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Reply from Tony Lee

From: []

Sent: Monday, June 27, 2011 17:54
To: James Middleton
Subject: E(11/1515) : Port Strategy – A new dawn

Dear Mr Middleton,

Thank you for your messages of 23 and 26 June.   The consolidated reply of EPD and the Marine Department (MD) is as follows.

1. What is the actual fuel sulphur cap here?
Ans. According to Regulation 29(1) of the Merchant Shipping (Prevention of Air Pollution) Regulation, the sulphur content of any fuel oil used on board ships in Hong Kong is not to exceed 4.5% m/m.

2.  How is this enforced for incoming vessels which refueled elsewhere?
Ans. According to Regulations 33(4) and 34 of the Merchant Shipping (Prevention of Air Pollution) Regulation, all incoming ships of 400 gross tonnage or above and engaged in international voyage shall carry Bunker Delivery Notes (BDN) with the associated representative sample of the fuel on board.  The BDN and the representative sample are subject to inspection by Government Surveyors.

3.  What samples are taken to ensure the ships are conforming to “grey smoke emissions instead of black smoke”?
Ans. MD is currently using Ringelmann Chart for the identification of black smoke.  If a ship emits smoke of or darker than Shade 2 for continuous 3 minutes, the emission is regarded as black smoke.

4.  Since these Charter member shipping lines have opted to switch to ULSD only at berth and not whilst sailing within Hong Kong waters what has Government done to seek their compliance whilst underway rather than just at berth?
Ans. The Fair Winds Charter signatories have committed themselves to switching their vessels to 0.5% sulphur fuel when at berth.  While sailing underway within HK waters, these vessels must meet the sulphur limit requirement stipulated under MARPOL Annex VI.  As mentioned, since China has not designated its waters (including that of Hong Kong) as an Emission Control Area, there is no vehicle for Hong Kong to “require” operators to use fuels of more stringent specifications.

5.  What is the sulphur content of bunker fuel supplied for refueling in Hong Kong?
Ans. It must be below 4.5% and is usually in the range of 3.5% – 4.0%.  You may contact the local suppliers in the attached document for details or access the MD’s website on the link provided for that document.

6.  Hong Kong is supposed to be an independent territory for 50 years from 1997 is it not?  We make our own laws do we not ?  The EPD intends to designate Low Emission Zones for traffic on Nathan Road, Causeway Bay and Central so that only Euro 5 diesels / hybrids will be allowed to enter those areas.  I see no difference with doing the same for HK waters – either meet the relevant standards or do not enter our waters or be fined if you do.
Using “China did not do it” is a lame duck reply more worthy of Donald Tsang than a body supposed to be looking after the air quality here , in this 50 year independent SAR.
Ans.  Under MARPOL Annex VI, there are general requirements on the sulphur content of any fuel oil used on board ships.  There is also a mechanism for member states of the International Maritime Organization (IMO) to apply for designating its waters as an Emission Control Area (ECA), within which the requirements are more stringent than the general requirements.  This mechanism is not mandated for all member States to designate its waters, in whole or in part, as an ECA.  As a matter of fact, Hong Kong is an associate member of IMO, not a full member (member state) and thus cannot file an application for ECA designation by Hong Kong itself.

Best regards,
Tony YT Lee

Encl. PDF : oilsupreg

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