August 26, 2025
Economic Development
PORT
DATE: August 26, 2025
TO: Mayor Martinez and Members of the City Council
FROM: Charles Gerard, Port Director
Subject: Contract Amendment No. 2 with Translogix, LLC, for an Approved Emissions Control Solution
FINANCIAL IMPACT: There is no financial impact on the General Fund.
The proposed $250,000 expenditure is included within
the approval fiscal year 2025-2026 budget, Port of
Richmond (Account String: 40162380-400532).
PREVIOUS COUNCIL
ACTION:
October 1, 2024
November 19, 2024
STATEMENT OF THE
ISSUE:
The California Air Resources Board (CARB) At-Berth
Regulation, effective January 1, 2025, mandates
emission reductions from Roll-On/Roll-Off (RoRo)
vessels while docked at California ports. To meet
regulatory requirements and avoid costly penalties, the Port must amend its Marine Terminal Operating
Agreement with Translogix LLC, enabling them to
contract directly with STAX Engineering for a CARB-
approved Emission Control System (CAECS).
RECOMMENDED ACTION: ADOPT a resolution and APPROVE a second amendment to the Marine Terminal Operating Agreement
between the Port of Richmond and Translogix LLC, to
authorize the deployment and management of a
California Air Resource Board-Approved Emission
Control System (CAECS) at the Point Potrero Marine
Terminal for a three-year initial term commencing upon
deployment, including a cost-sharing commitment of
$250,000 by the Port, and AUTHORIZE the City Manager
AGENDA
REPORT
August 26, 2025
or their designee to execute all related documents to
effectuate this amendment - Economic Development-Port
(Charles Gerard 510-829-2253).
DISCUSSION:
Regulatory Compliance Requirements:
Effective January 1, 2025, the California Air Resources Board (CARB) requires all Roll- On/Roll-Off (RoRo) vessels docking at California ports to reduce emissions under the At-Berth Regulation. Key regulatory components include:
1. Emission Reduction Targets: RoRo vessels must reduce nitrogen oxides (NOx) and particulate matter (PM) emissions from auxiliary engines by at least 80 percent compared to baseline levels while at berth.
2. Compliance Mechanisms: Acceptable options include connecting to shore power, using CARB-approved alternative control technologies (such as exhaust gas cleaning systems), or employing equivalent solutions that meet CARB standards.
3. Monitoring and Reporting: Ports and shipping lines are responsible for tracking and reporting vessel visits, time at berth, and emission control methods utilized.
4. Enforcement: CARB may impose significant fines and penalties for non- compliance.
These regulations aim to improve regional air quality by significantly reducing harmful vessel emissions while docked.
2023 – Initial Port Efforts to Deploy Shore Power:
In 2023 the Port commenced looking at options for shore power solutions to comply with the CARB regulation. However, due to ongoing supply chain constraints and a lack of familiarity with the solution requirements, the Port did not receive any proposals for this work. In 2025 the Port contracted with Rosendin Electric, a Bay Area electrical contractor that has done work with the Port in the past, to undertake the initial design work for At-Berth shore power.
Because shore power design, construction, deployment and the establishing the required PG&E connections at Berths 7 and 8 represent a multi-year effort, the Port simultaneously pursued alternative compliance solutions as described below.
2024 - Port engagement with STAX Engineering for a CARB-Approved Emissions Control Solution (CAECS):
August 26, 2025
In 2024, the Port pursued an alternative compliance method involving CARB-Approved Emission Control Systems (CAECS), specifically an exhaust gas filtration solution deployed via barge. These systems, often referred to as "barge and bonnet" solutions, capture exhaust directly from vessel stacks for emission treatment onboard the barge.
As shown in the picture below, a bonnet is placed over the exhaust gas stacks on the ships and transfers the exhaust gases to an emissions control solution on the barge.
The Port engaged extensively with shipping lines (NYK, MOL, Glovis) and CAECS provider STAX Engineering in an effort to establish direct contractual agreements between carriers and STAX. To bridge the financial gap and support deployment, the Port offered a $500,000 incentive, which City Council approved on October 1, 2024. A support agreement with STAX was finalized on November 19, 2025.
