Sveinung Oftedal seniorrådgiver - NTNU · Within a SECA Sulphur content of fuel oil used shall not...

Skipsfartens luftutslipp – internasjonalt rammeverk

Sveinung Oftedalseniorrådgiver

2 Norwegian Ministry of the Environment, Marintekniske dager 2007

Klimautfordringene i et marint perspektiv

Innhold:

• Historisk bakgrunn

• Luftforurensning - Internasjonalt rammeverk

• Klimagassutslipp – Internasjonalt rammeverk

• Fremtidige krav





International Maritime Organization

• Founded in 1948

• Headquarters in London

• 168 Member States

– Consultative status: 51 IGO’s and 66 NGO’s

• Has developed and adopted some 50 mandatoryinstruments

• The IMO Convention Article 1 sets out the purpose of theOrganization:

– Article 1(a): ”to provide machinery for cooperationamong Governments in the field of governmentalregulation and practices relating to technical matters of all kinds affecting shipping engaged in internationaltrade….

– Article 1(b): ” to encourage the removal ofdiscriminatory action…..”



What is the IMO?

• The IMO is the ”will” of its member States• Consensus• Purpose and role is defined by the Conventions• Flag State Regime (but port state control rights)• Voluntary Member State auditing

• Each Organization has its own powerbalance; alsothe IMO

• Very structured processes• Politicians are not present

• ”The most efficient UN body”



The International Maritime Organization

Structure:• Assembly• Council• Committees:

– MSC– MEPC

• Sub-Committees (9)– Legal Committee– Technical Co-operation Committee– Facilitation Committee

”Safe, secure and efficient shipping on clean oceans”



IMO Background – Air Pollution

• Air pollution: initiated in the late 1980’s

• Resolution A.719(17) adopted in 1991.Recognized the urgent necessity of establishing a policy on the prevention of air pollution from ships, leading to the adoption of Annex VI to MARPOL 73/78.

• IMO Air Pollution Conference in September 1997Protocol of 1997 to amend MARPOL 73/78 to include Regulations for the Prevention of Air Pollution from Ships adopted 26 Sept.

• Greenhouse Gas Emissions not included, but Conf. Res. 7 and 8 which addressed PFC’s and CO2 emissions respectively.

• Only Parties to MARPOL 73/78 may become Parties

• Norwegian ratification in December 1998 as one of the first

• Entry into force: 19 May 2005

• Revision agreed at MEPC 53 (July 2005)



MARPOL 73/78 Annex VI

• Annex VI applies to all ships and to fixed and floating drilling rigs

• Regulation 13 and the NOx technical code applies to diesel engines of 130 kW or more

• The requirements:– Regulation12 Ozone-depleting substances– Regulation 13 Nitrogen oxides– Regulation 14 Sulphur oxides– Regulation 15 Volatile organic compounds– Regulalation 16 Shipboard incineration– Regulation 18 Fuel oil quality

• Positive observation: ”The entry into force of global regulationsfor the prevention of air pollution from Ships is ground breaking.”

• Negative observation: ”We have waited a long, long time for regulations which will have no effect.”



All ship of 400 GT or above engaged in voyages to ports or offshore terminals under the jurisdiction of other parties: Shall be subject to surveys (initial, intermediate, periodical) and an International Air Pollution Prevention Certificate shall be issued by the Administration or a duly authorized body

Existing ships have to comply and be equipped with an IAPP Certificate at the first scheduled drydocking after entry into force, but in no case later than 3 years: 19 May 2008

MARPOL Annex VI - approach



Procedure of Certification for MARPOL Annex VI

In Manufacturer's works

Pre-Certification Survey

EIAPP-Certificate+ Supplement+ Technical File

On Shipyard

Initial Survey

IAPP-Certificate

Maintaining of Compliance by

Intermediate Survey

Periodical Survey

Renewal of IAPP-Certificate



Reg 12 Ozone-depleting substances

1) Deliberate emissions of Ozone-depleting substancesshall be prohibeted.

(2) New installations which contains Ozone-depletingsubstances shall be prohibeted on all ships, exceptthat new installations containinghydrochlorofluorocarbons (HCFCs), are permitted until1 January 2020.

