Attachment 4 - STAX Proposal_Richmond Lease RFP.pdf — Richmond City Council, September 22, 2026

′

Executive Order G-23-294-004 1
State of California

AIR RESOURCES BOARD
Executive Order G-23-294-004
CARB Approval of the STAXbox system used to control emissions from container vessels for compliance with the Control Measure for Ocean-Going Vessels At Berth STAX Engineering (STAX)
STAXbox
WHEREAS August 27, 2020, the California Air Resource Board (CARB) adopted the Control Measure for Ocean-Going Vessels (OGV) At Berth, California Code of Regulations, sections 93130-93130.22 (2020 At Berth Regulation), which establishes requirements for ocean-going vessels at berth in a California port to reduce oxides of nitrogen (NOx), diesel particulate matter (PM), and reactive organic gases (ROG) emissions from auxiliary engines; WHEREAS section 93130.5 of the 2020 At Berth Regulation establishes requirements for an emission control strategy to qualify as a CARB Approved Emission Control Strategy (CAECS) that can be used to reduce emissions from ocean-going vessel auxiliary engines and applicable tanker auxiliary boilers while at berth in a California port; WHEREAS no emission control strategy may be used to comply with the requirements of the 2020 At Berth Regulation unless CARB approves it as a CAECS; WHEREAS the 2020 At Berth Regulation requires that the emission control strategy, if applicable for auxiliary engines, achieves emission rates of less than 2.8 grams per kilowatt hour (g/kW-hr) for NOx, 0.03 g/kW-hr for PM 2.5, and 0.1 g/kW-hr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS for strategies approved after 2020, greenhouse gas (GHG) emissions from the strategy must be grid-neutral using the grid emission rate for the year that the technology is granted an Executive Order, as specified under section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS STAX is subject to the 2020 At Berth Regulation as a CAECS operator; WHEREAS STAX developed STAXbox, a barge-based capture and control system to reduce emissions from the auxiliary engines on an ocean-going container vessel while at berth; WHEREAS STAXbox consists of the following components and subcomponents as specified in the Description of Control Strategy in “Test Plan: STAXbox Emissions Control System” (Test Plan) dated February 28, 2023, including: an exhaust capture system using flexible ducting and an emission control system comprising of a particulate filter and Selective Catalytic Reduction (SCR) unit to reduce NOx, PM, and ROG; Executive Order G-23-294-004 2
WHEREAS the original emission control system STAXbox.A-1 described in STAX’s Test Plan has been renamed to STAXbox 1-1;
WHEREAS STAX submitted their final Test Plan on February 28, 2023, using the STAXbox 1-1, and CARB issued STAX a Test Plan approval letter on April 10, 2023; WHEREAS STAX submitted the “Emissions Measurement from Ocean Going Container Vessels Using a Capture and Control System” (Test Report) and “Application for CARB Approval of STAX Engineering’s STAXbox Emissions Control System as a CARB Approved Emissions Control Strategy (CAECS)” (request for Executive Order), dated May 2, 2023; WHEREAS CARB reviewed and evaluated the Test Report and request for Executive Order for the STAXbox 1-1 based on the requirements specified in the 2020 At Berth Regulation; WHEREAS CARB found the submitted documents indicate STAXbox 1-1 achieves the emission reductions and has GHG emissions that are grid neutral for 2023 as stated in the Test Report and required by the 2020 At Berth Regulation under section 93130.5(d); WHEREAS CARB issued EO G-23-294 on December 4, 2023, approving the STAXbox 1-1 for use for compliance with the 2020 At Berth Regulation for container vessels; WHEREAS EO G-23-294 approved STAXbox 1-1 to control a single auxiliary engine; WHEREAS G-23-294-002 approved STAXbox 1-2 as a duplicate of STAXbox 1-1 to control a single auxiliary engine;
WHEREAS STAX submitted “Research Test Plan for Design Change - RoRo Vessels:

Two Sources to Two Xbox Emissions Control System” (Design Change Test Plan) on May 5, 2025, seeking to use STAXbox 1-1 and 1-2 as a dual train system where each STAXbox controls one engine exhaust simultaneously, and CARB issued STAX a test plan approval letter on June 12, 2025, for the Design Change Test Plan; WHEREAS, STAXbox, also known as the control unit or train, is the emission control system, and Xcraft is the barge. Xcraft-1 barge includes two STAXboxes (STAXbox 1-1 and STAXbox 1-2), where each STAXbox controls one auxiliary engine; WHEREAS the Xcraft barge can operate either one STAXbox to control one auxiliary engine or both STAXboxes simultaneously to control two auxiliary engines, a configuration known as dual-train operation;
WHEREAS STAX submitted “Testing Results for Design Change – RoRo Vessels Two Sources to Two Xbox Emissions Control System” (Design Change Test Report) on May 15, 2025, and supplemental data submitted on July 7, 2025;
WHEREAS CARB found the submitted documents indicate the STAXbox 1-1 and 1-2 dual train system is a modification to the design or operation of a CAECS per section 93130.5(i)(2) of the 2020 At Berth Regulation, and the Executive Officer found it was appropriate to update the approval with changes to reflect the modification which include Executive Order G-23-294-004 3
the approval to operate a single STAXbox individually or two STAXboxes operating simultaneously in dual-train mode on the same ro-ro vessel and issued EO G-24-054-003; WHEREAS STAX submitted a request to extend the approved dual train operation for ro-ro vessels to container vessels on October 27, 2025;
WHEREAS STAX manufactured additional equipment that is a duplicate of the STAXbox 1-1 (single train system) and the STAXbox 1-1 and STAXbox 1-2 (dual train system) to be operated under the same approved operating conditions, and requested the duplicate be added to the Executive Order;
WHEREAS duplicate equipment can be added to an Executive Order after the equipment has been verified to be a duplicate, with the condition that the required in-use compliance testing is conducted with the in-use compliance test (including emissions) data submitted to CARB within 6 months or 30 vessel visits, whichever comes first; WHEREAS duplicate equipment must be identical to the equipment described in STAX’s Test Plan submitted on February 28, 2023, as amended by STAX’s Design Change Test Plan submitted on May 5, 2025, which updated the genset make/model information and dual train system operation;
WHEREAS equipment can be considered duplicates of either STAXbox 1-1 (single train system) or STAXbox 1-1 and STAXbox 1-2 (dual train system); WHEREAS the following in-use compliance tests must be conducted on duplicate equipment within 6 months or 30 vessel visits, whichever comes first, after the date that the duplicate equipment is approved and added to the Executive Order: 1) Third-party source testing at one load point following the requirements of section 93130.5(g) of the 2020 At Berth Regulation with Relative Accuracy Test Audit (RATA) testing.; 2) Third-party capture efficiency testing at one load point.; 3) Durability testing on a minimum of five vessels and a minimum of 200 hours;
WHEREAS for systems approved to use similar operating conditions for use on multiple vessel types (such as container, ro-ro, and/or tanker vessels) for auxiliary engines, the in-use compliance testing requirements outlined above shall only be conducted on one selected vessel type, based on the earliest applicable in-use compliance deadline, to avoid duplicative testing across vessel types;
WHEREAS for dual train systems approval, both STAXboxes (trains) must complete all of the in-use compliance testing outlined above;
WHEREAS during in-use compliance testing, either a single STAXbox can operate individually or two STAXboxes can operate simultaneously in dual-train mode on the same vessel;
WHEREAS in-use compliance third-party source testing must be conducted for all pollutants listed in section 93130.5 (g) of the 2020 At Berth Regulation, and all testing must follow the Executive Order G-23-294-004 4
test methods specified in section 93130.5 (g) and in STAX’s Test Plan submitted on February 28, 2023;
WHEREAS duplicate equipment may require additional testing or be removed from the Executive Order if the required testing is not submitted to CARB within 6 months or 30 vessel visits, whichever comes first, after the date that the duplicate equipment is approved and added to the Executive Order;
WHEREAS duplicate equipment will be removed from the Executive Order if, after CARB evaluates the test data, CARB determines that the in-use compliance test data demonstrates the system achieves emission rates greater than those specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS during the in-use compliance period, all requirements of the Executive Order must be followed, including all malfunction reporting and recordkeeping requirements.

Failure to comply with the requirements of the Executive Order, including section 93130.12 of the 2020 At Berth Regulation, will cause the equipment to be removed from the Executive Order and the approved equipment list;
WHEREAS STAX requested the STAXbox system(s) listed in addition to the STAXbox 1-1 and STAXbox 1-2 dual train system in Attachment 1 to be approved as duplicate equipment under this Executive Order and submitted information for CARB to verify the systems are duplicates of the STAXbox 1-1 (single train system) or the STAXbox 1-1 and STAXbox 1-2 (dual train system);
WHEREAS the Executive Officer finds it is appropriate to issue this Executive Order that identifies the operating conditions, recordkeeping, and monitoring requirements for STAX’s use of the STAXbox to allow its use as a CAECS for compliance with the 2020 At Berth Regulation;
WHEREAS this approval does not constitute an air pollution or land use permit, nor does it relieve the responsibility of STAX or the end user to comply with all Federal, State, and local laws, rules, and regulations;
NOW, THEREFORE, IT IS ORDERED that the STAXbox is approved for use in demonstrating compliance with the 2020 At Berth Regulation as a CAECS, when used by STAX as intended and in accordance with the following terms and conditions, and in accordance with all other applicable requirements in the 2020 At Berth Regulation.

The approved STAXbox system(s) (Approved Equipment) and the vessel and engine types for which the STAXbox system(s) are approved to control can be found in Attachment 1 of this Executive Order.

APPROVAL OF DUPLICATE EQUIPMENT
BE IT FURTHER ORDERED, the duplicate STAXbox system(s) listed as Approved Equipment in Attachment 1 of this Executive Order are approved as verified duplicates of the equipment described in STAX’s Test Plan submitted on February 28, 2023, as amended by Executive Order G-23-294-004 5
STAX’s Design Change Test Plan submitted on May 5, 2025, which updated the genset make/model information and dual train system operation, and may be used pursuant to the terms and conditions of this Executive Order on the vessels and engine types as provided in Attachment 1.

BE IT FURTHER ORDERED, STAX will conduct the required in-use compliance testing to verify compliance of duplicate equipment within six months or 30 vessel visits, whichever comes first, for every new piece of equipment added to this Executive Order.

BE IT FURTHER ORDERED, STAX may only use the STAXbox equipment identified as Approved Equipment in Attachment 1 to demonstrate compliance with the 2020 At Berth Regulation pursuant to this Executive Order, and any additional duplicates must receive CARB approval prior to use pursuant to this Executive Order.

APPROVED OPERATING CONDITIONS
Parameter Value
Ocean-going vessel engine type
Approved operating modes for STAXboxes on
ocean-going container vessels:
• One STAXbox controlling one auxiliary
engine,
• Two STAXboxes operating simultaneously in
dual train mode, each controlling one
auxiliary engine.

Ocean-going vessel type Container vessel
Ocean-going vessel fuel composition limitation
Marine distillate fuel meeting 0.1% sulfur content
limit (0.1% sulfur marine gas oil (MGO) or marine
diesel oil (MDO))
SCR inlet operating temperature range in degrees
Fahrenheit (⁰F) 600 – 720⁰F
Ocean-going vessel engine maximum continuous
rating (MCR) in kilowatts (kW) per engine 3,500 kW per STAXbox Ocean-going vessel allowable operating range (kW)
per engine 266 kW to 890 kW
Allowable exhaust flow rate in standard cubic feet
per minute (scfm) per STAXbox 3,642 to 6,330 scfm of engine exhaust Maximum engine exhaust temperature
requirements 1,000⁰F
Static Pressure Differential pressure between -2 to -20 inches of water across the diesel particulate filter
Other parameters that affect performance 1-2 inches of water back pressure at the capture system inlet
Executive Order G-23-294-004 6
Parameter Value
GRID Neutral Target – CA CO2e state output
emission rate from eGRID2021 in pounds per
megawatt hour (lb/MWh)
480.5 lb/MWh
Maximum CAECS auxiliary generator operating load
(kW) 320 kW
CAECS auxiliary generator renewable diesel carbon
intensity limit in grams of carbon dioxide equivalent
per megajoule of fuel (g CO2e/MJ)

26.99 g CO2e/MJ fuel
Maximum ammonia slip emissions in parts per
million by volume, dry basis (ppmdv) 5 ppmdv averaged over 60 minutes

OPERATIONAL REQUIREMENTS
BE IT FURTHER ORDERED, STAX will operate the STAXbox following the notification and operational requirements per sections 93130.12(b)(1) and 93130.12(b)(2) of the 2020 At Berth Regulation:

1. At least seven calendar days before a vessel’s arrival, the operator of the CAECS must coordinate in writing with the vessel operator and terminal operator for the use of the strategy and supply the vessel operator with information about the compatibility with the vessel and terminal of the CAECS.

