September 9, 2014, the global maritime environmental congress was held in Hamburg, Germany. The conference covered ways to further improve the environmental footprint of ships.
Cmdr. Ryan Allain, chief of the Coast Guard’s environmental standards division and advisor to the United States’ delegation for the International Maritime Organization’s Marine Environmental Protection Committee, spoke at the conference.
Allain’s remarks provided an overview of environmental compliance exams, ship efficiency and liquefied natural gas and natural gas as a marine fuel.
Written by Cmdr. Ryan Allain
Primary focus areas of environmental compliance exams
As signatory to MARPOL Annex’s I, II, III, V and VI, the United States enforces the same maritime environmental compliance regime as most of the rest of the world. Through the Coast Guard’s Port State Control program, we conduct over 10,000 vessel exams a year to ensure vessel compliance with international and United States environmental requirements. Primary focus areas of these environmental compliance exams include:
• Sampling of fuel oil to ensure compliance with the North American and U.S. Caribbean Emissions Control Act, or ECA
• Examination of oil record books to ensure they accurately depict conditions on board a ship
• Verification of the salinity of ship ballast water to determine if ballast water was exchanged
Consistency in enforcement is paramount to ensure all ships are held to the same standard.
Another one of the Coast Guard’s high priority environmental initiatives is the Polar Code. The Coast Guard participates with the Arctic Council’s working group on the Protection of the Arctic Marine Environment to coordinate and sponsor basic scientific research that supports policy and standard development at the International Maritime Organization, or IMO. The Polar Code will establish mandatory and recommendatory measures for ships operating in both Arctic and Antarctic waters.
The Energy Efficiency Design Index contains design efficiency standards for new ships and was recently adopted by the IMO. The EEDI established international shipping as the only international transportation sector with mandatory measures for reducing CO2 emissions. The United States, along with other countries, thinks the efficiency standards for existing ships can be improved as well.
Currently, the IMO is in the process of data collection. We need to have good data on the current status of ship efficiency before we can really decide what can be improved.
Liquefied natural gas and natural gas as a marine fuel
The IMO has been working to finalize the International Gas Fueled Ships Code. The United States has seen quite a bit of interest in the use of natural gas as a marine fuel. We have received numerous inquiries and formal concept review requests from vessels fueled by LNG.
LNG as a fuel offers a number of potential benefits such as lower cost fuel and a viable option to meeting the North American ECA SOX emission requirements however, we need to address a few things first:
• Design and construction of LNG fuel systems
• Operations, training and general safety for personnel on vessels where LNG fuel systems are installed
• LNG transfer options
• Small scale LNG such as bunkering operations conducted from vessels and shore side facilities which are currently viewed in the context of large scale cargo transfers
U.S. Approach to Emissions Control Area or ECA enforcement
The Coast Guard and the Environmental Protection Agency, or EPA, share responsibility for ensuring that vessels comply with the U.S. Caribbean and North American ECA. The Coast Guard conducts port state control exams to ensure compliance with ECA requirements. If a ship is found to be non-compliant, enforcement action is referred to the EPA.
The Coast Guard also conducts weekly queries of our inspection database for Annex VI deficiencies and refers them to EPA for enforcement consideration. The EPA also analyzes Fuel Oil Non Availability Reports, or FONARs, for anomalies that may trigger further investigation.
My advice is to always notify the Coast Guard and EPA when ECA compliant fuel is unavailable. From an enforcement perspective, it is always better to be upfront when you know that the ship doesn’t comply with the ECA requirements before we conduct an inspection.
This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.