North and Baltic Sea Seminar 2010 Program “Air Emissions from Shipping: Regulations and Challenges” Peter M. Swift MD INTERTANKO 26 November 2010 Paris INTERTANKO Today 250 + members operating ca. 3,100 ships > 75% of the independent oil tanker fleet and > 85% of the chemical carrier fleet 300 + associate members: in oil and chemical tanker related businesses [With strict membership criteria] 15 Committees – 5 Regional Panels Principal Offices – London and Oslo Representative Offices in US, Asia and Brussels Observer Status at IMO, IOPC, UNFCCC, OECD and UNCTAD International Association of Independent Tanker Owners “The Voice of the Tanker Industry” INTERTANKO’s Strategic Objectives To develop and promote best practices in all sectors of the tanker industry, with owners and operators setting the example. To be a positive and proactive influence with key stakeholders, developing policies and positions, harmonising a united industry voice, and engaging with policy and decision makers. To profile and promote the tanker industry, communicating its role, strategic importance and social value. To provide key services to Members, with customised advice, assistance and access to information, and enabling contact and communication between Members and with other stakeholders. TANKERS US Seafarer Concerns Today • Criminalisation & Fair Treatment • Piracy • Bureaucracy, including: - excessive paperwork - too many inspections More consideration should be given to the ramifications for the seafarer of new regulations and legislation at IMO and elsewhere – e.g. ballast water, multi-fuels, emission abatement technologies, etc. Air Emissions from Shipping • Toxic emissions – SOx, NOx, PM – covered by IMO MARPOL Annex VI, EU and other regional regulations • VOCs (Tankers) – covered by MARPOL • Ozone Depleting Substances – covered by MARPOL • Greenhouse gases (principally CO2) – under debate at UNFCCC and IMO SOx = Oxides of Sulphur, NOx = Oxides of Nitrogen, PM = Particulate Matter VOCs = Volatile Organic Compounds, UNFCCC= United Nations Framework Convention on Climate Change IMO = International Maritime Organisation . “ Toxic Emissions from Shipping - SOx and NOx ” The Challenges Today SOx and NOx Regulations • SOx emissions regulated via Bunkers - with alternative methodologies accepted as Equivalent Measures • NOx emissions regulated through engine design / limits Maximum Sulphur Limits - IMO MARPOL Annex VI • limits the sulphur content in marine fuels • different sulphur limits in open sea and in ECAs • requires quality criteria for the marine fuels IMO Global S limit: Currently 1 July 2012 1 January 2020 / (2025) IMO ECA limit: Initially 1 July 2010 1 July 2015 ECA = Emission Control Area 4.5% 3.5% 0.5% / (if not available in 2020) 1.5% 1.0% 0.1% IMO MARPOL Annex VI: Baltic and North Sea ECAs NOV. 2007 MAY 2006 IMO MARPOL Annex VI: North American ECA Entry into force 1 August 2012 Challenges: •Extent •Fuel availability •Ship bunker capacity 200 nm 200 nm Will Mexico join ? Caribs? Regional Regulations on Bunkers EU Sulphur Directive (presently being amended) – basically as per MARPOL Annex VI sulphur provisions – but with additional provision: use of 0.10% sulphur content fuel when ships ”at berth” (since 1 Janaury 2010) – & MGO/MDO on the EU market should have < 0.1% S content (since 1 January 2010) California Air Resource Board (CARB) – use marine distillates within 24nm of the shore – sulphur content in marine distillates: • before 1 January 2012 – MDO < 0.50% ; MGO <1.50% • after 1 January 2012 - MDO/MGO< 0.10% Sulphur in Bunkers: Application Dates and Limits 4.5 4 IMO/Global HFO SULPHUR CAP (%) 3.5 IMO/ECA 3 EU 2.5 CARB MGO 2 1.5 LSFO 1 0.5 MDO/MGO MDO MGO 0 01 01 01 01 01 01 01 01 nu Ja nu