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EPA's Role in the International Maritime Organization (IMO)
Congressional Testimony of Christopher Grundler, Director, Office of Transportation and Air Quality, March 2014The International Maritime Organization (IMO) promotes cooperation between governments in the regulation of shipping engaged in international trade and encourages the adoption of the highest practicable standards concerning maritime safety, efficiency of navigation, and prevention and control of marine pollution from ships. Among other things, EPA’s work has led to higher energy efficiency requirements for new ships, stricter emission limits on greenhouse gases, and the implementation of an Emissions Control Area (ECA) for both North America and the U.S. Caribbean.
68th session of the International Maritime Organization’s Marine Environment Protection Committee (MEPC)
EPA is participating in the 68th session of the International Maritime Organization’s Marine Environment Protection Committee (MEPC), which takes place May 11–15 in London. The session is anticipated to include:
- final adoption of MARPOL amendments to formally establish the IMO Polar Code,
- advancing MEPC work on the availability and quality of low sulfur marine fuels,
- enhancing the efficiency of existing ships,
- addressing black carbon emissions that impact the Arctic,
- revising test guidelines for ballast water management systems,
- and other matters.
North American and U.S. Caribbean Emission Control Areas
More stringent, legally enforceable regional emission and fuel quality standards took effect in August 2012 and January 2014, respectively, for ships operating in the waters off North American coasts and around Puerto Rico and the U.S. Virgin Islands. These areas were officially designated by the International Maritime Organization (IMO) as the North American and U.S. Caribbean "Emission Control Areas" (ECA) after the U.S. successfully demonstrated that the globally-applicable emission standards established by MARPOL Annex VI were insufficient for American needs.
Ships entering the designated ECAs will need to use compliant fuel and advanced emission control technology for the duration of their voyage within that area. These standards will dramatically reduce air pollution from ships and deliver substantial air quality and public health benefits that extend hundreds of miles inland.
About the IMO
The International Maritime Organization (IMO) was created in 1948 to promote multinational cooperation and coordination in the regulation of shipping engaged in international trade. The premise was – and remains – the recognition that action to improve the safety and security of maritime operations, as well as to prevent and control marine pollution from shipping, is more effective and less likely to distort international trade flows if carried out at an international level rather than by individual countries acting on a unilateral basis. To that end, the IMO has developed and promoted the adoption of over forty binding conventions and protocols and adopted over 800 codes and recommendations on maritime safety, pollution prevention and related issues.
From an environmental protection standpoint, some of the most important IMO Conventions are:
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- The International Convention for the Prevention of Pollution from Ships (MARPOL Convention);
- The 1990 International Convention on Oil Pollution Preparedness, Response and Co-operation (OPRC), meant to improve the capacity of nations to respond to sudden emergencies;
- The 1996 International Convention on Liability and Compensation for Damage in Connection with the Carriage of Hazardous and Noxious Substances by Sea;
- The Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (London Convention) and the London Protocol;
- The International Convention on the Control of Harmful Anti-fouling Systems on Ships;
- The International Convention for the Control and Management of Ships’ Ballast Water and Sediments; and
- The International Convention for the Safe and Environmentally Sound Recycling of Ships.
All of these conventions are in effect except for the Ballast Water and Ship Recycling conventions.
The MARPOL Convention currently has six Annexes that address the following marine pollution-related topics:
- Annex I: Regulations for the prevention of pollution by oil;
- Annex II: Regulations for the control of pollution of noxious liquid substances in bulk;
- Annex III: Regulations for the prevention of pollution by harmful substances carried by sea in packaged form;
- Annex IV: Regulations for the prevention of pollution by sewage from ships;
- Annex V: Regulations for the prevention of pollution by garbage from ships; and
- Annex VI: Regulations for the prevention of air pollution from ships (including through the improvement of ship energy efficiency).
Structure of the IMO
The IMO consists of an Assembly, a Council, five main technical Committees, and seven Sub-Committees that support the work of the technical committees. The IMO Secretariat is based in London. The highest Governing Body of the IMO, the Assembly consists of all Member States and meets once every two years to approve the work program and establish a biennial budget. The Council consists of forty IMO Member States elected by the Assembly for two-year terms. It supervises the IMO’s work, coordinates the activities of the committees and sub-committees, and considers and submits the draft work program and budget estimates to the Assembly for approval.
The IMO’s work is conducted mainly through the Maritime Safety Committee (MSC) Exit and the Marine Environment Protection Committee (MEPC). Exit MSC and MEPC are assisted in their work by seven sub-committees which are also open to all Member States. The two of greatest relevance to EPA are the Sub-Committee on Pollution Prevention and Response (PPR) Exit and the Sub-Committee on Ship Design and Construction (SDC). Exit
In 2014, the IMO started to implement a series of organizational reforms that were approved in 2013 by the Council and Assembly. These reforms are meant to reduce costs, enhance focus, and maintain the productivity of the IMO. In addition, the IMO reorganized and streamlined its operations, reducing the number of sub-committees from nine to the current seven.
EPA @ IMO
EPA works closely with our partners at the U.S. Coast Guard, National Oceanic and Atmospheric Administration (NOAA), the Department of State, and other U.S. Government entities to represent U.S. interests at the IMO Council and its subsidiary bodies.
EPA has been instrumental in pushing for higher energy efficiency requirements for new ships, the quantification of maritime greenhouse gas emissions, consideration of possible control regimes, the prohibition of especially toxic ship anti-fouling systems, and the implementation of Emission Control Areas (ECA) (under MARPOL Annex VI). These ECAs will control SOx, NOx and PM emissions from ships in both North America and the U.S. Caribbean.
More recently, EPA has worked at the IMO on such priorities as the development of regulations for marine geoengineering (specifically ocean fertilization), revised and more stringent MARPOL Annex V regulations on garbage, guidance to promote initial industry implementation of the IMO’s conventions on ballast water management, energy efficiency standards for existing ships, and black carbon emissions from ships that impact the Arctic.
In particular, EPA has worked on developing the environmental provisions of the IMO’s mandatory code for ships operating in polar waters (the Polar Code). The mandatory Polar Code will establish more rigorous environmental and safety requirements for those ships that will increasingly operate in the remote and ecologically vulnerable polar regions.
Regional and global economic development, international trade and tourism, and projected resource exploration and development are expected to intersect with climate warming, particularly the ongoing loss of summer sea ice cover in the Arctic, to result in growing levels of maritime shipping in the Arctic and the Antarctic. The remoteness of these areas and near-total absence of ports, which provide facilities for waste reception and handling, search and rescue operations, and spill response, means that the ships must be built and operated to higher standards.
The bulk of EPA’s recent work with the IMO has focused on the first sessions of the Ship Design and Construction (SDC) and Pollution Prevention and Response (PPR) subcommittees, and the latest session of the Marine Environment Protection Committee (MEPC), all in early 2014. The SDC session in January 2014 was most notable for its work to refine and complete the draft safety and environmental elements of the mandatory code for ships operating in polar waters (the Polar Code). The PPR session in February 2014 dealt with ballast water, black carbon, and a variety of air pollution-related matters, among others.
More information about the most recent MEPC session can be found at the U.S. Coast Guard's MEPC page.
For additional information on EPA's marine and treaty efforts within the IMO, contact:
U.S. Environmental Protection Agency
Office of International and Tribal Affairs (2660R)
1200 Pennsylvania Ave., NW
Washington, DC 20460