b'sels starting in 2009. CHC, according to CARB, can be broken downEarly implementation can offerinto 18 varied and unique operating categories. This regulation directly impacted new and in-use engines that were currently operating in thea competitive advantage beyond regulated waters off the California cost. The regulation applies to all CHC vessels such as ferries, excursion vessels, tugboats, towboats, crewthe direct financial contribution and supply vessels, work boats, pilot vessels, research vessels, emergen-cy response vessels, barges, and commercial and charter fishing boats.from grants. Mandatory upgrades to in-use engines were implemented from 2009 through 2022. (Source: Emission Standards: USA: California Emission Programs for In-Use Diesel Engines, dieselnet.com) Early implementation can offer a competitive advantage beyond the direct financial contribution from grants. It can also be in the form of improved Over the last several years there have been many public hearings andexperiences for passengers. Adding a diesel particulate filter to exhaust will hundreds of meetings with various groups in California to change thesignificantly improve the cleanliness of the exhaust resulting in a cleaner regulation, improving it for the better of the environment but also mak- vessel and improved customer perception of the air quality and comfort. ing it much more challenging to meet. These meetings have not all beenMany private yachts voluntarily add DPF systems on generators to increase met with acceptance by the vessel owners and operators. Looking at itthe vessel paint longevity and remove the oily sheen on the surrounding from the perspective of what it means to a vessel, the regulation is go- water surface from exhaust. Vessels can market the fact that they are ahead ing to require that boats operating under EPA Pre Tier 1 / Tier 1 rulesof the emissions curve and greener than the competition and improved are going to have to repower with new engines meeting EPA Tier 2 / 3customer air quality. Smell the ocean air instead of the diesel fumes.standards immediately. Technically speaking this should have been com-pleted already for most applications according to the 2009 regulations.To achieve the requirements that have been layered by the upcoming In-use requirements for ferries, excursion vessels, tugboats, and tow- Commercial Harbor Craft Regulation changes, vessels will need a shift boats include meeting US EPA Tier 2 or Tier 3 marine engine emissionin technology to fit each situation. The requirement will be for all vessels standards over a regulatory compliance schedule. Tier 4 is required forto exceed EPA Tier 4 by controlling PM through the addition of a DPF newly built vessels once standards come into effect. Best available controlby 2035. Some older vessels with Tier 1 on 2 engines will need to eventu-technology is required for all propulsion engines on newly built ferries.ally re-power. Most tier 3 engines can be brought up to the requirements (Source: Emission Standards: USA: California Emission Programs forthrough the addition of an SCR and DPF. Most engine manufactures In-Use Diesel Engines, dieselnet.com).During the March 24, 2022 CARB Board hearing, the board approved updates to its Commercial Harbor Craft Regulation. That is just the first step. Now the race to understand the individual timing of when vessels need to be compliant begins. In its simplest of terms, compliance means that the vessel must have the cleanest certified Tier 3 or 4 engine plus a die-sel particulate filter (DPF). The compliance guidelines are layered start-ing with the older engines, such as Tier 1 and 2, being required to com-ply starting in 2023 and completing the transition by 2035. The rules and timelines vary based on the boats use and designation as outlined in the 130-page CARB document. (Source: California Poised to Impose In its simplest of terms, complianceLET ASSUREDPARTNERS MCM MANAGEYOUR INSURANCE SO YOU CANmeans that the vessel must have theFOCUS ON YOUR VOYAGEcleanest certified Tier 3 or 4 engineAssuredPartners MCM is a leading independent plus a diesel particulate filter (DPF). insurance brokerage based in the Pacic Northwest. Our combined experience placing insurance and managing the marine industrys unique risks.Wave of Boat Emissions Rules in 2022, northbaybusinessjournal.com). Whether were working with vessel operators, builders, There is no one-size-fits-all situation for this regulation and every retrofit or engine upgrade will need to be looked at closely to see what makes sense for the vessel. One thing that is clear is that a DPF will be requiredAssuredPartners MCMin all situations and space claim will be key. Contact: Damon L. NasmanDirect Line: 206.262.6375Operators should consider the available implementation timing optionsDamon.Nasman@assuredpartners.comfor their specific vessel and customer base. Should they petition for an ex-tension based on implementation feasibility? Should they implement ear-ly and take advantage of available grants to help fund the improvements?www.assuredpartnersmcm.com9 MAY 2022'