Topics for Discussion

1. ECA & Low Sulfur Fuel Use in California: Lessons LearnedCDR Jason TamaPrevention DepartmentUSCG Sector San Francisco

5. Topics for Discussion • ECA & CARB Review • LOP & Routing Impacts • Coast Guard Response • Lessons-Learned re: Risk Management

6. ECA vs. CARB • CARB requires 0.1% sulfur limit one year earlier in 2014 • CARB @ 24 NM • CARB requires use of distillate fuel (ie, MGO/MDO) • CARB enforced solely by State of California • ECA currently requires 1.0% sulfur limit; 0.1% in 2015 • ECA @ 200 NM • ECA does NOT require use of distillate fuel for compliance • ECA jointly enforced by USCG & EPA

7. California ARB Boundaries * Image courtesy of California ARB

8. Reported Loss of Propulsion (LOP) Incidents by CA COTP Zones 2004 – 2013

9. Reported Loss of Propulsion Incidents Comparison by Sector (USCG 11th District)

10. Key Data Takeaways • Challenges of Casualty Reporting – subjectivity, propensity to report, location of incident, etc • What does “fuel switching-related” mean? • ~70% LOPs Experienced During INBOUND Transit • Most incidents occur during slow speed maneuvering • Duration of transit / complexity of maneuvering • Reluctance to use CARB Safety Exemption • LOP numbers remain above historic averages. Why?

11. Dynamic, Mixed Use Waterway Carquinez Bridge and Strait Benicia-Martinez Bridge San Rafael - Richmond Bridge Bay Bridge Golden Gate Anchorages 8 & 9 >130,000 transits managed annually San Mateo Bridge

12. Low Sulfur Distillate Challenges • Inherently Lower Viscosity • Reduced Energy Density– impacts volume of fuel needed to maintain same engine load • Residual vs. Distillate Temperature Differences – high temps exacerbate viscosity challenges • Lower Lubricity – potential long-term maintenance impacts

13. Typical Post-Casualty Findings • Human error • Lack of procedures • Lack of familiarity • Poor execution (eg, fuel rack management, heat/viscosity control, etc) • Failure to test • Equipment failure / lack of maintenance: • Effects exacerbated by use of distillate fuels

14. External Leakage

19. Coast Guard Response to Increase in LOPs in California • Increased data collection/analysis • Increased training & awareness • Issuance of Marine Safety Notices/Alerts • Strong response/operational control posture, particularly offshore • Industry/stakeholder engagement

20. Fuel Switching Risk Management • Unforgiving procedure: effects will be exacerbated by crew competency or maintenance problems. • USCG recommends: • Consult engine manufacturers; • Develop & PRACTICE detailed fuel switching procedures; • Robust fuel system inspection & maintenance; • Test propulsion on MGO/MDO well in advance of arrival; • Don’t wait until day of entry to try this for the first time. • This is cheaper, easier, and safer than dealing with an LOP!

21. San Francisco Bay and Approaches

22. Vessel Routing Implications • San Francisco Bay OUTBOUND Transits by TSS Lane • Observed marked increase in use of Western Traffic Lane

23. Vessel Routing Implications San Francisco Bay INBOUND Transits by TSS Lane Observed marked increase in use of Western Traffic Lane

24. Some Lessons Learned • Fuel switching CAN increase LOP risk • LOPs most probable on inbound transit • Duration/complexity of the transit matters • Potential routing/navigation safety implications • Risks CAN be mitigated • System-wide impacts at 0.1% remain unknown • Preventing is always better than responding!

25. 4.5% Global What to expect in the future? Sulfur Content 3.5% North America ECA PR/USVI ECA 1.5% ECA 1.0% 0.5% 0.1% 1 Jan 2012 1 Aug 2012 1 Jan 2014 1 Jan 2015 1 Jan 2020 1 Jan 2010 • LOPs further offshore? • Further changes to vessel routing? • Casualty reporting trends? 0.1% throughout ECA

26. Questions & DiscussionCommander Jason Tamajason.p.tama@uscg.mil510-437-3133

27. California Air Resource Board (ARB) Requirements • Requires use of cleaner fuels within 24 nautical mile zone • Includes safety exemption provisions • July 1, 2009 • use marine gas oil (MGO) with a 1.5% sulfur limit, or • use marine diesel oil (MDO) with a 0.5% sulfur limit • August 1, 2012 • use MGO with a 1.0% sulfur limit, or • use MDO with a 0.5% sulfur limit • January 1, 2014 (ONE YEAR IN ADVANCE OF ECA) • use MGO with a 0.1% sulfur limit, or • use MDO with a 0.1% sulfur limit

28. Typical Fuel-Related Issues • Most incidents occur during slow speed maneuvering • Fail to Start • Failure at Dead Slow –RPM unstable or the engine stalls when running at low speeds (may run reliably at higher speeds). • Failure to Respond to an Astern Bell – main engine cannot start in the astern direction due to wind milling effect of propeller. • Intentional Shutdown due to External Fuel Leakage

29. Casualty Reporting • Reportable Marine Casualty- 46 CFR 4.05-1 • Includes LOP or occurrence materially & adversely affecting the vessel's fitness for service. • Applies to all vessels within 12 miles, tank vessels within 200 miles • Hazardous Condition - 33 CFR 160.215 • Whenever there is a hazardous condition aboard a vessel, Master shall immediately notify nearest Coast Guard Sector. • Applies to U.S. and foreign vessels bound for or departing the U.S.

30. Casualty Response