Marpol Annex VI
The source of the potential impact on yachts caused by the introduction of Emission Control Area limits is twofold, namely the Tier III NOx level which comes into force 1 January 2016 and the fuel sulphur limit of 0.10% m/m which will be a requirement on and after 1 January 2015.
The Technical Team has continued to take an active role in the issues surrounding the requirements of MARPOL Annex VI concerning the significant reduction in NOxengine emissions, namely Tier III, which is scheduled to come into force in 2016 in Emission Control Areas. As previously reported the emission reductions stated within MARPOL cannot currently be achieved with ‘on-engine’ technology but will require exhaust after treatment. The most likely after treatment technology to meet Tier III will be Selective Catalytic Reduction, SCR. This article outlines the work that the BMF Technical Team has undertaken to date and future activities planned.
Vessels under 24m
The MARPOL Annex VI amendment was passed through the International Maritime Organisation, IMO, in 2008. At this time industry strongly objected and after extensive negotiations an exemption was secured stating: Regulation 13.5.2.1:‘..Standards…shall not apply to a marine diesel engine installed on a ship…with a length (LL) less than 24 metres when it has been specifically designed, and is used solely, for recreational purposes’. This exemption was only secured because of the existence of separate exhaust emission requirements within the Recreational Craft Directive.
The BMF Technical Team has worked closely with the MCA to secure confirmation that charter yachts <24m LL will be included within the exemption in the UK. In addition an amendment to the Recreational Craft Directive has been tabled to remove any ambiguity in the definition of a ‘recreational craft’ with the proposed wording being: ‘Watercraft also used for charter or for recreational boating (sports & leisure) training shall be covered by this Directive’. The argument to support exempting yachts is linked to their extremely low operating hours when compared to fully commercial vessels. The situation for light commercial vessels is less positive and, depending on their operating location and the development of Emission Control Areas, the fitting of SCR technology may be required.
Vessels over 24m
MARPOL Annex VI does not contain an equivalent exemption clause for other vessels however there is a review clause Reg 13.5.2.1: ‘Beginning in 2012 and completed no later than 2013, the Organization shall review the status of the technological developments to implement the standards set forth in paragraph 5.1.1 (Tier III) of this regulation and shall, if proven necessary, adjust the time periods set forth in that subparagraph’. To progress this review IMO set up a correspondence group and the BMF, through ICOMIA, have taken an extremely active role in this group to highlight industry concerns across the sectors we represent.
These ICOMIA interventions resulted in the groups’ interim report recognising ‘..physical constraints that may limit the application technologies to certain types of ships, notably small commercial ships as well as yachts and other recreational ships, need to be considered further and whether those constraints may be solved’.This report was discussed at the October 2012 IMO Marine Environmental Protection Committee, MEPC, where yachts were explicitly mentioned in the introduction by the US head of delegation.
The ICOMIA delegate also reinforced concerns by adding the following intervention: ‘…we have concerns that have yet to be satisfied that all yacht designs will be able to accommodate the demands of SCR treatment and remain commercially viable. Until then, we hope the committee agrees with our view that all aspects of Tier III compliance including considerations of the certification requisites vs. meeting Tier III under operational conditions must be assessed in every possible detail and we shall continue to contribute to the CG in the next phase of its work’.
Following this recognition ICOMIA instigated a major study to provide evidence to the2013 MEPC meeting to show the issues. This study comprises of three parts:
Study 1: Tier III Engine Installation Design Study
Builders around the world have been requested to provide general arrangements showing the detailed impact on the interior accommodation of this legislation. The information requested will include the required increase in engine room size and corresponding reduction in existing accommodation, plus cost and weight impacts.
Study 2: Socio-Economic Study
This will look at the socio-economic impact of the legislation.
Study 3 – Engineering Study
The aim of this study is to confirm that the installations being offered to the yacht sector represent the most cost effective solution in the 2016 timeframe and whether any application technology constraints found in the design studies may be solved. It will also examine the average total annual engine hours for such yachts and the yacht’s engine use profile.
This study has an extremely short timeline with reports needed by early February 2013 in order to meet the submission deadline for MEPC.
Further Resources