(3) Deliver to reception facilities when removed from ships.



Regulation 13 of the 1997 Protocol contains limits for emissions of nitrogen oxides (NOx) from marine diesel engines. According to Regulation 13, the NOx emissions of any diesel engine with a power output of more than 130 kW installed on a ship constructed on orafter 1 January 2000, or that undergoes a major conversion on orafter that date, shall not exceed the following limits:

17 g/kW-hr when n is less than 130 rpm

45.0*n(-0.2) g/kW-hrwhen n is 130 or more but less than 2000 rpm

9.8 g/kW-hr when n is 2000 rpm or more

MARPOL Annex VI – Reg.13 NOx



The NOx Curve:



No fuel oil on ships shall exceed 4,5 % m/m Sulphur

Within a SOx Emission Control Area (SECA) 1,5 % S

Only two ways to prevent Sulphur pollution:

Remove the Sulphur from the fuel oil or scrub the exhaust gas

MEPC 53 adopted Guidelines for:

EXHAUST GAS-SOxCLEANING SYSTEMS

MARPOL Annex VI – Reg 14 SOx



Sulphur Oxides Emission Control Areas (SECAs) may be designated by IMO in accordance with Appendix III

Within a SECA Sulphur content of fuel oil used shall not exceed 1,5 %, or the exhaust gas shall be scrubbed to reduce the total emission of SOx to 6.0 g SOx/kW hour or less

22 November 2007 19 May 2006

MARPOL Annec VI – Reg. 14 SOx



Sulphur in fuel oils globally



• Blends of hydrocarbons derived from petroleum refining shall be free of inorganic acid and shall not include any added substance or chemical waste which:- jeopardizes the safety of ships, or adversely

affects the performance of the machinery, or- is harmful to personnel, or- contributes to overall additional air pollution

• Details of fuel to be recorded by means of a Bunker Delivery Note (BDN) to be kept on board for minimum 3 years

• BDN to be accompanied by a representative sample of the fuel oil and retained under the ship’s control for minimum 12 months(sampling to be carried out according to IMO guidelines,ref. Resolution MEPC.96(47) of 8 March 2002)

MARPOL Annex VI – Reg. 18 Fuel Oil Quality



Appendix V

Information to be included in the bunker delivery note (Regulation 18(3))

Name and IMO number of receiving ship

Port

Date of commencement of delivery

Name, address, and telephone number of marine fuel oil supplier

Product names)

Quantity (metric tons)

Density at 15°C (kg/m3)*

Sulphur content (% m/m)+

A declaration signed and certified by the fuel oil supplier's representative that the fuel oil supplied is in conformity with regulation 14 (1) or (4)(a) and regulation 18(1)

*Fuel oil should be tested in accordance with ISO 3675.

+Fuel oil should be tested in accordance with I50 8754.



VOC is the mixture of light end components (methane to octane) in crude oil, emitted from the oil during production, processing, loading, transport, unloading and storage.

To be regulated Nationally in accordance with Reg 15

The lightest component (mainly methane) contributes to the greenhouse effect, whilst the heavier components (mainly propane and butane) contribute to ground level ozone, detrimental to human health and the vegetation. VOC can also be the direct cause of oil spill on the ship’s deck, as high flow out of the cargo tanks/ riser mast due to severe VOC generation can cause oil entrainment into the inert/ VOC flow.

MARPOL Annex VI – Reg. 15 VOC



MARPOL Annex VI - Reg 16 Shipboard incinertaion

• Each incinerator installed after 1 january 2000 shall

meet the requirements contained in Appendix IV (A

requrement for type approval)

• Meet the operational requirements established in

the regulation (eg. Prohibition of incineration of

PCBs)



MARPOL Annex VI – Reg 19 Plattforms and drilling rigs



MARPOL 73/78 Annex VI – Enforcement

• Our main obligation as Party to the Protocol is to ensure thatNorwegian flagged ships comply.

• Our fundamental right as Port State is to ensurethat all ships comply.

Flag State Control RegimePort State Control Regime



MARPOL 73/78 Annex VI - Enforcement

• As Flag State:• The NMD is responsible for providing services (such as

information, surveys and certification) to Norwegianships.

