AFO #30 - All the world an ECA? 2009.08.08

All the world an ECA?   

2009.08.08

California rules are shape of things to come

Elsewhere in this issue we take a look at the new California regula­tion that mandates that ships within 24 miles of the California coast must burn low sulfur distillate fuel­ and keep extensive records on their compliance.

While the words "fuel switching" have a nice simple sound to them, the actual practice of switching fuels on board is far from simple. It involves keeping bunkering additional grades of fuel, storing them separately under the conditions appropriate to each-and then gradually switching from one fuel to the other, balancing temperatures and viscosities as this is done.

As is clear from an API working paper that we quote extensively in the feature, it's just not that easy. And the penalty for getting it wrong can be a ship adrift without power, with all the potential for disaster that implies.

The new rules are the California Air Resources Board's second attempt to limit emissions from ships. An earlier regulation would have set levels for emissions of NOx, SOx and particulate matter by ships. That rule was slung out by the courts, but the just-imple­mented measure dictating fuel grades has thus far withstood legal challenges.

A TASTE OF THINGS TO COME?

In fact, the California rules can be seen as offering a taste of things to come. In the works is the North American ECA, which will set emission limits out to 200 miles off the US. and Canadian coastline. So fuel switching is going to become a widespread practice-at least

until such time as all ships burn distil­late fuel all the time. That was a solu­tion advocated by Intertanko in the dis­cussions that led to the most recent MARPOL Annex VI amendments .:

The North American ECA is being requested within the framework of the revised Annex VI.

NEW STANDARDS FOR ENGINES

Also within that framework, the US.

Environmental Protection Agency is proposing to revise the Clean Air Act engine program to include two addi­tional tiers of NOx standards for new Category 3 marine diesel engines (above 30 liters per cylinder displace­ment) installed in vessels registered in the United States.

The proposed near-term Tier 2 stan­dards for newly built engines would apply beginning in 2011 and would require more efficient use of current engine technologies, including engine timing, engine cooling, and advanced computer controls. The Tier 2 stan­dards would result in a 15 to 25% NOx reduction below the current Tier 1 lev­els, says EPA.

The proposed long-term Tier 3 stan­dards would apply beginning in 2016 and would require the use of high effi­ciency after treatment technology such as selective catalytic reduction to achieve NOx reductions 80% below the current levels. In addition to the NOx emission limits, EPA is proposing stan­dards for emissions of HC and CO from new Category 3 engines.

What's not entirely clear from the EPA is to what extent, if any, its pro-

posals exceed the new MARPOL requirements, putting an additional burden on US.-flag operators. .

EPA is not proposing to set a stan­dard for PM emissions for Category 3 engines. However, significant PM emis­sions benefits will be achieved through the ECA fuel sulfur requirements that will apply to ships that operate in areas that affect US. air quality. EPA is also proposing to require engine manufac­turers to measure and report PM emis­sions. Finally, EPA is proposing a change to the diesel fuel program that would forbid the production and sale of marine fuel oil above 1,000 ppm sulfur for use in the waters within the pro­posed US. ECA and internal US. waters; and allow for the production and sale of 1,000 ppm sulfur fuel for use in Category 3 marine vessels.

EPA says the proposal is part of a coordinated strategy to ensure that all ships that affect US. air quality meet stringent NOx and fuel sulfur require­ments. When taken together, the ele­ments of the coordinated strategy are expected by EPA to result in significant improvements in US. air quality and public health.

ALL THE WORLD AN ECA?

All of these regulatory developments have been predictable for long enough. What seems equally predictable is that more ECA's will come into existence and that the "non-ECA" areas of the oceans will grow ever smaller. The qus­tion really is "How long will it take before they disappear completely?"

来源 MARINELOG 什志 JULY 2009