Comment Log Display

March 23, 2009

Chairman Mary D. Nichols,
Air Resources Board
1001 “I” Street, 23rd Floor
Sacramento
California, 95814 

	
Dear Madam Chairman,

Re:	California Code of Regulations Title 13, Section 2299.2--
Regulations on fuel sulphur content and other operational
requirements for ocean going vessels within California waters and
24 nautical miles of the California base line.  


On behalf of the International Shipowners Alliance of Canada Inc.
(ISAC), we wish to provide you with our comments regarding CCR
Title 13, Section 2299.2.

We note and endorse in full, the comments posted on line from
Capt. Stephen Brown of the Chamber of Shipping of British Columbia
as well as those of Joseph Angelo of INTERTANKO.  

We wish to highlight our concern regarding safety and the fact
that there is a lack of operational expertise for operating
auxiliary boilers on MDO/MGO for long periods of time.  Our members
have been advised that for main and auxiliary engines, low sulphur
distillate fuel will most certainly cause problems with pump
failures, seizures and other wear related issues, thus creating
serious navigational and safety issues if vessels lose power or
propulsion in confined waters near the port.  The comments
submitted by INTERTANKO clearly set out the technical challenges. 


The request of use of MGO/DMA grade is possible, but there are
significant engine modifications required making it challenging to
have all vessels compliant by July 1st, 2009.   Finally, we are
aware that suppliers are unable to provide MDO in a timely manner,
an issue of great concern to our industry.

We thank you for the opportunity to comment and trust that our
input will be seriously considered.


Yours sincerely,

Kaity Arsoniadis-Stein  LLB, LLM
President & Secretary-General
International Ship-Owners Alliance of Canada Inc.

cc.  Cpt. Stephen Brown, Chamber of Shipping, British Columbia 
cc:  Joe Angelo, INTERTANKO