• We have authorized five classification societies to act onour behalf; ABS, BV, DNV, GL, Lloyds.

• The Administrations selection of RO represents an important element in an enforcement regime




Supervising the Classification Societies:• The Class Agreement (revised when needed)• Regular (annual) high level contact meetings• NIS-circulars inform on tasks to be undertaken by class.• Class audits

– System AuditsFocus on assessments of their systems, visits at their mainoffice/stations, review of documents and interviews

– Vertical AuditsSuperviseing the work of the class surveyor

• Unscheduled inspections of Norwegian Ships




• The NMD also undertakes survey and certificationson some Norwegian ships.

• The Annex VI survey and certification scheme is the ”standard IMO-regime”

• Included in the HSSC regime at MEPC 53




Port State Control• The Port State Control Regime is defined in Regulation 10

of Annex VI and Article 5 of the Convention.• The IMO guidelines for port state control for MARPOL

Annex VI was adopted at MEPC 53• The EU Port State Control Directive is amended to include

Annex VI• The PMOU manual is amended to include instructions on

PSC on Annex VI• NMD has developed internal instructions




Port state control – general• The Norwegian Maritime directorate has developed PSC

Quality Standards which includes;– Minimum criteria for port state control officers– Priority inspections– Types of inspection– Inspection procedures– Detention procedures– Release procedure– Banning procedure




PSC – Types of inspection• Initial inspection• More detailed inspection• Expanded inspection• Follow-up of inspections




Port state control• First approach will be to control of documents:

– Valid IAPP certificate?– Bunker delivery note(s) on board ship? In order?– Bunker samples on board ship?– Entries in the engine log book? (Important in relation

to SECA)– Approved documentation relating to exhaust gas

cleaning systems?




• More thorough inspections if there are cleargrounds due to e.g. observations during theinspection, information in Sirenac etc.– Thorough inspection of the engine log book (in

relation to SECA requirement)– Analyzing fuel samples




Inspection of ships of non-parties• Due to the no more favourable treatment clause,

these ships have to provide statements ofcompliance

Ships in innocent passage• Such ships shall comply but no enforcement actions

will be undertaken




Deficiencies/Violations

• Appropriate actions will be undertaken• Normal response to deficiencies are:

– ISM code related deficiency: Correct deficiency within threemonths

– Minor deficiency: Correct deficiency within 14 days– Serious deficiency: Correct deficiency before departure– Very serious deficiency: Detention

• Vioations: Will be reported to the marine investigator for appropriate legal reaction



Revision of MARPOL Annex VI - Timeline

• Proposed by Norway and some other states at thefirst MEPC meeting after entry into force (MEPC53)

• Accepted by MEPC and terms of reference includeda full revision with new elements such as PM and existing engines.

• Huge task with tight time schedule

• A revised Annex VI will possibly be approvedadopted in 2008 and enter into force 10 monthsafter the date of adoption.



Revision of MARPOL Annex VI –Norwegian viewpoints

• SOx – 0.5 % S in bunkers globally from 2015 at the latest

• NOxTier II: 20-25% reduction in [2010]Tier III:40-50% reduction in [2015]Pre 2000 engines: slow speed two stroke engines to comply with Tier I from [1 January 2010]. The effective date should be linked to the first intermediate or renewal survey whichever is the later.

• Fuel oil quality: introduce a global requirement from 2015 at the latest to use use and deliver fuel oils with a fuelspecification equal to distillates.

• VOC – VOC Management Plan

• PM – No specific proposal, but the distillate requirementwill to a great extent improve the situation



A major problem

A man with vision and guts

An historic solution



To allign shipping with other modes oftransport and use cleaner fuel, is like thePlimsoll line; one singel measure with a longlist of positive effects

Residual fuel

Distillate



Fuel specification will reduce air pollution

• Cleaner fuels will make larger reductions in NOxemissions feasible, and also the lower nitrogen content in distillates will lead to NOx reductions of 10-15 %.