2. During each visit, the operator of the CAECS shall:
a. Begin controlling emissions within two hours of vessel “Ready to Work”; b. Record inlet and outlet levels of emissions during the visit; c. Continue controlling emissions until at least one hour before “Pilot on Board”; and
d. Ensure vessels are operating on CARB compliant distillate marine fuel.

MONITORING REQUIREMENTS
BE IT FURTHER ORDERED, for every 1,000 hours of operation (and at a minimum annually), STAX shall submit data to the Executive Officer from the continuous emission monitoring system (CEMS) for each visit the CAECS is operated, to verify that the emission reduction levels are maintained, paying the applicable Certification Fee for the 2020 At Berth Regulation (California Code of Regulations, Title 13, Division 3, Chapter 16, Article 7, sections 2913 and 2914) for each visit.

BE IT FURTHER ORDERED, the CEMS parameters submitted to the Executive Officer must follow the parameters and measurement methods listed in STAX’s CEMS parameter list submitted on June 4, 2025.

BE IT FURTHER ORDERED, within 30 days of a vessel departure, for every visit where STAXbox is used as a CAECS, STAX shall report to CARB visit information as required by section 93130.12(b)(3) of the 2020 At Berth Regulation.

Executive Order G-23-294-004 7
BE IT FURTHER ORDERED, within seven days of a vessel departure, STAX shall report to their vessel operator customers the information necessary for vessel operators to submit their visit information to CARB as required by section 93130.7(e)(4) of the 2020 At Berth Regulation, including the following:
1) Emissions control start date and time
2) Emission control end date and time
3) Details on any delays or interruptions while controlling emissions and the times that emission reductions were uncontrolled during the visit.

BE IT FURTHER ORDERED, when vessel operators submit visit information to CARB as required by section 93130.7(e)(4) of the 2020 At Berth Regulation, the vessel operator must also report the following information per the compliance instructions for section 93130.7(e)(4)(Q):
1) Total power generated by vessel’s auxiliary engines while at berth in kW-hr. Data must be recorded at a minimum once an hour.

BE IT FURTHER ORDERED, within seven days of a vessel departure, STAX shall report to their terminal operator customers the information necessary for terminal operators to submit their visit information to CARB as required by section 93130.9(d)(5) of the 2020 At Berth Regulation, including the following:
1) Emissions control start date and time;
2) Emission control end date and time;
3) Details on any delays or interruptions while controlling emissions and the times that emission reductions were uncontrolled during the visit.

BE IT FURTHER ORDERED, STAX shall maintain the STAXbox in accordance with “Section 5. Maintenance” of STAX’s Test Plan.

BE IT FURTHER ORDERED, the Executive Officer may request that the STAXbox be tested annually using the test methods specified in the 2020 At Berth Regulation to demonstrate the overall percentage of the emission reduction being achieved, and the results of such testing shall be provided to the Executive Officer within 30 days of testing per section 93130.5(j) of the 2020 At Berth Regulation.

MALFUNCTION REPORTING AND RECORDKEEPING REQUIREMENTS
BE IT FURTHER ORDERED, STAX shall report within 24 hours to CARB, by electronic means, any malfunction that is expected to create emissions in excess of any applicable emissions limitation for a period greater than one hour and shall retain for five years all records pertaining to the malfunction pursuant to section 93130.12 of the 2020 At Berth Regulation.

BE IT FURTHER ORDERED, STAX shall report within 24 hours to CARB, by electronic means, any malfunction with the CEMS system that occurs for a period greater than one hour and makes the emission control unverifiable, and STAX shall retain for five years all records pertaining to the malfunction pursuant to section 93130.12 of the 2020 At Berth Regulation.

Executive Order G-23-294-004 8
BE IT FURTHER ORDERED, a delay or interruption in emissions control caused by a malfunction is eligible for remediation for the hours of uncontrolled emissions only when CARB is notified by STAX according to the provisions of section 93130.12(c) of the 2020 At Berth Regulation.

BE IT FURTHER ORDERED, STAX shall submit a corrective action report within seven calendar days after a malfunction has been corrected as pursuant to section 93130.12(d) of the 2020 At Berth Regulation.

BE IT FURTHER ORDERED, records made pursuant to section 93130.12 of the 2020 At Berth Regulation shall be kept for a minimum of five years and STAX shall submit information to CARB according to section 93130.19 of the 2020 At Berth Regulation.

Maintenance” of STAX’s Test Plan is being adhered to.
• STAX must keep records, including purchase receipts, for a minimum of five years, for renewable diesel purchases demonstrating the fuel used on the STAXbox complies with the Approved Operating Conditions in this Executive Order. • STAX must inform the vessel operator of the STAXbox operating conditions and ensure the vessel is only operating one or two auxiliary engine(s) while the STAXbox(s) is controlling emissions.
• STAX must operate either one STAXbox to control a single auxiliary engine on a container vessel, or two STAXboxes operating simultaneously in dual-train mode to control two auxiliary engines on the same container vessel, where each STAXbox controls only one auxiliary engine.
• Delays or interruptions in emissions control caused by a malfunction, or when the operational requirements in section 93130.12 of the 2020 At Berth Regulation are not met may result in enforcement actions and ultimately revocation of the EO unless the visits are made compliant through use of the Remediation Fund or with a Vessel Incident Event (VIE) or Terminal Incident Event (TIE).

DESIGN CHANGES AND EXTENSIONS
BE IT FURTHER ORDERED, no changes are permitted to Xcraft or STAXbox design, or approved operating parameters set forth in STAX’s application, test plan, and this Executive Order and its appendices, unless CARB is notified and approves in advance per section 93130.5(i)(2) of the 2020 At Berth Regulation. Design changes include changes to any part of the STAXbox system including the exhaust capture hood, ducting, control equipment, and deployment platform. The changes must be approved in writing by the Executive Officer and any applicable Certification Fees for the At Berth Regulation (California Code of Regulations, Title 13, Division 3, Chapter 16, Article 7, sections 2913 and 2914) must be paid before the modifications may be used for compliance with the 2020 At Berth Regulation. The Executive Officer may revoke this Executive Order, or approval of any Executive Order G-23-294-004 9
or all STAXbox system(s) listed as Approved Equipment in Attachment 1 of this Executive Order, if the system fails to demonstrate that the expected emissions reductions are being achieved or if the STAXbox design or approved operating parameters are changed without prior notification and approval by the Executive Officer. If a STAXbox system malfunctions and fails to achieve emissions reductions required by the 2020 At Berth Regulation while performing with the same design, conditions, and requirements approved for the original approved system, the Executive Officer may revoke its approval of the duplicate system, remove it from the Executive Order, and/or require additional testing requirements if necessary.

BE IT FURTHER ORDERED, this Executive Order shall have a duration of five years from the date G-23-294 was executed (December 4, 2023) unless it is revoked by CARB as set forth in section 93130.5(l) of the 2020 At Berth Regulation. As specified in section 93130.5(i)(1), at least six months prior to the expiration of this Executive Order, STAX may apply for an extension by submitting an extension application to the Executive Officer asserting that the strategy has not changed and is still effective, following the requirements specified in section 93130.5(d) as provided in section 93130.5(i)(1) of the 2020 At Berth Regulation, after paying any applicable Certification Fees for the At Berth Regulation (California Code of Regulations, Title 13, Division 3, Chapter 16, Article 7, sections 2913 and 2914).

BE IT FURTHER ORDERED, marketing of the STAXbox using any identification other than that shown in this Executive Order or marketing of the STAXbox for an application other than those listed in this Executive Order shall be prohibited unless prior approval is obtained from CARB.

BE IT FURTHER ORDERED, this Executive Order does not relieve STAX from complying with all other applicable regulations.

BE IT FURTHER ORDERED, this Executive Order may be revoked if the Executive Officer determines that STAX does not comply with any of the requirements in this Executive Order.

Executive Order EO G-23-294-003 is hereby superseded and is of no further force and effect.

Executed at Sacramento, California, this 20th day of May 2026. ______________________________
Bonnie Soriano, Branch Chief
Freight Activity Branch
Transportation and Toxics Division
Attachment 1: Approved Equipment List
Executive Order G-23-294-004 10
Barge STAXbox Ocean-going
Vessel Type
Ocean-going
Vessel Engine
Type***
Capture
Hood Type
In-Use Compliance
Testing*
Xcraft-1 STAXbox 1-1 Container
vessel
One auxiliary
engine Flex duct
Original STAXbox system
approved, and not a
duplicate. No requirement.

Xcraft-1 STAXbox 1-2 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by June 23, 2025,
whichever comes first.

Xcraft-2 STAXbox 2-1 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by January 15, 2025,
whichever comes first.

Xcraft-3 STAXbox 3-1 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by June 23, 2025,
whichever comes first.

Xcraft-3 STAXbox 3-2 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by June 23, 2025,
whichever comes first.

Xcraft-4 STAXbox 4-1 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.

Xcraft-4 STAXbox 4-2 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.

Xcraft-5 STAXbox 5-1 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.

Xcraft-5 STAXbox 5-2 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.

Executive Order G-23-294-004 11
Barge STAXbox Ocean-going
Vessel Type
Ocean-going
Vessel Engine
Type***
Capture
Hood Type
In-Use Compliance
Testing*
Xcraft-6 STAXbox 6-1 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.

Xcraft-6 STAXbox 6-2 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.

Xcraft-7 STAXbox 7-1 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.

Xcraft-7 STAXbox 7-2 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.

Xcraft-8 STAXbox 8-1 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.

Xcraft-8 STAXbox 8-2 Container
vessel
One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by
November 30, 2025,
whichever comes first.**
* Consistent with the terms and conditions of the Executive Order, duplicate equipment listed in Attachment A may be used for compliance with the At Berth Regulation. Duplicate equipment remains eligible for use under this Executive Order unless or until removed from Attachment 1.
** STAX requested the STAXbox 8-2 be removed from this Executive Order on November 12, 2025. STAXbox 8-2 is no longer approved for use on container vessels.

Before it can be used on container vessels, STAX must reapply and request that STAXbox 8-2 be added to this Executive Order.
*** Consistent with the terms and conditions of the Executive Order, STAX is approved to operate either one STAXbox to control a single auxiliary engine on a container vessel, or two STAXboxes operating simultaneously in dual-train mode to control two auxiliary engines on the same container vessel.

