coast of Coast Onshore
California
54%
69%
65%
-45%
Oregon and Washington
41%
Canada
41%
Mexico
83%
Total US
51%
Total Domain
56%
-
%change of West Coast SO2 Emissions 2002 -> 2018
Beyond
Within
100nm
100nm
Total
of Coast of Coast Onshore
California
43%
102%
-41%
-97%
Oregon and Washington
68%
Canada
68%
Mexico
118%
Total US
51%
Total Domain
71%
-
OTHER WEST COAST PORT INVENTORIES
ICF (2007) performed a review of available port inventories and identified two inventory efforts
outside California: for the Puget Sound area and the Port of Portland.
The Puget Sound ports inventory (PSMAF, 2007) for the calendar year 2005 covered a wide area
that includes activity in Canadian waters including the Puget Sound, Strait of Juan de Fuca, and
the Strait of Georgia. The project was coordinated with Environment Canada, the British
Columbia Chamber of Shipping (2007) and others who were concurrently preparing a similar
emissions inventory for Georgia Basin largely in Canada to avoid double-counting emissions
between the US and Canadian studies. The counties and major ports in the study included in the
Puget Sound work are those listed in Table 12, and 33 of the public ports in Washington State.
The Puget Sound inventory included large ocean-going vessels, harbor craft, intermodal off-road
equipment, truck and rail activity in the freight chain.
Table 13. Puget Sound emission inventory study area.
Counties Covered
Clallam
Island
Jefferson
King
Major Port
Port of Port Angeles in Clallam County
Port of Seattle in King County
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Kitsap
Mason
Pierce
San Juan
Skagit
Snohomish
Thurston
Whatcom
Port of Tacoma in Pierce County
Port of Anacortes in Skagit County
Port of Everett in Snohomish County
Port of Olympia in Thurston County
The data for the Puget Sound emission inventory were more detailed than had been performed to
date as outlined by ICF (2007) below detailing two revised estimates that resulted in an upward
revision to the emissions inventory. The first change was an upward revision of the vessel speed,
and the second change resulted in more vessel calls than appear in standard databases.
“…….a significant difference in RSZ emissions was noticed. This was because in the
detailed port inventory developed as part of the deep sea commercial marine guidance
document2, an RSZ speed of 15 knots was assumed through the Strait of Juan de Fuca
and 12 knots from pilot pick-up at Port Angeles to the final destination port. According to
Captain McKerty of the Puget Sound Pilots27, ships enter the Strait of Juan de Fuca at
service speed and continue at service speed until they reach Port Angeles where the pilot
boards. All ships except tankers continue at service speed or 20 knots, whichever is less,
until they are about 12 nautical miles from port. At that point they begin slowing to
maneuvering speed. Tankers on the other hand travel at service speed to Port Angeles
and then travel at 12 knots until 12 nautical miles before the port. At that point they slow
from 12 knots to maneuvering speed. This new information was used to calculate RSZ
speeds, load factors and times for all Puget Sound ports and thus resulted in higher
emissions than the prior inventory.”
“……it was found that a considerable amount of Jones Act tanker ships stop at Cherry
Point, Ferndale, March Point and other areas which are not within the top 89 US deep
sea ports analyzed in this analysis. In addition, since they are Jones Act ships carrying
US cargo (oil from Alaska) from one US port to another, they are not documented in the
USACE entrances and clearances data. To compensate for this anomaly, an additional
port was added which encompassed Jones Act tanker ships stopping within the Puget
Sound area but not at one of the Puget Sound ports analyzed in this analysis. Ship calls in
the 1996 typical port data to ports other than those in the top 89 US deep sea ports were
analyzed separately. There were 363 ship calls by tankers to those areas in 1996. In the
Starcrest inventory report for 2005, there were 468 calls. For 2002, it was estimated
there were 432 calls. The same ship types and ship characteristics were used as in the
1996 data, but the number of calls was proportionally increased to 432 calls to represent
these Jones Act ships. The location of the “Other Puget Sound” port was approximately
at Cherry Point near Aberdeen.”
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These two revisions to the Puget Sound port inventories would result in generally higher
emissions due to these changes. However, more detail about vessel type, berthing time, and
other activities were also included in the revised ports inventory.
According to ICF (2007), the Port of Portland inventory was prepared for the year 2000, and has
been updated to calendar year 2004 by Bridgewater (2007). The Portland inventory estimated on
emissions for vessel calls to the Portland area ports. Portland is only one of several ports along
the Columbia River, and so represented only a portion the large ocean-going vessel activity on
the Columbia.
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REFERENCES
Bridgewater Group and CH2M Hill, Inc., “Port Of Portland Calendar Year 2000 Baseline Air
Emission Inventory,” Prepared for the Port of Portland, April, 2005. Referenced by ICF
(2007).
L. Browning. 2008. “Current Methodologies and Best Practices for Preparing Ocean Going
Vessel Emission Inventories,” ICF International, presented at the TRB Data for Goods
Movement Impacts on Air Quality Workshop, March 2008.
