Commercial Marine Engine Emission Standards

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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.

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 Californiaregulations 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

/ Agency / Description / Enforcement Entity / Compliance Dates / Status
MARPOL Annex VI; 2000 Tier I NOx standard / 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. / US Coast Guard / May 2005,
(Voluntary in 2000) / Ship builders generally complied with this standard back to 2000.
MARPOL Annex VI Global Sulfur Caps / International
Maritime
Organization
(US Coast
Guard lead) / The global sulfur cap reduced initially to 3.5% (from the current 4.5%) effective from 1 January 2012; then progressively to 0.5%, effective from 1 January 2020 / US Coast Guard / January 2020 for final sulfur standards / Adopted on 10 October 2008
MARPOL Annex VI SOx Emissions Control Area (SECA) for North America / US Designated
(EPA/ARB lead) / US application for a SECA. Sulfur levels capped at 1.5%, 1.0% after July 1 2010, and 0.1% on or after 2015. / 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)
MARPOL Annex VI Tier II and Tier III exhaust emission standards / International
Maritime
Organization
(US Coast
Guard lead) / Tier II standards for vessels 2011 and later; Tier III for vessels 2016 and later while operating in an ECA. / US Coast Guard / 2011 for all new vessels
2016 for all new vessels when operating in certain areas / Adopted on 10 October 2008
Ongoing negotiations from a US delegation (including EPA) for amendments to MARPOL, Annex VI)
Marine compression-ignition (diesel) engine rule / 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) / EPA / Tier 1, 2, 3, 4 emission standards below 30 liters per cylinder.
Comply with international rules for above 30 l/cylinder / Feb 28, 2003 (Tier 1 and 2)
March 2008 (Tier 3 and 4)
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 / January 1, 2007 / In place – and currently enforced –under litigation 2007 and 2010 phase-in 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
Main engine and boiler low sulfur fuel rule / ARB / Requires low sulfur fuel use in main engines and boilers similar to auxiliary engine requirements. / ARB / July 24, 2008 Board Approval / Early 2009
At-Berth Ocean-Going Vessels Regulation / ARB / Control hoteling emissions via one of several possible methods / ARB / January 2, 2009 / In place. Phase in 2010-2020
Vessel Speed Reduction (VSR) / ARB / Evaluating need for VSR measure at major ports and along coastline. / ARB / TBD / Under evaluation for mid 2008
Clean Ship program / ARB / Evaluating measure or incentive program to require cleaner or retrofitted vessels in
CA ports / ARB / TBD / Under development for late 2008. Likely phase in from 2010-2020
CommercialHarbor Craft / ARB / Accelerated turnover (scrappage) of older engines and vessels / ARB / January 1, 2009 / In place with phase-in from 2009 - 2022

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(Tel): 415-899-0700  (Fax): 415-899-0707 

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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.

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

/ Tier / Model
Year* / THC + NOx
g/kW-hr / CO
G/kW-hr / PM
g/kW-hr
Power < 37 kW
And disp. <0.9 / Tier 2 / 2005 / 7.5 / 5.0 / 0.40
0.9 < disp. < 1.2 / Tier 2 / 2004 / 7.2 / 5.0 / 0.30
1.2 < disp. < 2.5 / Tier 2 / 2004 / 7.2 / 5.0 / 0.20
2.5 < disp. < 5.0 / Tier 2 / 2007 / 7.2 / 5.0 / 0.20
5.0 < disp. < 15 / Tier 2 / 2007 / 7.8 / 5.0 / 0.27
15 < disp. < 20
Power <3300 kW / Tier 2 / 2007 / 8.7 / 5.0 / 0.50
15 < disp. < 20
Power >3300 kW / Tier 2 / 2007 / 9.8 / 5.0 / 0.50
20 < disp. < 25 / Tier 2 / 2007 / 9.8 / 5.0 / 0.50
25 < disp. < 30 / Tier 2 / 2007 / 11.0 / 5.0 / 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 /