Executive Order G-24-054-004 1
State of California

AIR RESOURCES BOARD
Executive Order G-24-054-004
CARB Approval of the STAXbox system used to control emissions from auto carriers/roll-on roll-off (ro-ro) vessels for compliance with the Control Measure for Ocean-Going Vessels At Berth
STAX Engineering (STAX)
STAXbox
WHEREAS on August 27, 2020, the California Air Resource Board (CARB) adopted the Control Measure for Ocean-Going Vessels (OGV) At Berth, California Code of Regulations, sections 93130-93130.22 (2020 At Berth Regulation), which establishes requirements for ocean-going vessels at berth in a California port to reduce oxides of nitrogen (NOx), diesel particulate matter (PM), and reactive organic gases (ROG) emissions from auxiliary engines; WHEREAS section 93130.5 of the 2020 At Berth Regulation establishes requirements for an emission control strategy to qualify as a CARB Approved Emission Control Strategy (CAECS) that can be used to reduce emissions from ocean-going vessel auxiliary engines and applicable tanker auxiliary boilers while at berth in a California port; WHEREAS no emission control strategy may be used to comply with the requirements of the 2020 At Berth Regulation unless CARB approves it as a CAECS; WHEREAS the 2020 At Berth Regulation requires that the emission control strategy, if applicable for auxiliary engines, achieves emission rates of less than 2.8 grams per kilowatt hour (g/kW-hr) for NOx, 0.03 g/kW-hr for PM 2.5, and 0.1 g/kW-hr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS for strategies approved after 2020, greenhouse gas (GHG) emissions from the strategy must be grid-neutral using the grid emission rate for the year that the technology is granted an Executive Order, as specified under section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS STAX is subject to the 2020 At Berth Regulation as a CAECS operator; WHEREAS STAX developed STAXbox, a barge-based capture and control system to reduce emissions from the auxiliary engines on an ocean-going ro-ro vessel while at berth; WHEREAS STAXbox consists of the following components and subcomponents as specified in the Description of Control Strategy in “Test Plan: STAXbox Emissions Control System” (Test Plan) dated February 28, 2023, including: an exhaust capture system using flexible ducting, and an emission control system comprising of a particulate filter and Selective Catalytic Reduction (SCR) unit to reduce NOx, PM, and ROG; Executive Order G-24-054-004 2
WHEREAS the original emission control system STAXbox.A-1 described in STAX’s Test Plan has been renamed to STAXbox 1-1;
WHEREAS STAX submitted their final Test Plan on February 28, 2023, using the STAXbox 1-1, and CARB issued STAX a Test Plan approval letter on April 10, 2023; WHEREAS STAX submitted the “Emissions Measurement from Ocean Going Roll On/Roll Off (RoRo) Vessels Using a Capture and Control System” (Test Report) and request for Executive Order on May 26, 2023;
WHEREAS CARB reviewed and evaluated the Test Report and request for Executive Order for the STAXbox 1-1 based on the requirements specified in the 2020 At Berth Regulation; WHEREAS CARB found the submitted documents indicate STAXbox 1-1 achieves the emission reductions and has GHG emissions that are grid neutral for 2024 as stated in the Test Report and required by the 2020 At Berth Regulation under section 93130.5(d); WHEREAS CARB issued EO G-24-054 on March 21, 2024, approving the STAXbox 1-1 for use for compliance with the 2020 At Berth Regulation for ro-ro vessels; WHEREAS EO G-24-054 approved STAXbox 1-1 to control a single auxiliary engine; WHEREAS G-24-054-002 approved STAXbox 1-2 as a duplicate of STAXbox 1-1 to control a single auxiliary engine;
WHEREAS STAX submitted “Research Test Plan for Design Change - RoRo Vessels: Two Sources to Two Xbox Emissions Control System” (Design Change Test Plan) on May 5, 2025, seeking to use STAXbox 1-1 and 1-2 as a dual train system where each STAXbox controls one engine exhaust simultaneously, and CARB issued STAX a test plan approval letter on June 12, 2025, for the Design Change Test Plan;
WHEREAS, STAXbox, also known as the control unit or train, is the emission control system, and Xcraft is the barge. Xcraft-1 barge includes two STAXboxes (STAXbox 1-1 and STAXbox 1-2), where each STAXbox controls one auxiliary engine; WHEREAS the Xcraft barge can operate either one STAXbox to control one auxiliary engine or both STAXboxes simultaneously to control two auxiliary engines, a configuration known as dual-train operation;
WHEREAS STAX submitted “Testing Results for Design Change – RoRo Vessels Two Sources to Two Xbox Emissions Control System” (Design Change Test Report) on May 15, 2025, and supplemental data submitted on July 7, 2025;
WHEREAS CARB found the submitted documents indicate the STAXbox 1-1 and 1-2 dual train system is a modification to the design or operation of a CAECS per section 93130.5(i)(2) of the 2020 At Berth Regulation, and the Executive Officer finds it is appropriate to update the approval with changes to reflect the modification which include the approval to operate a single STAXbox individually or two STAXboxes operating simultaneously in dual-train mode on the same ro-ro vessel and issued EO G-24-054-003; Executive Order G-24-054-004 3
WHEREAS STAX manufactured additional equipment that is a duplicate of the STAXbox 1-1(single train system) and the STAXbox 1-1 and STAXbox 1-2 (dual train system) to be operated under the same approved operating conditions, and requested the duplicate be added to the Executive Order;
WHEREAS duplicate equipment can be added to an Executive Order after the equipment has been verified to be a duplicate, with the condition that the required in-use compliance testing is conducted with the in-use compliance test (including emissions) data submitted to CARB within 6 months or 30 vessel visits, whichever comes first; WHEREAS duplicate equipment must be identical to the equipment described in STAX’s Test Plan submitted on February 28, 2023, as amended by STAX’s Design Change Test Plan submitted on May 5, 2025, which updated the genset make/model information and dual train system operation;
WHEREAS equipment can be considered duplicates of either STAXbox 1-1 (single train system) or STAXbox 1-1 and STAXbox 1-2 (dual train system).

WHEREAS the following in-use compliance tests must be conducted on duplicate equipment within 6 months or 30 vessel visits, whichever comes first, after the date that the duplicate equipment is approved and added to the Executive Order: 1) Third-party source testing at one load point following the requirements of section 93130.5(g) of the 2020 At Berth Regulation with Relative Accuracy Test Audit (RATA) testing.; 2) Third-party capture efficiency testing at one load point.; 3) Durability testing on a minimum of 5 vessels and a minimum of 200 hours;
WHEREAS for systems approved to use similar operating conditions for use on multiple vessel types (such as container, ro-ro, and/or tanker vessels) for auxiliary engines, the in-use compliance testing requirements outlined above shall only be conducted on one selected vessel type, based on the earliest applicable in-use compliance deadline, to avoid duplicative testing across vessel types;
WHEREAS for dual train systems approval, both STAXboxes (trains) must complete all of the in-use compliance testing outlined above;
WHEREAS during in-use compliance testing, either a single STAXbox can operate individually or two STAXboxes can operate simultaneously in dual-train mode on the same vessel;
WHEREAS in-use compliance third-party source testing must be conducted for all pollutants listed in section 93130.5 (g) of the 2020 At Berth Regulation, and all testing must follow the test methods specified in section 93130.5 (g) and in STAX’s Test Plan submitted on February 28, 2023;
WHEREAS duplicate equipment may require additional testing or be removed from the Executive Order if the required testing is not submitted to CARB within 6 months or Executive Order G-24-054-004 4
30 vessel visits, whichever comes first, after the date that the duplicate equipment is approved and added to the Executive Order;
WHEREAS duplicate equipment will be removed from the Executive Order if, after CARB evaluates the test data, CARB determines that the in-use compliance test data demonstrates the system achieves emission rates greater than those specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS during the in-use compliance period, all requirements of the Executive Order must be followed, including all malfunction reporting and recordkeeping requirements.

The approved STAXbox system(s) (Approved Equipment) and the vessel and engine types for which the STAXbox system(s) are approved to control can be found in Attachment 1 of this Executive Order.

APPROVAL OF DUPLICATE EQUIPMENT
BE IT FURTHER ORDERED, the duplicate STAXbox system(s) listed as Approved Equipment in Attachment 1 of this Executive Order are approved as verified duplicates of the equipment described in STAX’s Test Plan submitted on February 28, 2023, as amended by STAX’s Design Change Test Plan submitted on May 5, 2025, which updated the genset make/model information and dual train system operation, and may be used pursuant to the terms and conditions of this Executive Order on the vessels and engine types as provided in Attachment 1.

Executive Order G-24-054-004 5
BE IT FURTHER ORDERED, STAX will conduct the required in-use compliance testing to verify compliance of duplicate equipment within six months or 30 vessel visits, whichever comes first, for every new piece of equipment added to this Executive Order.

Executive Order G-24-054-004 6

APPROVED OPERATING CONDITIONS
Parameter Value
Ocean-going vessel engine type
Approved operating modes for STAXboxes on
ocean-going ro-ro vessels:
• One STAXbox controlling one auxiliary
engine,
• Two STAXboxes operating simultaneously in
dual train mode, each controlling one
auxiliary engine
Ocean-going vessel type Ro-ro vessel
Ocean-going vessel fuel composition limitation
Marine distillate fuel meeting 0.1% sulfur content
limit (0.1% sulfur marine gas oil (MGO) or marine
diesel oil (MDO))
SCR inlet operating temperature range in degrees
Fahrenheit (⁰F) 600 – 720⁰F
Ocean-going vessel engine maximum continuous
rating (MCR) in kilowatts (kW) per engine 3,500 kW per STAXbox Ocean-going vessel allowable operating range (kW)
per engine 266 kW to 890 kW
Allowable exhaust flow rate in standard cubic feet
per minute (scfm) per STAXbox 3,642 to 6,330 scfm of engine exhaust Maximum engine exhaust temperature
requirements 1,000⁰F
Static Pressure Differential pressure between -2 to -20 inches of water across the diesel particulate filter
Other parameters that affect performance 1-2 inches of water back pressure at the capture system inlet
GRID Neutral Target – CA CO2e state output
emission rate from eGRID2022 in pounds per
megawatt hour (lb/MWh)
457.5lb/MWh
Maximum CAECS auxiliary generator operating load
(kW) 320 kW
CAECS auxiliary generator renewable diesel carbon
intensity limit in grams of carbon dioxide equivalent
per megajoule of fuel (g CO2e/MJ)

25.70 g CO2e/MJ fuel
Maximum ammonia slip emissions in parts per
million by volume, dry basis (ppmdv) 5 ppmdv averaged over 60 minutes Executive Order G-24-054-004 7

BE IT FURTHER ORDERED, the CEMS parameters submitted to the Executive Officer must follow the parameters and measurement methods listed in STAX’s CEMS parameter list submitted on June 4, 2025.

BE IT FURTHER ORDERED, within seven days of a vessel departure, STAX shall report to their vessel operator customers the information necessary for vessel operators to submit their visit information to CARB as required by section 93130.7(e)(4) of the 2020 At Berth Regulation, including the following:
1) Emissions control start date and time
2) Emission control end date and time
3) Details on any delays or interruptions while controlling emissions and the times that emission reductions were uncontrolled during the visit.

BE IT FURTHER ORDERED, when vessel operators submit visit information to CARB as required by section 93130.7(e)(4) of the 2020 At Berth Regulation, the vessel operator must Executive Order G-24-054-004 8
also report the following information per the compliance instructions for section 93130.7(e)(4)(Q):
1) Total power generated by vessel’s auxiliary engines while at berth in kW-h. Data must be recorded at a minimum once an hour.

BE IT FURTHER ORDERED, STAX shall maintain the STAXbox in accordance with “Section 5.

Maintenance” of STAX’s Test Plan.

BE IT FURTHER ORDERED, a delay or interruption in emissions control caused by a malfunction is eligible for remediation for the hours of uncontrolled emissions only when CARB is notified by STAX according to the provisions of section 93130.12(c) of the 2020 At Berth Regulation.

Executive Order G-24-054-004 9
BE IT FURTHER ORDERED, records made pursuant to section 93130.12 of the 2020 At Berth Regulation shall be kept for a minimum of five years, and STAX shall submit information to CARB according to section 93130.19 of the 2020 At Berth Regulation.

