If you’re building a megayacht whose keel is being laid come January or later, this is for you. You, your naval architect, and your builder have more time to ensure compliance with a new regulatory standard governing nitrogen oxide (NOx) emissions. Known as Tier III, it will apply to some superyachts starting in January 2021, rather than next month.
The Tier III rules were adopted by the International Maritime Organization (IMO) last year. The standard requires NOx emissions to be about 80 percent lower than what they are now. Tier III further applies to all types of vessels, not just yachts, whose keels are being laid as of January 1.
The yachting industry, however, gained a five-year deferral for Tier III compliance for some yachts. Megayachts measuring 79 feet (24 meters) and larger and of less than 500 gross tons fall into that category. The majority of said yachts measure up to about 131 feet (40 meters).
To be clear, the issue was not related to lack of knowledge. A variety of well-publicized engines, gensets, and exhaust-treatment products from trusted suppliers exist to ensure compliance. ICOMIA (International Council of Marine Industry Associations) and the Superyacht Builders Association (SYBAss) lobbied the IMO back in 2013 for more time. It was due to discoveries from three studies commissioned on the potential impact of the regulations. Both ICOMIA and SYBAss contributed to these studies. In fact, several shipyards that are SYBAss members conducted design impact research, which SYBAss in turn provided for the studies. The studies also evaluated technical and socio-economic issues. ICOMIA and SYBAss learned—and shared with the IMO—data showing that Tier III requirements cannot be met by conventional internal engine means. The current external solutions like exhaust-treatment units also require a larger footprint than what current engine-room parameters permit. While space could be annexed from guest accommodations, that would be impractical. If you’re an owner, imagine your yacht having much less space than similar-size craft built in the past year or so.
Related to this, the Marshall Islands and Cook Islands, each member states of the IMO, expressed support of ICOMIA’s and SYBAss’ findings. In a joint submission to the IMO in March 2013, the four stated:
The co-sponsors concur with the work carried out by ICOMIA and SYBAss and note that it appears, at the present time, that the available technology for NOx abatement is not suitable for deployment on yachts below 500 gross tonnage without very significant negative impacts and minimal environmental gain.
In particular, the co-sponsors are concerned that the studies indicate significant potential for widespread economic hardship amongst builders with little associated environmental benefit due to the low running hours of the vessels themselves and the issue that current NOx abatement technology is likely to be suboptimal when fitted to these vessels.
…The problem is exacerbated by the global nature of the yacht market, with prospective owners being unwilling to consider vessels that will not be able to trade in an unrestricted fashion. This creates the very real possibility that the 24m or over or the less than 500 gross tonnage yachts will disappear from the global market place.
Set against this, it is important that the pressure remains to resolve this issue and bring this group of vessels into compliance in the near future. It is considered by the co-sponsors that, based on the work being undertaken by the industry, it should be possible to bring the vessels into compliance by 1 January 2019.
As you might expect of regulatory decisions, particularly international ones, Tier III discussions continued for some time. SYBAss says, “As a result of interventions by Russia, our proposal was adopted one year later…granting a delay of five years instead of the requested three years. Our appreciation goes to Tony Rice of ICOMIA (now retired), who was the driving force behind the ‘silent lobbying’ in IMO circles.”
The five-year Tier III deferral should give equipment manufacturers and naval architects enough time to explore and adopt suitable solutions. These include more compact components.
Megayachts measuring more than 79 feet/24 meters LOA and exceeding 500 gross tons must still comply with Tier III come January 1, however.
On a related note, in late November SYBAss received an extension of its permanent consultative status at the IMO. SYBAss originally received provisional consultative status in 2010, then permanent consultative status in 2013. Permanent consultative status reviews for non-government organizations like SYBAss occur every two years. The IMO wants to ensure that these organizations are continuing to make significant contributions to its various working areas. Furthermore, the IMO requires that they distribute information about and promote the work. “We are delighted that we have had our permanent consultative status confirmed after the first official review,” says SYBAss secretary general Theo Hooning. “This will help ensure that the superyacht industry continues to be represented in a professional way at the highest maritime regulatory body and be acknowledged as a unique sector. It also reinforces the role of SYBAss in protecting the superyacht sector from regulations that might jeopardize the industry. We will continue to uphold the interests of the many thousands of people who work on the design, construction and operation of large yachts.”
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