1. Air Emissions from Ships

2. Governing Regulations
MARPOL Annex VI entered into effect in 2005
Baltic Sea - SECA from May 2006
North Sea - SECA in November  2007
Europe Sulphur Directive (1999 & Rev) governs inter alia emissions in port (0.1% S at berth)
California (CARB) new regulations which take effect in 2007
Various ports are facing new local regulations on Ship Emissions, which are inhibiting future expansion/development  

3. Control of Air Pollution from Ships and its Current Revision process
MARPOL – Annex VI
Control of Air Pollution
from Ships
and its Current Revision process

4. Air Emissions from Ships
Covered by Annex VI
Oxides of Nitrogen (NOx) – create Ozone
Sulphur Oxides (SOx) – create acidification
Hydrocarbons (HC) – gas, soot and some particulates
Volatile Organic Compounds (VOC)
Refrigerant Gases
Not covered (currently) by Annex VI
Carbon Dioxide (CO2)
Carbon Monoxide (CO)
Engine exhaust gases are dependent upon engine type, engine settings and fuel type

5. The Regulations in Annex VI
There are 19 Regulations but the following Regulations impact Vessel operation :
Regulation 12 – Ozone Depleting Substances
Regulation 13 – NOx emissions
Regulation 14 – Sulphur Oxide emissions
Regulation 15 – VOC emissions
Regulation 16 – Shipboard Incinerators
Regulation 18 – Fuel Oil Quality control

6. IMO Annex VI revision process
MEPC 53 (July 2005) – Decided Annex VI be revised
MEPC 54 (March 2006) – Proposals for revision. Delegated work to BLG Sub-Committee
BLG 10 (April 2006) – Initial review of proposals and documents (over 30 documents)
Two correspondence groups (April – October 2006)
Intersessional Meeting (November ) – discussion of key issues and draft proposals
BLG 11 (April 2007) – finalize draft proposals for revised Annex VI, the NOx Code and related Guidelines
MEPC 56 (July 2007) & MEPC 57 (March 2008) - consider and approve(?) the revised texts
Target date for Entry in to Force: 2010

7. Many proposals for significant amendments to Annex VI
Lower limits for SOx & NOx emissions
SECAs with lower S cap (1% or 0.5%)
NOx emission limitation on existing engines, particularly those installed after Jan. 2000
NECAs – NOx controlled areas
Restriction on CO2 emissions
Restriction on Particulate Matters (PM) emissions
Restriction on VOC emissions from cargo oil tanks

8. INTERTANKO Process
Reviews within ISTEC and Bunker sub-committee over many years – with new emphasis since 2005
Ongoing contacts with other stakeholders
Reviewed with Executive Committee (June 2006) - basis emphasis on IMO Intersessional meeting in November
- Decision that INTERTANKO should contribute actively to the revision process
- Secretariat to develop a position paper for submission to IMO, in conjunction with ISTEC for technical and operational evaluation
Reviewed draft submission with Executive Committee (September 2006)
- Decision to support submission to Intersessional
Informal discussion with RT since mid-year
Joint reviews with INTERCARGO’s CASTEC
Invitation to RT to co-sponsor submission immediately after agreed by Executive Committee

9. Guiding Principles
Executive Committee (June 2006) – Approach to revision process
prevent fragmented regulations
promote establishment of a global standard for at sea, coastal and at berth operations (maybe no SECAs)
international standards via IMO
regulations based on a fuel standard rather than an emissions performance standard, and thus reduce the onus of responsibility on the owner/operator for verification and compliance (sympathy for use of clean fuels / distillates only)

10. Guiding Principles
Executive Committee (June 2006) – Principles for an INTERTANKO position:
ensure a solid platform of requirements
be realistic and feasible
seek a long term and positive reduction of air emissions from ships, and
contribute to a long term and a predictable regulatory regime

11. Owners’ Concerns Multitude of differing requirements
Additional requirements for multi-fuel usage

12. EXISTING SECAs
SOURCE:
MAY
2006
NOV. 2007

14. Owners’ Concerns Multitude of differing requirements
Additional requirements for multi-fuel usage
Availability of appropriate fuels
Availability & reliability of fuel processing / emission equipment
Additional costs / possible cost recovery mechanisms

15. Owners’ Concerns Multitude of differing requirements
Additional requirements for multi-fuel usage
Availability of appropriate fuels
Availability & reliability of fuel processing / emission equipment
Additional costs / possible cost recovery mechanisms
Onus of responsibility for verification and compliance

16. Owners’ Concerns
Who bares responsibility for monitoring, verification and compliance ?
Owner for:
Combustion process
Exhaust gas emission standards
Disposal of by-products OR
Fuel supplier for:
Quality of fuel supplied

17. Alternative Approaches
Do nothing – retain HFO for deep sea
Extend SECAs
Global SECA
Establish local SECAs
Establish NECAs
Use technological solutions – catalytic converters, scrubbers and/or filters
Burn distillates close to shore
Cold ironing
Emissions trading

18. INTERTANKO Approach TABLING FOR DISCUSSION:
The use of distillate fuels, with a global S content cap introduced using a two tiered programme, as follows:
from [2010], a maximum of 1.00% S content
for ships’ engines installed on and after [2015], a maximum [0.50]% Sulphur content
A Global Sulphur Emission Control Area
If the above two issues were considered feasible, then the provisions for checking and monitoring compliance with Regulation 14 and 18 should be revised accordingly.

19. Objective of INTERTANKO submission
The main purpose of the INTERTANKO submission is to "present issues that merit further discussion by the IMO Working Group when considering the revision of Annex VI of MARPOL"  
INTERTANKO believes that it is important that there is open debate at the international level on the subject of how best to meet rapidly changing expectations for lower ship emissions and that there should be full and frank discussion of the various solutions possible.