Maintenance” of STAX’s Test Plan is being adhered to.
• STAX must keep records, including purchase receipts, for a minimum of five years, for renewable diesel purchases demonstrating the fuel used on the STAXbox complies with the Approved Operating Conditions in this Executive Order. • STAX must inform the vessel operator of the STAXbox operating conditions and ensure the vessel is only operating one or two auxiliary engine(s) while the STAXbox(s) is controlling emissions.
• STAX must operate either one STAXbox to control a single auxiliary engine on a ro-ro vessel, or two STAXboxes operating simultaneously in dual-train mode to control two auxiliary engines on the same ro-ro vessel, where each STAXbox controls only one auxiliary engine.
• Delays or interruptions in emissions control caused by a malfunction, or when the operational requirements in section 93130.12 of the 2020 At Berth Regulation are not met may result in enforcement actions and ultimately revocation of the EO unless the visits are made compliant through use of the Remediation Fund or with a Vessel Incident Event (VIE) or Terminal Incident Event (TIE).

DESIGN CHANGES AND EXTENSIONS
BE IT FURTHER ORDERED, no changes are permitted to Xcraft or STAXbox design or approved operating parameters set forth in STAX’s application, test plan, and this Executive Order and its appendices, unless CARB is notified and approves in advance per section 93130.5(i)(2) of the 2020 At Berth Regulation. Design changes include changes to any part of the STAXbox system including the exhaust capture hood, ducting, control equipment, and deployment platform. The changes must be approved in writing by the Executive Officer and any applicable Certification Fees for the At Berth Regulation (California Code of Regulations, Title 13, Division 3, Chapter 16, Article 7, sections 2913 and 2914) must be paid before the modifications may be used for compliance with the 2020 At Berth Regulation. The Executive Officer may revoke this Executive Order, or approval of any or all STAXbox system(s) listed as Approved Equipment in Attachment 1 of this Executive Order, if the system fails to demonstrate that the expected emissions reductions are being achieved or if the STAXbox design or approved operating parameters are changed without prior notification and approval by the Executive Officer. If a STAXbox system malfunctions and fails to achieve emissions reductions required by the 2020 At Berth Regulation while performing with the same design, conditions, and requirements approved for the original approved system, the Executive Officer may revoke its approval of the Executive Order G-24-054-004 10
duplicate system, remove it from the Executive Order, and/or require additional testing requirements if necessary.

BE IT FURTHER ORDERED, this Executive Order shall have a duration of five years from the date G-24-054 was executed (March 21, 2024) unless it is revoked by CARB as set forth in section 93130.5(l) of the 2020 At Berth Regulation. As specified in section 93130.5(i)(1), at least six months prior to the expiration of this Executive Order, STAX may apply for an extension by submitting an extension application to the Executive Officer asserting that the strategy has not changed and is still effective, following the requirements specified in section 93130.5(d) as provided in section 93130.5(i)(1) of the 2020 At Berth Regulation, after paying any applicable Certification Fees for the At Berth Regulation (California Code of Regulations, Title 13, Division 3, Chapter 16, Article 7, sections 2913 and 2914).

BE IT FURTHER ORDERED, this Executive Order does not relieve STAX from complying with all other applicable regulations.

BE IT FURTHER ORDERED, this Executive Order may be revoked if the Executive Officer determines that STAX does not comply with any of the requirements in this Executive Order.

Executive Order EO G-24-054-003 is hereby superseded and is of no further force and effect.

Executed at Sacramento, California, this 20th day of May 2026. ______________________________
Bonnie Soriano, Branch Chief
Freight Activity Branch
Transportation and Toxics Division
Attachment 1: Approved Equipment List
Executive Order G-24-054-004 11
Attachment 1: Approved Equipment List
Barge STAXbox Ocean-going
Vessel Type
Ocean-going
Vessel Engine
Type***
Capture
Hood Type
In-Use Compliance
Testing*
Xcraft-1 STAXbox 1-1 Ro-Ro vessel One auxiliary
engine Flex duct
Original STAXbox system
approved, and not a
duplicate. No requirement.

Xcraft-1 STAXbox 1-2 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by June 23, 2025,
whichever comes first.

Xcraft-2 STAXbox 2-1 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 24, 2025,
whichever comes first.**
Xcraft-3 STAXbox 3-1 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by June 23, 2025,
whichever comes first.

Xcraft-3 STAXbox 3-2 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by June 23, 2025,
whichever comes first.

Xcraft-4 STAXbox 4-1 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.

Xcraft-4 STAXbox 4-2 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.

Xcraft-5 STAXbox 5-1 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.

Xcraft-5 STAXbox 5-2 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.

Executive Order G-24-054-004 12
Barge STAXbox Ocean-going
Vessel Type
Ocean-going
Vessel Engine
Type***
Capture
Hood Type
In-Use Compliance
Testing*
Xcraft-6 STAXbox 6-1 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.

Xcraft-6 STAXbox 6-2 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.

Xcraft-7 STAXbox 7-1 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.

Xcraft-7 STAXbox 7-2 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.

Xcraft-8 STAXbox 8-1 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.

Xcraft-8 STAXbox 8-2 Ro-Ro vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by March 29, 2026,
whichever comes first.****
* Consistent with the terms and conditions of the Executive Order, duplicate equipment listed in Attachment 1 may be used for compliance with the At Berth Regulation. Duplicate equipment remains eligible for use under this Executive Order unless or until removed from Attachment 1.
** STAX requested the STAXbox 2-1 be removed from this Executive Order on March 16, 2025. STAXbox 2-1 is no longer approved for use on ro-ro vessels. Before it can be used on ro-ro vessels, STAX must reapply and request that STAXbox 2-1 be added to this Executive Order.
*** Consistent with the terms and conditions of the Executive Order, STAX is approved to operate either one STAXbox to control a single auxiliary engine on a ro-ro vessel, or two STAXboxes operating simultaneously in dual-train mode to control two auxiliary engines on the same ro-ro vessel.

Executive Order G-24-054-004 13
**** STAX requested the STAXbox 8-2 be removed from this Executive Order on November 12, 2025. STAXbox 8-2 is no longer approved for use on ro-ro vessels. Before it can be used on ro-ro vessels, STAX must reapply and request that STAXbox 8-2 be added to this Executive Order.

Executive Order G-25-200-001 1
State of California

AIR RESOURCES BOARD
Executive Order G-25-200-001
CARB Approval of the STAXbox system used to control emissions from tanker vessels for compliance with the Control Measure for Ocean-Going Vessels At Berth STAX Engineering (STAX)
STAXbox
WHEREAS August 27, 2020, the California Air Resource Board (CARB) adopted the Control Measure for Ocean Going Vessels (OGV) At Berth, California Code of Regulations, sections 93130-93130.22 (2020 At Berth Regulation), which establishes requirements for ocean-going vessels at berth in a California port to reduce oxides of nitrogen (NOx), diesel particulate matter (PM), and reactive organic gases (ROG) emissions from auxiliary engines; WHEREAS section 93130.5 of the 2020 At Berth Regulation establishes requirements for an emission control strategy to qualify as a CARB Approved Emission Control Strategy (CAECS) that can be used to reduce emissions from ocean-going vessel auxiliary engines and applicable tanker auxiliary boilers while at berth in a California port; WHEREAS no emission control strategy may be used to comply with the requirements of the 2020 At Berth Regulation unless CARB approves it as a CAECS; WHEREAS the 2020 At Berth Regulation requires that the emission control strategy, if applicable for auxiliary engines, achieves emission rates of less than 2.8 grams per kilowatt hour (g/kW-hr) for NOx, 0.03 g/kW-hr for PM 2.5, and 0.1 g/kW-hr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS for strategies approved after 2020, greenhouse gas (GHG) emissions from the strategy must be grid-neutral using the grid emission rate for the year that the technology is granted an Executive Order, as specified under section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS the 2020 At Berth Regulation requires that the emission control strategy, if applicable for tanker auxiliary boilers, achieves emission rates less than 0.4 g/kWhr for NOx,

0.03 g/kWhr for PM 2.5, and 0.02 g/kWhr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS STAX is subject to the 2020 At Berth Regulation as a CAECS operator; WHEREAS STAX developed STAXbox, a barge-based capture and control system to reduce emissions from the auxiliary engines on an ocean-going tanker vessel while at berth; Executive Order G-25-200-001 2
WHEREAS, STAXbox consists of the following components and subcomponents as specified in the Description of Control Strategy in “Test Plan: STAXbox Emissions Control System” (Test Plan) dated December 18, 2024, including: an exhaust capture system using flexible ducting, and an emission control system comprising of a particulate filter and Selective Catalytic Reduction (SCR) unit to reduce NOx, PM, and ROG; WHEREAS, STAXbox, also known as the control unit or train, is the emission control system, and Xcraft is the barge. Xcraft-1 barge includes two STAXboxes (STAXbox 1-1 and STAXbox 1-2), where each STAXbox controls one auxiliary engine.

WHEREAS STAX submitted their final Test Plan on December 18, 2024 using the Xcraft-1 (STAXbox 1-1 and STAXbox 1-2), and CARB issued STAX a Test Plan approval letter on March 19, 2025;
WHEREAS STAX submitted the “Emissions Measurement from Tanker Vessels Using STAX Engineering’s Barge Based Capture and Control System” (Test Report) and request for Executive Order on January 7, 2025;
WHEREAS CARB reviewed and evaluated the Test Report, supplemental data submitted on March 13, 2025, May 22, 2025, June 6, 2025, July 9, 2025, and request for Executive Order for the STAXbox 1-1 and STAXbox 1-2 based on the requirements specified in the 2020 At Berth Regulation;
WHEREAS CARB found the submitted documents indicate STAXbox 1-1 and STAXbox 1-2 achieves the emission reductions and has GHG emissions that are grid neutral for 2025 as stated in the Test Report and required by the 2020 At Berth Regulation under section 93130.5(d) and issued EO G-25-200 on July 29, 2025, approving STAXbox 1-1 and STAXbox 1-2 for use for compliance with the 2020 At Berth Regulation for tanker vessels.

WHEREAS STAX submitted “Research Test Plan for Design Change – Tankers: Two Sources to One STAXbox Emissions Control System ” (Design Change Test Plan) on July 22, 2025, seeking to use STAXbox 1-1 and STAXbox 1-2 to demonstrate control of two auxiliary engines with one STAXbox by using a “Y” manifold, and CARB issued STAX a test plan approval letter on August 28, 2025, for the Design Change Test Plan; WHEREAS STAX submitted “Testing Results for Design Change – Tanker Vessels:

Two Sources to One STAXbox Emissions Control System” (Design Change Test Report) on January 27, 2026;
WHEREAS CARB found the submitted documents indicate the use of the “Y” manifold to control two auxiliary engines with one STAXbox is a modification to the design or operation of a CAECS per section 93130.5(i)(2) of the 2020 At Berth Regulation, and the Executive Officer finds it is appropriate to update the approval with changes to reflect the modification which include the approval to control two tanker auxiliary engines using one STAXbox; WHEREAS CARB found the testing submitted by STAX indicates the STAXbox achieves the performance standards in section 93130.5(d) when operated as either one STAXbox to Executive Order G-25-200-001 3
control a single auxiliary engine on a tanker vessel, two STAXboxes operating simultaneously in dual-train mode to control two auxiliary engines on the same tanker vessel, where each STAXbox controls only one auxiliary engine, one STAXbox using a “Y” manifold to control two auxiliary engines while the other STAXbox is not in operation, or one STAXbox using a “Y” manifold to control two auxiliary engines while the other STAXbox controls one auxiliary engine;
WHEREAS STAX manufactured additional equipment that is a duplicate of the STAXbox 1-1 and STAXbox 1-2 dual train system to be operated under the same approved operating conditions, and requested the duplicate be added to the Executive Order; WHEREAS duplicate equipment can be added to an Executive Order after the equipment has been verified to be a duplicate, with the condition that the required in-use compliance testing is conducted with the in-use compliance test (including emissions) data submitted to CARB within 6 months or 30 vessel visits, whichever comes first; WHEREAS duplicate equipment must be identical to the equipment described in STAX’s Test Plan submitted on December 18, 2024.

