b'or with the help of a professional naval architect or marineACE plan regulations are covered in Section (f) engineer, make sure you have detailed all the reasons whyp.94. Some operators are planning to use the ACE you cannot comply with the regulations where exemptionsplan to get an approved long term compliance plan are allowed. Simply stating, it does not fit, will likely notinstead of submitting extension requests every be accepted. year and some are planning to exceed the regula-tions on some of their vessels to account for other PASSENGER FERRIESIN-USE vessels that are too expensive to make compliant, Section (e)(12) starting on page 73 addresses the compli- so the overall fleet emissions are in compliance. ance dates and methods for existing, or as they call them, in-usepassengerferries.PleasenotethatCARBhas Method 4Meet CARB (e)(9) standards in a two-stepchanged how they are managing the compliance date forprocess (applies to only Pre-Tier 1 and Tier 1)your vessels with this new regulation. Up until now, the compliance data was always tied to the build date of the Step 1: Repower to Tier 3 or 4 as required by the engines installed in your vessel. If the engines changeddate in Table 16, p.79then the compliance date changed to match the engines installed.CARBhasnowtiedthecompliancedatetoStep 2: Retrofit a CARB Level III verified DPF by the engines date of manufacture that were installed inthe date in Table 17, p.79 (except short run ferries)your vessel on Jan. 1, 2023. Repowering your vessel to Tier 4 will partially address the compliance but it willCompliance dates are covered in Section (e)(12)(D) starting not change the date for when you are supposed to haveon page 77. your DPFs installed. If your vessel was in the process of repowering when the regulation came into effect, there isTable 16, p.79: dates for pre-Tier 1 and Tier 1 enginessome language in there to address that in Section (e)(12)(D)b. Also, please note that Section (e)(12)(B)2 states thatTable 17, p.79: dates for Tier 2-4 engines in all ferries if you repowered to Tier 3 (below 600kW) and later a Tier(except short run)4 engine gets certified at your power level and rating youTable 18, p.80: dates for excursion vesselswould not need to repower to that newly certified Tier 4 engine. Once again, make sure you have a written deter- PASSENGER FERRIES mination from the CARB EO that your Tier 3 repowerNEW AND NEWLY ACQUIRED IN-USEis approved so you do not have to argue about anotherSection (e)(9), starting on page 61, addresses the perfor-repower to Tier 4 later.mance standards for new builds and newly acquired used, or as they call them, in-use passenger ferries. MethodsofcompliancearecoveredinSection(e)(12)(C) starting on page 75. Extension as applicable are covered later.A new vessel, keel laid before Jan. 1, 2023, falls underSection (e)(12) for in-use vesselsMethod 1Repower to Tier 3 or 4 as applicable meeting the emissions requirements of Section (e)(9) A new vessel, keel laid after Jan. 1, 2023, enginethat include a DPF.emissions must comply with Method 2Rebuild or repower to Tier 3 or 4 andAll engines Tier 4+DPF: Table 11, p.62-63 install a CARB Level III Verified Diesel Emissions Control Strategy (VDECS) or DPF. VDECS is definedAll engines Tier 3+DPF: Table 12, p.63-65on page 33 and the regulation is covered in Section (e)(12)(F) All engines Tier 4 Final Off Road+DPF: Table 13, p.65-66Method 3CARB EO approval of meeting (e)(9) emissions standard with an Alternative Control of Note: CARB tables 11-13 use g/bhp-hr. EPA uses g/ Emissions (ACE) plan. kW-hr for emissions as do all engine manufacturers.29 AUGUST 2023'