The importance of enforcement Niels Bjørn Mortensen, Director, Regulatory Affairs, Technology EEDI PM2.5 SOx Partnerskab for grøn Skibsfart 09-12-2013 Technology
12 years of environmental regulation ahead Other rules US-BWM MLC BWMC? ECA NO X EU Recycling EU SO X Scrubbers? Hong Kong Convention? Air pollution ECA SO X? Global SO X 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 Climate SEEMP & EEDI BC? EEDI 10 % EEDI 20 % EEDI 30 % LNG? MRV MBM? Bio Fuel? Technology Slide no. 2 09-12-2013
Maersk Oil Trading 2012 figures Key facts Fuel volume Volume Value 12 million tons 8 billion USD Operations Deliveries 17,000 Technology page 3 09-12-2013
SOx enforcement It all started with a rumour: Some shipowners never purchase a single drop of low sulphur fuel. Some bunker suppliers can issue BDNs with any content you d like. Figures received from the Netherlands confirmed our suspicions. The report from Cardiff University gave further rise to concerns. Ball park figures indicate a mismatch between total amount of LSFO sold and the estimated amount required. Technology 09-12-2013
SOx enforcement APMM encourages a strong enforcement regime, in particular in ECAs after 2015. An AFRAMAX tanker can save ~150-175,000 $ on a trip from North Atlantic to Primorsk and back again by being non-compliant, i.e. by using HFO instead of MGO. That is twice the running cost (incl. wages) for such a ship. In today s market it even exceeds the daily charter rate. These figures can be even larger for a containership. Technology 09-12-2013
SOx enforcement E.C. issued a tender for a service contract on: Development of sampling, analysis and inspection guidelines to ensure harmonized and comprehensive reporting on the sulphur content of liquid fuels falling under the scope of Directive 1999/32/EC. It is stated in the tender that only 1 of 1000 ships are inspected for fuel compliance within EU ports. Technology 09-12-2013
2 Investigations of testing frequency show that only a fraction of vessels are tested What is the testing frequency? Frequency report 1: Reported yearly SOx tests by Dutch Shipping Inspectorate vs. port calls in Rotterdam Frequency 2: Reported SOx tests in Paris MoU participating countries vs. port calls of seagoing vessels in Europe. 140 34,000 750 406,000 Port calls tests conducted 1 in 250 vessels tested = <0.4% Port calls* tests conducted** 1 in 555 vessels tested = <0.2% From 1 in 250 to 1 in 500 vessels The number of fuel samples tested by competent authorities lead to the conclusion that in some cases sampling only takes place in 1 out of 1000 ships. The European Commission, Directorate-General environment None of our vessels have to my knowledge ever been tested Head of bunker purchase at Carnival Cruise Source:MOTBD analysis; reports from national and European authorities about number of tests conducted vs. total port calls in same regions. 2010 figures *: Port calls is a rough estimate based on input from Great Britain s department of Transport. Not all vessel classes incl. **: No. of test conducted is an estimate based on the number of deficiencies found under Paris MoU coupled with input from Danish maritime Organization Technology Slide no. 7 09-12-2013
2012 PSC statistics Total nos. of inspections within N.E. ECA: 6909 Total nos. of detentions: 158 Total nos. of fuel related detentions: 10 All in the Netherlands: Rotterdam: 7 Amsterdam: 2 Terneuzen: 1 Technology Slide no. 8 09-12-2013
2012 APMM statistics for Maersk Line (ML) and Maersk Tankers (MT) ML total nos. of port calls within N.E. ECA: 3198 ML total nos. of inspections within N.E. ECA: 57 ML total nos. of fuel inspections within N.E. ECA: 0 MT total nos. of port calls globally: 9690 MT total nos. of inspections globally: 181 MT total nos. of fuel inspections within N.E. ECA: 0 Technology Slide no. 9 09-12-2013
Enforcement in Holland 2011 98 samples: 50 (51%) non compliant 27 actions taken by PSC 2012 86 samples: 40 (46%) non compliant 25 actions taken (10 detentions) 2013 (1H) 44 samples: 24 (54%) non compliant 16 actions taken Technology 09-12-2013
Why so few fuel samples? Checking fuel compliance today is HFO vs HFO. You ll need a lab-test to tell whether one HFO is above or below 1.00% S. A lab test usually cost around 750. After 2015 it will be HFO vs MGO. No lab test required to tell the difference. Feel the pipes! Technology Slide no. 11 09-12-2013
Way ahead 1. Paris MoU Concentrated Inspection Campaign - CIC 2. Monitoring, Reporting and Verification MRV 3. Under-bridge sniffers Technology Slide no. 12 09-12-2013
Way ahead: CIC Paris MoU initiates CIC every year. Present CIC is on implementation of the MLC. MLC entered into force 20 August 2013. We d suggest a CIC on Sulphur rules in North Europe in early 2015. Technology Slide no. 13 09-12-2013
Way ahead: MRV The draft MRV rules state: Article 9(a): (Companies shall monitor) amount and emission factor for each type of fuel consumed in total and differentiated between fuel used inside and outside emission control areas; Article 14.2:..the verifier shall assess the reliability, credibility and accuracy of the monitoring system and of the reported data and information relating to emissions; Article 15.4:..The verifier may conduct spot-checks during the verification process to determine the reliability of reported data and information. Technology Slide no. 14 09-12-2013
European Sustainable Shipping Forum - ESSF Status on Reporting in the Directive 1999/32/EC. Reporting by the Member States under Directive 1999/32/EC has proven insufficient for the purpose of verification of compliance with that Directive due to the lack of harmonized and sufficiently precise provisions on the content and the format of the Member States reports. Technology Slide no. 15 09-12-2013
Bunkerworld 21 November 2013: It is clear that there will be massive noncompliance in 2015, unless something is done urgently [for effective enforcement]. Statement by Transport and Environment (T&E). Call for monitoring of all shipping emissions under the MRV umbrella. We agree with the first statement, not the means to solve it. Technology Slide no. 16 09-12-2013
Way ahead: Under-bridge sniffers Project with scvn, nmdfn irul Technology Slide no. 17 09-12-2013
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