United Kingdom
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.
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.
