Regulations For Air Emissions From Ships: Purpose

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Marine Notice 5/2017

Supersedes 12/2015

Regulations for Air Emissions from Ships

Purpose
The purpose of this Marine Notice is to The current maximum sulphur content of fuel
provide general information to shipowners, oil for ships operating in areas other than
masters and crews on Annex VI of the ECAs is 3.5% m/m (mass/mass). This limit
International Convention for the Prevention of will be reduced to 0.5% m/m from
Pollution from Ships (MARPOL). Annex VI of 1 January 2020. This reduction follows an
MARPOL contains regulations for the International Maritime Organization (IMO)
prevention of air pollution from ships. commissioned study 1 to review the global and
regional demand for, and supply of, fuel oil
This Marine Notice focusses on MARPOL complying with the 0.5% m/m limit. More
Annex VI regulations that control emissions of information on the new sulphur content limit
sulphur oxides (SOx) and particulate matter, can be found in Marine Notice 2017/02.
and nitrogen oxides (NOx). These controls
are divided between those applicable inside The maximum sulphur content of fuel oil for
IMO designated Emission Control Areas ships operating in ECAs is 0.1% m/m. Four
(ECAs) and those applicable elsewhere. SOx ECAs have been designated by the IMO.
These are the Baltic Sea, North Sea, the
This notice is issued as general guidance only North American area (both east and west
and should be read in conjunction with the coasts of the United States and Canada) and
relevant Acts, Marine Orders and Standards. the United States Caribbean Sea area.
This document does not constitute legal
advice and is not a substitute for independent MARPOL Annex VI provides provisions for
professional advice. when a ship, despite best efforts, cannot
purchase compliant fuel oil during its planned
This Marine Notice supersedes Marine Notice voyage. In this case, the ships’ owners and
2015/12. operators must notify their Administration (for
Australian vessels, AMSA) and the
SOx and Particulate Matter competent authority of the relevant port of
Emissions destination prior to arrival in the port.
SOx and particulate matter emissions are a In Australia, local fuel oil suppliers are
function of the sulphur content of fuel. The required to be registered with AMSA, and are
SOx control requirements in MARPOL Annex listed on the AMSA web site.
VI provide for a progressive global reduction
in the sulphur content of fuel oil to reduce the
emission of SOx and particulate matter from
ships.

1 Further information on the IMO Commissioned Study is available at www.imo.org.

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As an alternative to using low sulphur fuel oil, These limits apply in all areas not designated
MARPOL Annex VI also permits the use of as a NOx ECA. Standards for existing ships
“equivalent methods” to meet sulphur are outlined in further detail below.
emission restrictions. Equivalent methods
include the use of exhaust gas cleaning The more stringent Tier III limits apply to
systems, or “scrubbers”, which act to remove marine diesel engines installed on ships
the SOx directly from the ship exhaust. The constructed on or after 1 January 2016
use of an equivalent method needs to be at operating in existing NOx ECAs.
least as effective, in terms of emission Replacement engines installed on existing
reductions, as the fuel oil requirements ships operating in NOx ECAs are required to
outlined above. Owners or operators of meet Tier III standards where possible.
Australian vessels considering this option Additional engines must meet the Tier III
need to obtain approval from AMSA and standard.
should also review the IMO Guidelines for
Exhaust Gas Cleaning Systems (Resolution There are currently two NOx ECAs - the North
MEPC.259(68)). American area and the United States
Caribbean Sea area.
Special conditions also apply to certain cruise
vessels berthed in Sydney Harbour. In For additional NOx ECAs designated in the
accordance with directions issued by AMSA, future, Tier III controls will apply to ships
affected cruise vessels are required to either constructed on or after the date of the
use fuel with a sulphur content not exceeding adoption of such an ECA, or a later date as
0.1% m/m; use a certified and approved may be specified in the designation of the
Exhaust Gas Cleaning System; use a power ECA, when operating in the area.
source external to the vessel; or use a
combination of these measures. More These requirements are summarised in the
information can be found in Marine Notice following table.
2016/21. Tiers for Effective date
NOx limits
NOx Regulations for Marine
Tier I* On or after January 1, 2000
Diesel Engines Tier II* On or after January 1, 2011
Regulations in MARPOL Annex VI provide for Tier III* On or after January 1, 2016
progressive reductions in NOx emissions
from marine diesel engines, with a power (operating in existing ECAs)
output of more than 130 kW, installed on a North American ECA and
ship. NOx emissions are restricted to certain United States Caribbean Sea
limits (Tier I, II and III) based on the ship’s Area ECA
construction date; date of major conversion 2; * Please refer to resolution MEPC.176(58) for the set
and area of operation. Within each of these emission limit based on ships’ rated engine speed.
Tiers, the NOx emission limit is set based on
the ship’s rated engine speed (crankshaft When purchasing a new marine diesel engine
rpm). with a power output of more than 130 kW,
shipowners and operators must ensure that
The Tier I and II limits apply to marine diesel the engine has been issued with an Engine
engines installed on ships constructed, or International Air Pollution Prevention
undergoing a major conversion, on or after Certificate (EIAPP) and its supporting engine
1 January 2000 and 1 January 2011 Technical File 4 to verify compliance.
respectively. Replacement engines and
additional engines installed on existing ships
are required to meet Tier II standards, unless
they meet the defined criteria for an ‘identical
engine’ 3.

