Frequently Asked Questions about
the Emission Control Area Application
Process
The United States Government is planning to request that the
International Maritime Organization designate an area off our
coasts in which stringent international emission controls would apply
to Ocean-going ships. The U.S. Environmental Protection Agency is
currently preparing the documents for this application package. This
information sheet answers questions we have heard from stakeholders
about the application package and approval process.
What are the international marine standards and why is appli-
cation for area designation necessary?
In October 2008, the International Maritime Organization (IMO) adopted stringent
new standards to control harmful exhaust emissions from the engines that power
ships. The IMO is the United Nations agency concerned with maritime safety and
security and the prevention of marine pollution from ships. The standards are found
in Annex VI to the International Convention on the Prevention of Pollution from
Ships (MARPOL).
MARPOL Annex VI is a program that consists of two sets of standards to control
emissions from ships. The global standards for the sulfur content of fuel and nitrogen
oxides (NOx) emissions from engines apply to ships at all times. In recognition that
some areas may require further control, Annex VI also contains geographic-based
standards. Ships operating in designated Emission Control Areas (EGAs) are re-
quired to comply with more stringent fuel sulfur and engine NOx limits.
United States
Environmental Protection
Agency
Office of Transportation and Air Quality
EPA-420-F-09-001
January 2009
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The table below summarizes the global and geographic-based international standards and their
phase-in schedule.
International Ship Engine and Fuel Standards (MARPOL Annex VI)
Emission Control
Area
Global
Year
Today to Jul 20 10
2010
2015
2016
Today to Jan 20 12
2012
2020
2011
Fuel Sulfur
1 5,000 ppm
10,000 ppm
1,000 ppm
45,000 ppm
35,000 ppm
5,000 ppm
NOx
Tier 3 Aftertreatment*
Tier 2 Engine Controls*
* Today's Tier 1 NOx standards range from approximately 10 to 17 g/kW-h, depending on engine speed. The
Tier 2 standards represent a 20% NOx reduction below Tier 1, and the Tier 3 standards represent an 80%
NOx reduction below Tier 1
These international standards are an important part of our national program to reduce NOx
and particulate matter (PM) emissions from ships operating in areas that affect air quality in the
U.S. To achieve the full benefits of the international program, areas off our coastlines must be
designated as an EGA.
Who can apply for EGA designation?
To be eligible to submit an application to designate a new EGA, an interested country must
have ratified, and thus become a Party to, MARPOL Annex VI. An application for an EGA
must be approved by the Parties to MARPOL Annex VI; this would take place at a meeting of
the Marine Environment Protection Committee (MEPC). The U.S. deposited its Instrument
of Ratification with the IMO on October 8, 2008. Annex VI entered into force for the U.S. on
January 8, 2009, thus the U.S. is now eligible to apply for an EGA.
The U.S. Environmental Protection Agency (EPA) has the lead on developing the EGA ap-
plication package for the U.S. Government. We are coordinating with U.S. Coast Guard, State
Department, the National Oceanic and Atmospheric Administration and other agencies to
develop the package.
What are the required components of an EGA application?
The criteria and procedures for EGA designation are set out in Appendix III to MARPOL An-
nex VI. To be approved, an EGA application must demonstrate a need to prevent, reduce, and
control emissions of sulfur oxides (SOx), PM, and/or NOx from ships. The specific criteria are
summarized below.
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Annex VI Appendix III requires:
> a delineation of the proposed area of application;
> a description of the areas at risk on land and at sea, from the impacts of ship emissions;
> an assessment of the contribution of ships to ambient concentrations of air pollution or to
adverse environmental impacts;
> relevant information pertaining to the meteorological conditions in the proposed area of
application to the human populations and environmental areas at risk;
> description of ship traffic in the proposed EGA;
> description of the control measures taken by the proposing Party or Parties;
> relative costs of reducing emissions from ships compared with land-based controls; and
> an assessment of the economic impacts on shipping engaged in international trade.
What is the expected timeline for the U.S. EGA application to the
IMO? When an application is submitted, what are the steps and time-
line for approval and for implementation?
Now that the United States has ratified Annex VI, the first opportunity to apply for EGA desig-
nation for U.S. coasts is at the 59th session of the Marine Environment Protection Committee
(MEPC 59), to be held in London in July 2009. To allow for time for translation of the package
into the working languages of the IMO, the EGA application must be submitted no later than
March 2009.
