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Rules of the Road: Retain records to show fuel oil complies with ECA regulations

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Rules of the Road: by Capt. Jake Desvergers

Longtime sufferers of this column may recall this topic being discussed back in early 2012.  At that time, the North American Emissions Control Area (NAECA) was scheduled to begin enforcement on Aug. 1, 2012.  The NAECA was the world’s third largest such area. The two larger ECAs cover the North Sea and the Baltic Sea regions.

Impacted areas

The NAECA covers nearly all coastal waters of the United States (including Puerto Rico and the U.S. Virgin Islands) and Canada out to 200 nautical miles from their coasts. Within the ECA, ships and yachts of 400 gross tons and above are required to reduce harmful air emissions by adopting one of three approved alternatives.  These were:

Use fuel with a sulfur content that does not exceed 1.0 percent m/m.

Utilize an exhaust gas cleaning system approved by its flag administration in accordance with IMO guidelines.

Adopt any other technological method that is verifiable, enforceable  and approved by its flag administration in accordance with IMO guidelines.

Where applicable, yachts that burn more than one type of fuel must maintain detailed records regarding fuel changeovers. All yachts must continue the current requirement of retaining bunker delivery notes and samples.

Starting in 2020, even lower sulfur limits will be implemented. Finalization of those limits are in discussion at the International Maritime Organization.

On Jan. 1, 2015, the maximum sulfur content in fuel oil was lowered to 0.1 percent m/m. There is a general misconception that these types of rules do not affect private yachts or yachts below a certain tonnage threshold (i.e. 400 GT). This interpretation is 100 percent  wrong. Except for certain public vessels, as defined in 40 CFR 1043.20, all vessels that operate in the North American ECA are required to be in compliance with the fuel oil sulfur standard.

It is important to note that most small yachts and those that operate exclusively in U.S. waters are likely already in compliance. However, this does not alleviate a yacht’s responsibility to demonstrate compliance.

How to demonstrate compliance

For those yachts utilizing low-sulfur fuel oil and operating within the ECA, the following actions are recommended:

Record in a logbook the volume of low-sulfur fuel oil in each tank. Indicate the date and place where the fuel was obtained. For yachts over 400 GT, this will be entered in the Oil Record Book;

Request a Bunker Delivery Receipt (BDR) from the fuel supplier. On this document, it will indicate the volume of fuel delivered, the sulfur content of the product and additional information.  If receiving fuel from a truck or barge, the supplier should have this document readily available;

Request or self-obtain a sample of the fuel being delivered. It does not need to be a large amount. For yachts over 400 GT, this action is compulsory.  The resultant sample must be kept in the yacht’s possession for one year. It is critical that each BDR on file has a corresponding fuel sample and proper entry in the Oil Record Book.

For smaller yachts that typically obtain fuel at a marina, obtaining a BDR can be a difficult task. It is not a commonly available item. In those cases, both the U.S. Coast Guard and Transport Canada recommend that the crew write the sulfur content of the fuel on the purchase receipt. If a marina does not have the sulfur content readily available, it does not mean the information is nonexistent. No marine diesel may be sold in the U.S. and Canada without a specification sheet.  Federal law requires very bunker supplier to provide this information. A quick phone call or email usually sorts the issue immediately.

Most important, yachts need to especially utilize the above due diligence when obtaining bunker outside of the U.S. and Canada. Yachts fueling in the Bahamas and/or Caribbean and then traveling to the ECA must ensure that they are meeting the above specifications.

If it is discovered that the yacht entering the ECA is utilizing noncompliant fuel, significant enforcement actions can be actioned. This can involve monetary fines, arrest of the captain and/or engineer, or seizure of the yacht.

Capt. Jake DesVergers is chief surveyor for International Yacht Bureau (yachtbureau.org). Comments are welcome below. See recent related news here:  Commercial captain fined for burning high-sulfur fuel

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