WHEREAS the following in-use compliance tests must be conducted on each duplicate equipment within 6 months or 30 vessel visits, whichever comes first, after the date that the duplicate equipment is approved and added to the Executive Order: 1) Third-party source testing at one load point following the requirements of section 93130.5(g) of the 2020 At Berth Regulation with Relative Accuracy Test Audit (RATA) testing; 2) Third-party capture efficiency testing at one load point; 3) Durability testing on a minimum of 5 vessels and a minimum of 200 hours;
WHEREAS for systems approved for use on multiple vessel types (such as container, ro-ro, and/or tanker vessels) for auxiliary engines, the in-use compliance testing requirements outlined above shall only be conducted on one selected approved vessel type, based on the earliest applicable in-use compliance deadline, to avoid duplicative testing across vessel types;
WHEREAS for dual train systems, each of the two STAXboxes (trains) must complete all of the in-use compliance testing outlined above.

WHEREAS in-use compliance third-party source testing must be conducted for all pollutants listed in section 93130.5 (g) of the 2020 At Berth Regulation, and all testing must follow the test methods specified in section 93130.5 (g) and in STAX’s Test Plan submitted on December 18, 2024;
WHEREAS duplicate equipment will be removed from the Executive Order if the required testing is not submitted to CARB within 6 months or 30 vessel visits, whichever comes first, after the date that the duplicate equipment is approved and added to the Executive Order; WHEREAS duplicate equipment may require additional testing or be removed from the Executive Order if, after CARB evaluates the test data, CARB determines that the in-use Executive Order G-25-200-001 4
compliance test data demonstrates the system achieves emission rates greater than those specified in section 93130.5(d) of the 2020 At Berth Regulation; WHEREAS during the in-use compliance period, all requirements of the Executive Order must be followed, including all malfunction reporting and recordkeeping requirements.

Failure to comply with the requirements of the Executive Order, including section 93130.12 of the 2020 At Berth Regulation, will cause the equipment to be removed from the Executive Order and the approved equipment list;
WHEREAS STAX requested the STAXbox system(s) listed in addition to the STAXbox 1-1 and STAXbox 1-2 dual train system in Attachment 1 to be approved as duplicate equipment under this Executive Order and submitted information for CARB to verify the systems are duplicates of the STAXbox 1-1 and STAXbox 1-2 dual train system; WHEREAS the Executive Officer finds it is appropriate to issue this Executive Order that identifies the operating conditions, recordkeeping, and monitoring requirements for STAX’s use of the STAXbox to allow its use as a CAECS for compliance with the 2020 At Berth Regulation;
WHEREAS this approval does not constitute an air pollution or land use permit, nor does it relieve the responsibility of STAX or the end user to comply with all Federal, State, and local laws, rules, and regulations;
NOW, THEREFORE, IT IS ORDERED that the STAXbox is approved for use in demonstrating compliance with the 2020 At Berth Regulation as a CAECS, when used by STAX as intended and in accordance with the following terms and conditions, and in accordance with all other applicable requirements in the 2020 At Berth Regulation.

The approved STAXbox system(s) (Approved Equipment) and the vessel and engine types for which the STAXbox system(s) are approved to control can be found in Attachment 1 of this Executive Order.

APPROVAL OF DUPLICATE EQUIPMENT
BE IT FURTHER ORDERED, the duplicate STAXbox system(s) listed as Approved Equipment in Attachment 1 of this Executive Order are approved as verified duplicates of the approved STAXbox 1-1 and STAXbox 1-2 dual train system described in STAX’s Test Plan submitted on December 18, 2024, and may be used pursuant to the terms and conditions of this Executive Order on the vessels and engine types as provided in Attachment 1.

Executive Order G-25-200-001 5

APPROVED OPERATING CONDITIONS
Parameter Value
Ocean-going vessel engine type
Approved operating modes for STAXboxes on
ocean‑going tanker vessels:
• One STAXbox controlling one auxiliary
engine,
• Two STAXboxes operating simultaneously in
dual‑train mode, each controlling one
auxiliary engine,
• One STAXbox using a “Y” manifold to
control two auxiliary engines while the other
STAXbox is not in operation, or
• One STAXbox using a “Y” manifold to
control two auxiliary engines while the other
STAXbox controls one auxiliary engine.

Only one STAXbox may use a “Y” manifold at a time,
and the maximum number of auxiliary engines
controlled between both STAXboxes is three.

Ocean-going vessel type Tanker vessel
Ocean-going vessel fuel composition limitation
Marine distillate fuel meeting 0.1% sulfur content
limit (0.1% sulfur marine gas oil (MGO) or marine
diesel oil (MDO))
SCR inlet operating temperature range in degrees
Fahrenheit (⁰F) 600 – 720⁰F
Ocean-going vessel engine maximum continuous
rating (MCR) in kilowatts (kW) 1056 kW per STAXbox
Ocean-going vessel allowable operating range (kW)
for one engine per STAXbox 207 kW to 671 kW
Allowable exhaust flow rate in standard cubic feet
per minute (scfm) for one engine per STAXbox 2,106 to 5134 scfm of engine exhaust Ocean‑going vessel total allowable operating range
combined for two engines (kW) per STAXbox when
using the “Y” manifold
257 to 1087 kW
Allowable exhaust flow rate for two engines in
standard cubic feet per minute (scfm) per STAXbox
when using the “Y” manifold
2938 to 7325 scfm of engine exhaust
Maximum engine exhaust temperature requirements 1,000⁰F Static Pressure Differential pressure between -2 to -20 inches of water across the diesel particulate filter
Other parameters that affect performance 1-2 inches of water back pressure at the capture system inlet
Executive Order G-25-200-001 6
Parameter Value
GRID Neutral Target – CA CO2e state output
emission rate from eGRID2023 in pounds per
megawatt hour (lb/MWh)
394.8 lb/MWh
Maximum CAECS auxiliary generator operating load
(kW) 320 kW
CAECS auxiliary generator renewable diesel carbon
intensity limit in grams of carbon dioxide equivalent
per megajoule of fuel (g CO2e/MJ)

22.18 g CO2e/MJ fuel
Maximum ammonia slip emissions in parts per
million by volume, dry basis (ppmdv) 5 ppmdv averaged over 60 minutes

BE IT FURTHER ORDERED, the CEMS parameters submitted to the Executive Officer must follow the parameters and measurement methods listed in STAX’s CEMS parameter list submitted on June 4, 2025.

Executive Order G-25-200-001 7
BE IT FURTHER ORDERED, within seven days of a vessel departure, STAX shall report to their vessel operator customers the information necessary for vessel operators to submit their visit information to CARB as required by section 93130.7(e)(4) of the 2020 At Berth Regulation, including the following:
1) Emissions control start date and time
2) Emission control end date and time
3) Details on any delays or interruptions while controlling emissions and the times that emission reductions were uncontrolled during the visit.

BE IT FURTHER ORDERED, STAX shall maintain the STAXbox in accordance with “Section 5. Maintenance” of STAX’s Test Plan.

Executive Order G-25-200-001 8
BE IT FURTHER ORDERED, a delay or interruption in emissions control caused by a malfunction is eligible for remediation for the hours of uncontrolled emissions only when CARB is notified by STAX according to the provisions of section 93130.12(c) of the 2020 At Berth Regulation.

BE IT FURTHER ORDERED, records made pursuant to section 93130.12 of the 2020 At Berth Regulation shall be kept for a minimum of five years, and STAX shall submit information to CARB according to section 93130.19 of the 2020 At Berth Regulation.

BE IT FURTHER ORDERED, this approval is subject to the following conditions:
• STAX must submit documentation, within 30 days upon request, to CARB showing STAXbox is being maintained and the maintenance schedule in “Section 5. Maintenance” of STAX’s Test Plan is being adhered to. • STAX must keep records, including purchase receipts, for a minimum of five years, for renewable diesel purchases demonstrating the fuel used on the STAXbox complies with the Approved Operating Conditions in this Executive Order. • STAX must inform the vessel operator of the STAXbox operating conditions and ensure the vessel is only operating one or two auxiliary engine(s) while the STAXbox(s) are controlling emissions.
• STAX must operate either one STAXbox to control a single auxiliary engine on a tanker vessel, or two STAXboxes operating simultaneously in dual-train mode to control two auxiliary engines on the same tanker vessel, where each STAXbox controls only one auxiliary engine.
• Delays or interruptions in emissions control caused by a malfunction, or when the operational requirements in section 93130.12 of the 2020 At Berth Regulation are not met may result in enforcement actions and ultimately revocation of the EO unless the visits are made compliant through use of the Remediation Fund or with a Vessel Incident Event (VIE) or Terminal Incident Event (TIE).

DESIGN CHANGES AND EXTENSIONS
BE IT FURTHER ORDERED, no changes are permitted to Xcraft or STAXbox design or approved operating parameters set forth in STAX’s application, test plan, and this Executive Order and its appendices, unless CARB is notified and approves in advance per section 93130.5(i)(2) of the 2020 At Berth Regulation. Design changes include changes to any part of the STAXbox system including the exhaust capture hood, ducting, control equipment, and deployment platform. The changes must be approved in writing by the Executive Officer and any applicable Certification Fees for the At Berth Regulation (California Code of Regulations, Title 13, Division 3, Chapter 16, Article 7, sections 2913 and 2914) must be paid before the modifications may be used for compliance with the 2020 At Berth Regulation. The Executive Officer may revoke this Executive Order, or approval of any Executive Order G-25-200-001 9
or all STAXbox system(s) listed as Approved Equipment in Attachment 1 of this Executive Order, if the system fails to demonstrate that the expected emissions reductions are being achieved or if the STAXbox design or approved operating parameters are changed without prior notification and approval by the Executive Officer. If a STAXbox system malfunctions and fails to achieve emissions reductions required by the 2020 At Berth Regulation while performing with the same design, conditions, and requirements approved for the original approved system, the Executive Officer may revoke its approval of the duplicate system, remove it from the Executive Order, and/or require additional testing requirements if necessary.

BE IT FURTHER ORDERED, this Executive Order shall have a duration of five years from the date G-25-200 was executed (July 29, 2025), unless it is revoked by CARB as set forth in section 93130.5(l) of the 2020 At Berth Regulation. As specified in section 93130.5(i)(1), at least six months prior to the expiration of this Executive Order, STAX may apply for an extension by submitting an extension application to the Executive Officer asserting that the strategy has not changed and is still effective, following the requirements specified in section 93130.5(d) as provided in section 93130.5(i)(1) of the 2020 At Berth Regulation, after paying any applicable Certification Fees for the At Berth Regulation (California Code of Regulations, Title 13, Division 3, Chapter 16, Article 7, sections 2913 and 2914).

BE IT FURTHER ORDERED, this Executive Order does not relieve STAX from complying with all other applicable regulations.

BE IT FURTHER ORDERED, this Executive Order may be revoked if the Executive Officer determines that STAXbox does not comply with any of the requirements in this Executive Order.

Executive Order EO G-25-200 is hereby superseded and is of no further force and effect.

Executed at Sacramento, California, this 19th day of March 2026. ______________________________
Bonnie Soriano, Branch Chief
Freight Activity Branch
Transportation and Toxics Division
Attachment 1: Approved Equipment List
Executive Order G-25-200-001 10
Attachment 1: Approved Equipment List
Barge STAXbox Ocean-going
Vessel Type
Ocean-going
Vessel Engine
Type**
Capture
Hood Type
In-Use Compliance
Testing*
Xcraft-1 STAXbox 1-1 Tanker vessel One or two
auxiliary engines
Flex duct or
“Y” manifold
Original STAXbox system
approved, and not a
duplicate. No requirement.

Xcraft-1 STAXbox 1-2 Tanker vessel One or two
auxiliary engines
Flex duct or
“Y” manifold
Original STAXbox system
approved, and not a
duplicate. No requirement.

Xcraft-5 STAXbox 5-1 Tanker vessel One or two
auxiliary engines
Flex duct or
“Y” manifold
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.

Xcraft-5 STAXbox 5-2 Tanker vessel One or two
auxiliary engines
Flex duct or
“Y” manifold
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.

Xcraft-6 STAXbox 6-1 Tanker vessel One or two
auxiliary engines
Flex duct or
“Y” manifold
Test data must be submitted
to CARB within 30 vessel
visits or by
September 19, 2026,
whichever comes first.

