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News: Reminder of requirements for complying with the California Ocean-Going Vessel Fuel Regulation

24 January 2020

 

Background

The California Air Resources Board (CARB) adopted the 'Fuel Sulfur and Other Operational Requirements for Ocean-Going Vessels within California Waters and 24 Nautical Miles of the California Baseline' (OGV Fuel Regulation) in 2008.

This regulation requires the use of cleaner-burning low sulphur marine distillate fuels by vessel main engines, auxiliary engines, and auxiliary boilers within 24nm of the California coastline. More importantly, the regulation does not allow compliance via scrubbers. Only the low sulphur distillate grades of fuel (marine gas oil or marine diesel oil) can be used to comply with the OGV Fuel Regulation.


New Marine Notice

CARB has now issued Marine Notice 2020-1 to remind vessel owners and operators that the requirements under the OGV Fuel Regulation remain in effect. The notice provides a comparison on the key regulatory requirements between the OGV Fuel Regulation, the North American ECA Regulation and the IMO 2020 sulphur cap.

Provisions in the IMO 2020 Regulation that differ from the California OGV Fuel Regulation include, but are not limited to:

  • The IMO 2020 Regulation allows the use of abatement technologies such as scrubbers, while the CARB OGV Fuel Regulation does not allow compliance via scrubbers. 
  • The IMO 2020 Regulation requires that a fuel does not exceed the 0.5% sulphur limit, while the OGV Fuel Regulation requires that the fuel meets specifications for distillate grades (marine gas oil or marine diesel oil) and does not exceed a 0.1% sulphur limit.

 

Summary

Members who have installed scrubbers (open or closed loop) onboard in order to comply with the 2020 global sulphur cap may not use those once the vessel is within 24nm of the Californian coastline.

Furthermore, vessels within 24nm of California must burn distillate fuels (marine gas oil or marine diesel oil), and not ultra-low sulphur fuel oil (ULSFO), with a sulphur content of 0.1% or less.

The club will continue to update members about relevant regulatory developments in North America.

 

Further information