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Web Alert: EPA issues FAQ guidance regarding North American and Caribbean ECA compliance

30 January 2017

In response to questions regarding Emissions Control Area (ECA) compliance issues, the US EPA has released the attached FAQ guidance. The FAQ’s address a range of topics including handling exhaust gas scrubber effluent, NOx Tier III for dual fuel engines, fittings of non-Tier III engines on vessels constructed on or after 1 Jan 2016, and additional information about the EPA and Annex VI requirements.

In March 2010, the IMO amended MARPOL designating specific portions of US, Canadian and French waters as an ECA. The North American ECA includes waters adjacent to the Pacific coast, the Atlantic/Gulf coast and the eight main Hawaiian Islands. The ECA extends 200 nautical miles from costs of the US and Canada. ECA designations also apply to territories of Puerto Rico and the US Virgin Islands (Caribbean ECA).

The second phase of regulations began on 1 Jan 2015, when requirements in both the North American and Caribbean ECAs became aligned requiring all ships to use fuel with a maximum sulphur content of 0.1%. If ultra-low low sulphur fuel oil cannot be obtained, authorities will permit the fuel blending and/or the use of distillates MGO or MDO. All ships using separate fuel oils when operating within an ECA are to carry a written fuel oil change-over procedure. An equivalent gas scrubber can be installed to remove sulphur from the engine exhaust gas as an equivalent to a fuel sulfur limit. If a ship is not able to comply with sulphur emissions limit while transiting the North American ECA, a Fuel Oil Non-Availability Report (FONAR) must be filled.

Members should also refer to the club’s November 2016 publication regarding sulphur emissions.