On the other hand, it is clarified in the text of the new Annex that the body to issue the lnternational Air Pollution Prevention Certificate is the Flag State Administration
Thus it is natural for the Flag State to ensure that engines comply with the NOx limit. Also with regard to other equipments regulatcd in SOLAS or MARPOL convention, Pre-Certificate is issued by the Flag State or recognised organization on its behalf. This means that issues of Pre-Certificate are merely a part of procedures of surveys carried out by the Flag State.
Because of the reasons above, Japan regards that it is not necessary to involve the provision on Pre-Certificate (EIAPP) in the NOx Technical Code at all.
8 If the above proposals in the paragraph 1 to 7 are accepted, the NOx Technical Code might also be amended or redrafted as appropriate to keep the consistency with the new Annex. These guidelines also should be made a compulsory code as NOx Technical Code because it includes esscntial and significant matters, such as detal Is of type approval or methods of NOx measuring, to ensure the appropriate implementaion of the new Annex.
9 Action requested of the Committee
The Committee is invited to consider the proposal above arid take action as appropriate.
Annex
1 The following marks are used in this ANNEX to identify the proposed revisions.
(1) Ellipsrs(...) indicate material which has not changed:
(2) Strike through indicates material proposed to be deleted:
and
(3) Underlined material is proposed for addition.
2 Proposed revisions to draft regulations (MEPC38/9)
Regulation 5; Surveys and Inspections
(i)Paragraph (1):Revise as Follows.
"(1)Every ship of 400 tons gross tonnage or above shall be subject to the surveys specified below
Reasons:
The power output is the scale directly relating to NOx emission from engines, Therefore, the use of this power output of engines' as the condition for al I items of surveys on ships, such as incinerators, VOCs, etc., does not make sense and is unreasonable.
The provision of Regulation 14 which prescribes the limit value of NOx emission applies to all engines of power output of more than 100kw. Under this provision, it is citrtain that all engines will be designed in accordance with this regulation.
(ii)Paragraph (7):Add the following new paragraph after existing paragraph (6).
"(7) For the purpose to ensure the compliance with the NOx limit specified in Regulation 14(3) (a) of this annex, the procedures and methods for survey arid inspection shall be subject to [NOx Technical Guidelines] [Code], in addition to paragraph (1) to (6) of this regulation.
Reason:
All provisions relating to surveys and inspections should basically be prescribed in Regulation 5. In this context, Japan also suggests that the present paragraph (b) of Regulation 14 should be transferred in this proposed paragraph (7) of Regulation 14.
Regulation 14: Nitrogen Oxides (NOx)
(i)Revise paragraph (3) as follows:
"(3)(a) Subject to the provision of regulation 3 of this Annex.
