Canada's ECA Limits

The North American ECA will come into force in 2012. This designation will apply to the Canadian economic exclusion zone, south of the Arctic Waters. The IMO designation will apply therefore to the external waters and the internal waters of Canada. The Canadian inland waters are not included part of the IMO designation. Canada has yet to decide on how the ECA will apply on the inland waters, particularly how non-convention ships will be regulated on the Great Lakes and the St. Lawrence River.

One question needing clarification is, where is the border line for the inland waters? In the oil pollution regulations Canadian inland waters start at the western tip of Anticosti Island. In the old sewage regulations, IMO compliant marine sanitation devices could be used in the waters east of the first Lock of the Seaway, i.e. into the Port of Montreal. I would expect that Canada uses the oil pollution regulation limit, i.e. the western tip of Anticosti Island, for the designation of the internal waters under the ECA.

For the Canadian inland waters, Canada asked for comments by May 31, 2010 from the shipping industry. Transport Canada has on the table 3 options on how to implement an ECA in the inland waters

Here is the conundrum for the domestic fleet. In the ECA zone all vessels are required to burn ECA compliant fuel. MARPOL Annex VI does not allow for vessel or fleet averaging of the sulfur content, the fuel burnt must meet the ECA prescribed S-limit. Therefore, a domestic vessel sailing to a port outside the inland waters of Canada will need to burn fuel with less than 1.00% S-content with the introduction of the ECA, then starting 2015 they will have to burn fuel with not more than 0.10%.

This means, that after 2012, any domestic, non-convention vessel needs to comply with the ECA fuel requirements on domestic voyages, which extend beyond the inland water limit - unless Canada waves the ECA requirements for the domestic fleet.