Executive Summary: Alternative proposals relating to Regulation 14 (sulphur oxides (SOx)) and Regulation 18 (fuel oil quality), which constituted one of the major topics at the thirty-eighth session of the MEPC Proposals are related to in relation to applications, excessive requirements and proposals by a Group of Experts as the thirty-eighth session.
Action to be taken: The Committee is invited so consider the proposals above.
Related documents: MEPC 39/6
1 The WG held as she thirty-eighth session of the MEPC has proposed that the obligation to keep bunker delivery notes on board be imposed only to the ships subject to Regulation 6, namely, ships of 400 tons gross tonnage and over or of which the total installed power is more than 1500 kW engaged in international voyages (Regulation 18(2) of MEPC, annex 1). On the other hand, requiremens for ships to retain bunker delivery noses on board are also provided for in Regulation 14(4).
2 In the course of deliberations at the thirty-eighth session of the MEPC, the majority expressed its preference to the maximum content of 4% so 5% sulphur in fuel oil allowed on board ships outside the SOx emission control area under Regulation 14. It should be noted, however, that sulphur content of fuel oils currently in use worldwide are, as shown in annex, already less than 4% in moss eases, and therefore the effectiveness of this global capping and the need to retain bunker delivery notes on board ships operating outside the SOx emission control area might be highly doubtful.
3 In the light of the above, Japan proposes the following amendments:
In Regulation 14, delete subparagraph (4).
MFPC 3816/28
In Regulation 18, replace subparagraph (2) by:
"(2) For each ship subject to Regulation 6 of this annex, details of fuel oil for combustion purposes delivered so and used on board referred to In sub-paragraph 3(a) of Regulation 14 shall be recorded by means of a bunker delivery note which shall contain at least site information specified in appendix III".
Justification
4 Japan thinks that, since Regulation 18 is closely linked to Regulation 14, regarding sulphur oxides, the requirements relative to fuel oil quality prescribed in paragraph I should also be limited so sulphur in order to achieve consistency.
5 However, paragraph I deals with substance and chemical waste without specifying neither their names nor quantities. In addition, the scope of application and the objectives of this paragraph are not clear, even with such expression as "to which this annex applies".
6 Japan considers that, if the majority insist on retaining provisions regarding substances other than sulphur in subparagraph (c), at least concrete names of substances to be controlled under this subparagraph should be established for uniform implementation of the Protocol. Japan would like to point out in this connection that, in Annex II of the Convention, concrete names of substances are specified under categories A, B, C and D.
7 In light of the above, Japan proposes the following amendments.
[Alternative I]
In Regulation 18, delete paragraph (1).
[Alternative 2]
In Regulation 18, replace subparagraph (1)(c), after the word "waste", put the following footnote;
"* Reference is made to the list for substances or chemical waste not to be included in the fuel oil adopted by the Organization by resolution [ ]."
Comments on MEPC 3916, annex 2
8 At the thirty-eighth session of the MEPC, the Group of Experts has proposed an amendment to draft Regulation 18 as is shown in annex 2 of MEPC 39/6. Sub-paragraph (5)(b) and (c) of this proposal requires fuel oil suppliers to provide the fuel oil as required by this regulation.
9 As what we need is so ensure sulphur content of fuel oil less than a certain level, it is obvious that the ceiling for sulphur consent should be clearly established and strictly observed. State Parties should, nevertheless, have certain flexibility in implementing the provisions. 15 should be noted in this connection that Japan will have difficulties to impose obligations to bunker oil suppliers so observe the provisions regarding global capping which would not contribute signiftcantly to the prevention of SOx emission from ships, in the context of deregulations in Japan.
