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THE REPUBLIC OF LIBERIA Liberia Maritime Authority 8619 Westwood Ctr. Dr. Suite 300 Vienna VA. USA 22182 Telephone: +1 703 790 3434 Fax: +1 703 790 5655 Email: [email protected] Office of Deputy Commissioner of Maritime Affairs 30 July 2012 Marine Advisory: 10/2012 This Marine Advisory supersedes Marine Advisory-08/2012 SUBJECT: North American Emission Control Area (ECA) under MARPOL Annex VI Ref: (a) MARPOL Annex VI, Regulations 13, 14, 18 and Appendix VII (b) Marine Notice POL-009 (c) United States Environmental Protection Agency memorandum dated June 26, 2012 Dear Shipowner/Operator: The sea area out to the boundary of the Exclusive Economic Zone of the coasts of the United States and Canada was designated as the North American ECA for reduction of Nitrogen oxides (NOx), Sulphur oxides (SOx) and Particulate Matter (PM) emissions under Regulations 13 and 14 of MARPOL Annex VI in August 2010 and entered into force on 1 August 2011. Ships entering the North American ECA shall comply with lower emissions standards when transiting the area starting 1 August 2012. The North American ECA covers three distinct areas: 1. Off the North American Atlantic/Gulf Coasts; 2. Off the North American Pacific coast; and 3. Around certain parts of Hawaii. It also includes the St. Lawrence Seaway, the Great Lakes and rivers (such as Mississippi) which are accessed by international shipping. The new appendix VII to MARPOL Annex VI contains the definition and boundaries with full coordinates of the North American ECA. Diagrams showing geographical distribution of the North American ECA are set out in Annex 1 to this Advisory. The lower emission standards are already in effect from 1 July 2010, for existing Baltic Sea and North Sea ECAs, including the requirements for recording data on entry and exit. Requirements within the North American ECA: While ships are operating in the North American ECA, the sulphur content of fuel oil used on board ships shall not exceed 1.00% m/m on and after 01 August 2012, and 0.10% m/m on and after 1 January 2015. Interim Guidance on the Non-Availability of Compliant Fuel Oil for the North American ECA: The United States EPA has published “Interim Guidance on the Non-Availability of

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  • THE REPUBLIC OF LIBERIA

    Liberia Maritime Authority 8619 Westwood Ctr. Dr. Suite 300 Vienna VA. USA 22182

    Telephone: +1 703 790 3434 Fax: +1 703 790 5655 Email: [email protected]

    Office of

    Deputy Commissioner of Maritime Affairs

    30 July 2012

    Marine Advisory: 10/2012

    This Marine Advisory supersedes Marine Advisory-08/2012 SUBJECT: North American Emission Control Area (ECA) under MARPOL Annex VI Ref: (a) MARPOL Annex VI, Regulations 13, 14, 18 and Appendix VII (b) Marine Notice POL-009

    (c) United States Environmental Protection Agency memorandum dated June 26, 2012

    Dear Shipowner/Operator: The sea area out to the boundary of the Exclusive Economic Zone of the coasts of the United States and Canada was designated as the North American ECA for reduction of Nitrogen oxides (NOx), Sulphur oxides (SOx) and Particulate Matter (PM) emissions under Regulations 13 and 14 of MARPOL Annex VI in August 2010 and entered into force on 1 August 2011. Ships entering the North American ECA shall comply with lower emissions standards when transiting the area starting 1 August 2012.

    The North American ECA covers three distinct areas: 1. Off the North American Atlantic/Gulf Coasts; 2. Off the North American Pacific coast; and 3. Around certain parts of Hawaii.

    It also includes the St. Lawrence Seaway, the Great Lakes and rivers (such as Mississippi) which are accessed by international shipping. The new appendix VII to MARPOL Annex VI contains the definition and boundaries with full coordinates of the North American ECA. Diagrams showing geographical distribution of the North American ECA are set out in Annex 1 to this Advisory. The lower emission standards are already in effect from 1 July 2010, for existing Baltic Sea and North Sea ECAs, including the requirements for recording data on entry and exit. Requirements within the North American ECA: While ships are operating in the North American ECA, the sulphur content of fuel oil used on board ships shall not exceed 1.00% m/m on and after 01 August 2012, and 0.10% m/m on and after 1 January 2015. Interim Guidance on the Non-Availability of Compliant Fuel Oil for the North American ECA: The United States EPA has published Interim Guidance on the Non-Availability of

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    Compliant Fuel Oil for the North American ECA, see Annex 2 to this Advisory. The letter provides additional US government guidance on demonstrating compliance with its fuel oil sulphur standard, and procedures, if compliant fuel oil meeting the 1.0% m/m (10,000 ppm) sulphur standard is not available when purchasing fuel oil. A Fuel-Oil Non-Availability Report containing the information listed in Annex 2 is required to be submitted to e-mail address: [email protected], until an electronic reporting system is developed. A copy of the report shall also be sent to the Administration at email address: [email protected] Operational Requirements: Ships using separate fuel oils entering or leaving an ECA must carry a written procedure showing how the fuel oil change-over is to be done, allowing sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the applicable sulphur content prior to entry into an ECA. The volume of low sulphur fuel oils in each tank as well as the date, time, and position of the ship when any fuel-oil-change-over operation is completed prior to the entry into an ECA or commenced after exit from such an area, shall be recorded in the engineering log book or other record book suitable for that purpose. Operational Guidance: Low and high sulphur fuel has to be stored in different tanks. Different grades of cylinder oils may have to be carried if operating with low sulphur fuel for any length of time to prevent excessive calcium deposits and resultant liner wear. If low sulphur fuels are used, high wear rates may be experienced with fuel injection equipment. Fuel Oil Quality: Refer to reference (a) and (b). Questions regarding this Advisory should be directed to Safety Department at +1 703 251 2469 or [email protected] Annex 1 Graphic view of North American ECA

