involvement of the Maritime and Coastguard Agency (MCA) and the only marine organisation appearing in the list of those consulted, apart from manufacturers of marine and industrial diesel engines, is British Marine.
However, intervention by the Passenger Boat Association, the Port of London Authority and representatives of the IMarEST Small Ships Group caused DfT to extend the deadline for consultation and open an ultimately fruitful and supportive dialogue with representatives of the commercial and leisure maritime and inland waterways sectors. Through this process, it became clear to DfT that several aspects would need to be specially considered, when introducing legislation, which affects inland waterways marine machinery:
- Inland Waterway Vessels and Recreational Craft tend to have a much longer operating lifespan than other Non-Road Mobile Machinery (NRMM).
- The engine and fuel systems technology in many of these vessels is not ‘state of the art’. Indeed much of it could be described as ‘old but reliable technology’ which may be operating for many years yet.
- The tanks and fuel systems in many inland waterways and other vessels, likely to be affected, cannot readily be drained entirely of water.
- The engines fitted to these vessels vary from hundreds of horsepower in fishing vessels, ferries, yachts and tugs down to 10 horsepower (7.5 KW) or less in some narrow boats and other smaller vessels.
Many of these vessels, both commercial and recreational, can be laid up over winter for fairly long periods of time. This is particularly true for the passenger boat trade and on the canal system where low temperatures prohibit recreational use and the canals themselves can frequently freeze over.
- The presence of salt water, dampness and condensation, the presence of bridges and locks on inland waterways, the operation of these vessels on fast flowing rivers and the ever- present considerations of marine safety all demand a degree of machinery reliability over and above that of other NRMM.
- From time to time, a large proportion of inland waterways vessels proceed to sea. So different fuel requirements would complicate logistic requirements.
Additionally, at the time of the initial stages of information gathering, it was not clear that there had been any meaningful tests carried out to ensure navigational and public safety or to determine the long term effects of changes to fuel specifications on the operation and maintenance of this wide range of marine engines, old and new, large and small.
As from 1st January 2011, the European Directive required that the limit on Sulphur content of NRMM and inland waterways Diesel fuel would be reduced to 10 ppm (0.001 %). This is classed as “Ultra- Low Sulphur” or “Sulphur-Free” fuel. The UK governing legislation took IW and marine considerations into account and the UK regulations came into force on 14th January 2011. After this date it became illegal to distribute or offer for sale diesel fuel with a greater than 10 ppm Sulphur content, for the purposes of NRMM and IW recreational and commercial vessels not operating “to sea”.
The European Directive was effectively a means of regulating sales of fuel, rather than upon the use of fuel. So, the requirements enforced in England and Wales by the appropriate Local Authorities, with special arrangements in Scotland and Northern Ireland. It remains unclear, at this stage, how local authorities accommodate this task but expected that enforcement should be undertaken by Trading Standards Officers.
Because the ISO, EN and BS standards were revised to align with the planned proposals for reduction of sulphur and aromatics, the refiners, blenders and distributors provide options of:
- EN590:2009 road diesel fuel (DERV), at Duty-paid price, with less than 10 ppm sulphur and up to 7% bio-diesel, as currently available for road vehicles.
- The same fuel with red dye added, calling it ‘Red Diesel’, at Duty-free (for commercial or non-propulsion leisure purposes) either under EN590:2009 or BS2869:2010 specification.
- “Red Diesel” fuel, to BS EN 2869:2010 Class A2 and red dye added, for Duty purposes, with less than 10 ppm Sulphur but zero % or de minimus bio-diesel.
This “FAME-Free” Red Diesel should become the fuel of choice, for inland waterways operators.
Alternatively:
- In UK tidal port areas, where the UK regulations do not apply and where ships’ Marine Gas Oil is available from distributors, “sea- going” operators may order fuel to ISO8217:2012 Category DMA or BS2869 Class D (essentially the same fuel), which is by specification free from FAME but has sulphur at up to 1,000 ppm.
BENEFITS OF THE NEW STANDARDS
ENVIRONMENTAL
As part of the UK Air Quality Strategy, the UK is committed to a progressive reduction of emissions into the atmosphere.
The principal areas of concern are Oxides of Nitrogen, Hydrocarbons and Particulate Matter and this strategy is directed not only at road vehicles, but also at Non-Road Mobile Machinery.
The Report • December 2017 • Issue 82 | 53
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