the operation of every diesel engine to which this reguletion applies is prohibited, except when the emission of nitrogen oxides (calculated as the total weighted emission of NO2) from the engine is within the following limits in operaating under the designated test cycle speccified in Appendix V or this Annex.
Reason:
The test cycles used in the measurement of NOx emission, should be incorporated as an Appendix in the new Annex.
The test cycles used in the measureinent of NOx emissiun is the most important factor and has a strong relationship with the value of NOx emission.
The test cycles have been considered in the Correspondence Group on NOx Technical Guidelincs. After finalization of the test cycles, the Appendix should be developed and attached to the new Annex.
(ii) Delete paragraph (4).
Reason:
Definition and details of ready means of verification" have not been developed yet, but Japan supposes that this is quite a simplified checking method using the Technical File and Record Book of Engine Parameter, which is proposed in the NOx Technical Code. Japan proposes new regulations on the Technical Files and the Record Book in new Regulation 141 and 14 2.
It would be better to have the provision for enforcement to keep and maintain both documents.
Concerning the NOx monitoring and recording device, it is very difficult to verify the compliance with the limit value of NOx emission, since ships will not be operated under the condition on proposed test cycles in the NOx Technical Code. In this context, Japan would propose the deletion of this paragraph.
Otherwise, details about Ready Means of Verifications should be spelled out in the relevant regulations or at least in the NOx technical Code.
Regulation 14-1: Engine Paraweter Record Book
Add the following new Regulation 14-1, after Regulation 14.
"Regulation 14-1
Engine Parameter Record Book
(1)This regulation shall I apply to ships which have APP Certificate specified in Reg.6.
(2)The ships to which this regulation applies shall be provided with an Engine Parameter Record Book which is the record of adjustments, changes and repairs. The Engine Parameter Record Book, whether as a part of the ship's official log book or otherwise, shall be in the Form specified in [NOx lechnical Code] [Guidelines].
(3)The Engine Parameter Record Book shall be completed on each occasion, on an engine to engine basis if appropriate, whenever adjustments, changes and repairs are carried out.
(4)The Engine Parameter Record Book shall be kept in such a place as to be readily available for inspection at all reasonable times. It shall be preserved for a period of [ three ] years after the last entry has been made.
Reason:
The Record Book of Engine Parameter is extremely important to ensure the compliance with regulations.
This record Book contains records of adjustment, repair, etc., affecting NOx emission. Japan would also suggest that the provision prescribing the obligations to keep them on board and bring them up to date should be incorporated in the new Annex. The details of the Technical File should be specified in [ NOx Technical Code ] [Guidelines].
Regulation 14-2; Technical File
Also, add the following new Regulation 14-2.
Regulation 14-2
Technical File
Ships specified in Regulation 5(1) shall be provided withTechnical File including technical information related to NOx emission of engines. It shall be based on [ NOx Technical Code ] [ Guidel ines ] and approved by the Administration.
Reason:
This file is also an extremely important document for surveys and the port State control.
The File contains the technical information concerning the NOx emission performance.
Japan would also suggest the provision prescribing the obligations to keep them on board.
The details of the Technical File should be specified in [NOx Technical Code] [Guidelines].
