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Enforcement of the NA ECA . Where We’ve Been Where We’re Going. Matt Haber US EPA Air Enforcement Division Office of Enforcement and Compliance Assurance. Today’s Presentation. Quick Reminder: Why the ECA What’s happened in the last year What’s coming.

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enforcement of the na eca

Enforcement of the NA ECA

Where We’ve Been

Where We’re Going

Matt Haber


Air Enforcement Division

Office of Enforcement and Compliance Assurance

today s presentation
Today’s Presentation
  • Quick Reminder: Why the ECA
  • What’s happened in the last year
  • What’s coming
why the eca reduced pm concentrations
Why the ECA-Reduced PM Concentrations

PM-2.5 standard

Current: Current: 12ug/m3 (annual) (12/14/12) (was 15 ug/m3)

35ug/m3 (24 hour)

eca benefits emissions and health
ECA Benefits—Emissions and Health
  • ECA standards will result in annual reductions starting in 2020 of:
    • 320,000 tons of NOx
    • 90,0000 tons of PM-2.5
    • 920,000 tons of SOx
    • 23%, 74% and 86% reduction of predicted levels absent the ECA
  • ECA benefits include preventing as many as 14,000 premature deaths and relieving respiratory symptoms for nearly 5 million annually.
what s happened
What’s happened?
  • Overall ECA situation
  • FONAR system updates
  • FONAR results
  • Flexibility
  • Flyover experiment
  • Investigations of FONAR abuse
  • Emerging problem areas
  • Detentions
overall quick look at eca
Overall Quick Look at ECA
  • ECA in place over one year
  • Vast majority of vessels obtained and used compliant* fuel in ECA
  • Some vessels could not obtain compliant fuel; most submitted FONAR

*based on BDN

fonar system
FONAR system
  • Put in place to address fuel availability under regulation 18.2
  • Initially email system
  • Changed to electronic system using EPA’s CDX in Spring, 2013
  • Many reports initially
  • Number of reports have tapered off dramatically
    • Reg 3 permits issued
    • NCL (scrubber)
    • TOTE (LNG)
    • Carnival (scrubbers)
    • RCL (scrubbers)
  • Reg 4 equivalence issued
    • RCL (averaging)
  • Problem: Point of compliance begins at 200 NM off shore
    • Point of enforcement is typically at berth
  • Question: Can we monitor compliance at 200 NM?
    • NOAA study says yes
  • We are testing concept over Chesapeake Bay
other issues
Other Issues
  • FONAR abuse
  • Tested sulfur >BDN (and >1.00%)
  • Detentions
what s coming
What’s coming?
  • January 2014—Caribbean ECA
  • January 2015—0.1% requirement
  • January 2016—NOx requirements
  • Mexico?
what s coming caribbean eca january 2014
What’s Coming: Caribbean ECA January 2014
  • IMO designated July 15, 2011 Enforceable January 2014
what s coming 0 1 s requirement
What’s Coming: 0.1% S Requirement
  • NOW is the time to test engines, fuel lines, other equipment & make any necessary modifications
  • If you are considering an equivalent method, implement it!
what s coming tier iii nox january 2016
What’s Coming: Tier III NoxJanuary 2016
  • Will require after treatment
    • selective catalytic reduction, exhaust gas recirculation, water injection strategies, dual fuel diesel/natural gas engines
  • Applies in ECAs only (Tier II otherwise)
mexico part of na eca
Mexico Part of NA ECA?
  • Demonstrated possible impacts of an ECA in Mexico
  • Provided technical information
  • Conducting evaluation of benefits of a Mexican ECA