Although it is outside of the scope of this Correspondence Group to revise the NOx Technical Code it should be considered whether some general items are to be covered better by a new paragraph (6.4) to the NOx Technical Code than by the guidelines. Such items may be but are not limited to:

　

	-		Criteria for engine load points suitable to determine the weighted emission if the engine is normally not operated under the applicable test cycle specified in paragraph 3.2 of the NOx Technical Code;
	-		Requirements for accuracy, repeatability etc. of the measurement equipment;
	-		Methods of determination of the actual NOx emission value (as the total weighted emission of NO2) including correction to reference conditions;
	-		Allowances.

　

These items are general conditions for the relevant monitoring and recording devices. To specify them in a new paragraph 6.4 is comparable to provisions made in paragraph 6.3 of the NOx Technical Code where general conditions are specified for the "simplified measurement method". Nevertheless, EUROMOT proposes to collect general aspects (revision of the NOx Technical Code) as well as criteria important for the decision whether a device is suitable or not (guidelines) for approval of the device.

　

EUROMOT strongly recommends that some items must be solved by an amendment to the NOx Technical Code possibly immediately after coming into force: As we learned during the development of the NOx Technical Code guidelines are not mandatory; this was the reason to call it "Technical Code" and to leave the former term "NOx Guidelines". Such mandatory items are, for example, new ideas if agreed like the data process algorithm, the frequency of reporting etc. as proposed by the United States as well as references to existing paragraphs of the NOx Technical Code if these paragraphs are placed e.g. under "simplified measurement method" and therefore not automatically are valid for "direct measurement and monitoring method", like test cycles and allowances etc. Up to my opinion the guidelines to be developed mainly should be a "check list" for Administrations when approving a device as suitable for the foreseen purpose. Guidelines must not be a vehicle to introduce new mandatory requirements for the onboard verification of compliance. Guidelines also must not specify a certain device but the necessary performance of suitable devices.

　

　

Additionally to the periodic and intermediate surveys the Administration shall institute arrangements for unscheduled inspections to be carried out during the period of validity of the certificate, according to regulation 5 of Annex VI. Therefore, to draw data only during a certain period before the periodical and intermediate surveys may be insufficient in order to demonstrate continuous compliance. It seems to be reasonable to consider also the use of other types of analysers than normally requested for pre-certification, e.g. to accept also NOx analysers not based on the CLD principle. This is also covered by paragraph 5.4.2 of the NOx Technical Code.

　

As for the on-board verification procedure "simplified measurement method" already requirements to repeatability, zero drift, span drift etc. are fixed, for the other on-board verification procedure "direct NOx measurement and monitoring" similar values should be required.

　

In paragraph 2.3.5 of the NOx Technical Code is stated that to demonstrate compliance by the direct measurement method, sufficient data shall be collected to calculate the weighted average NOx emissions. It might be not sufficient to take only data for the most frequently operated load.

　

　

US recommends that "continuous" should be understood in its narrow sense and samples should be taken more frequently. Keeping in mind that direct measurement and monitoring is one of the on-board verification procedures it has to be agreed firstly the intention and definition of continuous monitoring (see also the attached proposal of EUROMOT in Annex 1). Monitoring and recording of all data necessary for determination of the actual emission value even for engine load points different to the cycle modes (or to load points agreed to as suitable for determination of the weighted emission) or for transient operation is no pre-requisite for suitable devices. As US also stated, actual engine operating conditions affect emissions. Therefore, actually measured values have to be corrected before comparing with initial values determined during pre-certification, i.e. with corrected values. Effects of ambient conditions etc are not comparable with differences in NOx emission for the different modes because the latter are mostly dependent on the engine design and adjustment. In any case, to demonstrate compliance a weighted average value has to be determined.

　

　

On the subject of NOx, I am reporting back following a meeting of the ICS Environment Panel on Friday, 7 September. Please note that the shipping industry does not support continuous monitoring. Our position is that we do support the provisions in the NOx technical code that put the onus for 'monitoring' on the manufacturer's bench test. However if there is a need for continuous monitoring then our plea will be for a system that is simple, cheap and above all does not place a burden on the seafarer. Incidentally, I understand that Japan may be informing the next MEPC on a new 'inexpensive' monitoring system.

　

The question we really need answering is - What is the objective of continuous monitoring? Does it benefit anybody and above all does it benefit the shipping industry? Unless we see a growth in incentive schemes for low emission then it would seem that both answers will be no!