There Are No Shortcuts to Compliance
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1 MARITIME There Are No Shortcuts to Compliance KEY ENVIRONMENTAL ISSUES NAMEPA WORKSHOP, POSIDONIA 2014 Paal Johansen 5th June DNV GL th June 2014 SAFER, SMARTER, GREENER
2 Marine environmental regulations Development towards 2030 Stricter regulations on SO X and NO X GHG emissions - Technical, operational and market-based measures Ballast water and recycling conventions Regulation on new issues - black carbon, underwater noise, bio-fouling and VOC Local marine environmental requirements Drivers Public opinion and awareness public pressure Health hazards in populated coastal areas Climate change Invasion of alien species Barriers Cost of administration and compliance Unclear science (black carbon and noise) Developing/developed country conflict (GHG) 2
3 Existing Emission Control Areas 3 DNV GL th June 2014
4 New ECAs fact or fiction? Turkish Straits in 2018? Hong Kong / Guangdong? Mexico in 17/ 18? 4
5 SOx 5
6 Tightening sulphur emission requirements Requirement Global sulphur 2020 / 2025*; Sulphur < 0.50% * Date TBD pending MEPC review, end-2018 latest ECA sulphur Requirement 2010; Sulphur < 1.0% 2015; Sulphur < 0.1% Requirement EU sulphur 2012; updated ECA reqs. in EU law 2020*; Sulphur < 0.50% * All EU waters; EEZ (200NM) 6
7 Scrubber systems maturing and scaling >44 SOx Exhaust Gas Cleaning systems on 20 DNV classed ships and NB projects
8 EU Sulphur Directive Revised Directive agreed by EU - Alignment with MARPOL Annex VI, but not identical; Generally covers ships within EU waters Provisions similar, but not fully identical to Annex VI 0.1% at berth and in inland waterways PAX vessels on regular service ; 1,5% in all non-eca EU waters until 2020 (200 NM). 0.5% in EU EEZ waters in 2020 Future actions and consequences EC advisory body ESSF established Additional financial support measures may be forthcoming April 14 ECJ verdict may imply that regular service applies to cruise vessels Mediterranean ECA? Political climate and 0.5% in 2020 renders this unlikely Will shipping lanes shift in 2020? Safety implications? 8
9 NOx 9
10 NOx emissions MARPOL Annex VI NOx 2011: NOx Tier 2, -20% 2016: NOx Tier 3, -80%* * New builds, only in existing North American / U.S. Caribbean NECA. New NECAS define own date NECA - Baltic HELCOM working on issue. EC and EU Council pushing, member states split Submission date uncertain NECA North Sea Consultations on-going but slow moving must be seen in conjunction with Baltic NECA activities Submission date uncertain 10
11 MEPC 66 Update - Gas engines and NOx regulations An amendment to the definition of fuel oil and marine diesel engine was approved to include gas and gas fuelled engines respectively Gas fuel will be subject to the Fuel Oil Quality requirements in MARPOL Annex VI regulation 18.3 Gas turbines and other forms of combustion engines other than internal combustion engines are still not covered by MARPOL Annex VI The amendments are expected to be adopted at MEPC 67 in October
12 CO 2 12
13 GHG policy status IMO - EEDI and SEEMP key instruments while MBM is dead in the water. Focus on energy efficiency along with increasing activity on emission Monitoring, Reporting and Verification (MRV) US - Work on efficiency standards remains key US focus area; data collection ( MRV ) key first step EU - Focus shifted from regional MBM to regional MRV; regulation likely adopted in 2014 UNFCCC Working on global climate deal by 2015 with 2020 as effective target date; outcome & implications remain uncertain Developing countries Generally opposed to MBM & MRV, but positions may be softening slightly. UNFCCC principles remain key issue 13
14 EEDI new phases driving ship design changes Schedule and/or levels may change subject to IMO reviews in 2015 and 2022, debate related to 2015 review starting 14
15 MEPC 66 update - Further ship types covered by EEDI requirements 15
16 EU Monitoring, Reporting and Verification scheme Ships above 5000 GT (all flags) have to report CO2 emission on voyages to, from and between EU ports Regulation expected in effect January Four methods a. Bunker Fuel Delivery Note (BDN) and periodic stocktakes of fuel tanks; b. Bunker fuel tank monitoring on board; c. Flow meters for applicable combustion processes; d. Direct emissions measurements Efficiency metric still undecided (nm vs. tonne-nm) Has to be negotiated and approved with EU Council and Parliament (late 2014 likely) EU sees this as a step toward a global system and further reduction requirements for shipping
