United States                                  Office of Transportation and Air Quality
                Environmental Protection                                        EPA-420-F-12-040
                Agency                                                             June 2012
EPA Guidance on Use of Distillate Fuel for North American ECA Compliance
Question:  Does EPA require the use of 15ppm ULSD or other low viscosity marine fuel oils for
compliance with the 1.00% fuel sulfur ECA standard?

Answer: While distillate fuels meet the definition of a fuel oil, and therefore using distillate fuel
can clearly be an option to meet the 1.00% fuel sulfur ECA standard, EPA believes it is clear that
the MEPC  did not intend vessels to use straight distillate fuels (fuels with a viscosity below 11
Centistokes) to meet the 1.00% sulfur ECA standard. The technical analyses relied upon by
MEPC consistently assumed that a fuel sulfur standard of 0.5% would define the split between
residual fuels and distillate fuels and the MEPC consistently assumed that above 0.5% would be
a residual fuel or residual fuel blend, while below 0.5% would be primarily made up of distillate
fuels. In addition, distillate fuels below 1.00% sulfur are widely available in ports throughout the
world and have been and are used regularly by vessels for a variety of purposes.  Given this wide
availability and use, there would have been no need for the Regulation 18 fuel availability
provisions  in Annex VI if the MEPC intended vessels to use a widely available fuel to meet the
1.00% sulfur ECA standard. Finally, requiring vessels to use widely available distillate fuel
would simply advance the distillate standard set to begin in 2015.

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