Speaking with One Voice on the Environment

Some reasons we don’t!
Peter Weber
The views contained herein are those of the author,
not SeaRiver Maritime, Inc., or any of its affiliates.
Recent Headlines
Impediments to One Voice
• Differences of opinion in the various marine segments
Oceangoing, coastal, inland
Tanker, container, bulk, passenger, ferry
Owners, operators, charterers, financiers, insurers
Service providers, class societies, vendors, regulators
• Unaligned economic drivers
– Charterer pays for fuel; operator pays for fuel
– Customer considerations
• Varying regulatory influences
– International, National, State, Local
• Desire to be ‘seen green’
– Business strategy of some; not important to others
– May set expectations for all
• Suitability of solutions across various vessel types
Root Causes
• Lack of understanding of the
science behind an issue
– The EPA and international
counterparts have resources and
funding well beyond that typically
found in marine industry
– Marine Industry ability to review and
understand reports limited
• Lack of time and resources to
investigate the facts
– Environmental issues require the
industry to reach outside
– Capabilities, credentials and
political leanings need vetting
– Issues may move at rapid pace
Root Causes (cont’d)
• Media pressure
– Industry often portrayed in negative light
– Environmental articles dominated by
untested progressive solutions
– Urgency to ‘do something’
– ‘Truth’ accepted with limited questioning
– ‘Green’ sells
Root Causes (cont’d)
Internal industry pressure setting the vision
– Class society environmental divisions
taking an out-in-front role
– Vendors offering products and
– Expectations set before testing done
© DNV/Making Waves
Approved by: Henrik O. Madsen and Tor E.
Svensen, DNV, Richard Sadler and Alan Gavin,
Lloyd’s Register
“Technical and operational measures are likely to
enable shipping to reduce CO2 emissions per
tonne-mile by 50% for ships being delivered in
2030, and by up to 70% for ships being delivered
in 2050, compared to a 2008 baseline.”
Root Causes (cont’d)
• Lack of trust in motives of the
– Uncaring, greedy image
– Input from e.g. oil companies
automatically tainted;
environmental NGO motives pure
– Industry ‘bad actors’ haven’t
• Insufficient ‘political’ will to
defend a position
– Difficult to argue, for example,
numbers of deaths and value of
a life
– Easily painted as ‘Luddite’,
‘denier’ or even ‘evil’
Root Causes (cont’d)
Root Causes (cont’d)
• London version of the Stockholm
– Center of international marine
environmental regulations
– Most of our Industry NGOs and some
major companies are London based
– Interact heavily with each other and IMO
Meetings, lunches, cocktail parties, award
– Issues often look different from further
• ‘Negotiating with ourselves’
Reluctant to be tough negotiators
Sensitive to ‘bullying’ and accusations of ‘foot-dragging’
Regulation looks inevitable so propose what we can live with
But environmental groups never seem to stop - always seem to push for more
Resulting Headlines
What’s the Answer?
Well, let’s hear from our other panelists!
Shore Power
• Science debatable
– GHG - Depends on source of power; marginal kW must be from
renewable source (wind, solar, hydroelectric) or nuclear
– Pollution – may only transfer problem elsewhere
– Only captures at-berth component
• Practicality varies – reasonable for liner trades (container vessels,
passenger ships and ferries); difficult for tankers and bulk carriers
• Cost/Benefit – generally high compared to other solutions
• Industry Response - mixed
Shore Power example
• San Pedro Bay Clean Air Action Plan (CAAP)
– Calls for shore power for new projects and lease renewals
– Near ‘legacy’ item for POLA Director of the Port
• Industry Reaction Mixed
– Some container and passenger vessels complying
– Other container operators looking for alternatives and offsets (low sulfur fuel,
speed reductions)
– BP terminal in LB converted for two dedicated diesel-electric vessels – left
impression all tankers could be readily converted
– Tanker industry generally opposed – steam cargo systems on most tankers limit
usefulness to hotel loads; most tankers not in dedicated trade; high voltage and
50/60Hz frequency issues; manifold location determines required location for
non-hazardous area hookup; berths in deeper water - not at the shoreline
Fuel Sulfur Limits
• Amended MARPOL Annex VI at MEPC 57, April 2008
– Established new S limits for Global Cap and Emission Control Areas (ECA)
• Most industry NGOs supported keeping residual fuel in the mix
• INTERTANKO called for global low-sulfur distillate solution
– Took the ‘green’ card; aligned nicely with environmental group objectives
– Highlighted advantages in reduced pollution and eased workload on crew
– But didn’t consult with other industry bodies
Refining would need to make large capital investments; ‘chicken and egg’ scenario
Independent tanker operators typically don’t pay the fuel bill
Negative impact on GHG on ‘well-to-prop’ basis
• Large block of countries led by SA resisted large global cap reduction
– During dinner break industry NGOs negotiated with environmental block; ignored
SA block
– After dinner; settlement announced – no more discussion
• Global Cap impacts refining industry; not clear refining will follow;
‘train wreck’ scenario in 2025 still possible
– IPIECA warning MEPC 57/WP.7 paragraph 7.18
Statement by IPIECA (MEPC 57/WP.7)
7.18 While the working group reached full agreement on all elements of
the amended regulations on this issue, IPIECA drew the attention of the
working group to the fact that the oil industry did not expect that
sufficient fuel at 0.10% and 0.50% were expected to be available in all
regions by the desired dates of 2015 and 2020, respectively. In the
judgement of IPIECA, the data included in the report of the informal
cross government/industry scientific group of experts supported this
assessment. IPIECA also stated, that in their view, a global requirement
of 0.50% was not supported by scientifically demonstrated needs, while
it would incur significant additional energy and crude oil consumption as
well as overall CO2 emissions. IPIECA therefore recommended to
include an evaluation of further environmental needs in the 2018 review.
Fuel Sulfur Limits - Some Concerns
with the Science
Vessel routes and emissions
Air models
Sulfur deposition assumptions
Health Impacts and estimate of mortalities
– Extrapolation of one limited cancer study
– Not done by toxicologists
• Value of Life
– Premature mortality
– $5.8M
Gas Reduction
• Unless sufficient objection by July this year, will be regulated under
new chapter of MARPOL Annex VI – Air Pollution from Ships
– CO2 measure disguised as energy efficiency measure (GHG not a pollutant
under the UN)
– “First ever global and legally binding CO2 standard for an industry sector”
– Conveniently by-passes direct Senate approval of an International Convention on
GHG (The Maritime Pollution Prevention Act of 2008 (MPPA) gives the EPA and
USCG authority to prescribe regulations to implement MARPOL Annex VI)
• Requires new ships to meet an increasingly stringent EEDI and
existing ships to carry a SEEMP
• EEDI adopted in lieu of an MBM solution
Couldn’t reach MBM agreement due to CBDR argument
Outgoing IMO SG made clear passage a legacy item; had promised to the UN
Industry NGOs supported; fearful of environmental backlash, regional solutions
Insufficient discussion given to technical concerns – issues persist
Large % reductions (10, 20 and 30% over 3 phases)
Minimum power/reserve power requirements (EEDI proportional to speed squared)
Regression curves
Unique ship types, special uses, severe service
Pete’s Suggestions
• Speak up – don’t be star-struck by organizations – they’re only
• Re-engage with industry NGOs, ship owner/operator organizations
and registers of major flag states
• Don’t let something begin at the IMO that you don’t think should
proceed – once started it’s an unending bore-hole – it will only get
worse (EEDI formula)
• Trust but verify – environmental reports may not tell the whole truth
• “Peer reviewed” is only as good as the “peers”