An application for EGA designation must be approved by the Parties to Annex VI, as an
amendment to Annex VI. Assuming the application is considered at MEPC 59, the earliest
possible approval date is the following MEPC meeting, MEPC 60, which is anticipated to take
place in March 2010. Given the MARPOL amendment acceptance process and the lead time
specified in the regulations, an EGA submitted on this timeline could be expected to enter into
force as early as August 2012.
How would vessel operators be affected?
Since the EGA is likely to become effective between 2010 and 2015, ships operating in the
EGA would be required to use fuel with a sulfur content not exceeding 10,000 ppm; in 2015,
this would be reduced to 1,000 ppm. In most cases, ships already have the capability to store
two or more fuels. However, to meet the 2015 requirement of 1,000 ppm fuel sulfur, some ves-
sels may need to be modified for additional distillate fuel storage capacity. As an alternative to
using low sulfur fuel, ship operators may choose to equip their vessels with exhaust gas cleaning
devices ("scrubbers"). In this case, the scrubber extracts sulfur from the exhaust.
In addition, engines on vessels constructed in 2016 and later would need to comply with the
Annex VI Tier 3 NOx limits, when operating in an EGA. These NOx limits are expected to
necessitate the use of aftertreatment technology, such as selective catalytic reduction (SCR).
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Are there any EGAs currently in effect?
Yes, there are two EGAs in effect today, exclusively controlling SOX thus they are called Sulfur
Emission Control Areas, or SECAs. The first SEGA was designated to control the emissions of
SOX in the Baltic Sea area, and entered into force in May 2005. The second SEGA was desig-
nated to control the emissions of SC" in the North Sea area, and entered into force in Novem-
A
her 2006. Ships operating in these areas must currently use fuel with a sulfur content that does
not exceed 15,000 ppm.
Is the U.S. intending to submit a joint application with Canada and/or
Mexico?
We are collaborating with Environment Canada with the intent to submit a joint U.S./Canada
EGA application. President Bush and Canadian Prime Minister Harper agreed on this approach
at the March 2006 Security and Prosperity Partnership meeting. While our mutual goals could
be met with individual applications, a joint application will be received more favorably at the
IMO.
We have also had discussions with the Mexico National Institute of Ecology (INE) regarding
inclusion of Mexico in the joint application. While the INE has expressed interest, there is
concern that it will not be possible to perform the necessary inventory and air quality analyses
in time for a submittal to MEPC 59. In addition, it is not clear if Mexico will ratify Annex VI in
the near term. We expect to work with Mexico separately, if necessary to extend the EGA in the
/i \ future.
How far off the U.S. coastline will the EGA extend? How will practicali-
ties like the sovereign waters of adjacent nations be handled in the
application?
We have not yet completed all of the analyses that will be necessary to make a determination of
the boundaries of a U.S./Canada EGA. Preliminary air quality modeling suggests that emissions
from ships are transported over great distances. As such, the area included in the application
will likely be continuous along the coasts.
In the case of adjacent nations, the EGA would not extend into the exclusive economic zones
(EEZ)1 of countries that are not part of the application, even if the emissions from ships operat-
ing in the EEZs of those countries have an impact on U.S. air quality. Generally a country's EEZ
extends to a distance of 200 nautical miles (nm) out from its coastal baseline. One exception is
in the area around Florida, where the U.S. EEZ is much smaller because of the proximity to the
Bahamas EEZ.
1 An EEZ is a seazone over which a country has sovereign rights for the purpose of exploring, conserving
and managing natural resources of the seabed and subsoil and the superjacent waters. For more informa-
tion on the U.S. EEZ, see http://www.nauticalcharts.noaa.gov/csdl/mbound.htm
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Will the coasts of Alaska and Hawaii (and other U.S. territories) be in-
cluded in the application? If not, can they be included in the future?
Ideally, we would like to include all of the U.S. coasts in our application for EGA designation,
including Alaska, Hawaii, and the U.S. territories. To do so, however, we will have to provide
information that demonstrates a need for control, as specified in the criteria for EGA designa-
tion. This is challenging because, although our emissions modeling includes all 50 states, our air
quality modeling does not extend beyond the 48 contiguous states. Therefore, it will be neces-
sary to find other ways to measure the health and environmental impacts of marine emissions on
health and human welfare outside the continental United States.
We have not made a final determination on whether the coasts of Alaska and Hawaii will be
included in the initial U.S./Canada EGA application. We are working with the Alaska DEC
and Hawaii DOH to generate information that would better inform us of the health and envi-
ronmental impacts that shipping may have in these states. We have not yet engaged other U.S.
territories on this issue.
We intend to submit an application for EGA designation at the earliest possible date cover-
ing the areas for which we have the strongest case. If the case for controlling additional areas is
compelling, such areas would be included in a future, supplemental application for EGA desig-
nations.
