b'short-run ferry, but the EPA Decisionsion request is subject to the reviewmust be installed, and the DPF added LEGISLATIVE Documentdeclinedtoapprovethatand approval by the executive officerwhen it becomes available. aspect of the rule. of CARB, and approval is at CARBs discretion. For all the provisions re- Feasibility Extension CAN COMPLIANCE garding extensions, see page 80 of theEquipment Not Feasible and DEADLINES BE EXTENDED? 2022 amendments. Operator Cannot AffordThe 2022 amendments establish com- Vessel Replacement (E3). pliance dates for various categories ofTherearefivetypesofcomplianceThedurationofanE3extensionis vessels and their engines, but is thereextensions potentially available.two years. For most passenger vessels, anywiggleroom?Cantherebeex- theextensioncanpotentiallybere-tensionsofthecompliancedates?IfShore Power and ZEAT newed in two-year increments for up so, what circumstances might induceInfrastructure Extension (E1).to a total of six years (but not beyond CARB to grant an extension? This extension may be for only one yearDec. 31, 2034). extension, but there is the possibilityThere is a very specificof a renewal for an additional year. However,apassengervesselconsid-ered to be a Low-Use Hours vessel process for requestingAn E1 extension is limited to those op- canpotentiallyobtainanunlimited an extension, and theerators or facilities that are obligated tonumber of E3 extensions. Table 22 in put in shore power and ZEAT (Zerothe CHC Amendments specifies the applicant must provideEmission and Advanced Technology)number of operating hours for a vessel a lot of documentation.infrastructure,alimitednumberofto be considered a Low-Use Hours entities. To obtain an E1 compliancevessel; it ranges between 40 and 700 The rule also has rigidextension, the applicant must explainhours annually depending on the en-timing requirementsthe unforeseen, temporary, or extenu- gine tier and the area of operation.during which anating circumstances outside the appli-cants control that prevent the installa- TobeeligibletoseekanE3feasi-exemption request tion of the required infrastructure bybility extension, the vessel operator can be submitted. the compliance deadline.mustdemonstratethatnosuitable tier 3 or tier 4 marine engine and/or An extension requestFeasibility Extensiondiesel particulate filters (DPFs) will is subject to the reviewNo Certified Engines or fitwithintheexistingvesselstruc-Diesel Particulate Filters (DPFs)tureandthatnoamountofmodi-and approval by theavailable (E2).fications can be made to the vessel executive officer ofAn initial E2 extension can be for a peri- structure without compromising the CARB, and approval isod of two years, but an additional two- vessels integrity.year extension is potentially available.at CARBs discretion.In addition, the vessel operator must Theapplicantmustshowthattherealsodemonstratethatremovingthe are no certified engines or DPFs suit- vesselfromserviceandreplacingit The rule does hold out the prospectable for use on the vessel are availablewithanewlyacquiredvesselwith ofextensionsofcompliancedatesby the compliance dates. The operatorcompliant engines is not financially in certain situations. There is a verymust also show that no combinationpossible.Ifthemodificationswill specificprocessforrequestinganof certified engines can be used in lieuresult in the reduction of passenger extension,andtheapplicantmustof engines of the original horsepowercapacitybyatleast25percentthat provide a lot of documentation. Theratingtoperformtheworkofthewillbeconsideredtobenon-feasi-rulealsohasrigidtimingrequire- particular vessel design. If compliantble, assuming that the reduction in mentsduringwhichanexemptionengines are available, but a compliantpassengercapacitywillresultinin-request can be submitted. An exten- DPFisnot,thecompliantenginescreased emissions.FOGHORN 34'