17 Regulations summary air emissions 1. SOx ECA requirements will remain unchanged though global 0.5% may be delayed until 2025 but note EU waters in Limited near-term spread of new ECAs, prime candidates are Bosporus / Marmara, Hong Kong / Guangdong, Mexico 3. NOx ECA requirements effective in North American waters from NOx NECA application for North Sea and Baltic possible this decade, but politically challenging. Effective date will depend on applications. 5. CO 2 MRV for the EU likely this decade, may possibly be superseded by IMO MRV 6. CO 2 pricing in the 2020 s at the earliest, potential UNFCCC deal remains a dark horse 17
18 Ballast Water 18
19 Ratification date of the Ballast Water Convention still uncertain As of , the required 35% of the world fleet tonnage flagged by the signatories was not reached. With ratification of one Flag State with 6% gross tonnage (e.g. Panama), BWM Convention becomes mandatory 12 months later. 33 BWT systems have obtained full IMO type approval. 46 BWT manufactures are in the certification process. (basic approval IMO May 2013) 19
20 The implementation schedule has been harmonised and relaxed Compared to the initial IMO schedule, we see a relaxation suggested for vessels with small BW volume and constructed before 2009: 2 more years* vessels with small BW volume and constructed after 2009 and before EiF: 5 more years* vessels with large BW volume and constructed after 2012 and before EiF : 5 more years* But the US-requirements for BW treatment are already in force! *) years before BWT system installation becomes mandatory for all ships 20
21 Emerging regulations 21
22 Emerging regulations - summary Hull bio-fouling Particles, Black Carbon Underwater noise Expect regulations to be agreed within the next 5 10 years, effective some time later And if considering Arctic operations; keep an eye on IMO Polar Code developments 22
23 Possible developments towards 2030 Adopted EU Recycling Regulation US BW requirements EEDI phase 2 EEDI phase 1 EU 0.5% sulphur cap 0.1% ECA sulphur limit NOx tier III for new builds in North America 0.5% global sulphur cap EEDI phase Ballast Water Convention - entry into force Global CO 2 monitoring, reporting and verification Operational requirements on CO2 BC, noise, biofouling and VOC regulation EEDI phase 4 EU CO 2 monitoring, reporting and verification Additional ECAs established 0.5% global sulphur cap HK Recycling convention ratified Possible 23
24 SAFER, SMARTER, GREENER 24
25 Abbreviations 25
26 Key abbreviations BC Black Carbon BCH Code - Dangerous Chemicals in Bulk Code BLG Bulk Liquid and Gases (MEPC sub-committee) BWMC Ballast Water Management Convention CARB California Air Resources Board CG Correspondence Group DMA Marine gas oil DMB Marine diesel oil EC European Commission ECA Emission Control Area ECJ European Court of Justice EEDI Energy Efficiency Design Index EEOI Energy Efficiency Operational Indicator EEZ Exclusive Economic Zone EiF Entry into Force EMSA - European Maritime Safety Agency EPA US Environmental Protection Agency ESSF European Sustainable Shipping Forum EU European Union FORS - Fuel Oil Reduction Strategy GHG Greenhouse gases IAEA International Atomic Energy Agency IBC Code - International Bulk Chemical Code ICS International Chamber of Shipping III Code IMO Instruments Implementation Code ISPI - Individual Ship Performance Indicator LNG Liquid Natural Gas MARPOL - International Convention for the Prevention of Pollution from Ships MBM Market Based Measures ( carbon price ) MEPC Marine Environmental Protection Committee MRV Monitoring Reporting and Verification NECA NOx Emission Control Area NOx - Nitrogen oxides PPR Pollution Prevention and Response (MEPC subcommittee) SECA SOx Emission Control Area SEEMP Ship Energy Efficiency Management Plan SOx Sulphur oxides TBD To Be Determined UNFCCC United Nations Framework Convention on Climate Change US United States of America VGP Vessel General Permit 26
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