However, the Board of Harbor Commissioners imposed a mitigation measure on the project requiring increasing percentages of AMP (alternative marine power) calls beginning in year two of project operation and rising to 80 percent of vessel calls by year 16 of operation, even though they found AMP to be generally infeasible for marine tankers.
At the time of project approval, only two tankers in the world crude oil tanker fleet (out of approximately 1200 vessels) were equipped for AMPing and neither vessel had made a single, successful AMP call at any facility. Also, neither of those vessels is configured to be able to use the proposed AMP facility at Berth 408.
The Board of Harbor Commissioners also found that vessels calling at crude oil marine terminals typically do not make multiple calls at the same facility like vessels calling at container terminals where AMP is required. The substantial physical modifications necessary for a vessel to use shore power are simply not feasible for a vessel making a single call at a particular facility.
Likewise, CARB (California Air Resources Board) has not found shore power feasible for tankers. CARB adopted a shore power rule in 2007 that expressly excluded tankers and it has announced that it has dropped its plans to adopt a Phase II rule that would apply to tankers.
The Ports' Clean Air Action Plan and the 2010 update have concluded that shore power is generally best suited for vessels that make multiple calls per year, require significant demand for power while at berth, and for vessels that will continue to call at the same terminal for multiple years.
Since none of these conditions apply to crude oil marine tankers, the Clean Air Action Plan does not call for shore power for tankers. The Clean Air Action Plan does state that the use of shore side pumps, which the Pier 400 Berth 408 project includes, is a feasible measure for tankers.
Despite these findings, the Board of Harbor Commissioners adopted a very aggressive schedule for AMP implementation. There is no evidence that more aggressive measures can be justified.
The estimates of the number of vessel calls that may occur in the future are overstated as well. For example, Mr. Warren states that up to 201 Supertankers could call at the facility each year.
It appears that the figures used by Mr. Warren may have been inferred from the EIR/EIS for the project, which estimated the maximum number of vessel calls that the berth would be physically capable of accommodating.
That estimate included a mix of large and small vessels, and the estimate was chosen by the Port to avoid underestimating the project's impacts. However, PLAMT (Pacific LA Marine Terminal) has repeatedly stated that far fewer vessels are ever likely to call at Berth 408 both due to demand and other limiting factors.
The key limiting factor on the number of vessel calls will be the enforceable emission caps imposed in the SCAQMD air quality permit. If emissions approach an emissions cap, no additional vessels can be accommodated.
While PLAMT does not know and can't predict the exact number of vessel calls in future years, it can be said with certainty that they will not be all supertankers and that the emissions will be less than the SCAQMD caps. The SCAQMD caps are significantly lower than the emission estimates in the EIR/EIS.
Lastly, Mr. Warren's estimates of the project's potential profits bear no relationship to reality. It should be noted that while PLAMT hopes to make a profit it will have to compete with the other marine terminals in Los Angeles and Long Beach that do not have the costly environmental mitigation measures imposed on Pier 400. Therefore, it will not be possible to pass on all the costs of those measures and remain competitive.
If the community wants to continue to add mitigation measures and extra project costs, the project will simply cease to be economically viable at some point and imports will continue to be shipped through berths without emission caps and mitigation measures.
(David E. Wright is Vice President at Pacific LA Marine Terminal, LLC.) -cw
Tags: supertankers, AMP, CARB, California Air Resources Board, Harbor Commissioners, marine terminals, marine tankers, clean air
Vol 9 Issue 50
Pub: June 24, 2011