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Enforcement of the NA ECA . Where We’ve Been Where We’re Going. Matt Haber US EPA Air Enforcement Division Office of Enforcement and Compliance Assurance. Today’s Presentation. Quick Reminder: Why the ECA What’s happened in the last year What’s coming.
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Enforcement of the NA ECA Where We’ve Been Where We’re Going Matt Haber US EPA Air Enforcement Division Office of Enforcement and Compliance Assurance
Today’s Presentation • Quick Reminder: Why the ECA • What’s happened in the last year • What’s coming
Why the ECA-Reduced PM Concentrations PM-2.5 standard Current: Current: 12ug/m3 (annual) (12/14/12) (was 15 ug/m3) 35ug/m3 (24 hour)
ECA Benefits—Emissions and Health • ECA standards will result in annual reductions starting in 2020 of: • 320,000 tons of NOx • 90,0000 tons of PM-2.5 • 920,000 tons of SOx • 23%, 74% and 86% reduction of predicted levels absent the ECA • ECA benefits include preventing as many as 14,000 premature deaths and relieving respiratory symptoms for nearly 5 million annually.
What’s happened? • Overall ECA situation • FONAR system updates • FONAR results • Flexibility • Flyover experiment • Investigations of FONAR abuse • Emerging problem areas • Detentions
Overall Quick Look at ECA • ECA in place over one year • Vast majority of vessels obtained and used compliant* fuel in ECA • Some vessels could not obtain compliant fuel; most submitted FONAR *based on BDN
FONAR system • Put in place to address fuel availability under regulation 18.2 • Initially email system • Changed to electronic system using EPA’s CDX in Spring, 2013 • Many reports initially • Number of reports have tapered off dramatically
Flexibility • Reg 3 permits issued • NCL (scrubber) • TOTE (LNG) • Carnival (scrubbers) • RCL (scrubbers) • Reg 4 equivalence issued • RCL (averaging)
Flyover • Problem: Point of compliance begins at 200 NM off shore • Point of enforcement is typically at berth • Question: Can we monitor compliance at 200 NM? • NOAA study says yes • We are testing concept over Chesapeake Bay
Other Issues • FONAR abuse • Tested sulfur >BDN (and >1.00%) • Detentions
What’s coming? • January 2014—Caribbean ECA • January 2015—0.1% requirement • January 2016—NOx requirements • Mexico?
What’s Coming: Caribbean ECA January 2014 • IMO designated July 15, 2011 Enforceable January 2014
What’s Coming: 0.1% S Requirement • NOW is the time to test engines, fuel lines, other equipment & make any necessary modifications • If you are considering an equivalent method, implement it!
What’s Coming: Tier III NoxJanuary 2016 • Will require after treatment • selective catalytic reduction, exhaust gas recirculation, water injection strategies, dual fuel diesel/natural gas engines • Applies in ECAs only (Tier II otherwise)
Mexico Part of NA ECA? • Demonstrated possible impacts of an ECA in Mexico • Provided technical information • Conducting evaluation of benefits of a Mexican ECA www.epa.gov/international/fuelswitch.html