Circular No: 647 /2011

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istanbul & Marmara, Aegean, Mediterranean, Black Sea Regions CHAMBER OF SHIPPING Istanbul 13.12.2011 Our Reference : 4677 Subject : About Sulfur Content of Marine Fuels Circular No: 647 /2011 Re: (a)"the Regulation for Reducing Sulfur Ratio in Certain Types of Fuel" of the Ministry of Environment and Forestry, published in the Official Gazette no. 27368 dated 06.10.2009 (b) "The Regulation for Amending the Regulation for Reducing Sulfur Ratio in Certain Types of Fuel" of the Ministry of Environment and Forestry, published in the Official Gazette no. 27449 dated 31.12.2009 (quadruplicate) (c) The letter of the Ministry of Transport, Shipping and Communication, the Undersecretariat of Shipping, the General Directorate of Marine Transport ref. 34438 dated 07.12.2011. Please find enclosed the letter specified in Re (c) under the Regulation specified in Re(b) amended by Re(a), marine fuels with Sulfur content higher than 0.1% by mass shall not be used after January 1'12012 In internal water crafts and berthed ships In the maritime domains in Turkey; Ships passing the Turkish Straits without calling to Turkish Ports shall not be subject to the rule of using marine fuels with sulfur content not exceeding 0.1% by mass, as long as they proceed without calling to any Turkish Port; Ships with Turkish flag in SOx Emission Control Areas specified in the Regulation shall not use marine fuels with sulfur content higher than 1.5%; however, there are no SOx Emission Control Areas in Turkey for the time being; Similarly, all Passenger Boats sailing on regular voyages under the maritime line authorization of the ShippIng Administration shall be required to use marine fuels with Sulfur content not exceeding 1.5% on and after January 1st 2012; Inspections regarding the said regulations shall be made by the Shipping Administration and In the event of any nonconformity, the related provisions of the Environment Law 2872 shall apply. For your information. ANNEXES: Annex-l: Letter specified in Re(c) (2 pages) CC: For action: - All members (Web page) - Turkish Ship Owners Association - Limited Liable Ship Owners Motor Crafts Cooperative - Ship Owners and Agents Society - TURKLIM -IMEAK DTO Professional Committees No. 14, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 29, 30, 31, 32, 33, 36, 44, 45, 46, 47 - Ship Fuel Suppliers Society. Limited Liable Marine Tankers Fuel Transport Cooperative - All Agents For information: - Chairman of the Board and Directors - imeak DTO Environmental Commission IMEAK DTO Branches

The Republic of Turkey The Ministry of Transport, Shipping and Communication The Undersecretariat of Shipping Ref : B.02.01.DNM/0.06.14.01.143.01/34438 07.12.2011 Subject: Sulfur in Marine Fuels imeak CHAMBER OF SHIPPING ISTANBUL Re: a) "The Regulation for Reducing Sulfur Ratio in Certain Types of Fuel" effected after publishing in the Official Gazette no. 27368 dated October 6 th 2009 (b) "The Regulation for Amending the Regulation for Reducing Sulfur Ratio in Certain Types of Fuel" effected after publishing in the Official Gazette no. 27449 dated December 31 st 2009 (c) Our letter ref. 25963 dated 07.09.2011 (d) The letter of Lloyd's Register ref. 2301/EY/es/347 dated 11.11.201i. Detailed information has been requested with the letter specified in Re(d) on certain matters contained in our letter specified in Re(c). As will be understood in the related articles of Regulation(a) amended by Regulation(b), the obligation to use marine fuels with sulfur content not more than 0.1% by mass after January 1 st 2012 shall apply for "internal water crafts" and "berthed ships" In this Regulation, "internal water" covers "natural and artificial lakes, dam lakes, fisheries and rivers and "internal water craft" means all boats used for transporting passengers and cargo in internal waters and fishing boats." The term "berthed ships" is defined as "ships safely moored or anchored within the boundaries of a port during loading, discharging or accommodation activities or during periods of time past without any cargo operations. Consequently, every kind of boat and fishing boats operating in internal waters and all boats moored or anchored within port boundaries shall have to use bunkers with a maximum sulfur content of 0.1% after January 1 st 2012. In this context, the regulation stipulates that "ships must complete their bunker replacement operations within the shortest time possible after arrival at a port and as late as possible after departure from a port." As will be understood from Article 2 - "Scope" of the said Regulation, the stipulations in the Regulation shall apply at "maritime domains or in defined pollution control areas." Also, as will be understood from this Article of the Regulation, "bunkers used by warships and ships used for military purposes are excluded from the scope of the Regulation. Ships arriving at Turkish ports and ships anchored at anchorages shall be subject to the rule of using bunkers with a maximum sulfur content of 0.1% by mass, excluding paragraph 2 of Article 7 of the said Regulation, during loading, discharging or accommodation activities or during periods of time they are safely berthed or anchored without any cargo operations. In this context, the obligation of berthed ships to use bunkers with a maximum sulfur content of 0.1% by mass shall not apply if the ship in question is or should be berthed for less than two hours according to the published tariff.

