IN 1324 – Application to designate the North Sea and English Channel and the Baltic Sea ECAs as ECA NOₓ

Applications have been submitted to the next meeting of the International Maritime Organization (IMO) Marine Environmental Protection Committee (MEPC) to extend the scope of the North Sea & English Channel and the Baltic Sea Emissions Control Areas (ECAs) to ECA NOx.

If approved, any new ships constructed on or after 1 January 2021 would have to meet the Tier III NOx emission standard (see MARPOL VI Regulation 13) when operating within these areas.

Unlike emissions of sulphur oxide (SOx), emissions of nitrogen oxide (NOx) are regulated by engine certification.

MARPOL VI Regulation 13 is applicable to diesel engines only; gas turbine engines are excluded from its scope as are steam raising boiler. Tier III compliant engines may be significantly different to Tier II engines and be provided with additional systems such as selective catalytic reduction (SCR) or exhaust gas recirculation (EGR).

This should be expected to increase the cost of engines and potentially to increase the size of the engine and its associated systems. If SCR is fitted then additional reductant tank space will be needed, if EGR is used then this may also require chemicals and potentially effluent treatment if used in conjunction with heavy fuel oil (HFO).

This will affect new ships built from 1 January 2021 which are to operate in the North Sea, Baltic Sea and/or English Channel. If your ship is built before 1 January 2021, or if your ship will not operate within the defined areas then it will not affect you.

Ships built before the 1 January 2021 will have grandfather rights unless additional or non-identical replacement engines are installed in which case such engines will be subject to the Tier III emission limit.

At this time, nothing. MEPC70 will consider the applications, however it is unlikely that the applications will be unsuccessful. Assuming that the applications are successful as is likely then operators planning construction of new tonnage may want to consider building schedules so as to avoid having to buy and install Tier III engines.

As an alternative to SCR, EGR and other NOx reduction technologies, diesel engines operating on some alternative fuels such as liquefied natural gas (LNG) and methyl alcohol (methanol) may be able to achieve the Tier III emission limit without needing any NOx reducing systems. However, if operators elect to base their compliance strategy on use of a fuel associated with low NOx combustion characteristics then they should be aware that this will restrict their ships to operating on these fuels when in an ECA NOx. If they desire dual fuel operability, then the engines must be certificated on the basis of their emissions on oil fuel meaning that technologies such as SCR or EGR will still be necessary.