Navigating California’s 2020 At-Berth Regulation: A Look Ahead to 2025 Compliance

Navigating California's 2020 At-Berth Regulation: A Look Ahead to 2025 Compliance

The California Air Resources Board (CARB) has long been at the forefront of pushing for cleaner air through stringent emissions regulations. For marine vessels, one key regulation in this effort is the **At-Berth Regulation**, which focuses on reducing emissions from vessels when they are docked at California ports. If your business operates oceangoing vessels, it’s crucial to stay updated on the current and future requirements outlined by this regulation.

1.Regulatory Background: The Evolution of the At-Berth Regulation

2007 At-Berth Regulation

The original “2007 At-Berth Regulation” was aimed primarily at container ships, passenger ships, and refrigerated-cargo vessels docked at certain California ports. Compliance with this regulation began in 2014, and it set the stage for further emission reduction measures in the maritime industry.

2020 At-Berth Regulation

The “2020 At-Berth Regulation” expanded significantly upon the 2007 framework. It introduced new reporting requirements for all oceangoing vessels visiting California marine terminals, regardless of the cargo they carry. However, the emissions control requirements—focused on reducing **nitrogen oxide (NOx)**, **particulate matter (PM 2.5)**, and **reactive organic gases (ROG)**—are applicable only to container ships, refrigerated-cargo vessels, and cruise (passenger) ships.

The regulation’s compliance timeline varies by vessel type, and crucial updates are coming soon. Starting **January 1, 2025**, the emissions control requirements will apply to additional vessel types, including:

  • **Tanker vessels** calling at the Port of Los Angeles and Port of Long Beach terminals
  • **Roll-on/roll-off (Ro-Ro) vessels** at any California terminal

Notably, **bulk and general cargo vessels** are not subject to emissions control requirements but are required to report their visits to California terminals beginning **January 2023**. 

2.2020 At-Berth Regulation: Key Dates and Compliance Overview

Table 1: CARB 2020 At-Berth Regulation Compliance Dates by Vessel Type**

Compliance StartVessel Type
January 1, 2023Container and refrigerated cargo vessels
January 1, 2023Cruise (passenger) vessels
January 1, 2025Ro-Ro vessels (including vehicle carriers)
January 1, 2025Tanker vessels visiting the Port of Los Angeles or Port of Long Beach
January 1, 2027Tanker vessels visiting any California terminal

3. Compliance Options for Regulated Vessels

To comply with the **2020 At-Berth Regulation**, vessel operators and terminal operators have several options for emissions control:

1. **Onshore Power Supply (OPS)** – Connecting vessels to shore-based power while docked to avoid running their engines.

2. **Exhaust Capture and Control Systems (CAECS)** – Using CARB-approved exhaust capture technologies. Notably, by January 2025, there will be two approved barge-based exhaust capture solutions for tankers, developed by **STAX Engineering** and **Clean Air Engineering Maritime**.

3. **Remediation Fund** – If no viable alternative CAECS is available, vessels can contribute to a Remediation Fund. However, contributions cannot be made solely for lack of availability and must meet specific eligibility requirements.

4. **Alternative Fuels** – Vessels that switch to alternative fuels, such as **liquefied natural gas (LNG)**, can comply if their emission rates meet the CARB performance standard.

5. **Innovative Emissions Solutions** – Vessels can explore other novel technologies or strategies that result in emissions reductions, such as measures to cut emissions from other sources around the port.

4. **Enforcement and Penalties for Non-Compliance**

CARB maintains a **strict enforcement policy** and will investigate any potential violations. If a vessel or terminal operator is found to be non-compliant, they may receive a **Notice of Violation**, and financial penalties can be imposed. These penalties apply to all regulated parties, including vessel operators and terminal operators.

CARB’s enforcement is expected to remain robust, with no indication that the compliance deadlines will be delayed, meaning that **2025 and 2027 deadlines** for tankers and Ro-Ro vessels will require immediate preparation.

5. **Looking Ahead: Recommendations for Vessel Operators**

If your fleet includes tankers calling at the **Port of Long Beach** or **Port of Los Angeles** in **2025**, or if you operate **Ro-Ro vessels** at California terminals, now is the time to begin planning for compliance with the 2020 At-Berth Regulation.

The regulatory environment is shifting toward stricter emissions controls, and while alternatives such as shore power and exhaust capture systems are becoming more available, it’s essential to ensure that your vessels meet CARB’s emissions reduction targets ahead of the deadlines. Early preparation will not only help avoid penalties but will also contribute to the overall health of the environment and communities surrounding California’s vital marine ports.

6. **References for Further Reading:**

– CARB 2020 At-Berth Regulation (Full document)

– DNV Technology Assessment of At-Berth Regulation for Tankers (2021)

By staying informed and planning ahead, vessel operators and terminal operators can ensure compliance with the **2020 At-Berth Regulation** and contribute to California’s ongoing efforts to reduce port-related air pollution.

Marine Surveyor Consultant Sagl

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