EUROPEAN PANEL ROME CONFITARMA OFFICE

EUROPEAN PANEL ROME CONFITARMA OFFICE 27 & 28 SEPTEMBER 2016 Dragos Rauta

AIR EMISSIONS SOx - ECA FUEL AVAILABILITY NO ISSUES / NEW LSFOs COMPLIANCE over 95%

AIR EMISSIONS SOx - ECA

AIR EMISSIONS SOx - ECA USCG Voluntary fuel sampling Suspended (after 4 week pilot trial) Tests on 74 fuel samples taken from 47 vessels Only 9 samples from 6 vessels gave a sulphur content > 0.10%. 8 of these 9 fuel samples - marginal above 0.10% with Majority results within acceptable limits of statistical confidence of test errors. USCG concluded that the results of the pilot programme show a relatively good accuracy of the sulphur content values provided in the BDN and thus suspended the programme. Canada fuel sampling for sulphur content verification Canada s Vessel Pollution and Dangerous Chemicals Regulations Pacific Region has started the fuel sampling week of 1 August

AIR EMISSIONS SOx - Local CALIFORNIA AIR EMISSIONS BOARD «Sunset Clause» CARB Marine Notice 2014-1 (August 2014) Guidance for Complying with the California OGV Fuel Regulation during CARB Sunset Review Process. Evaluate the extent to which the enforcement program implemented by USCG and EPA will be as effective as the program being implemented to enforce the California OGV Fuel Regulation. Last info from CARB / decision by end of 2016

CHINA ECA REGULATIONS Pearl River Delta, Yangtze River Delta and Bohai Sea waters 1 Jan. 2016 - ports inside ECAs if necessary can request ships to use fuel with a sulphur content 0.5% m/m. 1 Jan. 2017 - vessels at berth in core ports within ECAs shall use fuel with a sulphur content 0.5% m/m (excluding the first hour at berth and the last hour before leaving berth) 1 Jan. 2018 - vessels at berth at all ports within ECAs shall use fuel with a sulphur content 0.5% 1 Jan. 2019 - all vessels entering ECAs shall use fuel with a sulphur content 0.5% m/m. end of 2019 - assessment whether further measures, such as lowering the sulphur limit to 0.1% m/m or extending the ECAs, will be needed Scrubbers or Shore Power permitted

CHINA ECA REGULATIONS The Pearl Delta sea water connected by the points: A. Coastline junction point of Huizhou and Shanwei B. 12NM off Zhentouyan C. 12NM off Jiapeng Islands D. 12NM off Weijia Island E. 12NM off Dafanshi Island F. Coastline junction point of Jiangmen and Yangjiang The Core Ports are Guangzhou, Shenzhen and Zhuhai.

CHINA ECA REGULATIONS

CHINA ECA REGULATIONS The Bohai Sea Waters the sea water inside the line of two points: the coastline junction point of Dalian and Dandong; and the coastline junction point of Yantai and Weihai. The Core Ports are Tianjin, Qinhuangdao, Tangshan and Huanghua.

GLOBAL SULPHUR CAP MARPOL ANNEX VI GLOBAL SULPHUR CAP ON MARINE FUELS BY 1 JAN. 2020 OR 1 JAN. 2025 DECISION PENDING ON THE OUTCOME OF AN IMO FUEL AVAILABILITY STUDY - TO BE TAKEN LATEST 2018 IMO STUDY CONCLUDED FUEL WILL BE AVAILABLE FOR 2020 PARALEL STUDY BY IPIECA AND BIMCO FUEL WILL NOT BE AVAILABLE FOR 2020 DIFFERENCE IN OUTCOME DUE TO ASSUMPTIONS MADE ANTICIPATE POLITICAL DECISION SIMPLE MAJORITY OF VOTES OF 87 PARTIES TO ANNEX VI

GLOBAL SULPHUR CAP 2020-2025 0.50% 0.10% 0.50% 0.50% 0.50% 0.50% 0.50%

NOx emissions limits YEAR OPEN SEA NECA 1 Jan. 2010 Tier I - 1 Jan. 2011 Tier II - 1 Jan. 2016 (keel laid) Tier II Tier III AIR EMISSIONS NOx North American & US Caribbean Sea areas 1 Jan. 2021* (keel laid) Tier II Tier III [North Sea and Baltic Sea]* * North Sea States and Baltic Sea States have submitted separate documents to MEPC 70 requesting these two Seas becoming NECAS as from 1 Jan 2021 rpm Tier I Tier II Tier III (in NECA only) < 130 rpm 17.0 g/kwh 14.4 g/kwh 3.4 g/kwh 130< rpm < 2000 45 x rpm (-0.2) g/kwh 44 x rpm (-0.23) g/kwh 9 x n (-0.2) g/kwh 2000 < rpm 9.8 g/kwh 7.7 g/kwh 2.0 g/kwh

NO x Reduction Technologies Available Methods Possible NO x Reduction 0% 50% 100% After Treatment SCR, HP or LP EGR, HP or LP Primary method Emulsion fuel Water injection Engine tuning Tier III SCR: Selective Catalytic Reduction System; EGR: Exhaust Gas Recirculation System Combination of Methods also being pursued MAN Diesel & Turbo Niels B. Clausen Tier III NO x Control Methods September 2016 < 16 >

IMO GHG EMISSIONS REDUCTION

IMO Policy on further GHG Emissions Reductions Phase I - data collection Phase II - data analysis (followed by a debate on whether decision-making on further technical and operational measures for enhancing the energy efficiency of international shipping were needed and, if so) Phase III define measures The data collected should give support to consider type and level of CO 2 emissions reduction legislation taking into consideration the shipping contribution to the general anthropologic GHG emissions and historical evolution of such contributions.

