13 Mar 2014
Canadian port state control (PSC) officials will not be ready to enforce the sulphur limit applying to vessels sailing in the North American Emission Control Area (ECA) when it takes effect on August 1, 2012.
Transport Canada (TC) has signalled that its national regulations and ability to fully enforce the ECA requirements should be in place sometime in November 2012.
Between August 1, 2012 and when the amended Canadian regulations come into force, TC and Canadian PSC cannot take any enforcement action for vessels that are not in compliance with ECA requirements.
The North American ECA, which stretches 200 nautical miles off the majority of the US and Canada coastlines, was formally approved by the International Maritime Organization (IMO) in March 2010.
All ships flagged in signatory states to MARPOL Annex VI are expected to comply with its provisions in all parts of the world. As such, ships will be expected to observe the North American ECA sulphur limits from August 1, 2012, even though Canada lacks the legal means of controlling enforcement.
Do you think vessels sailing in the Canadian part of the ECA zone will observe the 1.00% sulphur limit from August 1, even if Canada is unable to take enforcement action?
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It is fully expected that there will be non-compliance due to the difficulties of enforcement at the best of times so in the absence of any enforcement there will be higher than normal levels of non-compliance.
But the real question is not if but to what extent?
Of course, the North American ECA is far less expensive than the Baltic and North Sea and a proposed Mediterranean one.
With an open coastline vessels can enter and leave with a total ECA journey of around 400miles.
Since there is no interception at sea to check whether vessels are compliant at the moment they enter an ECA chances are most that are compliant will only be compliant for the last stages of their run into port.
Heading for St Petersburg say, there is a long journey from the English Channel to St Petersburg, all operated under ECA rules each way. So the chances are that the level of compliance ought to be higher in Canadian waters than was the case early in the Baltic and North Sea (subject to the price differences, availability etc.)
What may happen in the North American ECA is that some ports start to be differently preferred than others. Of course, if that means more trade diverts through Canadian ports in preference to nearby US ports and ditto Mexican ports, then there may be some signs that compliance is low.
As for your suggestion that vessels "will only be compliant for the last stages of their run into port" - maybe this will be the case, but I suspect it won't go down well with US authorities. The date, time and position of the ship when the fuel changeover operation was completed is supposed to be recorded in a vessel's logbook. If inspectors become suspicious that ship crew are fiddling with the records, it is quite possible that they will look at ways of exposing and penalising such behaviour. US authorities have certainly been coming down hard on those who have been found guilty of falsifying vessel oil record books to cover up illegal discharges of oily wastes.
this poll-result, that most vessels will not comply to ECA regulations, gives the answer:
Humans are bad and regulations needs strong penalty. An other way is, to use the wind again, like www.b9shipping.com and www.modern-merchant-sailing-vessel.com.
Best regards from www.windships.de , Heinz Otto