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August 11, 2008

Mary Nichols, Chairperson

California Air Resources Board

1001 I Street

Sacramento, CA95812

RE: AB 32 Draft Scoping Plan Appendices for Transportation Sector (Amended Comments)

Dear Chairperson Nichols and Members of the Board:

Upon invitation by the California Air Resources Board (ARB), Friends of the Earth submits these comments in response to the recently issued AB 32 Draft Scoping Plan Appendices. FoE’s comments focus on the goods movement industry within the transportation sector, with particular emphasis on measures designed to curtail greenhouse gas emissions from ocean-going vessels and harbor craft.

While acknowledging that transporting goods via ship can be a more energy efficient modality than truck or rail transport,[1]opportunities exist to enhance vessel energy efficiency and therefore decrease significantly greenhouse gas (and criteria pollutant) emissions from ships. Globally, carbon dioxide (CO2) emissions from shipping accounted for 1,120 metric tons in 2007 and are expected to rise to 1,475 metric tons by 2020.[2] Several regulatory and programmatic options related to vessel design, operation, and maintenance are available to ARB that would reduce substantially the greenhouse gas profile of shipping in the state and allow for the attainment of goods movement objectives within the Scoping Plan’s transportation sector. Below, are previously identified techniques and programs, as well as potential new methods, to reduce greenhouse gas emissions from marine vessels.

Shore power (T-4 – Discrete Early Action)

Shore power constitutes an important aspect of any greenhouse gas reduction program pertaining to shipping. By plugging into the electrical grid or using comparable alternative energy technologies, shipswill end the harmful practice of running auxiliary diesel engines while at berth, or hotelling, for power generation. Hotelling is responsible for significant criteria pollutant and carbon dioxide emissions that impact portside communities. For a frame of reference, one cruise ship on a 10-hour port call can generate emissions equal to more than 12,400 cars.[3] Full implementation of the Shore Power I regulation – approved in November 2007 by the Board – will dramatically reduce harmful particulate matter emissions from ships, thereby improving air quality in affected communities, and also decrease carbon dioxide emissions by between approximately 122,000 and 242,000 metric tons in 2020.[4] FoE looks forward to the impending release of the 15-day modification package requested by the Board and the near-term formal finalization of this regulation. Furthermore, FoE offers its full support and encouragement for staff efforts to capture the twenty percent of emissions from ocean-going vessels outstanding in the subsequent Hotelling II regulation as soon as practicable. In addition, the Shore Power I regulation will not only benefit California residents, but the program will aid other states and countries in developing their own shore power programs, as many shipswill have installed shore power hook-up capability to comply with the California shore power regulation that can be used while visiting non-California ports.

Goods Movement Efficiency Measures (T-5)

Greenhouse Gas Emissions Inventories & Reduction Plans

In order to assess and subsequently remedy the problems posed by greenhouse gas emissions from the goods movement sector, it is imperative that greenhouse gas emissions inventories, especially within the port context, be developed immediately. The Puget Sound Maritime Air Emissions Inventory,which includes a carbon dioxide emissions profilefor Puget Sound shipping, could possibly serve as a model or point of reference for efforts in California.[5] ARB possesses the resources and technical know-how to assist ports in inventory and reduction-plan processes. As recent documents attest, ARB plans to create program requirements for greenhouse gas reduction plans at individual ports, by establishing plan boundaries, greenhouse gas sources covered, and emission reduction targets, and will provide the preliminary supporting tools such as standardized emission reduction calculation methodologies and tracking tools.[6] ARB’s leadership role in this regard is essential and will ensure program uniformity as well as adequate oversight.

Optimized Hull and Propeller Design

ARB’s Clean (or Green) Ship program offers a tremendous opportunity to improve ship design and operational features to lessen fuel use and therefore reduce CO2 emissions. Ship designattributes’ effects on fuel efficiency historically have not proven salient in the marketplace; however, with the current and projected price of fuel many in industry, including the International Chamber of Shipping, are calling for efficiency improvements such as a CO2 design index, which is currently being developed by the IMO. The IMO design index will contemplate all ship features, including engine performance, waste heat recovery systems, and optimized hull and propeller characteristics. To the maximum extent practicable, ARB should, through EPA and the U.S. IMO delegation, work with IMO to develop and fine-tune a CO2 ship design index.

Optimized Hull and Propeller Performance

In addition, many other promising options to enhance vessel operations and increase efficiencies exist. For example, advanced hull and propeller coatings and maintenance programs have evidenced fuel efficiency benefits. Hull fouling from marine biota increases ship drag, thus reducing fuel efficiency. In one case study, Propulsion Dynamics, a company specializing in hull performance monitoring,found that hull brushing a 4,000 TEU containership provided a 10 metric ton per day fuel savings.[7] In another case concerning Horizon Lines Inc., increased propeller maintenance resulted in fuel savings of approximately 1 metric ton per day.[8] Further, the use of advanced hull coatings can enhance smoothnessand assure more efficient vessel operation. FoE supports use of these coatings as long as they do not impair water quality or harm marine life.