The Republic of Turkey The Ministry of Transport, Shipping and Communication The Undersecretariat of Shipping The General Directorate of Marine Transport However, ships passing Turkish Straits without calling to Turkish Ports shall not be subject to the rule of using bunkers with sulfur content not exceeding 0.1% by mass, as long as they proceed without calling to any Turkish Port. Under the said Regulation, all passenger boats sailing on regular voyages under the maritime line authorization of the Shipping Administration shall be required to use marine fuels with Sulfur content not exceeding 1.5% by mass in "maritime domains or in defined pollution control areas" after January 1 st 2012. The Regulation separately defines "regular voyages" and "passenger ships", and a passenger ship making regular voyages under the maritime line authorization of the Administration shall change to the said bunkers before entering marine domains or in the defined pollution control areas and use the said bunkers while sailing in the said areas. The regulations defined above relates to marine fuels which cover all marine fuels without any exception, including fuels used in the main engines, auxiliary engines, boilers or other machines. There are no NOx control areas in Turkey currently, although mentioned in the Regulation. Statistical and measurement studies must be performed and risk/benefit analyses must be made in order to be able to define and declare such areas. We have project studies in progress to perform such studies and evaluate the results thereof to cover the Turkish Straits and the Sea of Marmara primarily, followed by all marine domains. These projects are at the stage of evaluation and final decision shall be made whether it will be possible to define such domains according to project outputs after finalization of these projects. Within the frame of the said regulations, ships shall be checked whether they correctly perform bunker ~hange operations regularly and correctly upon examination of bunker delivery documents and ship journals during inspections to be made by the staff of the Administration. However, samples shall be collected from samples delivered to ships at the time of delivery of bunkers and from the tanks declared by the ship to contain the fuel which should be used according to the Regulation and sent for analysis: If any nonconformity is detected, the related provisions of the Environment Law 2872 shall apply. Please be advised and take the necessary action. (Signature) For the Minister Dr. Ozkan POYRAZ General Manager DISTRIBUTED TO: For action: Lloyd's Register IMEAK Chamber of Shipping Mersin Chamber of Shipping For Information: Ministry of Environment and Urban Planning (General Directorate of Environmental Management)

