New Emission Control and Fuel Standards for Large Marine Engines

In conjunction with international standards, the U.S. Environmental Protection Agency (EPA) has finalized its new emission and fuel standards for Category 3 marine diesel engines, which were proposed in mid-2009. The amendments were harmonized to the October 2008 amendments to Annex VI of the International Convention for the Prevention of Pollution from Ships (MARPOL). The new standards will also apply to non-U.S. vessels in U.S. waters once the U.S.-Canadian application to the IMO for an amendment to MARPOL Annex VI is approved. The amendment would designate an area up to 200 nautical miles off the U.S. coast as an emissions control area (ECA).

In March 2008, EPA finalized a three part program that will dramatically reduce emissions from marine diesel engines.The new rule is part of EPA’s coordinated strategy to reduce emissions from marine diesel engines and, in particular, from larger marine diesels such as those installed on tankers, cargo ships and cruise ships. Compliance obligations for newly built engines will be phased in beginning in 2011, with the most stringent emission standards becoming effective in 2016; the new fuel standards will be effective for all Category 3 vessels by January 1, 2015. The rule will cut PM emissions from these engines by as much as 90 percent and NOx emissions by as much as 80 percent when fully implemented.

Moving Global Standards Forward

Globally, the effective date for the current MARPOL Annex VI Tier 1 NOx limits was January 1, 2000. Annex VI entered into force for the United States on January 8, 2009. Vessel owners are now required to comply with these standards, although most voluntarily complied in the interim since 2000.

Under the new global standards, NOx emissions will be reduced, and the fuel sulfur cap will drop to 5,000 ppm in 2020 (pending a fuel availability review in 2018). Under the new geographic standards, ships operating in designated areas will be required to use engines that meet the most advanced technology-forcing standards for NOx emissions, and to use fuel with sulfur content at or below 1,000 ppm.

The United States and Canada have proposed the designation of an Emission Control Area (ECA) for specific portions of U.S. and Canadian coastal waters. This action would control the emission of nitrogen oxides (NOx), sulfur oxides (SOx), and particulate matter (PM) from ocean-going ships, most of which are flagged outside of the United States. These ships are significant contributors to our national mobile-source emission inventory. In the U.S. and Canada combined, the ECA is expected to reduce emissions of NOx by 320,000 tons, PM2.5 by 90,000 tons, and SOx by 920,000 tons per year, which is 23 percent, 74 percent, and 86 percent below current levels, respectively. The overall cost of the ECA is estimated at $3.2 billion. The ECA would be expected to save as many as 8,300 lives and provide relief from respiratory symptoms for over three million people each year. In total, the monetized health-related benefits of the proposed ECA are estimated to be as much as $60 billion in the U.S. in 2020.

For the U.S., the proposed ECA designation is one component of EPA’s coordinated strategy to address harmful ship emissions, along with our Clean Air Act (CAA) standards. In parallel to the ECA proposal, EPA is developing standards for Category 3 marine diesel engines that are expected to require the application of high efficiency after-treatment emission controls similar in stringency to the new NOx standards that will apply to all engines in the ECA.

The proposed area of the ECA includes waters adjacent to the Pacific coast, the Atlantic/Gulf coast and the eight main Hawaiian Islands. The proposed ECA would extend 200 nautical miles from the coastal baseline, except that it would not extend into marine areas subject to the sovereignty, sovereign rights, or jurisdiction of any State other than the United States or Canada.
Impact by EPA on Foreign flagged vessels.

The EPA’s harmonization of Category 3 marine engine controls with standards under MARPOL’s Annex VI address Tier 3 engine and sulfur fuel content of Category 3 marine engines, which correspond to MARPOL’s Annex VI Tier III controls. Following final action by the IMO, the ECA could enter into force as early as 2012. California and the European Union (EU) have already issued rules requiring vessels to use reduced sulfur content fuel in certain areas.

Ship emission standards represent a significant effort to reduce air pollution from large marine vessels. The EPA’s recent ruling attempts to harmonize standards to the most stringent of existing international marine pollution standards. The EPA’s final regulations will require testing, recordkeeping, reporting requirements and technical operating requirements that will only impact U.S. flagged vessels or marine engines destined for the United States for U.S.-flagged vessels.