• By requiring a global cap of 0.5 % Sulphur in fuels, the reduction in SOx emissions from ships will be (60% to 80%),

• Large reductions, approximately 90 %, in emissions of Particulate Matter (PM) emissions will be achieved



Distillates and CO2

• If it is decided that shipping shall be required to use distillates and not residual fuels, the CO2 emissions will be reduced for the following reasons:– The energy content in the fuel will increase. Moreover, the

fuel contains less carbon resulting in less CO2 being generated during the combustion. Furthermore;

– There will be no need for energy demanding preheating of fuel and fuel separation processes as for residual fuels, and

– The significant increased fuel costs will require international shipping to focus more on energy efficient ship design and operation. In particular, increased fuel costs will most likely adjust the optimal ship speed resulting in significant fuel savings. This effect can be compared with the introduction of a carbon tax

• Moreover, it should be noted that producing additional distillate fuels would result in less CO2 emissions than de-sulphurization of residual fuels, and much less emissions than those resulting from manufacturing and operation of abatement technologies.

• Finally, we have to remember that in Europe the refineries are included in an Emission Trading Scheme, so increased CO2, if any, will have to be compensated.



Distillates will reduce discharges to sea

• Low production of oily waste by using distillates will reduce the problems experienced on illegal spills of oily waste from ships.

• Distillates have less hazardous components than residual fuels, and when an accident occur causing spills of bunker oil, the environmental consequences will be much less for distillates than that of residual fuel (heavy bunker oil)



Distillates will increase safety

• Cleaner fuels will lead to fewer engine breakdowns and consequently fewer accidents.

• Using different types of residual fuel, compatibility problems will occur which will lead to less stable operation. Such problems will not occur for distillates.



Background - GHG

• Resolution A.719(17) adopted in 1991.Recognized the urgent necessity of establishing a policy on the prevention of air pollution from ships, leading to the adoption of Annex VI to MARPOL 73/78.

• Air Pollution Conference in September 1997Adopted Conf. Res. 7 and 8 which addressed PFC’s and CO2 emissions respectively.

• IMO GHG studySubmitted to MEPC 45 (October 2000). Financed by Denmark, the Netherlands, Norway, Sweden, United States, European Commission.

• Resolution A.963(23) IMO Policies and Practices Related to the Reduction of Greenhouse Gas Emissions from ShipsAdopted on 5 December 2003.



Resolution A.963(23) IMO Policies and Practices Related to the Reduction of Greenhouse Gas Emissions from Ships

1. URGES the Marine Environment Protection Committee to identify and develop the mechanism or mechanisms needed to achieve the limitation or reduction of GHG emissions from international shipping and, in doing so, to give priority to:

(a) the establishment of a GHG emission baseline;

(b) the development of a methodology to describe the GHG efficiency of a ship in terms of a GHG emission index for that ship. In developing the methodology for the GHG emission indexing scheme, the MEPC should recognize that CO2 is the main greenhouse gas emitted by ships;

(c) the development of Guidelines by which the GHG emission indexing scheme may be applied in practice. The Guidelines are to address issues such as verification;

(d) the evaluation of technical, operational and market-based solutions;



Resolution A.963(23) IMO Policies and Practices Related to the Reduction of Greenhouse Gas Emissions from Ships

2. REQUESTS the Marine Environment Protection Committee:

(a) to consider the methodological aspects related to the reporting of GHG emissions from ships engaged in international transport;

(b) to develop a work plan with a timetable;

(c) to keep this matter under review and to prepare consolidated statements on the continuing IMO policies and practices related to the limitation or reduction of GHG emissions from international shipping;



Policy Considerations

• Late 1980’s → Air Pollution Conference 1997:

• Not explicitly mentioned in the Resolution A.719(17), but GHG emissions from ships was inherent in the deliberations taking place at the IMO towards the Conference.

• Conference resolution 7 & 8 represents the first IMO response to the issue of climate change




• Air Pollution Conference (1997) → MEPC 48 (Oct 2002):

• GHG got more mature in the IMO (slowly).

• The IMO GHG study was a needed base document

• The draft resolution (arising from the correspondence group – Norway) was embraced by the Committee except from China which referred to Article 2.2 of the Kyoto Protocol.

