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NORTHWEST SAN PEDRO NEIGHBORHOOD COUNCIL COMMENTS ON THE SAN PEDRO BAY PORTS DRAFT CLEAN AIR ACTION PLAN (CAAP) [Page notations refer to the CAAP Overview Document]
The plan indicates that the Ports will be open to new technologies and other advancements to accelerate meeting the Clean Air Action Plan vision. It is our understanding that implementation of these new technologies will only occur after CARB has certified the technology. The plan should include assisting promising technology in getting tested and certified by CARB in a shorter time frame. An alternative would be for the Ports to assist CARB in testing and certifying new technologies and equipment through a cooperative agreement that allows the Ports to act on CARBs behalf for the purposes of testing and evaluation of new emission control technologies. 2. Page 15 – The Ports will work with tenants and the railroads to assist them in developing their own programs to meet the CAAP standards The CAAP asks each Port tenant and user of Port infrastructure to develop individual CAAPs. Port staff could be overwhelmed reviewing individual CAAPs from each tenant, especially since individual CAAPs are due by December 31, 2006. To achieve the same goals it may be more efficient to have CAAPs submitted by industry type (liquid bulk, container, automobile transport). This could be accomplished by working with industry groups such as the Western States Petroleum Association and PMA. This approach would reduce the number of plans submitted for review and would allow for standardization of CAAPs across industry sectors. 3. Page 15 – Green Container Transport 4. Page 17 – Emissions by Source Category The pie charts provide a summary of the Port of Los Angeles 2001 and Port of Long Beach 2002 baseline year inventories. The figures should indicate that emissions by source category are a sum of two different baseline years and emission inventories. A brief discussion of the possible error in the emission estimates should be provided to benchmark future emissions reductions and compare future San Pedro Bay wide emission inventories. If the emission inventory techniques used by the two Ports are different a notation should be provided. 5. Page 17 – Emissions by Source Category Since SOx are emissions that the CAAP is designed to reduce, the baseline year pie chart for SOx emissions should be provided. 6. Page 17 – Emissions by Source Category Emission source category emission standards should extend to all construction equipment used for Port projects. These standards should be included with all proposals and contracts issued for construction by the Ports. 7. Page 18 Bullet (2) - Port Approval Policy When Cancer Risks Exceed Thresholds The CAAP should state whether a project will go forward if the excess cancer threshold is greater than 10 in 1,000,000 after best available technologies and controls have been modeled.
One policy that will do a great deal to reduce existing air pollution is for the two Harbor Commissions to require each discretionary project they approve to actually reduce air pollution. In particular, the Port of Los Angeles has many current permits requiring renewal soon, where it should be fairly easy to require improvements that will reduce existing emissions. Similarly, any new projects should require a reduction in actual, existing emissions. 9. Page 18 - Heavy Duty Vehicles/Trucks (second column) The plan calls for all trucks calling at the ports frequently and semi-frequently to meet the EPA 2007 on road emission standards for PM and be the cleanest available for NOx at the time of engine upgrade. It would be easier to set a numerical standard that all trucks will be required to meet by a certain date rather using frequent and semi-frequent truck calls. For instance, a goal of 80% for all trucks calling at the Ports by 2011 will meet the EPA 2007 PM standard and best available NOx emissions, and would be more easily measured and verified. 10. Page 18 - Ocean- Going Vessels (OGV) - Vessel Speed Reduction (VSR) An evaluation should be performed to determine the most efficient speed for reducing emissions for frequently calling ships. A speed standard for all vessels, although achieving emissions reductions, may not achieve the greatest emission reduction possible per vessel. An evaluation as to the individual speed for lowest emissions per ton of fuel combusted should be evaluated for ships (or a specific class of ships with similar propulsion systems) frequently calling at the Ports. A timeline for OGV to only use low sulfur marine diesel fuel for ship propulsion within 20 km of the California Coast needs to be included. 11. Page 18- Ocean-Going Vessels – Vessel Speed Reduction The VSR plan is currently voluntary. The CAAP should discuss incentives and possible penalties for compliance and non-compliance. 12. Page 18 – Ocean-Going Vessels – Shore Power The CAAP should include a timetable for phasing out OGV not using shore power or equivalent emission control during hotelling. 13. Page 19- Ocean-Going Vessels (cont.) The plan calls for use of NOx and PM control devices on the auxiliary and main engineers for new vessels and frequent callers. The plan should also include the phasing out of ship calls by the OGV that do not meet specific PM and NOx emissions limits. 14. Page 20 – Implementation - Lease Requirements The CAAP needs to provide more detail on specific terms that will be included in new agreements issued by the Ports. For example, requiring terminal operators to contract only with cleaner or newer truck fleets would substantially improve truck emission totals. At a minimum, these terms should also include use of shore power for OGV and specific standards on how each lessee will meet the CAAP. 15. Page 20 – Implementation - Lease Requirements Each new agreement or renewal issued by the Ports should
include an incentive clause related to emission reductions. An incentive
should be provided if a tenant reduces emissions below those agreed
to in the lease agreement. Future lease agreements should include a clause that defines what will happen should the total TEU volume exceed projections. This clause should require that the tenant reduce total emissions to levels below those forecast in the approved CEQA documents. 17. Page 20 – Implementation – General Comment The CAAP is an ambitious plan and will take the collective work of all Port employees. In order to achieve the goals outlined in the CAAP, the Ports should include working towards CAAP goals as part of the annual performance review for all employees.
Involving the ILWU in evaluating terminal cargo handling improvements could result in system efficiencies which result in emissions reductions.
The CAAP discusses how implementation will be evaluated or implemented in conjunction with other regulatory efforts being undertaken by California Air Resources Board. This discussion should include how the Ports will work with US EPA to create a Sulfur Emissions Control Area (SECA) along the west North American Coast.
There are many aspects of the CAAP that will have significant impacts on the environment. For example, lease requirements and tariff provisions that might change the types of trucks used need to be determined. 21. Overall Comment - The CAAP should include a timeline and plan in which reductions in greenhouse gases and other criteria pollutants will be included. |
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