Ja nu Ja nu Ja nu Ja nu Ja nu Ja nu Ja y ar y ar y ar y ar y ar y ar y ar y ar 24 20 22 20 20 20 18 20 16 20 14 20 12 20 10 20 NOx Emission Regulations - IMO MARPOL Annex VI IMO MARPOL Annex VI sets limits in 3 Tiers • Generally on ships built pre 2000 and engine not modified - No limits • Engines on ships built post 2000 mostly comply with Tier I limits • Engines on ships built after 1 January 2011 must comply with Tier II standards Emission reductions related to Tier I limits: – 15.5% reduction (engines with n<130 rpm) (i.e. 14.36 g/kWh) – reductions between 15.5% and 21.8% depending on the engine’s rpm (engines with 130 rpm < n < 2000 rpm) – 21.8% reduction (engines n > 2000 rpm) (i.e. 7.66 g/kWh) NOx Emissions-Tier III (new engines) Tier III limits – 80% emission reductions from Tier I limits Tier III limits apply to engines: – installed on ships constructed after 1 Jan 2016 – power output of > 750 kW (130 kW – 750 kW may be exempted by the Administration) Tier III limits apply in ECAs only Emission levels for Tier III are as follows: – 3.40 g/kWh (engines with n<130 rpm) – 9*n(-0.2) g/kWh (engines with 130 rpm < n < 2000 rpm) – 1.96 g/kWh (engines n > 2000 rpm Fuel Challenges for Ships • Availability of Low S bunkers globally • Quality issues (incl. measurement and verification) • Requirements for multi-fuels • Fuel switching – safety concerns (main engines and auxiliaries) • Onboard storage & segregation capacity “ Volatile Organic Compounds Emissions ” Challenges mostly met VOC Control Measures Reductions during loading and on passage e.g. using INTERTANKO VOCON procedure plus Absorption, Condensation and other measures “ Greenhouse Gas Emissions ” The Coming Challenges Climate Change Challenges For shipping: Protection of the Marine Environment includes Atmospheric Environment GHG emissions – principally CO2 emissions Shipping is energy efficient - environmentally responsible, reliable and cost efficient Transport distance for 1 ton cargo per kg GHG emissions Air plane 1,9 Heavy truck 9,0 Ro-ro ship 29,8 Freight train 40,5 Container ship 53,8 General cargo ship 72,6 Product tanker 91,2 Bulk carrier 217,1 VLCC tanker 235,9 0 50 100 150 km Source: Danish Shipowners Association 200 250 Shipping is energy efficient, BUT… CO2 emissions by country (2007) CO2 emissions from shipping 2.7% of global total (2007) and predicted to grow as trade expands Reducing GHG Emissions from Shipping Regulatory Processes & Timetables • UNFCCC Programme • IMO Programme • Industry Initiatives The Regulatory Processes • UNFCCC 1992 • IMO since 1997 • Kyoto Protocol, adopted 1997 entered into force 2005 • Copenhagen Accord 2009 UNFCCC = United Nations Framework Convention on Climate Change Kyoto Protocol • Established under UN Framework Convention on Climate Change (UNFCCC) – adopted in 1997 • Ratified by 181 countries – not the USA • Categorises Annex 1 (Developed) Countries and NonAnnex 1 (Developing) Countries • Annex 1 Countries are committed to make GHG reductions with set targets, but also flexible mechanisms • Runs through to 2012, - Conference of Parties endeavouring to develop a successor • Kyoto recognises “common but differentiated responsibilities”, i.e. developed countries produce more GHGs and should be more “responsible” for reductions • Kyoto looks to IMO to address Shipping and ICAO to address Aviation, and as such these emissions are currently excluded from Kyoto targets Recent and future timetable Selected Key Dates 12/2009 UNFCCC COP15 Meeting, Copenhagen 3/2010 IMO MEPC 60 2010 IMO MEPC MBM-Expert Group IMO MEPC Intersessional (EEDI) 2010 UNFCC Intersessional meetings 9/2010 -----------11/2010 -----------7/2011 IMO MEPC 61 11/2011 UNFCCC COP17 Meeting, South Africa 12/2011 EU Deadline