• In the period 1997-2002 UNFCCC served as a driving element in the IMO discussions




• MEPC 49 (Aug. 2003) → MEPC 52 (Oct. 2004):• MEPC 49 decided that the Policy resolution should be

based on a common policy applicable to all ships, rather than based on the provisions of the Kyoto Protocol which states that the reduction of GHG emission from ships is under the responsibility of the Annex I countries of the Protocol.

• Massive lobby by China towards and under Assembly 23. Near a collapse.

• Blocking by China, Saudi Arabia and others• MEPC 52: Work on technical issues only

• UNFCCC and Article 2.2 of the Kyoto Protocol creates a stumblingstone for any substantial IMO action on the GHG issue.




• MEPC 53 (July 2005) → MEPC 55 (Oct 2006):

• MEPC 53 approved the “Interim Guidelines for Voluntary Ship CO2 Emission Indexing for Use in Trials”

• MEPC 54 developed a revised work plan, but did not adopt it. Significant progress.

• MEPC 55 adopted the revised work plan and agreed to update the IMO GHG study.

• Active and positive role taken by China and India.

• Blocking by Saudi Arabia and USA continued

• MEPC 56: Further follow-up of the resolution. New signals.



IMO achievements

• 1997 Conference resolution 8• 2000 An IMO GHG Study• 2003 A policy resolution• 2005 Interim guidelines for Voluntary Ship

CO2 emission indexing of ships foruse in trials

• 2006 Work plan to identify and develop the mechanisms needed to achieve the limitation or reduction of CO2 emissions from international shipping

• 2007 Discussions on the next steps, including the update of the IMO GHG study, and establishing data in the IMO GISIS

• 2008 Discussions on the next steps, revised guidelines, start on GHG study

• 2009 More to come….. possibly



IMO GHG Work Plan

1 CO2 Emission Indexing Scheme (action 1(b) of resolution A.963(23)):.1 Member States and the industry to continue to carry out trials

in accordance with MEPC/Circ.471 and submit the results to MEPC; and

.2 Improve indexing method set out in MEPC/Circ.471.

2 CO2 emission baseline(s) (action 1(a) and (b) of resolution A.963(23)):.1 Consider methodology for CO2 emission baseline(s) in terms

of efficiency;.2 Evaluate the methodology referred to in paragraph 2.1 by

accumulated data on CO2 emission;.3 Draft proposal(s) on CO2 emission efficiency baseline(s); and .4 Explore other types of baseline(s), if necessary.

3 Consider technical, operational and market-based methods for dealing with GHG emissions (action 1(d) of resolution A.963(23)).



IMO GHG Work Plan - Timetable

OOOO3

OO2.4

OO2.3

OOO2.2

OOOO2.1

OO1.2

OOOO1.1

MEPC 59July 09

MEPC 58Oct. 08

MEPC 57Mar. 08

A 25Nov. 07

MEPC 56July 07

MEPC 55Oct. 06

Item



Climate Change at the IMO - overview

• 1997 Conference resolution 8• 2000 An IMO GHG Study• 2003 Resolution A.963(23) IMO GHG policy• 2005 Interim guidelines for Voluntary Ship

CO2 emission indexing of ships foruse in trials

• 2006 Work plan to identify and develop the mechanisms needed to achieve the limitation or reduction of CO2 emissions from international shipping

• 2007 Discussions on the next steps, including the update of the IMO GHG study, and establishing data in the IMO GISIS

• 2008 Discussions on the next steps, revised guidelines, start on GHG study

• 20xx IMO progress are dependent on theinternational policy situation



The Challenge……



Future

• No magic formula in sight, but in searching for solutions, the basic principles in the role of IMO cannot be overlooked.

• A more binding requirement for emissions from international sources should be the target, but the “Article 2.2 trap” of Kyoto should be avoided

• IMO must be given the task to develop the mechanisms which responds to a requirement of the UNFCCC.



Final remark• Air Pollution:

– Regulations in place– Stricter regulations will come– The ongoing work on the revision of

MARPOL Annex VI may end with theintroduction of dramatic GHG policy tool….

• GHG:– No binding mechanism in place– International policy situation will

decide if/when a binding mechansimwill be established



Thank you for yourattention!

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