... Please log on.. www,turkloydu:org..jor previous issues :,'.... ofturk L:oydu,.... Newsletter... REGULATION ON REDUCTION OF SULPHUR RATE IN SOME TYPES OF FUEL OILS IN TERRITORIAL WATERS OF REPUBLIC OF TURKEY The following changes have been made on "Regulation on Reduction of Sulphur Rate in Some Types of Fuel Oils" by "Regulation Amending the Regulation on Reduction of Sulphur Rate in Some Types of Fuel Oils with the decision number 2009/15667: Before Revision After Revision ARTICLE 5 ARTICLE 5 (1) Middle distillate product containing (1) The following products containing sulphur of more than 0.1% by mass sulphur of more than 0.1 % by mass shall not be used shall not be used: ARTICLE 7 ARTICLE 7 a) Middle Distillate Product b) 1. Group marine diesel fuel (1) All the necessary measures shall be (1) Marine fuels containing sulphur of taken to prevent use of marine fuels more than 0,1% by mass shall not be containing sulphur of more than 0,1% used by tne following vessels by mass by the following vessels TEMPORARY ARTICLE 2 TEMPORARY ARTICLE 2 (1) The third paragraph of Article 6, (1) The subparagraph (b) of first first paragraph of Article 7 and third paragraph of Article 5, third paragraph paragraph of Article 10 of this of Article 6, first paragraph of Article 7 Regulation shall be applied by the date and third paragraph of Article 10 of this of European Union membership of Regulation shall be applied by the date Republic of Turkey. 01.01.2012. According to the latest revision of "Regulation on Reduction of Sulphur Rate in Some Types of Fuel Oils": 1. No marine fuel with sulphur content more than 1.5% by mass is permitted on ECA/SECA zones as defined either by Republic of Turkey or by MARPOL Annex-VI. (No ECA/SECA Zone is defined by Turkish Authority yet) 2. By the date 1st of January 2012, all of the passenger ships engaged in regular voyages shall use marine fuels with sulphur content not more than 1.5% by mass on jurisdiction areas and defined emission control areas of Republic of Turkey. This is valid for all vessels including the vessels started their voyage out of Turkish territorial waters, regardless of their flag. 3. As an entry requirement to Turkish ports, all of the vessels, regardless of their flag, shall have their journals recorded regularly and correctly, including fuel changeover operations, 4. Inland vessels and all the vessels at berth, regardless of their flag, shall use marine fuels with sulphur content not more than 0.1%by mass, by 1st of January 2012, Page 3/4

As a summary; 1. The limitation of marine fuels 0,1% by mass shall be applied to all inland vessels and the vessels at berth, regardless of their flag, by the date 1st of January 2012. Unless any other application decision will be specified by the Administration, it is understood that the existing Regulation shall also be applied to all of the transit vessels waiting at anchorage for passage of straits. 2. The limitation of marine fuels 1,5% by mass shall be applied to all passenger vessels engaged in regular voyages, regardless of their flag and the starting port of voyage, by the date 1st of January 2012. 3. Control and sampling activities for the use of marine fuels shall be carried out by the relevant General Directorates of Ministry of Transportation, Maritime Affairs and Communications of Republic of Turkey. 4. Transit passenger vessels engaged in regular voyages, sailing through territorial waters of Republic of Turkey and transit vessels waiting at anchorage for passage of straits, unless they have imparied their status of transit passage, are exempted from the Regulation. S. In case of violation of the provisions of the relevant Regulation, relevant provisions of Environmental law dated 9/8/1983 with no.2872 shall be applied. The vessels at berth is defined as the vessels connected or anchored safely during loading, unloading and layover operations or during the times without any load operation, inside the port boundaries. The conditions of vessels berthed less than 2 hours according to the published tariff, the inland vessels, having certificate of compliance with the latest SOlAS 1974 Convention, navigating at sea and the vessels at berth, having their engines/fuelconsumers switched off and being supplied by their electricity shore connection are exempted. According to the Regulation, all the fuel changeover op~rations of vessels at berth to be recorded to the journal, the vessels shall changeover as soon as possible after arriving the port and as late as possible before leaving the port. The time required will be provided by the Administration. Inland vessels are defined as all kind of vessels being used for cargo and passenger transportation on natural and artificial lakes, reservoirs, seal-fisheries and rivers of Turkey, including fishing vessels. You can see the final version of the Regulation (in Turkish) by the following link: http://www.mevzuat.adalet.gov.tr/html/30020.htmi For more information please contact: Daha detail bilgi i<;in: Yener TOHUMAT Plan Approval and Research Engineer TURK LdYDU PLAN APPROVAL AND RESEARCH DIVISION Phone : +90-216-5813700 (PBX) Fax: +90-216-5813840 E-mail: ytohumat@turkloydu.org Web : www.turkloydu.orq Page 4/4