Liquid bulk terminals, such as the proposed Berth 408 facility for crude oil offloading, are subject to many of the same strict South Coast Air Quality Management District (SCAQMD) New Source Review regulations that apply to stationary sources such as power plants and refineries. Because vessels’ piping is connected to onshore facilities such as offloading arms, pipes, valves, pumps and tanks permitted by the SCAQMD, the emissions from the vessel while at berth (and non-propulsion related emissions while the vessel is underway) are required by SCAQMD to be fully “offset”. This stringent requirement is in stark contrast to the requirements placed on container vessels as they transit and hotel in the harbor area. SCAQMD’s authority does not reach to these vessels because they do not require onshore permitted equipment and they are unregulated by SCAQMD.

Emission Reduction Credits
In order to receive permits from the SCAQMD, emission offsets - known as Emission Reduction Credits (ERCs), must be provided to SCAQMD in quantities sufficient to offset 120 percent of all emissions accumulated from the project’s stationary sources and the vessels emissions while at berth. ERCs are obtained by reductions in emissions from other sources within the same geographic region of the South Coast Air Basin.

Since Berth 408 is located in the coastal area of the South Coast Air Basin, ERCs generated in the coastal zone will be required. ERCs are emissions reductions that have been reviewed and certified by the SCAQMD. Only certified ERCs can be used for offsets. Generation of ERCs is a difficult process due to the requirement that any reductions must first be found to be real, surplus, and enforceable before SCAQMD will issue ERCs. The surplus requirement, which means the reduction cannot be required by any rule or regulation, also mandates that the reduction in emissions be adjusted downward to the level emissions would have been if the source had first applied the current, most stringent BACT. In this way, SCAQMD has proof that emissions reductions are valid and have been removed from the air basin. By requiring 120 percent offsetting, SCAQMD further ensures an additional 20 percent reduction in basin emissions when the ERCs are later used by a new project.

The Pier 400, Berth 408 Project has acquired coastal zone emission reduction credits (ERCs) for the following pollutants:

• Oxides of Nitrogen
• Oxides of Sulfur
• Reactive Organic Gases (ROG) or Volatile Organic Compounds (VOC) which are ozone precursors

In addition, ERCs have been acquired for particulate matter less than 10 microns. However, these will not be used.

The use of these ERCs to offset 120 percent of the Project’s stationary source emissions (including the portion from vessels at berth) results in a full mitigation of the impact of these emissions to the South Coast Air Basin. The Berth 408 facility will further be required to operate under a detailed Permit to Operate from SCAQMD, which will have enforceable caps on the emissions of each pollutant. This permit will require monitoring, recordkeeping and reporting to the SCAQMD to ensure that Pacific L. A. Marine Terminal LLC operates the facility in compliance with the facility-wide emissions caps. Pacific L. A. Marine Terminal LLC will be required to periodically report the actual emissions compared to the permitted cap emissions. SCAQMD will have authority to board any vessel to verify compliance.