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Smoke and mirrors
Katherine Hawes from Aquarius Lawyers on complex impending ECA legislation
Despite ship transportation being considered as the most energy efficient mode of transport, it still represents a significant contribution to global emissions.
The sulphur content of marine fuels is determined by local legislation and regulated through the International Maritime Organization (IMO) MARPOL Annex VI which is in turn implemented by national legislation of the signatory parties.
During the 1980s the International Maritime Organisation (IMO) started work on the reduction of air pollution from ships. However, it wasn’t until May 2005, with the ratification of MARPOL Annex VI, that it directly impacted the shipping industry. Since that time the emissions from shipping have played a major part in the development of the marine industry, with the IMO increasingly setting tighter limits. In addition, the European Union has added supplementary requirements to those imposed by IMO and the state of California has set its own specific requirements.
The MARPOL Annex VI legislation regarding sulphur emissions is mainly contained in Regulation 4 and Regulation 14 which covers sulphur oxides and particulate matter. The regulation defines the sulphur content of the fuel where compliance is to be achieved on the basis of the fuel as loaded. There are different sulphur limits applicable inside and outside Emission Control Areas (ECAs). The ECAs are as follows:
1. Baltic Sea area – as defined in Annex I of MARPOL (SOx only);
2. North Sea area – as defined in Annex V of MARPOL (SOx only);
3. North American area
4. United States Caribbean Sea area
Most ships which operate both outside and inside these ECAs will therefore operate on different fuel oils in order to comply with the respective limits. In such cases, prior to entry into the ECA, it is required to have fully changed-over to using th ... More>>