Alternative Energy Assistance

Wind-powered assistance for ocean-going vesseltransiting presents substantial possibilities that ARB should explore. Recently, fuel savings of between 10-15 percent were achieved by a containership using a towing-kite from Germany to Venezuela. As the kite size is scaled up and computer-controlled deployment is optimized, fuel savings will increase. Annual average fuel savings of 10-35 percent are projected for the kite propulsion system, with savings of up to 50 percent possible during optimal conditions.[9] In addition, solar power has already been incorporated into ferry design to provide propulsion power,[10]and the potential exists to extend use of solar power, at least in some capacity, to larger, cargo ships. Moreover, hydrogen and fuel cell technology also provide promise in the marine environment. TheMarine Hydrogen & Fuel Cell Association e.V. asserts that “there are a number of projects around the world where hydrogen and fuel cell technologies are already demonstrating their potential, providing power for propulsion, charging batteries and storing renewable energy as hydrogen.”[11] Incentive-based programs, special “green” privileges, and the extension of grants and other funding opportunities to facilitate the integration of alternative energy capabilities into the vessel sector, especially amongst ocean-going ships, is imperative. We request that ARB initiate a process for exploring such incentives as quickly as possible.

Ocean-Going Vessel Speed Reduction (VSR) (Early Action Measure)

Reducing vessels speeds in California waters, even by 10 percent, can achieve significant greenhouse gas and criteria pollutant reductions.[12] However, some contend that “slow steaming” may have the unintended consequence of leading companies to add ships to routes to offset slower transiting times, thereby effectively negating emissions reduction gains.[13] The myriad benefits of “slow steaming,” however,can be coupled with enhanced weather routing and planning techniques to derive maximum transportation (goods movement) efficiencies.[14] As companies such as Maersk note, “[f]aster port turnarounds would mean that we could slow down the ships and still run the services using the same number of ships.”[15] An integrated, holistic approach to greenhouse gas reductions from ships involved in goods movement ought to include a vessel speed reduction program supported by ancillary efficiency measures referenced above. We request that CARB consider enforcing speed limits in Californiaregulated waters and begin working with ports in California to increase vessel fuel efficiency within the goods movement sector.

A vessel speed reduction program would provide the additional benefit of reducing noise impacts and risks to marine wildlife. For example, in the fall of 2007,freight ships moving through the Santa Barbara Channel were thought responsible for striking and killing three federally protected blue whales. The problem is also acute in East Coast waters, where ship strikes are “the greatest source of known deaths” of right whales.[16] Strikes “are responsible for over 50 percent of known human-related right whale mortalities and are considered one of the principle causes for the lack of recovery in [the right whale population].”[17] In addition, noise pollution emitted by cargo ships is growingly rapidly as the number of vessels plying the oceans rises. According to The Ocean Mammal Institute, noise pollution can have profound effects on marine life, including “masking social communications used to find mates or identify predators, temporary and permanent hearing loss or impairment, displacement from preferred habitat, disruption of feeding, breeding, nursing and communication, strandings, and in worst case scenarios, death and serious injury from hemorrhaging and tissue trauma.”[18]

ARB has conducted empirical work over the years to identify emissions reduction benefits from a VSR program based on certain distances from the California baseline. However, the release of new data surrounding a VSR program has lagged somewhat – although arescheduled workshop date for mid to late August has been proposed. While voluntary speed reduction programs initiated by SouthCoast ports have been successful, the speedy implementation of a viable statewide VSR program should be a priority for the State. Many shippers now embrace “slow steaming” as a way to cut fuel costs, which may comprise more than half of ship trip expenses. Thus, a VSR program makes particular sense in this economic climate and should be implemented expeditiously.

CommercialHarbor Craft

FoE believes that the operational and maintenance options recommended for the harbor craft sector are sound. However, we do not believe that the program should merely be educational, or voluntary, in design. It is important that at least some program elements for reducing greenhouse gas emissions from harbor craft be mandated by regulation to ensure adequate reductions and also to maintain regulatory equity within the sector.

