(iii) each diesel engine with a power output of more than 130 kW which is installed on a ship to which regulation 6 applies on or after 1 January 2000, and
(iv)each diesel engine with a power output of more than 130 kW which is installed on a ship to which regulation 6 applies and which undergoes a major conversion on or after I January 2000."
4 (1) In Japan, there are tens of thousands of ships equipped with a diesel engine with a power output of more than 130 kW and engaged in domestic voyages. Before the entry into force of thin Protocol it is difficult for their shipowners to instal diesel engines which comply with the requirements of NOx emission control voluntarily. Japan believes, therefore, that the application of this regulation to the ships engaged in domestic voyages should be at the discretion of each Administration.
(2) On the other hand, taking into account the fact that the ships engaged in international voyages emitting NOx within the territorial waters of other countries will be controlled by a port State in a reliable and fair manner, application of regulation 13 to existing ships engaged in international voyages could be acceptable.
Regulation 5 - (Surveys and Inspections), Regulation 6 - (Issue of International Air Pollution Prevention Certificate)
5 Japan has proposed to apply regulation 5 to "Every ship of 400 tons gross tonnage or above" and not to "Every ship of 400 tons gross tonnage or above or of which the total installed power in more than 1,500 kW" before. Japan now submits, in a spirit of compromise, the following proposals on regulation 5
1 Replace present paragraph (1) by the following two paragraphs:
(1) This regulation applies to
(a) ships of more than 400 toss gross tonnage, unless expressly provided otherwise, and
(b) tug boats or pusher boats of more than [ISO] tons gross tonnage.
(2) Ships prescribed its paragraph (1) shall be subject to the surveys specified below.
(a) Transfer from the present paragraphs (1)(a) to (c).
(b) Transfer from the present paragraphs (1)(a) to (c).
(c) Transfer from the present paragraphs (1)(a) to (c).
2 Renumber the remaining paragraphs accordingly.
6 Japan also proposes that in regulation 6(1), "or of which the total installed power is more than 1,500 kW" be replaced by "or above".
MEPC 39/6/25
7 These proposals are justified by the following considerations.
(1) Engines are used to adjust the output according to the performance of the ships and the usage of engines although they have the same structures. With regard to the main engines, the de-rating of a power output of engines is usually carried out for the purpose of improving the fuel consumption;
(2) An a result, for example, when a diesel engine is designed and produced with a power output of 1 ,800 kW originally but it is de-rated and approved as a diesel engine with a power output of 1,450 kW and installed on board, the application of surveys and
inspections of diesel engines is different although they have the same structures. Such cases may cause confusion;
(3) Moreover, it would be possible to raise the power outputs of dc-rated engines after installation and it would be difficult to identify such a modification from the outside. In case the power outputs of dc-rated diesel engines are less than 1,500 kW, the surveys and inspections are not required, therefore, Administrations have no chance so identify such modifications and correct them;
(4) As mentioned above, if the total power output of diesel engines would be introduced as the criterion of the application for surveys and inspections, some confusion and unfairness would arise Therefore, Japan cannot support the introduction of the total power output of diesel engines to the criterion for the application prescribed in regulation 5 of this Annex; and
(5) On the other hand, Japan recognizes that ships installed with a great power output of diesel engines, even if they are small like tug boats, should be subject to surveys and inspections Concerning the necessity of surveys and inspections for such ships, Japan believes that it is not difficult to specify ship types in the Protocol.
Harmonized System of Survey and Certification (HSSC)
8 Japan would like to point out that the scheme of the HSSC is not incorporated in the provisions of the draft regulation 5 (Surveys and Inspections) and the draft regulation 6 (Issue of International Air Pollution Prevention Certificate).
9 At present, SOLAS 88 Protocol and LL 88 Protocol on HSSC have not entered into force yet. The Secretary-General of the Organization has invited alt Member Slates to conclude these two Protocols as soon as possible If these Protocols have entered into force, the amendment to incorporate HSSC into MARPOL 73/78 has also entered into force.
10 In the present situation, it is impossible so anticipate which will ester into force first: this Protocol, or SOLAS 88 and LL 88 Protocol regarding HSSC. Japan nevertheless believes that the Organization should develop the Protocol on the assumption of entry into force of HSSC.
Action requested of the Committee
11 The Committee is invited to consider the above comments and take action as appropriate.