for IMO/International Agreement 2012 Kyoto Protocol expires UNFCCC COP16 Meeting, Cancun IMO MEPC 62 IMO – UNFCCC Conflicting principles - a major issue IMO Principle: “No More Favourable Treatment” Versus Kyoto Protocol principle: “Common But Differentiated Responsibility” UNFCCC - COP15 The outcome: • NO targets • NO resolution of Kyoto/IMO Treaty conflict • NO direct reference to international shipping in the non-binding Copenhagen Accord BUT subsequently: • International Aviation and Shipping should be regulated via UNFCCC and have targets as per other industries (EU Parliament) • Shipping should make its “contribution” to Climate Change measures with $$$$ (UN Advisory Group) • ICAO and IATA agree a package of reduction measures IMO Programme IMO (MEPC) developing: • Technical Measure (EEDI for new ships) • Operational Measure (SEEMP & EEOI for new and existing ships) • Market Based Measure (if needed) Technical Measures Energy Efficiency Design Index (EEDI) Environmen tal cost Attainedenergyefficiencydesign index Benefit for society Environmental cost = Emission of CO2 Benefit = Cargo capacity transported a certain distance • measures energy efficiency of new ships • encourages design and technical developments Technical Measures Energy Efficiency Design Index (EEDI) EEDI = (g/tonne mile) CO2 factor x SFC[FOC] (g/kW h) x Engine Power (kW) ----- ---------------------------------------------------------------Capacity (tonne) x Speed (mile/h) Initially only the calculation of the Attained EEDI was planned to be mandatory, but the drive is to establish a mandated requirement, such that the Attained EEDI < Required EEDI EEDI Required [ Tankers>20,000 DWT ] Reference Line = Phase 0 = no reduction (2013 & 2014) EEDI Phase 1 2015 - 2019 Attained EEDI < Required EEDI 10% 20% Phase 2 2020 - 2024 30% Phase 3 on and after 2025 DWT Operational Measures • Ship Energy Efficiency Managment Plan (SEEMP) – encourages improvement energy efficiency of ships in operation – best measurable practices on operational procedures setting goals – plan implementation strategy – monitoring – Energy Efficiency Operational Indicator (EEOI) – procedures for self-evaluation and improvement towards set goals • Energy Efficiency Operational Indicator (EEOI) = CO2 emitted per unit of transport work CO2 emitted measured from fuel consumption Transport work = cargo mass x distance (nm) EEOI is “voluntary” – a management tool Operational Measures Energy Efficiency Operational Indicator (EEOI) CO2 factor x [FOC] (g) EEOI (g/tonne mile) = ---------------------------------------------------------------Cargo Mass (tonne) x Sailed Distance (mile) Market Based Measures MBMs under review at MEPC • Emissions Trading Schemes • GHG Fund and Leveraged Incentive Schemes • Ship Efficiency & Credit Trading and Vessel Efficiency System • Rebate Mechanism Some would require all ships to pay a contribution Some provide rewards to more energy efficient ships Most include a support mechanism to developing countries Why are MBMs Proposed ? • Ships have a long life – EEDI takes time / operational measures not readily quantifiable; further “incentives” may be needed • International trade and shipping will continue to grow • A deemed “need” to fund offsetting in other sectors or ETS or other MBM Future Means of Reducing GHG Emissions from Shipping Industry activities and initiatives Means of Reducing GHG Emissions from Shipping Industry initiatives: • Work on EEDI – formula and reference line (workshops) • Developing and assessing additional GHG reduction measures for new and existing ships (workshops) • Developing Marginal Abatement Cost Curves - to determine what is achievable (study groups) • Developing and implementing operational