Comment Log Display

August 5, 2011

Clerk of the Board
California Air Resources Board
1001 I Street, 23rd Floor
Sacramento, CA 95814

SUBMITTAL OF COMMENTS

Re:  Proposed Amendments to the Regulations for Fuel Sulfur and
Other Operational Requirements for Ocean-Going Vessels within
California Waters and 24 Nautical Miles of the California
Baseline.

APL Co. Pte LTD, hereafter known as APL, is a global container
shipping business facilitating world trade since 1848.  We operate
a fleet of deep draft ocean going freight vessels calling at
California ports and have a strong commitment to improving air
quality in California.  This is most recently evident through our
initiation of the first-ever shore power “cold iron” system in the
Port of Oakland in conjunction with the California Air Resources
Board (ARB).  To that end, we are concerned with the proposed
amendments to the Regulations for Fuel Sulfur and Other Operational
Requirements for Ocean-Going Vessels within California Waters and
24 Nautical Miles of the California Baseline, particularly with
regards to regulatory consistency and potential loss of propulsion.
 

As members of the Pacific Merchant Shipping Association (PMSA), a
maritime trade association representing shipping companies
servicing regular trade routes through U.S. West Coast ports; we
fully support their comments on these proposed amendments in their
letter dated July 22, 2011.  Furthermore, we support PMSA’s
approach to developing an international response to solving vessel
emission problems.  Given that vessels are mobile and routinely
cross a wide array of boundaries and jurisdictions, the United
States recognized the value of an international response with the
creation of the United States and Canada Emission Control Area
(ECA).  As you are undoubtedly aware, it was approved by the
International Maritime Organization in March 2010 and is scheduled
to be implemented in August 2012. 

The ARB Proposed Amendments take a step toward regulatory
consistency by postponing until to 2014 the date at which the
percent sulfur required will decrease.  While we welcome this
postponement, particularly for reasons relating to loss of
propulsion as outline below, it leaves a one year gap of
inconsistent regulations for vessels calling at California ports. 
We strongly encourage ARB to make the postponement date 2015 in
order to align with the ECA’s percent sulfur reduction date.

With regards to loss of propulsion (LOP) associated with fuel oil
switching, APL’s U.S.-flag division, APL Maritime (AML) conducted
an analysis of the LOP marine casualty reports made to the U.S.
Coast Guard for vessels calling California ports in 2010.   As you
are aware, a vessel’s loss of propulsion dramatically increases the
risk to the environment and APL is committed to striving to
eliminate such risk.  

The LOP analysis was conducted in conjunction with underway audits
aboard AML vessels operating from California ports in response to
the ARB zone requirements.  Recommendations were developed from
this analysis and used in discussions with the various regulatory
bodies concerning the issue of fuel oil switching, including the
U.S. Coast Guard Sector San Francisco “Loss of Propulsion/ Marine
Engineers” meeting on March 16, 2011 in Oakland.  AML found enough
subjective evidence in their analysis to believe LOP marine
casualties reported by large ocean going vessels was directly
related to fuel oil switching and contributed to stalling, loss of
fuel oil pressure, and clogging of fuel lines and filters all of
which resulted in the reportable marine casualty.  To that end, APL
strongly recommends that ARB postpone until 2015 the implementation
of more stringent sulfur criteria in order for vessel owners and
operators to be fully prepared for all possible contingencies when
fuel oil switching.  

In conclusion, APL strongly supports an international approach to
addressing the emission issues associated with international
shipping throughout the world.  We believe that the international
approach is critical to maintaining competitive parity of
California ports.  If you have any questions regarding our
comments, please do not hesitate to contact me at
earl_agron@apl.com or 510-272-3985.  Thank you for your
consideration of our comments.

							Sincerely,


Robert A. Clark, II
Director of Environmental Affairs, Americas
APL