Liberia: Guidelines for implementing the 2021 revised MARPOL Annex VI on air pollution prevention from ships

Eda Zenic -

Liberia Maritime Authority has issued amended marine notice regarding the implementation of the 2021 revised MARPOL Annex VI, regulations for the prevention of air pollution from ships.

Purpose:

To provide detailed guidance on implementing the 2021 Revised MARPOL Annex VI regulations for the prevention of air pollution from ships, as updated by Resolution MEPC 385(81).

Key Changes and Updates:

  1. New Definitions: Section 1 includes new definitions to clarify terms used in the updated regulations.
  2. NOx Emissions Reporting: Section 12.2 is amended to mandate reporting for all cases where Tier II engines are accepted instead of Tier III engines.
  3. SOx Requirements: Section 12.3.14 is updated to clarify that SOx requirements are not applicable to gas fuel systems.
  4. Fuel Oil Quality: Section 14 has been revised to include low-flashpoint fuels and gas fuels in the bunker delivery note.
  5. Fuel Sampling Guidelines: Section 14.7 includes amendments to the guidelines for fuel sampling.
  6. Power Reserve Reporting: Section 15.10 introduces a new format for reporting power reserve usage.
  7. Early Data Collection: Section 15.11 allows for the voluntary early collection of data starting from 1 January 2025, including fuel consumption data per fuel type and consumer type, to be reported to the IMO.
  8. Recording 'Other Data': Section 16.7 now allows for the recording of additional data.
  9. Updated Attachments: Attachments 3, 4, 5, 7, and 8 have been updated, along with the Supplement to Annex 1. New attachments 9 and 10 have also been included.

Historical Context:

  • MARPOL Annex VI Ratification: Liberia ratified MARPOL Annex VI on 27 August 2002, which became effective on 19 May 2005.
  • Revised MARPOL Annex VI: Adopted by the IMO’s Maritime Environment Protection Committee (MEPC) in October 2008 via Resolution MEPC.176(58), effective from 1 July 2010.
  • Further Amendments: The latest amendments by MEPC Resolution 328(76), known as the 2021 Revised MARPOL Annex VI, came into force on 1 November 2022.

Applicability: The 2021 Revised Annex VI applies to all ships unless specifically exempted in the following regulations:

  • Regulation 13: Controls on NOx emissions for marine diesel engines over 130 kW, including engines that undergo major conversion post-1 January 2000, and specific requirements for engines installed on ships built between 1 January 1990 and 1 January 2000.
  • Regulation 3: Exemptions for emissions necessary for safety, emissions from damaged ships, emissions from sea-bed mineral resource activities, and UNSP barges without oil or equipment generating emissions.
  • Regulation 5: Survey and certification requirements for ships of 400 gross tons and above, including drilling rigs and platforms.
  • Regulation 15: VOC Management Plans are required only for oil tankers carrying crude oil.
  • Regulations 22, 23, 24, 25: EEDI (Energy Efficiency Design Index) and EEXI (Energy Efficiency Existing Ship Index) calculations for new ships and significantly converted ships, with some exemptions for non-conventional propulsion ships, certain cruise ships, and LNG carriers.
  • Regulations 26 & 27: SEEMP (Ship Energy Efficiency Management Plan) Part I and fuel oil consumption data collection for ships of 5,000 gross tons and above.
  • Regulations 26.3.1 & 28: SEEMP Part III and annual operational Carbon Intensity Indicator (CII) for ships of 5,000 gross tons and above falling into specific categories.
  • Regulation 19: Exemptions for non-mechanical propulsion ships, platforms, FPSOs, FSUs, and drilling rigs.

Certification Requirements:

  • Regulation 13: Marine diesel engines must have an Engine International Air Pollution Prevention (EIAPP) Certificate and a NOx Technical File.
  • Chapter 4: Ships must have an International Energy Efficiency (IEE) Certificate and, for new ships, an EEDI Technical File.
  • EEXI Compliance: Ships must carry an EEXI Technical File containing information and calculation processes for attained EEXI.

Fuel Usage: The revised Annex VI applies to all types of fuels used on board ships, including gas, heavy fuel oil, diesel oil, and gas oil for main and auxiliary engines, boilers, and gas turbines.