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Hellenic Forum Athens 6 March 2007

Hellenic Forum Athens 6 March 2007. Peter M. Swift. Hellenic Forum REVISION of MARPOL ANNEX VI Air Emissions. Peter M. Swift. Governing Regulations. MARPOL Annex VI entered into effect in 2005 Baltic Sea - SECA from May 2006 North Sea - SECA in November  2007

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Hellenic Forum Athens 6 March 2007

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  1. Hellenic ForumAthens6 March 2007 Peter M. Swift

  2. Hellenic ForumREVISION ofMARPOL ANNEX VIAir Emissions Peter M. Swift

  3. 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 took effect Jan 2007 • Various ports - local regulations on Ship Emissions, which are inhibiting future expansion/development - introducing differentiated port fees Of particular concern to tramp sectors, trading internationally, lifting bunkers in ports worldwide

  4. SECAs & CHANGE OVER AREAS Source: http://maps.google.com/ Changeover Area MAY 2006 AUGUST 2007

  5. IMO & UNILATERAL LEGISLATION ON LOW SULPHUR MARINE FUELS

  6. MARPOL Annex VIPROPOSALS FOR AMENDMENTS • Lower limits for SOx & NOx emissions • SECAs with lower S cap (1.0% or 0.5%) • NOx emission limitation on existing engines • NECAs – NOx controlled areas • Restriction on Particulate Matters (PM) emissions • Further controls on VOC emissions from cargo oil tanks

  7. INTERTANKO Process (1/2) • 2005 Revision Process for Annex VI initiated • 2005/6 INTERTANKO initiates committee review of Annex VI • 2005/6 INTERTANKO Council discusses CARB, cold ironing et al • Apr/May Intersessional Meeting called for November 2006 ‘06 (Date clash with Nov ’06 Council) • May ’06 HKSOA announces (LS) Global SECA proposal • June ’06 ExCom support principle of assessing a distillate only option, but refer to ISTEC • June ’06 INTERTANKO “thinking” discussed with ICS and INTERCARGO • Jul ’06 ICS invite INTERTANKO to Strategy Committee. INTERTANKO accepts highlighting current thinking re distillates, Subsequently INTERTANKO expresses same to RT Members et al. (Committee now scheduled for first meeting May 2007)

  8. INTERTANKO Process (2/2) • Sept ’06 Draft INTERTANKO paper to intersessional passed to ICS, BIMCO et al • Sept ’06 Joint meeting of ISTEC and INTERCARGO’s CASTEC support case for distillates being tabled at IMO intersessional • Sept ’06 ExCom agree to tabling of submission FOR DISCUSSION of distillate option. Copy of DRAFT submission passed immediately to RT colleagues, inviting comments and support. • Oct ’06 INTERTANKO secures extension on filing and submits revised paper aimed at removing any ambiguities and to clarify purpose of submission; in particular stressing “suggestion” i.e. merits discussion • Nov ’06 IMO Intersessional WG develops 4 options to be sent to MEPC

  9. INTERTANKO : 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

  10. 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 & associated systems • 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

  11. REVISION OF MARPOL ANNEX VIINTERTANKO SUGGESTION FOR DISCUSSION • Distillate fuels & 2-tiered S cap program: • from [2010], a maximum of 1.00% S content • for ships’ engines installed on and after [2015], a maximum [0.50]% S content • A Global Sulphur Emission Control Area • A New Fuel specification in Annex VI • Simpler monitoring of compliance

  12. MDO – ADVANTAGESAIR EMISSIONS • Applies to ALL existing ships/engines • With no other measure, immediately reduces: • SOx emissions by 80% to 90% • PM emissions by 90% • NOx emissions by 10% to 15% • Reduces fuel consumption with some 4% from ALL ships and thus CO2 emissions • Facilitates further NOx reductions by in-engine modifications for IMO’s Tier II & III

  13. MDO – ADVANTAGESAIR EMISSIONS • Engines designed for use of MDO only will accommodate further emission reductions over their entire life time • Further regulatory reduction of air emissions from ships will be a function of better quality fuels and not limited by engine’s functional parameters

