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The reduction of Sulphur content of diesel fuel to 10 ppm is addressing two issues:


- The catalytic emissions control technology necessary to achieve the required level of pollution reduction is available and is currently in use on road vehicles. It is, however, intolerant to Sulphur. Road vehicle diesel already has this reduced Sulphur content. The reduction of Sulphur content in fuel for NRMM allows the emissions control technology to be used on NRMM as well, a process which started from 1st January 2011 on new engines.


- A continuing general reduction of Sulphur emissions is of benefit to the environment in reducing the acidity of rainfall, etc.


SUSTAINABILITY


With the development of vegetable-based fuels and the increasing cultivation of oil- producing plants for the bio-fuel industry, a degree of sustainability is evident which could counter the reduction in global stocks of fossil-based fuels and, at the same time, assist the effort for cleaner emissions into the atmosphere. The biofuel that is now added to some blends of diesel is also known as FAME (Fatty Acid Methyl Ester).


The bio-fuel industry is still developing, and there are hurdles to overcome, as will be seen in these notes. However, it is here to stay and the environmental and economic benefits and opportunities for further development and improvement are considerable.


Notwithstanding, FAME is not the same, in chemical formulation, as refined mineral fuel and many key properties render its inclusion in marine fuels as potentially hazardous to navigation and public safety. For a sudden engine breakdown, caused by microbiological contamination blocking filters or injection equipment, could give rise to cause an accident of considerable


significance. These causes, effects and recommended courses of action to prevent such risk are covered in the following chapters.


WHICH VESSELS ARE AFFECTED AND WHERE?


“This Directive sets, in respect of road vehicles, and nonroad mobile machinery (including inland waterway vessels when not at sea), agricultural and forestry tractors, and recreational craft when not at sea:


(a) technical specifications on health and environmental grounds for fuels to be used with positive ignition and compression- ignition engines, taking account of the technical requirements of those engines; and


(b) a target for the reduction of life cycle greenhouse gas emissions.”


The Wording in UK Legislation Enforcing the European Directive


The European Directive is enforced in the UK through Statutory Instrument 2010 number 3035 (called, hereafter “the SI”). This legislation amends existing regulations:


The Motor Fuel (Composition and Content) Regulations 1999 and amending Statutory Instruments, to date (which, amongst other subjects, previously regulated fuel used for NRMM, reduced levels of sulphur in the fuel and introduced the option for inclusion of Biofuels) and The Merchant Shipping (Prevention of Air Pollution from Ships) Regulations 2008 and amending Statutory instruments (which, amongst other subjects, previously regulated sulphur content in marine fuels).


It is important to understand that the regulations contained in the European Directive and relevant parts of the SI apply to the sale of fuel, not the use of fuel. However, vessel operators, engineers and surveyors need to be aware of the


54 | The Report • December 2017 • Issue 82


regulations’ implications, and the effect of the changes, so that they can ensure that the best fuel for their purpose is procured and used.


5A. (1) For the purposes of this regulation:


“marine diesel oil” means any marine fuel which has a viscosity or density falling within the ranges of viscosity or density defined for DMB or DMC grades in Table I of ISO 8217 (2005); “marine gas oil” means any marine fuel which has a viscosity or density falling within the ranges of viscosity or density defined for DMX or DMA grades in Table I of ISO 8217 (2005);


“marine fuel” means any petroleum based liquid fuel intended for use or in use on board a vessel including those fuels defined in ISO 8217 (2005); “placing on the market” means supplying or making available to third persons, against payment or free of charge, anywhere within the United Kingdom marine fuels for on-board combustion, but excludes supplying or making available marine fuels for export in ships’ cargo tanks.


Restrictions on the distribution and sale of gas oil and other liquid fuel


NOTES ON INTERPRETATION


There is no limit on vessel size or other parameter, in the application of the Regulations. They apply to all vessels regardless of length, tonnage or engine power.


The MCA recognizes four categories of water, in addition to those waters, which are regarded as “sea”. The four categories (‘A’, ‘B’, ‘C’, ‘D’) are defined and identified in the statutory Merchant Shipping Notice MSN 1837(M) as below and are referred to (as seen above), in the SI:


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