Xcraft-6 STAXbox 6-2 Tanker vessel One or two
auxiliary engines
Flex duct or
“Y” manifold
Test data must be submitted
to CARB within 30 vessel
visits or by
September 19, 2026,
whichever comes first.

Xcraft-7 STAXbox 7-1 Tanker vessel One or two
auxiliary engines
Flex duct or
“Y” manifold
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.

Xcraft-7 STAXbox 7-2 Tanker vessel One or two
auxiliary engines
Flex duct or
“Y” manifold
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.

Xcraft-8 STAXbox 8-1 Tanker vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.***
Executive Order G-25-200-001 11
Barge STAXbox Ocean-going
Vessel Type
Ocean-going
Vessel Engine
Type**
Capture
Hood Type
In-Use Compliance
Testing*
Xcraft-8 STAXbox 8-2 Tanker vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.***
*Consistent with the terms and conditions of the Executive Order, duplicate equipment listed in Attachment 1 may be used for compliance with the At Berth Regulation. Duplicate equipment remains eligible for use under this Executive Order unless or until removed from Attachment 1.
**Consistent with the terms and conditions of the Executive Order, STAX is approved to operate either one STAXbox to control a single auxiliary engine on a tanker vessel, two STAXboxes operating simultaneously in dual-train mode to control two auxiliary engines on the same tanker vessel, where each STAXbox controls only one auxiliary engine, one STAXbox using a “Y” manifold to control two auxiliary engines while the other STAXbox is not in operation, or one STAXbox using a “Y” manifold to control two auxiliary engines while the other STAXbox controls one auxiliary engine.
*** STAX requested that STAXbox 8-1 and STAXbox 8-2 be removed from this Executive Order on November 12, 2025. STAXbox 8-1 and STAXbox 8-2 are no longer approved for use on tanker vessels. Before they can be used on tanker vessels, STAX must reapply and request that STAXbox 8-1 and STAXbox 8-2 be added to this Executive Order.

Executive Order G-25-200 1
State of California

AIR RESOURCES BOARD
Executive Order G-25-200
CARB Approval of the STAXbox system used to control emissions from tanker vessels for compliance with the Control Measure for Ocean-Going Vessels At Berth STAX Engineering (STAX)
STAXbox
WHEREAS August 27, 2020, the California Air Resource Board (CARB) adopted the Control Measure for Ocean Going Vessels (OGV) At Berth, California Code of Regulations, sections 93130-93130.22 (2020 At Berth Regulation), which establishes requirements for oceangoing vessels at berth in a California port to reduce oxides of nitrogen (NOx), diesel particulate matter (PM), and reactive organic gases (ROG) emissions from auxiliary engines; WHEREAS section 93130.5 of the 2020 At Berth Regulation establishes requirements for an emission control strategy to qualify as a CARB Approved Emission Control Strategy (CAECS) that can be used to reduce emissions from ocean-going vessel auxiliary engines and applicable tanker auxiliary boilers while at berth in a California port; WHEREAS no emission control strategy may be used to comply with the requirements of the 2020 At Berth Regulation unless CARB approves it as a CAECS; WHEREAS the 2020 At Berth Regulation requires that the emission control strategy, if applicable for auxiliary engines, achieves emission rates of less than 2.8 grams per kilowatt hour (g/kW-hr) for NOx, 0.03 g/kW-hr for PM 2.5, and 0.1 g/kW-hr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS for strategies approved after 2020, greenhouse gas (GHG) emissions from the strategy must be grid-neutral using the grid emission rate for the year that the technology is granted an Executive Order, as specified under section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS the 2020 At Berth Regulation requires that the emission control strategy, if applicable for tanker auxiliary boilers, achieves emission rates less than 0.4 g/kWhr for NOx,

0.03 g/kWhr for PM 2.5, and 0.02 g/kWhr for ROG demonstrated through testing conducted under a CARB approved Test Plan as specified in section 93130.5(d) of the 2020 At Berth Regulation;
WHEREAS STAX is subject to the 2020 At Berth Regulation as a CAECS operator; WHEREAS STAX developed STAXbox, a barge-based capture and control system to reduce emissions from the auxiliary engines on an ocean-going tanker vessel while at berth; Executive Order G-25-200 2
WHEREAS, STAXbox consists of the following components and subcomponents as specified in the Description of Control Strategy in “Test Plan: STAXbox Emissions Control System” (Test Plan) dated December 18, 2024, including: an exhaust capture system using flexible ducting, and an emission control system comprising of a particulate filter and Selective Catalytic Reduction (SCR) unit to reduce NOx, PM, and ROG; WHEREAS, STAXbox, also known as the control unit or train, is the emission control system, and Xcraft is the barge. Xcraft-1 barge includes two STAXboxes (STAXbox 1-1 and STAXbox 1-2), where each STAXbox controls one auxiliary engine.

WHEREAS the Xcraft barge can operate either one STAXbox to control one auxiliary engine or both STAXboxes simultaneously to control two auxiliary engines, a configuration known as dual-train operation.

WHEREAS STAX manufactured additional equipment that is a duplicate of the STAXbox 1-1 and STAXbox 1-2 dual train system to be operated under the same approved operating conditions, and requested the duplicate be added to the Executive Order; WHEREAS duplicate equipment can be added to an Executive Order after the equipment has been verified to be a duplicate, with the condition that the required in-use compliance testing is conducted with the in-use compliance test (including emissions) data submitted to CARB within 6 months or 30 vessel visits, whichever comes first; WHEREAS duplicate equipment must be identical to the equipment described in STAX’s Test Plan submitted on December 18, 2024.

WHEREAS in-use compliance third-party source testing must be conducted for all pollutants listed in section 93130.5 (g) of the 2020 At Berth Regulation, and all testing must follow the test methods specified in section 93130.5 (g) and in STAX’s Test Plan submitted on December 18, 2024;
WHEREAS duplicate equipment will be removed from the Executive Order if the required testing is not submitted to CARB within 6 months or 30 vessel visits, whichever comes first, after the date that the duplicate equipment is approved and added to the Executive Order; WHEREAS duplicate equipment may require additional testing or be removed from the Executive Order if, after CARB evaluates the test data, CARB determines that the in-use compliance test data demonstrates the system achieves emission rates greater than those specified in section 93130.5(d) of the 2020 At Berth Regulation; WHEREAS during the in-use compliance period, all requirements of the Executive Order must be followed, including all malfunction reporting and recordkeeping requirements.

Failure to comply with the requirements of the Executive Order, including section 93130.12 of the 2020 At Berth Regulation, will cause the equipment to be removed from the Executive Order and the approved equipment list;
WHEREAS STAX requested the STAXbox system(s) listed in addition to the STAXbox 1-1 and STAXbox1-2 dual train system in Attachment 1 to be approved as duplicate equipment under this Executive Order and submitted information for CARB to verify the systems are duplicates of the STAXbox 1-1 and STAXbox1-2 dual train system; WHEREAS the Executive Officer finds it is appropriate to issue this Executive Order that identifies the operating conditions, recordkeeping, and monitoring requirements for STAX’s use of the STAXbox to allow its use as a CAECS for compliance with the 2020 At Berth Regulation;
WHEREAS this approval does not constitute an air pollution or land use permit, nor does it relieve the responsibility of STAX or the end user to comply with all Federal, State, and local laws, rules, and regulations;
NOW, THEREFORE, IT IS ORDERED that the STAXbox is approved for use in demonstrating compliance with the 2020 At Berth Regulation as a CAECS, when used by STAX as intended and in accordance with the following terms and conditions, and in accordance with all other applicable requirements in the 2020 At Berth Regulation.

Executive Order G-25-200 4
The approved STAXbox system(s) (Approved Equipment) and the vessel and engine types for which the STAXbox system(s) are approved to control can be found in Attachment 1 of this Executive Order.

APPROVAL OF DUPLICATE EQUIPMENT
BE IT FURTHER ORDERED, the duplicate STAXbox system(s) listed as Approved Equipment in Attachment 1 of this Executive Order are approved as verified duplicates of the approved STAXbox 1-1 and STAXbox 1-2 dual train system described in STAX’s Test Plan submitted on December 18, 2024, and may be used pursuant to the terms and conditions of this Executive Order on the vessels and engine types as provided in Attachment 1.

APPROVED OPERATING CONDITIONS
Parameter Value
Ocean-going vessel engine type
One auxiliary engine per STAXbox, either by
operating a single STAXbox individually or by
operating two STAXbox simultaneously in dual-train
mode on the same tanker vessel
Ocean-going vessel type Tanker vessel
Ocean-going vessel fuel composition limitation
Marine distillate fuel meeting 0.1% sulfur content
limit (0.1% sulfur marine gas oil (MGO) or marine
diesel oil (MDO))
SCR inlet operating temperature range in degrees
Fahrenheit (⁰F) 600 – 720⁰F
Ocean-going vessel engine maximum continuous
rating (MCR) in kilowatts (kW) 1056 kW per STAXbox
Ocean-going vessel allowable operating range (kW)
per STAXbox 207 kW to 671 kW
Allowable exhaust flow rate in standard cubic feet
per minute (scfm) per STAXbox 2,106 to 5134 scfm of engine exhaust Maximum engine exhaust temperature requirements 1,000⁰F Static Pressure Differential pressure between -2 to -20 inches of water across the diesel particulate filter
Other parameters that affect performance 1-2 inches of water back pressure at the capture system inlet
Executive Order G-25-200 5
Parameter Value
GRID Neutral Target – CA CO2e state output
emission rate from eGRID2023 in pounds per
megawatt hour (lb/MWh)
394.8 lb/MWh
Maximum CAECS auxiliary generator operating load
(kW) 320 kW
CAECS auxiliary generator renewable diesel carbon
intensity limit in grams of carbon dioxide equivalent
per megajoule of fuel (g CO2e/MJ)

22.18 g CO2e/MJ fuel
Maximum ammonia slip emissions in parts per
million by volume, dry basis (ppmdv) 5 ppmdv averaged over 60 minutes

BE IT FURTHER ORDERED, the CEMS parameters submitted to the Executive Officer must follow the parameters and measurement methods listed in STAX’s CEMS parameter list submitted on June 4, 2025.

Executive Order G-25-200 6
BE IT FURTHER ORDERED, within seven days of a vessel departure, STAX shall report to their vessel operator customers the information necessary for vessel operators to submit their visit information to CARB as required by section 93130.7(e)(4) of the 2020 At Berth Regulation, including the following:
1) Emissions control start date and time
2) Emission control end date and time
3) Details on any delays or interruptions while controlling emissions and the times that emission reductions were uncontrolled during the visit.

BE IT FURTHER ORDERED, STAX shall maintain the STAXbox in accordance with “Section 5. Maintenance” of STAX’s Test Plan.

Executive Order G-25-200 7
BE IT FURTHER ORDERED, a delay or interruption in emissions control caused by a malfunction is eligible for remediation for the hours of uncontrolled emissions only when CARB is notified by STAX according to the provisions of section 93130.12(c) of the 2020 At Berth Regulation.

DESIGN CHANGES AND EXTENSIONS
BE IT FURTHER ORDERED, no changes are permitted to Xcraft or STAXbox design or approved operating parameters set forth in STAX’s application, test plan, and this Executive Order and its appendices, unless CARB is notified and approves in advance per section 93130.5(i)(2) of the 2020 At Berth Regulation. Design changes include changes to any part of the STAXbox system including the exhaust capture hood, ducting, control equipment, and deployment platform. The changes must be approved in writing by the Executive Officer and any applicable Certification Fees for the At Berth Regulation (California Code of Regulations, Title 13, Division 3, Chapter 16, Article 7, sections 2913 and 2914) must be paid before the modifications may be used for compliance with the 2020 At Berth Regulation. The Executive Officer may revoke this Executive Order, or approval of any Executive Order G-25-200 8
or all STAXbox system(s) listed as Approved Equipment in Attachment 1 of this Executive Order, if the system fails to demonstrate that the expected emissions reductions are being achieved or if the STAXbox design or approved operating parameters are changed without prior notification and approval by the Executive Officer. If a STAXbox system malfunctions and fails to achieve emissions reductions required by the 2020 At Berth Regulation while performing with the same design, conditions, and requirements approved for the original approved system, the Executive Officer may revoke its approval of the duplicate system, remove it from the Executive Order, and/or require additional testing requirements if necessary.