  14. MDO - ADDITIONAL BENEFITS • ENVIRONMENTAL: • Reduces onboard fuel generated waste • No fuel heating/treatment = energy saving • ALL ships become “greener” • “Cleaner” waste & free of hazardous elements contained in residual fuels • Avoiding use of abatement technologies = no further additional waste & no need of further waste disposal • Potential bunker spills significantly less harmful • SAFETY: • Less incidents with engine breakdowns caused by poorer quality fuels • No need of complex fuel change-over operations • No risk of incompatibility of blended fuels • Safer working environment for crews

  15. BLG Working Group Options: SOx • A. Status Quo - No change • B. Sulphur Emissions Control Area (SECA): • A global sulphur cap (unchanged or lower value) • SECA sulphur cap lowered in two tiers: • 1.0% in [2010] • 0.5% in [2015] • C1. Change to distillate fuels (no SECA): • Use of distillate fuels for all ships • A global sulphur cap in two tiers: • 1.0% in [2012] • 0.5% in [2015] • Include in MARPOL Annex VI the specification for the distillate fuel to be used by ships • C2. Global cap – As C1 but allows use of residual fuel + scrubbers

  16. Challenges for IMO Reduce air emissions from ships • What emissions - SOx, NOx, PM, VOCs ? - Later CO2 ? • Where - Globally, Coastal regions ? • Timing: - Phased, where/when/how ?

  17. OPTIONS ? Reduce air emissions from ships AT WHAT COST AND WHO TAKES RESPONSIBILTY ? • High sulphur residual with scrubbers • Low sulphur residual • Combination HS/LS residual • MDO (Low sulphur) • Other combination

  18. CO2 Emissions – Net Environmental Benefit • High refinery CO2 emissions from de-sulphurisation of residuals • High refinery CO2 emissions from MDO production/distillation • Ship CO2 emissions lower with MDO due to lower fuel consumption • Ship CO2 emissions lower with MDO since no need to heat residual fuels prior treatment & injection • High CO2 emissions in manufacturing & operating scrubbers

  19. USA Proposal to BLG11 • SOx & PM – emission limits at [200] nm from shore as from 2011 [0.1% S cap] • NOx standards for existing (pre-2000) engines - 20% reduction • NOx for new engines: • Tier II - 15% – 25% as from 2011 • Tier III - 80% only in defined areas (NECAs) as from 2016

  20. Norwegian proposal to BLG11 • SOx: MDO 0.5% sulphur content in all ships by 2015 • NOx - slow speed engines (n < 130 rpm) and intermediate speed engines (130rpm < n < 1000 rpm) - in engine technology • a) Tier II: 20% • b) Tier III: 40% • NOx on existing (pre 2000) slow speed engines – as by Tier I standard (17 g/kWh)

  21. Other Propsals to BLG11 Japan • No suggestions for measures related to SOx and PM emissions. • NOx emissions - reduction by 80% by a combination of fuel quality, in engine technology and after treatment technology. Sweden • SOx & PM emissions - use of MDO with a lower sulphur content, most likely in a two tier step at dates to be established by IMO.

  22. What next? • BLG : 16 -20 April 2007 • MEPC 56: 9-13 July 2007 • EU Commission to take stock of progress • Review of Sulphur Directive – 2008 • Scope for Community measures to reduce ship emissions pursuant to Council’s conclusions - 2008 • US considers own legislation if IMO does not deliver

  23. What next? • Annex VII – Scrubber / Catalytic Converter toxic waste handling • Biomass – 20% reduction target for CO2 • Emissions trading – extended to shipping • Sequestration of CO2

  24. Current position • INTERTANKO encourages open debate on the options available to reduce damaging air emissions from ships and has sought to provide for discussion comprehensive solutions that are applicable on a global basis. • We remain anxious that the current reviews around the world do not result in a mix of local and regional requirements that impose an onerous burden on international shipping, especially those engaged in tramp shipping - bunkering in and trading to ports around the world. • We continue to stress the importance that any new requirements should take full account of all the operational and safety considerations, and should be assessed on the same basis - this latter should involve the cost and environmental implications of all the production, manufacturing, operating and waste handling aspects of the proposed system, as well as other practicalities with respect to introduction, fitting/retrofitting, etc.

  25. INTERTANKOEncourages further discussion at Panel Meetings, Seminars and Councilpre BLGNOTE:NO INTERTANKO submission to BLG

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