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Delivering Legal Services

Executing the Mission. Delivering Legal Services. Maritime Law Association Spring Meeting April 28-30, 2015 New York, New York. MARPOL Annex VI: Emission Control Areas Coast Guard Updates & Enforcement. CAPT Patrick J. McGuire Chief, Office of Maritime & International Law. Overview.

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Delivering Legal Services

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  1. Executing the Mission Delivering Legal Services Maritime Law Association Spring Meeting April 28-30, 2015 New York, New York

  2. MARPOL Annex VI: Emission Control AreasCoast Guard Updates & Enforcement CAPT Patrick J. McGuire Chief, Office of Maritime & International Law

  3. Overview • Introduction and Standard • Enforcement and US/EPA Protocols • Fuel Oil Non-Availability Reports (FONARS) • Regulations 3 & 4 • Compliance Statistics

  4. Emission Control Areas (ECA) • IMO – Designated through amendments to MARPOL Annex VI • Establishes limits on NOx emissions from marine diesel engines and sulfur content of marine fuels. • North American ECA • Adopted by IMO: March 26, 2010 • Enforcement: August 1, 2012 (Reg. 14.7) • U.S. Caribbean Sea ECA • Adopted by IMO: July 15, 2011 • Enforcement: January 1, 2014 (Reg. 14.7) • Applies to U.S. flagged ships and foreign flagged ships operating within 200 nm of United States

  5. Fuel Oil Requirements Annex VI, Reg. 14 and 18: SOx & Particulate Matter (PM) & Fuel Oil Availability and Quality Shipboard Requirements Fuel Oil : Sulfur Content Caps (Reg. 14) Fuel Quality Standards (Reg. 18) Operations: Bunker Delivery Notes & Samples (Reg. 18) Fuel Oil Change-Over Procedures (Reg. 14.6) Fuel Oil Change-Over Logbook Entries (Reg. 14.6)

  6. Joint Agency Annex VI Implementation • Coast Guard’s Role • Shipboard compliance • Flag State (U.S. Ships) • Port State Control (Foreign) • IAPP Certificate • Bunker Delivery Notes & Samples • EPA’s Role • Shoreside Compliance • Engine Emissions (NOx) • EIAPP Certificate • Fuel Oil Quality & Availability(SOx)

  7. USCG & EPA: Referral Protocol • General Enforcement Roles under MOU • USCG and EPA may request assistance regarding inspections, investigations, or enforcement from one another. • March 2015 Revised Referral Protocols • Refines USCG enforcement determinations and outlines referral process to EPA for further investigation and enforcement. • USCG may refer matters to EPA for civil enforcement with a LOU, bond, or other surety satisfactory obtained by USCG.

  8. Fuel Oil Non-Availability Reports (FONARs) • Annex VI, Regulation 18 • If fuel not available, vessels must provide notification of actions taken to attempt compliance and locate alternative sources of compliant fuel • Filed with the EPA • Matter referred upon filing, EPA takes FONAR into consideration when determining whether or not to take enforcement action for non-compliance. • Filing of FONAR does not prevent inspection or enforcement for non-compliance.

  9. Regulations 3 & 4 • Regulation 3 (Permits) • Provides exception for vessels engaging in trial programs for alternate ship emissions reduction and control technology research • Must be approved by Flag State and acknowledged by USCG and EPA. • Regulation 4 (Equivalencies) • Allows alternative equipment or fuels to be used to achieve equivalent level of compliance • Must be approved by Flag State. • Compliance with Annex VI cannot be waived

  10. USCG Enforcement Statistics 5 vessels detained since August 2012. As of 01 March, 22 deficiencies and one “no sail” order has been issued. Coast Guard has, in at least two instances, given companies 30 days to come into compliance when low sulfur fuel caused safety concerns; vessels operated on reduced power in ECA until parts became available

  11. Annex VI Resources • Coast Guard Homeport: www.Homeport.USCG.milSelect the following links: Missions > Domestic Vessels > MARPOL ANNEX VI • CG-543 Policy Letter 09-01 (Annex VI Implementation) • CG-CVC Policy Letter 12-04 (ECA Compliance) • CG-CVC Policy Letter 13-02 (IEE/SEEMP) • USCG & EPA Revised Protocols on Referrals under Annex VI http://www.uscg.mil/hq/cgcvc/cvc/marpol/annexsix-EPAProtocols.pdf • Marine Safety Alert 02-15, Fuel Switching and Annex VI requirements: https://homeport.uscg.mil/cgi-bin/st/portal/uscg_docs/MyCG/Editorial/20150317/0215.pdf?id=33a6d6535954eaf0fef8da9b2e4ebae949b058c1 • EPA MARPOL Annex VI http://www2.epa.gov/enforcement/marpol-annex-vi • EPA Ocean Going Vessels http://www.epa.gov/otaq/oceanvessels.htm

  12. Questions?

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