Despite these efforts, contract negotiations fell through in December 2024 when shipping line Glovis announced its withdrawal from the Port of Richmond.
2025 - Agreement with Translogix, LLC (Auto Warehousing Co., or AWC):
At the beginning of 2025, the Port collaborated with our tenant, Translogix (an AWC owned company), to identify a pathway to achieve CARB compliance. The Port has a Marine Terminal Operating Agreement with Translogix that covers certain administrative and clerical terminal operations services for the Port of Richmond and for Auto Warehousing Company. This Marine Terminal Operating Agreement runs in parallel to our lease agreement with AWC for the auto-importing business and is the appropriate company for managing CARB compliance vendor agreements due to alignment with the services Translogix is already providing.
Our collaboration with Translogix resulted in Translogix entering into a service agreement with STAX Engineering to deploy a CAECS at the Port of Richmond.
August 26, 2025
To enable this deployment, the Port must execute Amendment No. 2 to the Marine Terminal Operating Agreement, granting Translogix the authority to manage key operational and commercial aspects related to the CAECS barge.
Key outcomes of this amendment include:
CARB Compliance: STAX Engineering will initiate construction of the barge upon final agreement execution, with delivery anticipated in March 2026. Shared Deployment Cost: The previously approved $500,000 deployment incentive will be split evenly between the Port and Translogix, reducing the Port's direct cost to $250,000. Tariff revenues from CAECS operations will be used to reimburse the Port this $250,000 over the agreement term. Berthing Commitment: The Port and Translogix will provide berthing space for the STAX barge at no cost.
Tariff Administration: Translogix will be authorized to collect an Environmental Services Tariff on behalf of the Port from RoRo carriers to support CAECS operation.
Revenue Sharing: Once both parties recover their initial $250,000 investments, the Port will receive 5 percent of net profits from the Environmental Services Tariff for the duration of the agreement's initial term. Regulatory Flexibility: A change-in-law clause allows for renegotiation in the event of future regulatory shifts.
Cost of Non-Compliance or Remediation Fees with CARB:
As of January 1, 2025, CARB’s At-Berth Regulation is in full effect. To mitigate penalties while compliance infrastructure is finalized, the Port applied for and received a 2025 remediation classification from CARB. This designation waives direct non-compliance penalties in favor of remediation fees, currently assessed at $2,340 per hour of vessel time at berth. These fees are paid directly to CARB by the shipping lines. Deployment of the CAECS barge will eliminate the need for these remediation charges and bring the Port to full compliance.
Conclusion:
Over the past several years, the Port of Richmond has worked diligently to meet CARB At-Berth regulations. Initial challenges, including COVID-related supply chain disruptions and limited vendor familiarity, delayed implementation. Additionally, the Port's relatively small RoRo vessel volume—approximately 60 ship calls per year— creates financial challenges not faced by larger ports such as Port Hueneme, which receives over 200 ship calls annually and can therefore distribute costs more effectively.
Through strategic collaboration with Translogix LLC, the Port has secured a viable compliance pathway. Approval of this amendment will ensure regulatory compliance, protect the Port from financial penalties, and support the continued operation and growth of RoRo services at Point Potrero Marine Terminal.
August 26, 2025
SYNERGISTIC POLICIES:
City Council Goals and Priorities – Strategic Goal Area 2.5: Revitalization of the Port.
This Amendment will bring the Port into CARB Compliance, generate jobs to deliver these emission control activities, and will reduce emissions and particulate matter from visiting ship’s auxiliary engines.
DOCUMENTS ATTACHED:
Attachment 1 – Marine Terminal Operating Agreement with Translogix LLC Attachment 2 – Amendment No. 1 to Marine Terminal Operating Agreement Attachment 3 – Amendment No. 2 to Marine Terminal Operating Agreement Attachment 4 – Resolution Translogix Amendment No. 2 for CARB Approved Emissions Control Solution