Chamber of Shipping 2007. “2005 – 2006 BC Ocean-Going Vessel Emissions Inventory,”
January.
EPA 2003. “Control of Emissions From New Marine Compression-Ignition Engines at or Above
30 Liters per Cylinder,” Volume 68, Number 40, Federal Register, February 28, 2003.
EPA 2008. “Regulatory Impact Analysis: Control of Emissions of Air Pollution from
Locomotive Engines and Marine Compression Ignition Engines Less than 30 Liters per
Cylinder,” EPA420-R-08-001, March.
ICF. 2007. “Commercial Marine Port Inventory Development 2002 and 2005 Inventories,”
Prepared for U.S. Environmental Protection Agency, Prepared by: ICF International,
September.
MARPOL. 2008. “Revised Annex VI adopted October 2008: MEPC 176(58) Amendments to the
Annex of the Protocol of 1997 to amend the International Convention for the Prevention
of Pollution from Ships, 1973, as modified by the Protocol of 1978 relating thereto
(Revised MARPOL Annex VI)” Available online at
http://www.imo.org/environment/mainframe.asp?topic_id=233
Puget Sound Maritime Air Forum 2007. “Maritime Air Emissions Inventory,” Prepared by
Starcrest Consulting, April.
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APPENDIX
METHODOLOGY FOR GENERATING GRIDDED 2018 COMMERCIAL
MARINE EMISSIONS
Overview of Methodology
1. Create GIS shapefile that defines regions
2. Identify gridcells with regions
3. Apply growth and control factors to each grid cell in 2002 inventory to forecast to 2018
The regions are defined in GIS tools by a shapefile that describes the spatial areas within GIS
tools. ENVIRON created a shapefile delineating the following 12 regions each with different
growth and control factors shown in Figure A1.












Canada
Oregon and Washington
California north, beyond 100nm from shore
Californa north, with 100nm of shore
California north, Port Regions and Onshore
California central, beyond 100nm from shore
Californa central, with 100nm of shore
California central, Port Regions and Onshore
California south, beyond 100nm from shore
Californa south, with 100nm of shore
California south, Port Regions and Onshore
Mexico
California was divided into north, central and south regions, the line of latitude intersecting Point
Reyes defines the north/central line, the central/south line is defined as the line of latitude
intersecting Point Conception. Table A1 provides the specific definition of the latitudes used to
define the regions.
Table A1. Lateral boundaries between regions.
Border
Washington/Canada
Oregon/California
North California/Central California
Central California/South California
California/Mexico
Latitude
49°N
42°N
37.9958°N
34.4486°N
32.5°N (approx)
Datum
NAD83
NAD83
WGS84
WGS84
unknown
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Figure A1. Shapefile delineating 12 regions overlaying the WRAP 36k grid.
Once the regions had been defined, ENVIRON delineated the 12 regions by the WRAP 36k grid
in order to assign each grid cell to a region. For grid cells spanning more than one region, that
grid cell was assigned to the region that covered the larger area of the grid cell. The grid cells
along the shoreline were inspected and one grid cell near the Port of Los Angeles was reassigned
to be port/onshore instead of 100nm because although a larger portion of the grid cell was in the
100nm region, most emissions in that grid cell would come from Port of Los Angeles, and
port/onshore control factors are appropriate. Figure 2 shows the regions.
Figure 2. Regions with different growth and control factors within WRAP domain.
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Emissions were then forecasted from 2002 to 2018 using the projection factors shown in Table
A2; these factors include both growth and control factors that were applied to each region to
estimate 2018 emissions from 2002 emissions. The California factors were provided by ARB;
growth outside of California was derived from EPA estimates; and both were adjusted for the
16% NOx control from the international emission standards.
Table A2. Growth and control factors to forecast from 2002 to 2018.
Region
North Pacific
Mexico
Canada
Central ocean
Central onshore
South ocean
South onshore
North ocean
North onshore
Central 100nm
South 100nm
North 100nm
CO2
168%
218%
168%
192%
52%
247%
42%
194%
41%
192%
190%
173%
NOx
141%
183%
141%
161%
70%
207%
41%
163%
54%
160%
175%
143%
PM25
168%
218%
168%
192%
13%
247%
9%
194%
10%
95%
61%
82%
SOx
168%
218%
168%
192%
3%
247%
3%
194%
3%
79%
34%
67%
Table A3 shows how each of the pollutants in the gridded inventory was forecasted according to
pollutant type.
Table A3. Forecast surrogates for all emissions.
Inventory Pollutant
CO
VOC
NH3
NO2
NO
SO425
PM25
PMc
SO2
OC25
EC25
Pollutant forecast factor
CO2
CO2
NOx
NOx
NOx
SOx
PM25
CO2
SOx
20%(PM25-SO425)
80%(Pm25-SO425)
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