BE IT FURTHER ORDERED, this Executive Order shall have a duration of five years from the date it was executed, unless it is revoked by CARB as set forth in section 93130.5(l) of the 2020 At Berth Regulation. As specified in section 93130.5(i)(1), at least six months prior to the expiration of this Executive Order, STAX may apply for an extension by submitting an extension application to the Executive Officer asserting that the strategy has not changed and is still effective, following the requirements specified in section 93130.5(d) as provided in section 93130.5(i)(1) of the 2020 At Berth Regulation, after paying any applicable Certification Fees for the At Berth Regulation (California Code of Regulations, Title 13, Division 3, Chapter 16, Article 7, sections 2913 and 2914).

BE IT FURTHER ORDERED, this Executive Order does not relieve STAX from complying with all other applicable regulations.

BE IT FURTHER ORDERED, this Executive Order may be revoked if the Executive Officer determines that STAXbox does not comply with any of the requirements in this Executive Order.

Executed at Sacramento, California, this 29th day of July 2025. ______________________________
Bonnie Soriano, Branch Chief
Freight Activity Branch
Transportation and Toxics Division
Attachment 1: Approved Equipment List
Executive Order G-25-200 9
Attachment 1: Approved Equipment List
Barge STAXbox Ocean-going
Vessel Type
Ocean-going
Vessel Engine
Type**
Capture
Hood Type
In-Use Compliance
Testing*
Xcraft-1 STAXbox 1-1 Tanker vessel One auxiliary
engine Flex duct
Original STAXbox system
approved, and not a
duplicate. No requirement.

Xcraft-1 STAXbox 1-2 Tanker vessel One auxiliary
engine Flex duct
Original STAXbox system
approved, and not a
duplicate. No requirement.

Xcraft-5 STAXbox 5-1 Tanker vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.

Xcraft-5 STAXbox 5-2 Tanker vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.

Xcraft-7 STAXbox 7-1 Tanker vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.

Xcraft-7 STAXbox 7-2 Tanker vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.

Xcraft-8 STAXbox 8-1 Tanker vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.

Xcraft-8 STAXbox 8-2 Tanker vessel One auxiliary
engine Flex duct
Test data must be submitted
to CARB within 30 vessel
visits or by January 29, 2026,
whichever comes first.
*Consistent with the terms and conditions of the Executive Order, duplicate equipment listed in Attachment 1 may be used for compliance with the At Berth Regulation. Duplicate equipment remains eligible for use under this Executive Order unless or until removed from Attachment 1.

Executive Order G-25-200 10
**Consistent with the terms and conditions of the Executive Order, STAX is approved to operate either one STAXbox to control a single auxiliary engine on a tanker vessel, or two STAXboxes operating simultaneously in dual-train mode to control two auxiliary engines on the same tanker vessel, where each STAXbox controls only one auxiliary engine.

Financial Statement
Independent auditor's report evidencing STAX's capacity to fund tenant improvements, operations, insurance, and lease
obligations without Port funding.

Proposal for the Lease, Development, and Operation of Basin 4 • Point Potrero Marine Terminal STAX ENGINEERING, LLC Proposal • Lease, Development & Operation of Basin 4

APPENDIX
Point Potrero Marine Terminal
STAX HOLDING INC.

CONSOLIDATED FINANCIAL STATEMENTS
DECEMBER 31, 2025
1 INDEPENDENT AUDITOR’S REPORT
To the Board of Directors of
STAX Holding Inc.

California
Opinion
We have audited the accompanying consolidated financial statements of STAX Holding Inc. (the “Company”), which comprise the consolidated balance sheet as of December 31, 2025, and the related consolidated statements of operations, changes in stockholders’ deficit, and cash flows for the year then ended, and the related notes to the consolidated financial statements.

In our opinion, the consolidated financial statements referred to above present fairly, in all material respects, the financial position of the Company as of December 31, 2025, and the results of their operations and their cash flows for the year then ended in accordance with accounting principles generally accepted in the United States of America.

Basis for Opinion
We conducted our audits in accordance with auditing standards generally accepted in the United States of America. Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the Consolidated Financial Statements section of our report. We are required to be independent of the Company and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements relating to our audits. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

Responsibilities of Management for the Consolidated Financial Statements Management is responsible for the preparation and fair presentation of the consolidated financial statements in accordance with accounting principles generally accepted in the United States of America, and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of consolidated financial statements that are free from material misstatement, whether due to fraud or error. In preparing the consolidated financial statements, management is required to evaluate whether there are conditions or events, considered in the aggregate, that raise substantial doubt about the Company’s ability to continue as a going concern within one year after the date the consolidated financial statements are available to be issued.

Auditor’s Responsibilities for the Audit of the Consolidated Financial Statements Our objectives are to obtain reasonable assurance about whether the consolidated financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor's report that includes our opinion. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with generally accepted auditing standards will always detect a material misstatement when it exists. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from To the Board of Directors of
STAX Holding Inc.
2 error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Misstatements are considered material if there is a substantial likelihood that, individually or in the aggregate, they would influence the judgment made by a reasonable user based on the consolidated financial statements.

In performing an audit in accordance with generally accepted auditing standards, we:
 Exercise professional judgment and maintain professional skepticism throughout the audit.  Identify and assess the risks of material misstatement of the consolidated financial statements, whether due to fraud or error, and design and perform audit procedures responsive to those risks.

Such procedures include examining, on a test basis, evidence regarding the amounts and disclosures in the consolidated financial statements.
 Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the Company's internal control. Accordingly, no such opinion is expressed.  Evaluate the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluate the overall presentation of the consolidated financial statements.
 Conclude whether, in our judgment, there are conditions or events, considered in the aggregate, that raise substantial doubt about the Company's ability to continue as a going concern for a reasonable period of time.

We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control related matters that we identified during the audit.

MILLER KAPLAN ARASE LLP
Burbank, California
June 4, 2026

ANY PROPRIETOR/PARTNER/EXECUTIVE
OFFICER/MEMBER EXCLUDED?

INSR ADDL SUBR

LTR INSD WVD

DATE (MM/DD/YYYY)

PRODUCER CONTACT
NAME:

PHONE FAX
(A/C, No, Ext): (A/C, No):

E-MAIL
ADDRESS:

INSURER A :

INSURED INSURER B :

INSURER C :

INSURER D :

INSURER E :

INSURER F :

POLICY NUMBER POLICY EFF POLICY EXP TYPE OF INSURANCE (MM/DD/YYYY) (MM/DD/YYYY) LIMITS

AUTOMOBILE LIABILITY

UMBRELLA LIAB

EXCESS LIAB

WORKERS COMPENSATION

AND EMPLOYERS' LIABILITY
DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES (ACORD 101, Additional Remarks Schedule, may be attached if more space is required)

AUTHORIZED REPRESENTATIVE
EACH OCCURRENCE $
DAMAGE TO RENTED CLAIMS-MADE OCCUR PREMISES (Ea occurrence) $ MED EXP (Any one person) $
PERSONAL & ADV INJURY $
GEN'L AGGREGATE LIMIT APPLIES PER: GENERAL AGGREGATE $
PRO- POLICY JECT LOC PRODUCTS - COMP/OP AGG $
OTHER: $
COMBINED SINGLE LIMIT $ (Ea accident)
ANY AUTO BODILY INJURY (Per person) $
OWNED SCHEDULED BODILY INJURY (Per accident) $ AUTOS ONLY AUTOS HIRED NON-OWNED PROPERTY DAMAGE $ AUTOS ONLY AUTOS ONLY (Per accident) $
OCCUR EACH OCCURRENCE $
CLAIMS-MADE AGGREGATE $
DED RETENTION $ $

PER OTH- STATUTE ER
E.L. EACH ACCIDENT $
E.L. DISEASE - EA EMPLOYEE $
E.L. DISEASE - POLICY LIMIT $ If yes, describe under
DESCRIPTION OF OPERATIONS below
INSURER(S) AFFORDING COVERAGE NAIC #

COMMERCIAL GENERAL LIABILITY
Y / N
N / A
(Mandatory in NH)

SHOULD ANY OF THE ABOVE DESCRIBED POLICIES BE CANCELLED BEFORE

THE EXPIRATION DATE THEREOF, NOTICE WILL BE DELIVERED IN ACCORDANCE WITH THE POLICY PROVISIONS.

THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED. NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS

CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.

THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER. THIS

CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.

IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed.

If SUBROGATION IS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).

COVERAGES CERTIFICATE NUMBER: REVISION NUMBER:

ACORD 25 (2016/03) The ACORD name and logo are registered marks of ACORD

CERTIFICATE OF LIABILITY INSURANCE
Lockton Companies, LLC
DBA Lockton Insurance Brokers, LLC in CA
CA license #0F15767
8110 E Union Ave., Ste. 100
Denver CO 80237
[email protected]
STAX Holding, Inc.
and its subsidiaries
215 West Figueroa Street
Floor 2
Santa Barbera, CA 93101 Great American Assurance Company 26344 Beazley Insurance Company, Inc. 37540
Endurance American Insurance Company 10641
Starr Indemnity & Liability Company 38318
American Longshore Mutual Association
--- SEE ATTACHMENT ---
X
X
1,000,000
100,000
5,000
1,000,000
2,000,000
1,000,000

XXXXXXX

XXXXXXX
X
X
4,000,000

XXXXXXX

XXXXXXX
N
X
1,000,000
1,000,000
1,000,000
Pollution
Hull & Mach/P&I
$10M
See attachment; P&I: $1M
A MASILSF00601425 (60%) 3/22/2025 3/22/2026
B OML30083010400 (25%) 3/22/2025 3/22/2026
C V39398250101 (15%) 3/22/2025 3/22/2026
D See Attachment 3/22/2025 3/22/2026
D See Attached 3/22/2025 3/22/2026
E WCE832401 03 3/22/2025 3/22/2026
F ALMA-032222-065916-04 3/22/2025 3/22/2026

NOT APPLICABLE
3/22/2026
1543261
Y N
N N
N
4/4/2025
Y N
21434464
21434464 XXXXXXX
Acquiom Agency Services LLC,
as Notes Representative
Attn: Shon McCraw-Davis
950 17th St Suite 1400
Denver CO 80202
THIS CERTIFICATE SUPERSEDES ALL PREVIOUSLY ISSUED CERTIFICATES FOR THIS HOLDER, APPLICABLE TO THE CARRIERS LISTED AND THE POLICY TERM(S) REFERENCED.

Pollution Liability Policy #: V-17687-25 Carrier: Safe Harbor Pollution Insurance - Policy Term: 03/22/2025 - 03/22/2026 - Limit: $10,000,000.

Mortgagee Interest Insurance / Mortgagee Additional Perils Pollution Policy #: MACR2510004350-01, SE25CFTZ0CAGC03/SE25LIAZ0CAGC04, OPK30084862900 Carrier: Ascot Insurance Company (50%) Navigators Insurance Co. (25%) Endurance Risk Solutions Assurance Co. (25%) - Policy Term: 4/4/2025 - 3/22/2026 - Limit: $20M RE: Acquiom Agency Services LLC is/are Additional Insured on the General Liability, Vessel Pollution, and Protection and Indemnity policies with respect to liability arising out of the operations of the insured and to the extent provided by the policy language or endorsement issued or approved by the insurance carrier. Acquiom Agency Services LLC is/are included as Lender's Loss Payee on the Hull & Machinery policy.