measures, such as “Optimal speed” (Liners) and “Virtual Arrival” (Tankers and Bulkers) • Developing industry SEEMPs, such as INTERTANKO’s TEEMP – Tanker Energy Efficiency Management Plan plus • Active participation in MBM Expert Group Technical and Operational Mitigation Measures Technical and Operational Mitigation Measures Marginal Abatement Cost Curves PRELIMINARY DRAFT, Not for circulation Developed in conjunction with DNV Virtual Arrival OCIMF / INTERTANKO project THE CONCEPT: Virtual arrival is about identifying delays at discharging ports, then managing the vessel’s arrival time at that port/terminal through well managed passage speed, resulting in reduced emissions but not reducing capacity. It is NOT not about blanket speed reduction to match current market conditions. Virtual Arrival is all about managing time and managing speed. Virtual Arrival OCIMF / INTERTANKO project THE MECHANICS: • Cooperation agreement between Charterer (Terminal Operator) and Owner • Speed is “optimised” when ship’s estimated arrival is before the terminal is ready • Owners and Charterers agree a speed adjustment • May use an independent 3rd party to calculate / audit adjustment • Owners retain demurrage, while fuel savings and any carbon credits are split between parties Virtual Arrival - additional benefits In addition to directly reduced emissions, other benefits include: • Reduced congestion & toxic emissions in the port area • Improved reliability/safety • Potentially increased use of weather routing Important pre-conditions: • The safety of the vessel remains paramount • The authority of the vessel’s Master remains unchanged • The basic terms of trade remain the same Is an MBM needed for Shipping ? With bunker costs frequently 60-80 % of total operating costs, does shipping need any further market incentive to reduce GHG emissions ? 1400 USD/tonne 1200 Bunker prices 2000 – 2010 [USD/tonne] HFO 380 cst / MDO / MGO*, Fujairah 1000 MDO/MGO* 800 600 *MGO since Dec 2008 400 HFO Source: Bunkerworld Sep-10 May-10 Jan-10 Sep-09 May-09 Jan-09 Sep-08 May-08 Jan-08 Sep-07 May-07 Jan-07 Sep-06 May-06 Jan-06 Sep-05 May-05 Jan-05 Sep-04 May-04 Jan-04 Sep-03 May-03 Jan-03 Sep-02 May-02 Jan-02 Sep-01 May-01 Jan-01 0 Sep-00 200 THANK YOU For more information, please visit: www.intertanko.com www.shipping-facts.com www.maritimeindustryfoundation.com IMO MARPOL Annex VI: North Sea ECA 62˚N 4˚W 57˚44.8’ N 5˚W 48˚30’N Global Bunkering One - third of bunkers are supplied in ECA ports USA 12.70% Canada & Mexico 0.30% Baltic Sea 3% North Sea 18% Rest of the World 66% Marine distillates on EU must have < 0.10% sulphur content Source: Poten & Partners Challenges for ships • Switching between at least 3 grades of fuel • Calling at EU ports, ships need to use: – Deep sea fuel (HFO) – ECA fuel (LSFO) – EU - ”at berth”/”at anchor” fuel (MGO) • Onboard storage & segregation capacity • Increase risk of fuel incompatibility • Increases the risks of boiler incidents • Safety requires upgrading/modifications • Viscosity, lubricity, flash point temp. Quality Problems with Marine Fuel Oils • • • • • • • • • • • • • HIGH ABRASIVE FUELS HIGH ASH LOW FLASH POINT HIGH SEDIMENTS HIGH DENSITY FUELS CONTAINING USED LUBE OILS POLYETHYLENE CONTAMINATION POLYSTYRENE CONTAMINATION HIGH CALCIUM & HIGH SODIUM HIGH WATER CONTENT CONTAMINATED FUELS INCOMPATIBILITY OF BLENDS FATTY ACIDE METHYL ESTER (FAME) EEDI / EEOI CO2 factor x SFC[FOC] (g/kW h) x Engine Power (kW) EEDI (g/tonne mile) = -----------------------------------------------------------------------------Capacity (tonne) x Speed (mile/h) CO2 factor x [FOC] (g) EEOI (g/tonne mile) = ---------------------------------------------------------------Cargo Mass (tonne) x Sailed Distance (mile)