MARPOL Annex VI Emission Control Areas CDR Ryan Allain U.S. Coast Guard Environmental Standards Division Washington, D.C.
ECA Requirements Why? Compliance with the MARPOL Annex VI air emission standards, including the fuel oil sulfur standards, will significantly reduce emissions from foreign and domestic vessels that affect U.S. air quality and impact human health. The Annex VI standards, in conjunction with the U.S. Clean Air Act standards applicable to U.S. ships, are expected to reduce the annual emissions of nitrogen oxides (NoX) sulfur oxides (SoX), and particulate matter by 1.2 million, 1.3 million, and 143,000 tons, respectively by 2030. Annually, these reductions are estimated to prevent between 12,000 and 30,000 PM-related premature deaths, between 210-920 ozone-related premature deaths, 1,400,000 work days lost and 9,600,000 minor restricted activity days.
Coast Guard s Role Shipboard compliance Joint Agency Annex VI Flag State (U.S. Ships) Port State Control (Foreign) IAPP Certificate Bunker Notes & Samples 5 Detentions and 184 deficiencies referred to EPA (Aug 2012-May 2014) EPA Role Engine Emissions (NOx) EIAPP Certificate Fuel Oil Quality (SOx) Fuel Quality (Sulfur Content) Implementation
Fuel Oil Requirements Annex VI, Reg. 14 and 18: SOx & Particulate Matter (PM) & Fuel Oil Availability and Quality Shipboard Requirements Fuel Oil : Sulfur Content Caps Fuel Quality Standards Operations: Bunker Notes & Samples Fuel Oil change-over procedures Fuel Oil change-over log-book entries Annex VI, Reg. 14 - Fuel Oil Sulfur Content Limits North American ECA Sulfur Content Cap Effective Date Sulfur Limit %m/m (ppm) On and after JULY 2010 1.0% (10,000) On and after JAN 2015 0.1% (1,000) Global Sulfur Content Cap Effective Date Sulfur Limit %m/m (ppm) On and after JAN 2012 3.5% (35,000) On and after JAN 2020 0.5% (5,000)
North American ECA Update for Jan 1, 2015 Owners and operators are reminded that the allowable level of sulfur in fuel will be decreasing to 0.10% as of January 1, 2015. In order to ensure a smooth transition to lower sulfur fuel, owners and operators should ensure that all relevant equipment on board is capable of handling this fuel, and that any modifications necessary are put in place and tested well before the deadline. Contracts with fuel suppliers should also be reviewed to ensure an adequate supply of compliant fuel is provided for any operations within the North American or Caribbean ECAs. A vessel must use compliant fuel when operating in the ECA. If a ship owner is not able to obtain compliant fuel because it is not available, a FONAR must be submitted. A FONAR is not a waiver, it is a statement of noncompliance. NOTE: If 0.10% (1,000ppm) fuel is not available, but another compliant diesel fuel is available (e.g., ultra low sulfur diesel, 15 ppm), then ECA-compliant fuel will not be deemed "unavailable" for the purpose of a FONAR
ECA Non-Fuel Availability Reporting Ships not able to purchase compliant fuel must: Notify flag Administration Notify competent authority of the relevant port of destination, and: Submit Fuel Oil Non-Availability Report (FONAR), and; Present a record of actions taken to attempt to achieve compliance and provide evidence the vessel attempted to purchase compliant fuel oil in accordance with its voyage plan Further guidance and reporting requirements are available at: http://www.epa.gov/otaq/oceanvessels.htm. EPA reviews submitted reports and USCG referred deficiencies to: Verify proper submittals/documentation Cross check USCG issued deficiencies w/submitted FONARs Review data/assess trends (i.e. same vessel submitting FONAR during every US arrival)
USCG Verification of Compliant Fuel Oil During Coast Guard Port State Control Exam Present a record of actions taken to attempt to achieve compliance Provide evidence the vessel attempted to purchase compliant fuel oil in accordance with its voyage plan, and if not available where planned, that attempts were made to locate an alternative source Provide documentation that Flag Administration and EPA were notified USCG will refer deficiencies identified during a PSC exam of ECA non-compliance to EPA (Reg. 14/18) for enforcement EPA responsible for adjudication of non-compliant event 7
ECA Fuel Switching Concerns North American ECA 200 NM Buffer Indications of propulsion loss should be detected prior to port entry. Preventive Measures Annex VI, Reg. 14.6 Fuel oil change-over procedures ISO 13617 Maintenance and testing to reduce losses in critical systems for propulsion USCG Marine Safety Alert 03-09 API Technical Considerations Safety Management Systems (SMS) Environmental Management
ECA Exemptions & Equivalencies USCG works with EPA in considering exemptions and equivalencies The Coast Guard, in consultation with EPA is responsible for issuing exemptions or equivalencies for U.S. flagged vessels Foreign ships have own flag administration issue exemption or equivalency EPA and USCG review foreign ship proposals to consider acceptability to U.S. government Compliance with the ECA requirements through use of scrubbers is verified by the Coast Guard by examining IAPPs for reg 4 equivalencies. 9
Exemptions Regulation 3.2 Ship may be exempted from fuel sulfur limits to allow trials for development of new emission reduction/control technology or engine design improvements (e.g. conversion to LNG fuel, development of exhaust gas scrubber technologies). Robust terms and aggressive schedule for technology testing. Joint CG/EPA Policy coming soon. 10
Annex VI Resources Coast Guard Homeport: www.homport.uscg.mil Select the following links: Missions > Domestic Vessels > Domestic Vessel General > MARPOL ANNEX VI CG-543 Policy Letter 09-01 (Annex VI Implementation) CG-CVC Policy Letter 12-04 (ECA Compliance) CG-CVC Policy Letter 13-02 (IEE/SEEMP) EPA Ocean Going Vessels Air Emissions Web Page: http://www.epa.gov/otaq/oceanvessels.htm 11
Thank You Coast Guard Point of Contact: CDR Ryan Allain, Environmental Standards Division, CG-OES-3 Ryan.D.Allain@uscg.mil 202-372-1430 E-Mail: ECA-USFlag@uscg.mil or ECA- ForeignFlag@uscg.mil 12
North American & Caribbean Emission Control Areas (ECA) North American ECA: Adopted by IMO: March 26, 2010 Entry-into-force: August 1, 2011 Enforcement: August 1, 2012 (Reg. 14.7) Caribbean ECA Adopted by IMO: July 15, 2011 Entry-into-force: January 1, 2013 Expected Enforcement: January 1, 2014 (Reg. 14.7)