X
See Attachments

ADDENDUM TO CERTIFICATE OF INSURANCE
STAX Holding, Inc. and its subsidiaries 2025-2026
COVERAGE CARRIER POLICY NO. POLICY TERM
Hull & Machinery /
Protection & Indemnity
Endurance American
Insurance Company (25%)
Starr Indemnity and Liability
Company (25%)
Liberty Mutual Insurance Company (20%)
Starstone National Insurance Company (20%)
Hartford (10%)
OBR10015280203
MASIHSF00813725
LIUH-00469-04
MAR00288411P-01
SE25CFTZ0CAGC02
03/22/2025 – 03/22/2026
Attachment Code: D648234 Master ID: 1543261, Certificate ID: 21434464 Vessel Schedule
2024-2025
Vessel: H&M /War
Insured Value
H&M Deductible P&I Limit P&I Deductible
$62,500 $1,000,000 $10,000
$15,000 $2,500
STAX-4 $7,462,856 $62,500 $1,000,000 $10,000
$1,000,000 $5,000
STAX-5 $7,462,856 $62,500 $1,000,000 $10,000
$62,500 $1,000,000
STAX-6 $1,000,000 $10,000 $1,000,000 $10,000
STAX-2 $7,462,856
STAX-7 $1,000,000 $10,000 $1,000,000 $10,000
$62,500 $1,000,000
STAX-8 $1,000,000 $10,000 $1,000,000 $10,000
$10,000
$10,000
Skiff – Boston Outrage 20 $16,000 $2,500 $1,000,000 $5,000 STAX-1
Boston Whaler
Skiff – Boston Outrage 22 $16,000 $2,500 $1,000,000 $5,000 $15,000 $2,500
Skiff – Westerly Duffy $12,000 $2,500 $1,000,000 $5,000 $1,000,000 $5,000
Skiff - Wellcat $11,000 $2,500 $1,000,000 $5,000
$7,462,856
Boston Whaler
Skiff – Inmar 550R PT $51,392 $2,500 $1,000,000 $5,000
STAX-3
Total: $40,450,672
$7,462,856
Attachment Code: D648234 Master ID: 1543261, Certificate ID: 21434464 Acquiom Agency Services LLC, as Notes Representative Attn: Shon McCraw-Davis 950 17th St Suite 1400
Denver CO 80202
To whom it may concern:

In our continuing effort to provide timely certificate delivery, Lockton Companies is transitioning to paperless delivery of Certificates of Insurance, thus this is your final hard-copy delivery.

To ensure electronic delivery for future renewals of this certificate, we need your email address. Please contact us via one of the methods below, referencing Certificate ID 21434464.  Email: [email protected]  Phone: 303-728-8060
If you received this certificate through an internet link where the current certificate is viewable, we have your email and no further action is needed. In the event your mailing address has changed, will change in the future, or you no longer require this certificate, please let us know using one of the methods above. The above inbox and phone number is for automating electronic delivery of certificates only. Please do NOT send future certificate requests to this inbox or contact the phone number below with email updates.

Thank you for your cooperation and willingness in reducing our environmental footprint. Lockton Companies Lockton Companies
8110 E. Union Avenue, Suite 100
Denver, CO 80237
Attachment Code: D644713 Master ID: 1543261, Certificate ID: 21434464

ADDENDUM TO CERTIFICATE OF INSURANCE
STAX Holding, Inc. and its subsidiaries Excess Liability Policies 2024-2026 COVERAGE LIMIT CARRIER POLICY NO. POLICY TERM
1st Layer Excess Liability
$4,000,000
Navigators Insurance
Company (50%)
Starstone Specialty
Insurance Company
(25%)
Beazley Insurance
Company (25%)
SE25LIAZ0CAGC01
MAR00288412P-01
V394C7250101
03/22/2025 –
03/22/2026
COVERAGE LIMIT CARRIER POLICY NO. POLICY TERM
2nd Layer Excess Liability
$5,000,000
Endurance Risk
Solutions Assurance Co. (50%)
Starr Indemnity &
Liability Company
(50%)
OMX30048659602
MASILSF00647325
03/22/2025 –
03/22/2026
COVERAGE LIMIT CARRIER POLICY NO. POLICY TERM
3rd Layer Excess Liability*
*Applicable only to
Protection & Indemnity
and Vessel Pollution
$23,000,000
StarStone National
Insurance Co. (25%)
Beazley Insurance Co.
(25%)
Endurance Risk
Solutions Assurance Co
(25%)
Liberty Mutual
Insurance Co. (25%)
MAR00270310P-00
V38972240101
OMX30073930000
SFAC55M4001
12/1/2024 –
12/1/2025
Attachment Code: D658435 Certificate ID: 21434464

ADDENDUM TO CERTIFICATE OF INSURANCE
STAX Holding, Inc. and its subsidiaries
2025-2026
COVERAGE CARRIER POLICY NO. POLICY TERM
Mortgagee Interest
Insurance /
Mortgagee Additional Perils
Pollution /
Breach of Warranty
Ascot Insurance Company
(50%)
Navigators Insurance
Company (25%)
Endurance Risk Solutions
Assurance Co. (25%)
MACR2510004350-01
SE25CFTZ0CAGC03 (MII)
SE25LIAZ0CAGC04 (MAP)
OPK30084862900
4/4/2025 – 3/22/2026
Vessel Schedule
2025-2026
Vessel: Mortgagee Interest
Limit
Mortgagee Additional Perils Pollution
Limit
STAX-1
$20,000,000 $20,000,000
STAX-2
STAX-3
STAX-4
STAX-5
STAX-6
STAX-7
STAX-8

CITY OF RICHMOND
Sanctuary City Compliance Statement
The undersigned, Department Head of the Risk and Revenue Department (hereafter "Department"), has had an opportunity to review the requirements of City of Richmond Ordinance 12-18 (hereafter "Sanctuary City Contracting Ordinance" or “SCCO”). The Department understands and agrees that the City shall not knowingly enter into a new contract or agreement, nor amend or extend an existing contract or agreement with any Person or Entity that provides Data Broker or Extreme Vetting services to the U.S. Immigration and Customs Enforcement Division of the United States Department of Homeland Security (“ICE”). Department understands the meaning of the following terms used in the SCCO:
a. "Data Broker” means either of the following:
i. The collection of information, including personal information about consumers, from a wide variety of sources for the purposes of reselling such information to their customers, which include both private-sector business and government agencies; ii. The aggregation of data that was collected for another purpose from that for which it is ultimately used.
b. “Extreme Vetting” means data mining, threat modeling, predictive risk analysis, or other similar services."
Department understands that it shall not knowingly receive or retain a contract if at the time the Contract is executed, or at any time during the term of the Contract, the contractor provides Data Broker or Extreme Vetting services to ICE.

By executing this Statement, Department certifies that it has complied with the requirements of the SCCO during the 20XX Calendar Year. If at any time the Department ceases to comply, Department will promptly notify the City Manager in writing.

Based on the foregoing, the undersigned declares under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this day of , 20XX, at , California.

Department Head
Printed Name: Signature:

Name of Department: Date:

Department SCCO Compliance Statement (Augt2020)
Frank Strasheim
Risk and Revenue August 4, 2026

PO Box 5100
San Pedro, CA 90733-1301
Port Office (310) 549-8030
Shop (310) 835-5021
Fax (310) 835-3924
July 28, 2026
To Whom It May Concern,
It is my pleasure to recommend Stax Engineering as a tenant. They have occupied the warehouse at 327 Lakme Ave in Wilmington, CA since August 2024 and continue to lease the space today. Over that time, I have come to know them as a dependable and conscientious tenant, and I am glad to share my experience.

Stax Engineering has consistently met every obligation under their lease. Payments have always arrived in full and on schedule, and any questions or requests have been handled through clear, courteous communication. They have shown steady respect for the building, for their neighbors, and for the people who manage the property.

I would also point to the care they have invested in the space itself. During their tenancy they have carried out several improvements to the premises, completed to a professional standard and leaving the property in better shape than they found it.

The warehouse has remained clean, orderly, and well cared for under their occupancy. When maintenance issues have come up, they have flagged them promptly and responsibly, treating the space as if it were their own.

In short, Stax Engineering has been the kind of tenant any owner would hope for, and I recommend them wholeheartedly. I have no hesitation about the value they would bring to another property and would happily lease to them again. If it would be helpful to discuss further, I can be reached at (310) 994-2772 or [email protected].

Sincerely,
Kent M. Phillips
Chief Financial Officer
Letter of Recommendation for STAX Engineering and Frank Strasheim To Whom It May Concern:

I am pleased to provide this letter of recommendation for STAX Engineering and its Chief Risk and Revenue Officer, Mr. Frank Strasheim.

Olympus Terminals has worked closely with STAX Engineering for more than two years in support of vessel emissions control operations under California's At-Berth Regulation. During that time, STAX has successfully completed more than 100 Capture and Control Emissions Control System (CAECS) vessel calls at our facility.

Throughout our relationship, STAX has consistently demonstrated an unwavering commitment to safety, regulatory compliance, operational excellence, and customer service. They have performed every assignment safely and professionally, with no safety incidents, operational violations, or regulatory compliance issues. Equally important, STAX has maintained a perfect record of reliability, never missing a scheduled vessel operation.

Their team has been diligent in all aspects of execution, including operational planning, vessel coordination, communications, documentation, and regulatory reporting. Their attention to detail has helped ensure full compliance with California Air Resources Board (CARB) At-Berth requirements while providing confidence to terminal operators, vessel operators, and regulatory stakeholders alike.

Frank Strasheim has been an exceptional partner throughout our engagement. His professionalism, responsiveness, and commitment to customer success have contributed significantly to the successful execution of emissions capture operations at our facility. Frank and his team have consistently demonstrated a practical understanding of operational challenges while maintaining a strong focus on compliance, risk management, and service delivery.

Based on our experience, I can recommend STAX Engineering without reservation to any organization seeking a proven, reliable, and compliant emissions capture solution. Their track record of safety, operational performance, and regulatory excellence makes them a trusted partner in supporting environmental compliance and maritime emissions reduction initiatives.

Should you require any additional information regarding our experience with STAX Engineering, I would be pleased to discuss it further.

Sincerely,
Martin Graham
Chief Operating Officer
Olympus Terminals LLC
Long Beach, California

POST IN A CONSPICUOUS PLACE
215 W. Figueroa Street - NON TRANSFERABLE -
Santa Barbara CA 93101
Expires: 12-31-2026
Business tax is due yearly regardless if renewal notice is received. You are required by City Ordinance RMC 7.04 to have a valid Business Tax Certificate if your business is located in the City of Richmond, or if you perform work within the City.

Summary of Fees Paid
O Transportation, Trucking $1,164.00 eCheck
SB1186 $4.00 eCheck
New Business Application $35.00 eCheck
Receipt for Current License Fees
Receipt No: iMS1142456
Payment Date: 6/23/2026
Paid by: STAX Engineering LLC
Total Paid $1,203.00
Business Type: Class O
License 40069870
City of Richmond • 450 CIVIC CENTER PLAZA • RICHMOND, CA 94804 • (510) 620-6742

BUSINESS TAX CERTIFICATE
2026
Prepared in accordance to the Administrative Policy and Procedures manual POLICY NUMBER: AP 516

DETACH YOUR BUSINESS LICENSE TAX CERTIFICATE FROM ABOVE AND POST IN PUBLIC VIEW License 40069870 Effective Date 6/23/2026 To 12/31/2026 Owner(s)
STAX Holding Inc
215 W Figueroa St
Santa Barbara, CA 93101
STAX Holding Inc
215 W Figueroa St
Santa Barbara, CA 93101
This is not a Bill
For Information contact the City of Richmond Business Tax Office 450 CIVIC CENTER PLAZA • RICHMOND, CA 94804 • (510) 620-6742 www.ci.richmond.ca.us/bl IT-10-11
AP-08-99
STAX Engineering LLC
215 W Figueroa St
Santa Barbara, CA 93101
Business Mailing Address / Account: 40069870
STAX Engineering LLC

Richmond City CouncilSeptember 22, 2026

Richmond City Council
September 22, 2026