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News: Use of scrubbers in US Waters

30 December 2019

On 7 November, 2019, the USCG issued an updated policy letter, CVC Policy Letter 12-04 CH-1, Guidelines for Compliance and Enforcement of the Emission Control Areas Established within the United States Jurisdiction as Designated in MARPOL Annex VI Regulation 14.

This policy letter outlines the USCG’s methods and procedures for verifying compliance with MARPOL Annex VI Regulation 14 (Sulphur Oxides [SOx] and Particulate Matter [PM]) as well as Regulation 18 (Fuel Oil Availability & Quality). It also explains how violations regarding these two regulations are documented by the USCG and referred to the Environmental Protection Agency (EPA) for enforcement. It also provides guidance to USCG inspectors on recording deficiencies and lists a summary of enforcement procedures for detected violations.

For exhaust gas scrubbers, it removes a request for correspondence from Flag administrations on granted equivalencies. The USCG will instead be verifying this information through the IMO’s Global Integrated Shipping Information System (GISIS).

Provided the systems are tested, surveyed, and verified in accordance with MEPC 184(59) or MEPC 259(68) and are appropriately granted equivalencies by a flag administration, exhaust gas scrubbers may be used to meet the ECA requirements in the US.

Foreign flagged vessels using an exhaust gas scrubber to meet the North American and U.S. Caribbean Emission Control Area (ECA) requirements do not need to make a separate notification to USCG prior to arrival in US waters.

US flagged vessels planning to use an exhaust gas scrubber must submit an equivalency request to USCG in accordance with Section 5(b)(i) of CVC Policy Letter 12-04.

Vessels using an open-loop or hybrid system that will generate an exhaust gas scrubber wash-water discharge within 3nm of the US, are subject to additional monitoring and effluent limitations under the 2013 Vessel General Permit (VGP) Requirements. An excerpt of the exhaust gas scrubber requirements from the 2013 VGP is included below.

  • While the requirements are generally similar to those in MARPOL Annex VI, the pH limit is more stringent under the VGP.
  • Analytical monitoring must be carried out and reported to EPA as part of the vessel’s Annual Report.
  • If the wash-water can be contained and is not discharged within VGP waters, these requirements do not apply.
  • The discharge of any scrubber wash-water is prohibited in Connecticut State waters. Vessels calling ports in Connecticut, may not operate an open-loop scrubber while in State waters.

Use of exhaust gas scrubber systems are not authorized to meet the California fuel oil requirements unless a special research exemption is granted by the State. More information on applying for an exemption is provided in the California Air Resources Board (CARB) Marine Notice 2017-1. If an exemption is not obtained from the State, vessels using an exhaust gas scrubber will need to switch to compliant fuel prior to entry within California Regulated Waters (24nm from the baseline).

Members with ships trading in US waters are recommended to take note of these requirements, and if intending to use exhaust gas scrubbers ensure that the crew are familiar with any additional requirements or restrictions that may apply locally.