Comments on the draft regulations on NOx reduction in new MERPOL convention for the prevention of air pollution, which has been prepared as MEPC38/9.
Japan would like to make some comments on the draft regulations on NOx reduction contained in the draft Annex.
Although some revisions to the draft regulations in relation with our comments are described in Annex, the summary of them is as follows;
1 General application for surveys and inspections of ships
The present draft regulation 5(1) states that every ships of 400 tons gross or above, or of which the total installed power is more than 1500kW, shall be subject to the surveys. Japan would like to propose that application of surveys for ships should be decided using the value of "gross tonnage" only there are many survey items, such as SOx emission, VOCs, etc. in this new Annex, however, the unit 'kW" is relating to engine size only. Therefore, the condition prescribed by "kW' should be deleted.
2 The_provision on procedures and methods of surveys and inspections for engines
In Regulation 14(5) of draft new Annex, it is stated as follows:
The survey of engines and equipment prescribed in regulation 5 of this Annex shall be conducted in accordance with the [NOx Technical Code] [Guide lines] developed by the Organization.
However, it seems that all matters on survey and inspection for engine: should be stated appropriately in Regulation 5 "Survey" in order to avoid confusion.
3 Technical File and Record Book of Engine Parameter
Both materials are proposed in the NOx Technical Code and are very important for surveys and port State control.
Japan would also suggest the new provision prescribing the obligations to keep them on board and bring them up to date.
4 Ready Means of Verifications
Definition and details of ready means of verification has not been developed. In this connection, Japan considers that it is sufficient and appropriate to ensure the NOx emission performance by having Technical File and Record Book described in paragraph 3. Also, the NOx monitoring and recording device is useless as a means of verifications between periodical surveys. Therefore, Japan would like to propose the deletion of draft Regulation 14 (4).
5 Data of application on NOX regulation for engines
In the proposed draft regulation 14. the date of the application of this provision is given as [1 January 1998]. Japan would like to suggest changing the proposed date to the date "1st January 2000". From an economical and physical viewpoint, such an early implementation date, 1 January 1998, is unrealistic and unreasonable.
6 Test Cycles
The test cycles used in surveys for engines on NOx emission are very important factors in surveys to determine the NOx emission, and should be incorporated as an Appendix [ ] of the new Annex. This should also be refereed to in the draft Regulation 14(3).
7 Issue of Pre-Certificate (EIAPP Certificate)
Until now, members of the correspondence group have considered developing the NOx Technical Code.
These guidelines provided a scheme for an issue of Pre-Certificate(EIAPP Certificate) for engines whose compliance with the NOx limit are proved on test bed.
