Ireland

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As Ireland is a member of the European Union, Directive(EU) 2016/802 applies and a maximum of 0.10% sulphur fuel is to be used in port. Irish waters are not in a Emission Control Area defined by MARPOL Annex VI Regulation 14 and therefore the global limit of 3.50% sulphur applies to vessels except some passenger ships until January 1, 2020, when the limit will be reduced to 0.50%.  Passenger ships on regular voyages between EU ports (e.g. UK-Ireland ferries) are an exception, as subject to a limit of 1.50%S until January 1, 2020 under the EU Sulphur Directive.

A number of Irish ports have prohibited overboard discharges from exhaust gas cleaning systems to waters within their jurisdiction, citing the EU’s Water Framework Directive, 2000/60/EC and Environmental Quality Standards Directive, 2008/105/EC as the rationale:
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Ship operators should check if other Irish ports are similarly regulated.

United Kingdom

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The UK is to leave the European Union on 31 January 2020, however Directive(EU) 2016/802 will continue to apply during a ‘transition’ period currently scheduled to end 31 December 2020 and therefore a maximum of 0.10% sulphur fuel is to be used in port **. UK waters to the east and south in the English Channel are in the North Sea Emission Control Area as defined by MARPOL Annex VI Regulation 14 and therefore the limit of 0.10% sulphur also applies to vessels outside of ports.

Waters to the west of  the UK mainland and of Northern Ireland are not in the ECA and the IMO global fuel sulphur limt of 0.50% applies from January 1, 2020.  Passenger ships on regular voyages between EU ports (e.g. UK-Ireland ferries) are no longer an exception to this rule, and are now also subject to a limit of 0.50%S from January 1, 2020 under the EU Sulphur Directive.

** Further information on the UK’s withdrawal from the European Union can be found here.

Maritime & Coastguard Agency advice

In response to questions from EGCSA (March 2019), the UK Maritime and Coastguard Agency has advised that:

  • UK legislation on the use of Exhaust Gas Cleaning System (EGCS) is in accordance with the Merchant Shipping Regulations.
  • Transport Scotland does not have its own policies in-excess of this legislation.
  • Local ports and harbours have the right to impose stricter water quality requirements to any transport or industrial sector, including ship operations, in order for their region to meet water quality requirements under the Water Framework Directive.

As such ship operators are advised to check the latest requirements regarding the use of EGCS with the relevant ports and harbours authorities.

Click to view the email

Firth of Forth & Tay – Scotland

Forth Ports Ltd issued Notice to Mariners 45 of 2019 (2 Dec. 2019) titled “Use of Open Loop Scrubbers on the Forth and Tay“. 

The notice can be downloaded from the Forth Ports website here.

The notice recognises scrubbers as a means to deal with air pollution under MARPOL Annex VI, but goes on to cite OSPAR controls on disposal of dredge material in spoil grounds and a local bylaw – Forth Ports and Port of Dundee Byelaw 59 which prohibits the discharge of materials into the Forth and Tay.

Therefore, as a precaution, the company prohibits the use of “Open Loop” scrubbers on the Forth and Tay until further notice.

Forth Ports Authority byelaws give a definition for the docks and harbours of the Authority as “the docks and harbours of Burntisland, Grangemouth, Granton, Kirkcaldy, Leith, Methil and Newhaven, the Hound Point Marine Terminal and any other works which may from time to time belong to the Authority and includes the jetties, piers, quays, slipways and wharves of the said docks and harbours, marine terminal and other works and the recognised water approaches thereto.”

The byelaws also give geographic coordinates for the Hound Point Marine Terminal.

 

Singapore

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16 May 2019

MPA Port Circular 11 of 2019 on reception facilities (which can also be downloaded at the MPA website here) classifies exhaust gas cleaning residues generated by ships as Toxic Industrial Waste (TIW), which must be disposed of ashore through licensed collectors, if offloaded in Singapore.

EGCSA Comment:
It should be noted that analysis by an oil major has shown that residue from exhaust gas cleaning systems is no more harmful than used engine crankcase oil.

The IMO Exhaust Gas Cleaning System Guidelines, which is now in its fourth iteration since 2005, requires that the residues generated by the EGC unit should be delivered ashore to adequate reception facilities. Such residues should not be discharged to the sea or incinerated onboard. However it has never been deemed necessary for the Guidelines to require segregation of scrubber residue from, for example, centrifugal purifier or oily water separator waste for specialised shoreside disposal.

30 November 2018

In an opening address to the Singapore Registry of Ships Forum, Maritime & Port Authority Chief Executive Mr Andrew Tan, presented the MPA’s plan for introduction of IMO’s fuel sulphur limit of 0.50% in 2020.

In his speech Mr Tan advised that “the discharge of wash water from open-loop exhaust gas scrubbers in Singapore port waters will be prohibited. Ships fitted with open-loop scrubbers calling at Singapore will be required to use compliant fuel. Ships fitted with hybrid scrubbers will be required to switch to the closed-loop mode of operation. Singapore, as a party to MARPOL Annex VI, will be providing reception facilities for the collection of residues generated from the operation of scrubbers.”

This is confirmed in the MPA’s publication A Guide For Ships Calling To Port Of Singapore, which can also be found on the MPA website here.

See EGCSA’s statement on this announcement.

Green Port Programme

There is no Emissions Control Area around Singapore and the fuel sulphur limits under MARPOL Annex VI apply, however the Green Port Programme offers a 25% discount on port dues to ocean going vessels using fuel with a sulphur content of 0.50% or less as of  July 1, 2016.

Port Circulars & Notices including updates on port limits coordinates can be downloaded from:
https://www.mpa.gov.sg/media-centre

 

Hong Kong

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01 January 2019

Cap. 311AB Air Pollution Control (Fuel for Vessels) Regulation replaces the previous ‘at berth’ fuel rules and sets a 0.5%m/m fuel sulphur limit for vessels operating within Hong Kong waters, including at berth. Scrubbers can be used as an alternative method of compliance subject to grant of an exemption (application to be submitted at least 14 days before first arrival or exemption expiry):

There appears to be no restriction on the use of open loop scrubbers in port written into the Hong Kong legislation or in an accompanying government press release:

Compliant fuel required by the Regulation includes low-sulphur marine fuel with sulphur content not exceeding 0.5 per cent, liquefied natural gas or any other fuel approved by the Director of Environmental Protection. If a vessel uses emission reduction technology that can achieve the same or less emission of sulphur dioxide when compared with using low-sulphur marine fuel, it may be exempted from using compliant fuel. (Click for the full press release)

July 2015

Hong Kong is a special administrative region within the Pearl River Delta.

Cap. 311AA Air Pollution Control (Ocean Going Vessels) (Fuel at Berth) Regulation – [now replaced by Cap.311AB] sets a 0.5%m/m fuel sulphur limit for vessels at berth.

Scrubbers are allowed as an alternative method of compliance, however the exemption requires an application to be submitted at least 14 days before arrival:

Are there any exemptions?

A vessel may be exempted from using compliant fuel if that vessel uses technology which can reduce SO2 reduction at least as effectively as using low sulphur marine fuel or the compliance with the fuel switch at berth requirement will pose a risk to the safety of the vessel.

Application for exemption must be in writing in a specified form with supporting documents to the Environmental Protection Department at least 14 days in advance.

A link to  “A Guide to the Air Pollution Control (Ocean Going Vessels)(Fuel at Berth) Regulation” can be found at https://www.epd.gov.hk/epd/english/environmentinhk/air/prob_solutions/guide-air-pollution-control-ocean-going-vesselsfuel-berth-regulation.html