    Annex 2 - United States EPA Memorandum - Interim Guidance on the Non-Availability of Compliant Fuel Oil for the North American ECA

    * * * * *

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    Annex 1 GEOGRAPHICAL DISTRIBUTION OF THE NORTH AMERICAN EMISSION CONTROL AREA

    1. General view of the North American Emission Control Area

    2. Magnified view of the Pacific Coast

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    3. Magnified view of the Atlantic coast and the Gulf of Mexico coast

    4. Magnified view of the Hawaiian Islands

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    Annex 2

    Interim Guidance on the Non-Availability of Compliant Fuel Oil for the North

    American Emission Control Area

  • Interim Guidance on the Non-Availability of Compliant Fuel Oil for the North American

    Emission Control Area

    June 26, 2012

    Annex VI to the International Convention for the Prevention of Pollution from Ships (MARPOL)

    has been in effect in the United States since January 8, 2009. MARPOL Annex VI is implemented

    in the United States through the Act to Prevent Pollution from Ships (APPS). Under the authority

    of APPS, the U.S. Environmental Protection Agency (the EPA), in consultation with the United

    States Coast Guard, has promulgated regulations which incorporate by reference the full text of

    MARPOL Annex VI. See 40 C.F.R. 1043.100(a)(1).

    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 (PM) 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 and 920 ozone-

    related premature deaths, 1,400,000 work days lost, and 9,600,000 minor restricted-activity

    days.

    Why is the United States government issuing this guidance?

    Under Annex VI, the North American Emission Control Area (North American ECA) will

    become enforceable on August 1, 2012. Beginning on that day, the sulfur content of the fuel oil

    used onboard ships operating in this area may not exceed 1.00% m/m (10,000 ppm). Compliant

    fuel oil is expected to be available from fuel oil suppliers that serve vessels that will operate in

    the North American ECA. However, if a ship owner or operator is unable to obtain compliant

    fuel oil, this document clarifies how the United States government will implement the fuel oil

    availability provisions contained in Regulation 18 to Annex VI, as incorporated by reference in

    40 C.F.R. 1043.100(a)(1). This guidance is based on information available to the United

    States government as of June, 2012. This guidance may be superseded at any time.

    What are the geographic boundaries of the North American ECA?

    The specific geographic coordinates that comprise the North American ECA are listed in the

    Marine Environment Protection Committee Resolution MEPC.190(60). Available at

    1

  • http://www.imo.org/Publications/Documents/Supplements%20and%20CDs/English/IA664E.pdf.

    What are the MARPOL Annex VI fuel oil sulfur standards?

    The MARPOL Annex VI fuel oil sulfur standards are set out in Annex VI Regulation 14 and 40

    C.F.R. 1043.60(b). The maximum sulfur content of fuel oil used in the North American ECA,

    which becomes enforceable on August 1, 2012, will be limited as follows:

    1.00% m/m (10,000 ppm ) from August 1, 2012 to December 31, 2014

    0.10% m/m (1,000 ppm) on and after January 1, 2015.

    Which vessels are required to comply with the Annex VI ECA fuel oil sulfur standard

    while operating in the North American ECA?

    With limited exceptions, including for certain public vessels (as defined in 40 C.F.R.

    1043.20), all vessels that operate in the North American ECA are required to be in compliance

    with the Annex VI ECA fuel oil sulfur standard. Note, most vessels under 400 gross tonnage are

    likely already in compliance with the standard as the majority of these vessels operate using

    solely distillate fuel oil that meets the Annex VI ECA fuel oil sulfur limit.

    How do I comply with the Annex VI ECA fuel oil sulfur standards while operating in the

    North American ECA?

    You are required to either use Annex VI ECA compliant fuel oil when operating within the

    designated North American ECA, or to install and use an equivalent method as approved and

    allowed under MARPOL Annex VI Regulation 4, and 40 C.F.R. 1043.55 (e.g., exhaust gas

    cleaning device).

    How do I demonstrate that the fuel oil used on my ship complies with the Annex VI ECA

    fuel oil sulfur standard while operating in the North American ECA?

    You are required to maintain and, if requested, make available to the United States government,

    the following:

    Bunker delivery notes, for vessels 400 gross tonnage and above. See Annex

    VI Regulation 18.5 and 40 C.F.R. 1043.70, 1043.100. While bunker

    delivery notes are not required for ships less than 400 gross tonnage, owners

    and operators of such ships may maintain appropriate fuel oil records that

    document