Dear Member,
The Port of Vancouver has announced a proposed ban on exhaust gas cleaning system “scrubber” wash water at berth and at anchor (i.e., from auxiliary engines), which would come into effect on March 1, 2022 after a comment period that ends on January 8, 2022. This would be the first of three phases in the ban. More context can be found in CL #11246 from March 2021, and proposed language is below.
Based on member feedback we received when a proposed ban was first announced (and then delayed) this past spring, it is our understanding that this prohibition would have little to no effect on our members’ operations. The Federation will be submitting written comments to the port. Kindly revert to the undersigned by January 4, if your company’s operations would be affected by this proposed ban.
We do see this as part of a larger move to prohibit scrubber use within Canada. The federal government has stated both in meetings with us and at the IMO Environment meeting last month that it supports phasing out use of HFO as soon as possible.
PROPOSED LANGUAGE: Proposed amendment to PVFA Port Information Guide 11/24/2021:
Section 14.5 Environmental requirements – exhaust gas cleaning system (EGCS) wash water discharges
The discharge of wash water from exhaust gas cleaning systems (EGCS) from all fuel combustion machinery (excluding main engines) into the environment is not permitted while a vessel is at anchorage or at berth within the Port of Vancouver. This applies to the wash water from open-loop and closed-loop EGCS. It does not apply to inert-gas scrubbers required by tankers for cargo operations and safety reasons. While in the Port of Vancouver, ships fitted with hybrid scrubbers shall switch to the closed-loop mode and operate the scrubber in a zero-discharge mode. Bleed-off from closed-loop scrubbers is prohibited and all EGCS wash water must be retained on the vessel in a holding tank or be disposed of at an authorized shore reception facility. If wash water cannot be recirculated, vessels must switch over to compliant fuel or shore power (where available). The change-over should be effected as soon as possible after arrival to anchorage or berth and as late as possible before departure. ECGS overboard discharge valves should be shut and secured/sealed in closed position while the vessels are in the Port of Vancouver. All vessels are required to electronically submit a 24-hour pre-arrival declaration through the ‘Pacific Gateway Portal’.
CURRENT STATUS OF CANADIAN LAW AND POLICY ON SCRUBBERS NATIONALLY:
Vessels are allowed to use scrubbers in Canadian waters per Vessel Pollution and Dangerous Chemicals Regulation. However:
- Per Vessel Pollution and Dangerous Chemicals Regulations in the Canada Shipping Act, 2001, vessels using scrubbers must meet the IMO Guidelines,
- Fresh and brackish water use: Transport Canada has advised that open-loop scrubbers are not to be used in freshwater or brackish water as they are not designed to be effective in these environments.
- Under Canada Marine Act, ports have the authority to prohibit scrubber use in waters under their jurisdiction. To our knowledge, only one port in Canada (Port of Sept Iles) currently has a scrubber ban in place. However, other ports including Quebec and Montreal are considering similar measures.
Sincerely,
Miako Ushio
Manager, Environmental and Regulatory Affairs