L / Cylinder

/ THC + NOx
g/kW-hr / PM
g/kW-hr /

Model Year

<19 kW / < 0.9 / 7.5 / 0.40 / 2009+
19 to <75 kW / < 0.9 / 7.5
4.7 / 0.30
0.30 / 2009 - 2013
2014+
75 to <3700 kW
(kW / liter  35) / < 0.9 / 5.4 / 0.14 / 2012+
0.9 to <1.2 / 5.4 / 0.12 / 2013
1.2 to <2.5 / 5.6
5.6
5.6 / 0.11 <600kW
0.10 <600kW
0.11 600kW / 2014 - 2017
2018+
2014+
2.5 to <3.5 / 5.6
5.6
5.6 / 0.11 <600kW
0.10 <600kW
0.11 600kW / 2013 – 2017
2018+
2013+
3.5 < 7.0 / 5.8
5.8
5.8 / 0.11 <600kW
0.10 <600kW
0.11 600kW / 2012 – 2017
2018+
2012+
75 to <3700 kW
(kW / liter > 35)
and recreational engines / < 0.9 / 5.8 / 0.15 / 2012+
0.9 to <1.2 / 5.8 / 0.14 / 2013+
1.2 to <2.5 / 5.8 / 0.13 / 2014+
2.5 to <3.5 / 5.8 / 0.12 / 2013+
3.5 < 7.0 / 5.8 / 0.11 / 2012+
Category 2
<3700 kW / 7 to <15 / 6.2 / 0.14 / 2013
15 to <20 / 8.7 / 0.27 / 2014
20 to <25 / 9.8 / 0.27 / 2014
25 to <30 / 11.0 / 0.27 / 2014

Table 4. EPA Tier 4 standards for commercial marine engines (EPA 2008).

Engine Power

/

HC

g/kW-hr

/ THC + NOx
g/kW-hr / PM
g/kW-hr /

Model Year

> 3,700 kW <15 l/cyl.
> 3,700 kW 15 – 30 l/cyl.
> 3,700 kW all / 0.19
0.19
0.19 / 1.8
1.8
1.8 / 0.12
0.25
0.06 / 2014 – 2015
2014 – 2015
2016
2,000 to <3,700 kW / 0.19 / 1.8 / 0.04 / 2014
1,400 to <2,000 kW / 0.19 / 1.8 / 0.04 / 2016
600 to <1,400 kW / 0.19 / 1.8 / 0.04 / 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 2008are 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.

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 StatesEnvironmental Protection Agency to enforce the regulation. For more details, refer to the following advisory:

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 / Reduced Onboard Power Generation Option / Equivalent Emissions Reduction Option
Jan. 1, 2010 / Shore-power equipped ships must use shore power if available at berth / 10% Emission Reduction
Jan. 1, 2012 / Shore-power equipped ships must use shore power if available at berth / 25% Emission Reduction
Jan. 1, 2014 / 50% shore-power visits and power reduction / 50% Emission Reduction
Jan. 1, 2017 / 70% shore-power visits and power reduction / 70% Emission Reduction
Jan. 1, 2020 / 80% shore-power visits and power 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.

CommercialHarbor 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

Commercial fishing

Charter fishing boats

Pilot boats

Work boats

Other vessels

The regulation affects harbor craft statewide, and in the SouthCoast 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 /

Total Annual Hours of Operation

/

Compliance Date

1975 and earlier / ≥ 1500 / 12/31/2009
1975 and earlier / ≥300 and < 1500 /

12/31/2010

1976 – 1985 / ≥1500 /

12/31/2011

1976 – 1985 / ≥ 300 and < 1500 /

12/31/2012

1986 – 1995 /

≥ 1500

/

12/31/2013

1986 – 1995 / ≥ 300 and < 1500 /

12/31/2014

Ferries Only (1996 – 1999) / ≥ 300 /

12/31/2014

Vessels Other Than Ferries

1996 – 1999 / ≥ 1500 /

12/31/2015

Vessels Other Than Ferries
1996 – 1999 / ≥ 300 and < 1500 /

12/31/2016

2000 / ≥ 1500 /

12/31/2015

2000 / ≥ 300 and < 1500 /

12/31/2016

1996 – 2000 / ≥1500 /

12/31/2015

1996 – 2000 / ≥ 300 and < 1500 /

12/31/2016

2001 – 2002 / ≥ 300 /

12/31/2017

2003 / ≥ 300 /

12/31/2018

2004 / ≥ 300 /

12/31/2019

2005 / ≥ 300 /

12/31/2020

2006 / ≥ 300 /

12/31/2021

2007 / ≥ 300 /

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.

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, andbeyond 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