ECM Client Alert 22-2019 - US ECA - USCG Guidelines for Compliance & Enforcement
US Emission Control Areas (ECA), USCG Guidelines for Compliance & Enforcement dated 07.11.2019
On 7 November, 2019, the USCG issued its CG-CVC Policy Letter 12-04 CH-1 which provides the CG’s latest Guidelines for Compliance and Enforcement of the Emission Control Areas established within the United States’ jurisdiction, as designated in MARPOL Annex VI, Regulation 14. Members are referred to the attached Client Alert 22-2019 from ECM Maritime Services LLC for details of these Guidelines.
If Members have any questions on these Guidelines, your usual contact at the Club would be pleased to assist you.
The USCG’s Office of Commercial Vessel Compliance (CG-CVC) has issued an updated guidance outlining how it will enforce Marpol Annex VI requirements, including the IMO 2020 Sulphur cap, within the two US. Emission Control Areas (ECA). Initial guidance on enforcement is also provided to USCG units not within either ECA. Please see ECM Maritime Services.LLC’s Client Alert 1-2020 for full details. Members are asked to note that the guidance previously provided in CG-CVC Policy Letter 12-04 Change 1 has been cancelled with immediate effect.
The Panama Canal Authority (ACP) has issued a new Advisory A‐15‐2017 which clarifies certain issues relating to requirements under the ACP's fuel regulations for all vessels transiting the Panama Canal.
The Club would like to remind Members that commercial vessels calling at the ports of Los Angeles and Long Beach will, in addition to complying with the U.S. federal government’s enforcement of MARPOL Annex VI and the California Air Resources Board’s enforcement of its low-sulphur and shore power connection (At-Berth) regulations, also have to ensure compliance with the rules of the South Coast Air Quality Management District (“AQMD”).
Marpol Annex VI requires ships to reduce SOx emissions either by burning low sulphur fuel or by cleaning the exhaust gas. Exhaust gas cleaning systems (EGCS), also known as “scrubbers”, have been fitted onboard many ships as an acceptable equivalent method of compliance under Marpol Annex VI. Many more ships are intending to have scrubbers fitted.
