EMISA is concerned about the effectiveness of the regulatory framework introduced by the IMO under Marpol Annex VI (regulation 13, NOx emissions). The three on-board verification procedures provided by the NOx Technical Code are:
- The on-board Parameter Method (Art. 6.2 fo NOx Technical Code) hereinafter the “Parameter Method” or the “Method”;
- The on-board simplified measurement method (Art. 6.3 of NOx Technical Code);
- The on-board direct measurement and monitoring method (Art. 6.4 of NOx Technical Code)
Point b. and c. remain practically unused. Approximately two decades after its inception, the Parameter Method is now out-dated and no longer supports its own original aims. Moreover:
- It creates a monopoly, especially the IMO reference numbering system
- It delays innovation to reduce air pollution and it is definitely not the most effective way of measuring emmissions to protect the environment
- We acknowledge the necessity to also measure SOx, CO2 and PM.