California Air Resources Board: Ocean Going Vessels Fuel Rule Sunset Review Process Update
In August 2014 the Club advised that the California Air Resources Board (CARB) would instigate a sunset review process to determine whether the MARPOL requirements that came into force on 1 January 2015 would provide an equivalent reduction in emissions to the CARB’s Ocean Going Vessels (OGV) fuel rule.
Although MARPOL reduced the maximum sulphur content for fuel oil from 1.0% to 0.1% within emission control areas, which aligned with the OGV fuel rule maximum sulphur content, MARPOL allows the use of low sulphur heavy fuel oil, whereas the OGV fuel rule only permits the use of distillate fuel (MDO or MGO). MARPOL also allows the use of alternative technologies (eg exhaust gas scrubbers), however, the OGV fuel rule does not allow the use of such technologies as a means of compliance.
The CARB, as advised in Marine Notice No. 2016-1, has completed its review of the differing compliance regimes, and concluded that the MARPOL requirements in force at present would not achieve equivalent emissions reductions in Californian waters, when compared to the OGV fuel rule requirements. The CARB plans to re-evaluate the situation in two years as it will allow the federal MARPOL enforcement program to become established, and permit the CARB to examine the emissions impact of vessels using alternative technologies such as exhaust gas scrubbers, and from the use of low sulphur heavy fuel oil.
Members requiring further guidance should contact the Loss Prevention department.