20. INTERTANKO Approach ITEMS FOR DISCUSSION include:
Future production of distillates & time frame
Confirmation of switch-over implications
Costs of engine conversions
Net benefits
Future costs of distillates

21. Alternative Approaches
ITEMS FOR DISCUSSION include:
Future production of low sulphur fuels & time frame
Proving of / reliability of SCR and scrubber technologies
Costs of extra bunker tanks
Costs of manifold modifications / sampling
Costs of additional maintenance
Means of disposing of wash water and scrubbed by-products
Suitability of blended fuels
Net benefits
Future costs of low sulphur HFO/IFOs

22. Where to debate ? IMO Or Series of bilateral discussions
External forums with all stakeholders

23. DISTILLATES - ADVANTAGES
reduces all types of air emissions from ships, including PM
reduces the bunker consumption (by weight) by 5% to 10%
eliminates the need of retrofitting of additional bunker storage capacity and associated piping
eliminates current onboard fuel treatment plants and significantly reduces onboard generated ER waste and exposure of the engines to damaging materials

24. DISTILLATES - ADVANTAGES
eliminates the need for scrubbers for the inert gas system
no additional costs of installing, operating and, maintaining/repairing equipment for reducing PM and SOx emissions
no potential losses due to delay in case of unexpected breakdown of onboard technology
if no SECAs, no operational burdens for ships & no associated risks when changing fuel types, lube oils and settings for the ship’s engines

25. ONE Approach for CALIFORNIA
Environmental achievements 2006
Maersk Line announced a pilot environmental initiative that annually reduces vessel-related emissions from the company’s fleet that calls the ports of Los Angeles and Oakland, USA. Maersk Line has voluntarily switched to low-sulphur diesel on the main and auxiliary engines of its vessels when they are within 24 miles of the port and alongside. Maersk Line projects a 73% annual reduction in particulate matter and a 92% reduction in sulphur dioxide (SOx).

26. Further information

27. Regulation 14 - SOx
The Worldwide Sulphur cap on fuel oil is set at 4.5%.
Sulphur Emission Control areas (SECAs)
Areas – Baltic, North Sea and English Channel
Sulphur Level of fuel – 1.5% or;
Alternatively use an exhaust gas cleaning system
Ship must have cleared all pipe systems and tanks and be using low sulphur fuel on entry

28. Proposed Revisions of Regulation 14 - SOx
Reduction of SOx emissions
Reduction of the Global Cap – e.g. to 3.00%
Reduction of the SECA Cap – e.g. to 1.00% or 0.50%
Correction for the reporting and measurement standard to two decimal places for Sulphur content (Bunker Delivery Note criterion).

29. Regulation 13 – NOx
For all Engines (except emergency engines) installed on ships after 1st January 2000 of more than 130 kW must comply to this Regulation.
The NOx emission is limited to 17 g/kW h for engines operating at 130 rpm but reducing to 9.8 g/kW h for 2000 rpm. Between these revs the limit is designated by equation:
45 * n(-0.2) g/kW h
Existing engines can become a “new” engine if substantially modified.

30. Proposed Revisions of Regulation 13 - NOx
Tiered approach to further NOx reductions – Tier 2 from date of revisions coming into force , and Tier 3 from 2015
Lower limit NOx emissions ( % reduction discussed for first tier – 2010)
Further NOx emission limitation on all existing engines, particularly those installed after Jan. 2000
NECAs – NOx emission control areas (Tier 3 levels for these areas?)

31. New Parameter for Air Pollution Control
Particulate Matter Emission control
What are these Particulates?
Sulphates from SOx
Nitrates from NOx
VOC from uncombusted hydrocarbons
Heavy Metals e.g. Vanadium, Nickel, Aluminium, Sodium, Calcium, Zinc; from Heavy Fuel oil and Lube Oil
Soot – from the aromatics in heavy fuel oil

32. Particulate Matter Regulation and Control Methods
At present this subject matter has not been fully debated within the working group
Issues to be confronted:
Size of the Particulate to be regulated – 10 micron or 2.5 micron
Extent of limitation of Particulate emission
Methods for control of Particulate emissions – e.g. Scrubbers and/or Filters
Storage and Disposal of Particulates
Control and verification of reduced emissions

33. Current Regulation 18 – Fuel Oil Quality
“Fuel oil shall be blends of hydrocarbons derived from petroleum refining”
“Fuel oil shall be free from inorganic acid”
“Fuel oil shall not include any added substance or chemical waste which either:
Jeopardises the safety of ships or adversely affects the performance of the machinery, or
Is harmful to personnel, or
Contributes overall to additional air pollution”

34. Regulation 18 – Fuel Oil Quality
Bunker Delivery Note (BDN)
Becomes a Statutory document
Must be kept on board for 3 years for inspection and a copy taken for further examination.
Must contain all data required by appendix V
Name and IMO number of vessel
Port
Date of Commencement of delivery
Details of fuel oil supplier
Product name, quantity , Density at 15 0C and Sulphur content % m/m
A declaration that fuel supplied meets Regulation 14 and 18.

35. Regulation 18 – Fuel Oil Quality
Fuel Oil Sampling
A sealed sample meeting the requirements in associated guidelines has to given to the ship by the bunker supplier
For each individual BDN a sample has to be taken at the vessel’s bunker receiving manifold. (see procedure in associated guidelines)
The sample label has to be signed by both the bunker supplier’s representative and the vessel’s Chief Engineer.
The sample size shall be not less than 400 mls
The sample is not to be used for any commercial purpose
The sample is to be retained on board for at least 1 year for inspection by PSC as required