California Air Resources Board (CARB) has published guidance for vessel operators, utilizing the research exemption to use fuel at or below 0.1% sulphur that does not meet specifications for distillate fuel grades in the California Ocean-Going Vessel Fuel Rule.Several vessel operators are now complying with the California Ocean-Going Vessel Fuel Regulation (OGV Fuel Rule) using fuel at or below 0.1% sulfur that does not meet the OGV Fuel Rule specifications for distillate fuel grades under a process detailed in Marine Notice 2014-1 .While these low sulfur non-distillate fuels, primarily described as ultra-low sulfur fuel oil (“ULSFO”), can be used to comply with the regulation under the Research Exemption, ARB staff has found that without taking precautions, there is a high likelihood of a violation of the sulfur limit. Based on reviews of bunker delivery notes from the vessel operators, these fuels, as purchased, are generally reported to be below, but close to, the 0.1% sulfur regulatory limit.However, shipboard in-use samples collected and tested by ARB staff have sometimes been found to exceed the regulatory limit. The discrepancy could be due to shipboard contamination with high sulfur fuels in tanks or pipes, or other factors. This notice is to alert vessel operators that ...
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