Will designation of a U.S. EGA encourage shipping lines to divert "dis-
cretionary" shipments away from U.S. ports (in favor of nearby ports
not within the designated EGA)?
We are exploring this question as we develop our application for EGA designation. Our current
analysis suggests that this will not be the case. We don't expect shipping to shift from U.S. ports
to ports outside the EGA. Shippers currently choose ports for a number of reasons including
available facilities, geographic location, and access to land-based distribution channels (railroads
and highways). EGA designation will not affect these underlying reasons for choosing one port
over another. In addition, the increase in fuel costs associated with operating in an EGA zone
are expected to be small compared to the total fuel costs of ocean-going vessels, since operating
in the EGA would be only a small portion of the total operating time of such a vessel. Even if
it would be advantageous for a ship to take steps to avoid operating in an EGA, at least some of
those benefits would likely be offset by additional costs in terms of time and labor.
Finally, we expect the EGA to cover a continuous zone along U.S. and Canadian coasts, and
Mexico at a later date. Therefore, the options for avoiding the EGA by using some other port
would be limited.
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Will the low-sulfur fuel that meets the EGA requirements be available
when the U.S. EGA goes into force? What will happen if the fuel is not
available in time?
Distillate fuel is already available, in the U.S. and Canada, which would meet the long term
1,000 ppm fuel sulfur limit that applies in EGAs beginning in 2015. Although a U.S./Canada
EGA could result in additional demand for distillate fuel, on a global scale, we believe the
amount of distillate fuel used in an EGA would be very small.
Global distillate fuel demand is projected to grow significantly over the timeframe of the long
term EGA standards. The U.S. Energy Information Administration projects an annual growth
in global demand for refined products of about 1.5 percent per year over the next five years.2
This growth is largely from developing economies such as in India and China. In response to
this demand, refineries have planned and begun substantial refinery capacity expansion projects.
In comparison to this growth in distillate supply and demand, any effect on demand from a U.S./
Canada EGA would be small.
What are the projected health benefits from a U.S. EGA designation?
Projected economic benefits? How do these outweigh the differential
fuel costs?
Many of our nation's most serious nonattainment areas for ozone and particulate matter with
diameter less than 2.5 microns (PM25) are affected by emissions from ships. Currently more than
40 major U.S. ports are located in nonattainment areas for ozone and/or PM25 and are heavily
impacted by these emissions. The contribution of these engines to air pollution is substantial
and is expected to grow rapidly in the next two decades. Without further action, by 2030, NOx
emissions from ships are projected to more than double, growing to 2.1 million tons a year, while
annual PM25 emissions are expected to almost triple to 170,000 tons.
In preparation for an EGA designation application, EPA is performing a number of scientific
and economic analyses including air quality, health effects, deposition, and refinery modeling.
Preliminary results suggest that the health (and other) benefits would greatly outweigh the costs
of an EGA. The application will use our final air quality modeling and benefits analyses to make
a strong case for an EGA designation based on the health and environmental impacts of the
sulfur, particulate matter, and NOx emissions from ships.
How would a U.S. EGA be implemented and enforced under U.S. law?
MARPOL Annex VI is implemented by U.S. law through the Act for the Prevention of Pol'
lution from Ships (APPS). APPS grants authority to both the EPA and the U.S. Coast Guard
with respect to implementation and enforcement. EPA has authority to issue regulations to
implement the standards; we expect to work with Coast Guard as we develop those regulations.
Coast Guard and EPA each have enforcement authority, although the Coast Guard will have
the lead especially with respect to vessel surveys and compliance actions.
2 U.S. Energy Information Administration, "International Energy Outlook 2008," September 2008, www.
eia.doe.gov/oiaf/ieo/index.html.
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How does an EGA fit into EPA's Clean Air Act Program?
An Emission Control Area is part of a three-part program to address emissions from shipping,
along with the stringent international standards recently adopted by the IMO and our Clean Air
Act standards for Category 3 marine diesel engines. In our Advance Notice of Proposed Rule-
making, we indicated we are considering standards similar to the program set out in the United
States Government submittal to the IMO for the international program (see 72 FR 68522, De-
cember 5, 2007). We are currently preparing a Notice of Proposed Rulemaking for the Clean Air
Act program, and the final rule is due by December 17, 2009 (see 72 FR 69518, December 7,
2007). More information about our Clean Air Act marine diesel engine program can be found at
www.epa.gov/otaq/marine.htm and www.epa.gov/otaq/oceanvessels.htm.
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