2 For definition of a ‘major conversion see MARPOL Annex VI, reg. 13 para. 2.1 and 2.2
3 See the Unified Interpretations (UI) to the Revised MARPOL Annex VI, paragraph 6- Identical replacement engines.
4 See the IMO NOx Technical Code (2008), Chapter 2, section 2.4.1 for the contents of a Technical File.

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Tier III Exceptions Details on determining the requirements for a
specific ship can be found in MARPOL Annex
The Tier III NOx emission limits will be VI, the NOx Technical Code 2008 as
primarily met through technologies such as amended, and the following MEPC
selective catalytic reduction (SCR) systems. Resolutions that have been developed to
support these regulations:
The IMO, in recognising that current SCR
• Resolution MEPC.251(66) - Amendments
technology cannot be used by ships such as
superyachts, agreed that ships less than to MARPOL Annex VI and the NOx
500GT, but over 24m in length, designed to Technical Code 2008 (relating to the
be used solely for recreational purposes are application of the Energy Efficiency Design
not required to meet the Tier III limits until Index (EEDI) to a wide range of ship types
2021 (refer to MEPC.251(66) for more and certification of dual-fuel engines);
information). This will allow time for the • Resolution MEPC.243(66) – 2014
industry to develop appropriate technologies Guidelines on the Approved Method
to meet this requirement. Process;
• Resolution MEPC.230(65) – 2013
NOx Standards for Existing Guidelines as required by Regulation
Engines 13.2.2 of MARPOL Annex VI in respect of
Existing marine diesel engines with a power non-identical replacement engines not
output of more than 5,000 kW, and a per required to meet the Tier III limit;
cylinder displacement at or above 90 litres, • Resolution MEPC.198(62) – 2011
installed on a ship constructed on or after Guidelines addressing additional aspects
1 January 1990 but prior to 1 January 2000, to the NOx Technical Code with regard to
are also required to comply with Tier I limits. particular requirements related to marine
To achieve compliance, such existing marine diesel engines fitted with selective
diesel engines must also have an Approved catalytic reduction (SCR) systems;
Method (for example, an engine upgrade kit) • Resolution MEPC.259(68) – 2015
certified by an Administration, and the IMO Guidelines for Exhaust Gas Cleaning
needs to be notified. Systems;
When an Approved Method has been • Resolution MEPC.182(59) – 2009
certified, it is to be applied to all relevant Guidelines for the sampling of fuel oil for
engines on ships no later than the first determination of compliance with the
renewal survey that occurs 12 months or revised Annex VI;
more after IMO is notified. A publicly available • Resolution MEPC.176(58) – Amendments
list of Approved Methods and notification to the Annex of the Protocol of 1997 to
dates is maintained online in the IMO Global amend the international Convention for
Integrated Shipping Information System the Prevention of Pollution from Ships,
(GISIS). Where the owner or operator of an 1973, as modified by the Protocol of 1978
Australian ship is able to demonstrate to relating thereto (Revised MARPOL Annex
AMSA that an Approved Method is not VI) (set NOx emission limit based on
commercially available, the above ships’ rated engine speed).
requirement may be extended so that it is
installed on the ship no later than the next Copies of these Resolutions can be obtained
annual survey which falls after the Approved from the IMO website.
Method is commercially available.
Further Information Gary Prosser
Ship owners and operators should note that Deputy Chief Executive Officer
this Marine Notice provides only a summary Australian Maritime Safety Authority
of MARPOL Annex VI requirements relating March 2017
to sulphur oxides and particulate matter and
nitrogen oxides. GPO Box 2181
CANBERRA ACT 2601

File No: 2017/1249

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