Other Concerns

Short-Sea Shipping

Efforts to alleviate truck corridor and port traffic through the expansion of coastal and inland short-sea shipping could result in increased localized impacts, especially to smaller ports within the San FranciscoBay and Delta area. While ship traffic can be more energy efficient than land-side goods movement transport, much more could be done to increase fuel efficiency by ships and thus decrease greenhouse gas emissions. The same efficiency methods and techniques applied to international shipping are relevant and necessary for domestic shipping operators as well. In fact, opportunities potentially exist to condition the expansion of short-sea shipping operations on the satisfaction of certain fuel efficiency standards and environmental mitigation obligations. In any event, ARB and other appropriate government agencies should fully investigate impacts from short sea shipping on marine mammals, ecosystems, water quality, local communities, and existing goods movement before promoting this option as a transportation solution.

Thank you for considering these comments.

Sincerely,

John Kaltenstein

Clean Vessels Campaign Manager

Friends of the Earth

______

1717 Massachusetts Avenue, NW· Suite 600·Washington, DC20036-2008· (202) 783-7400 ·

311 California Street· Suite 510·San Francisco, CA94104-2607· (415) 544-0790

[1]Compare Texas Transportation Institute, A Modal Comparison of Domestic Freight Transportation Effects on the General Public, for the U.S. Maritime Administration and the National Waterways Foundation, Nov. 2007, at 38, available at with James Corbett and James Winebrake, Total Fuel Cycle Analysis for Alternative Marine Fuels: Sulfur and CO2 Emissions Tradeoffs of California’s Proposed Low-Sulfur Marine Fuel Rule: Final Report, prepared for ARB, May 2008, at 5, available at

[2]Note by Secretariat, Report on the outcome of the Informal Cross Government/Industry Scientific Group of Experts established to evaluate the effects of the different fuel options proposed under the revision of MARPOL Annex VI, submitted to IMO subcommittee on Bulk Liquids and Gases, Dec. 20, 2007, BLG 12/6/1, at 5, available at

[3]TeriShore, Tom Plenys, and Diane Bailey, Feasibility of Providing Shore-Based Electrical Power to Ships While Docked: Environmental Perspective, Nov. 9, 2004, citing Monterey Air Pollution Control District estimate.

[4] California Air Resources Board, Technical Support Document: Initial Statement of Reasons for the Proposed Rulemaking – Regulations to Reduce Emissions from Diesel AuxiliaryEngines on Ocean-Going Vessels while At-Berth at aCaliforniaPort, October 2007, at IX-8, available at

[5]See

[6] ARB, AB32: The California Global Warming Solutions Act, Goods Movement Sector Workshop, April 15, 2008, at PowerPoint Slide 40, available at

[7] Guy Wilson-Roberts, Clean up, save on fuel, SUSTAINABLESHIPPING.COM, March 14, 2008.

[8]Guy Wilson-Roberts, Shipowner benefits from hull performance monitoring, SUSTAINABLESHIPPING.COM, Feb 13, 2008.

[9]Unni Einemo, Beluga eyes bigger kite, double fuel savings, SUSTAINABLESHIPPING.COM, Feb. 25, 2008; Gregory M. Lamb, A secret to improving cargo ship efficiency: Go fly a kite, Christian Science Monitor, available at

[10]

[11]Unni Einemo, Hamburg conference to host marine fuel cell workshop, SUSTAINABLESHIPPING.COM, Aug. 5, 2008.

[12] A fleetwide 10 percent speed reduction would result in a 23 percent decrease in CO2. Secretariat, Report on the outcome of the IMO Study on Greenhouse Gas Emissions from Ships, submitted to IMO Marine Environment Protection Committee, June 29, 2000, MEPC 45/8, at 17, original report available at

[13]See Nick Jameson, Tanker operator introduces slower steaming, SUSTAINABLESHIPPING.COM, June 30, 2008.

[14]The absence of a ‘vessel traffic planning system’ means that “ships navigate at full speed and then they are stopped in ports waiting for their ‘slot’ to get serviced. By allowing ships to know the exact time they will be able to stop at a port one allows for a better planning of the journey, with speed and routes optimized according to those timings. This would drive lower emissions of GHG as it would avoid emissions from ships queuing while approaching a port.” Friends of the Earth International, Measures to Reduce CO2 Emissions from Ships,submitted to IMO Greenhouse Gas Working Group, May 30, 2008, available at

[15] Nick Jameson, Maersk line official wants shipping to ‘focus on’ environment, SUSTAINABLESHIPPING.COM, Aug. 1, 2008.

[16] 71 Fed. Reg. at 36,300 (June 26, 2006), Proposed Rule To Implement Speed Restrictions To Reduce the Threat of Ship Collisions with North Atlantic Right Whales.

[17] 70 Fed. Reg. 36,121 (June 22, 2005), Right Whale Ship Strike Reduction Strategy Notice of Intent To Prepare an Environmental Impact Statement and Conduct Public Scoping.

[18]Natalie Brucker-Menchelli, Efforts to protect whales from vessel noise pollution, SUSTAINABLESHIPPING.COM, July 31, 2008.