Members will be aware from the Club’s legal briefing on stricter air pollution regulations and subsequent updates that from 1st January 2015 vessels trading in designated areas would have to use fuel on-board with a sulphur content of no more than 0.10%.
The US Coast Guard and the Environmental Protection Agency (EPA) are actively enforcing the North American and US Caribbean Emissions Control Areas (ECA). To clarify the penalties that may be imposed on vessels that violate the ECAs the Environmental Protection Agency has published a "Policy for Violation by Ships of the Sulfur in Fuel Standard and Related Provisions."
The policy sets out the methodology the EPA will use to assess civil penalties for violations of the pollution regulations involving the North American and US Caribbean Emission Control Areas.
A pdf of the penalty policy is available here: http://www2.epa.gov/sites/production/files/2015-03/documents/marinepenaltypolicy.pdf
If Members have any questions, please do not hesitate to contact Ioana Gonciari or your usual contacts at the Club.