INTERTANKO revised Policy on GHG Emissions Reductions 1. INTERTANKO, working with other stakeholders, would support IMO developing a Work Plan to assist it in determining if there is a need to define international shipping s fair share to reduce greenhouse gas emissions through further technical and operational measures for enhancing the energy efficiency of international shipping. 2. INTERTANKO, working with other stakeholders, should support development of policy actions that: are based on the results and assessments of the fuel consumption data collected from ships are implemented through an international regime are effective, equitable, simple to enforce and to monitor provide transparency to maintain current level playing field are technically achievable and consistent with sound transportation and economic development objectives do not place disproportionate financial and operational burden on the industry

INTERTANKO revised Policy on GHG Emissions Reductions 3. Until the results of the fuel consumption data collected from ships are assessed, INTERTANKO believes it is premature for IMO to develop an "Intended IMO Determined Contribution" on CO 2 emissions reduction for the international shipping. 4. Should MBMs still be required as further additional measures, the GHG FUND (levy) seems to be by far the simplest and most transparent from a ship owner s point of view.

WHAT IS A FAIR-SHARE? (if need to define it) Is it a process to define the need of further technical and operational measures? Is it a process to define the expected level for actual emissions reductions? Is it a process to determine both of the above which ensures that the expected reduction and measures to be required (1) are achievable; (2) do not place disproportionate financial and operational burden on the industry so that (3) transportation at sea becomes less efficient and expensive for many nations of which economies do depend on transportation at sea Industry submission- MEPC 70 develops a road map for (i) a decision on determination of an initial reduction and (ii) a long-term strategy for further reductions Alternative proposal initiate development of a GHG emissions relative reduction target for international shipping (Japan) Reason: avoiding a target based on absolute (cap) total amount of CO 2 Alternative idea Emission Trading Scheme as defined by ICAO

Shipping GHG emissions reduction Second IMO GHG Study (consensus activity-based) 2007-2012 Third IMO GHG Study 22 James J. Corbett, 2014

SCOPE: Limiting the increase of a global temperature at - 2ºC from the pre-industrial level - requires to keep the CO 2 concentration in the atmosphere below 520 ppm How much CO 2 needs to be reduced? - 1.5ºC - requires to keep CO 2 concentration in the atmosphere below 450 ppm Total current CO 2 concentration is estimated to be close to 400 ppm Pre-industrial time (before year 1800) the concentration is given of 280 ppm

EU MRV & IMO DATA COLLECTION

EU MRV Rule enforced since 1 July 2015 Mandatory reporting of: - Name of the ship & IMO # - total fuel consumption - Port of Registry & Home Port - distance - Name of shipowner - time at sea / in port - Ship type - efficiency in operations, - DWT; GT (e.g. fuel/distance, fuel/transport work) - RO; Ice Class; Flag - data made public (voluntary entries) IMO Data Collection - enforced on 1 January 2018(?) Mandatory reporting of: - total fuel consumption - IMO # [built year] - Distance - Ship type - time at sea / in port - registered owner [company] (no actual cargo and no efficiency indicators) - GT, NT, DWT - data will NOT be made public - EEDI&Ice Class (if applicable)

EU MRV Regulation MONITORING & REPORTING Standard additional technical rules defining the calculation of cargo Review of the monitoring methods & efficiency assessment Templates for MPs & AERs Best practices on monitoring and reporting compendium VERIFICATION & ACCREDITATION Further define procedures regarding the assessment of MPs Further define procedures for the verification of emissions reports Define procedures related to accreditation verification plan and internal review ; site visits based on risk assessment IMO Data Collection monitoring/verification guides considered

UCL Study for INTERTANKO Annual total CO2 emissions (t) 25000 20000 15000 10000 5000 Annual average EEOI (gco2/tnm) 0 35 30 25 20 15 10 5 0 12/31/2010 12/31/2011 12/31/2012 12/31/2013 12/31/2014 12/31/2010 12/31/2011 12/31/2012 12/31/2013 12/31/2014 Data collected (for the last 5 years) from 11 «identical» ships: «identical» means built alike (same shipyard) operated by the same management company all equipped with flow meters and automatic monitoring and recording systems Among other obeservations, a ship with highest CO 2 emissions had the best (lowest) EEOI and the other way around Commercial and environmental elements (not under ship operator control) influence the EEOI result by up to 60%.

UCL Study for INTERTANKO EEOI vs Emissions 25000 20000 y = -120.79x + 16950 R² = 0.0295 Emissions (t) 15000 10000 all Linear (all) 5000 0 0 5 10 15 20 25 30 35 EEOI (gco 2 /t-nm)

UCL Study for INTERTANKO non-dimensional speed factor 1.6 1.4 1.2 1 0.8 0.6 0.4 0.2 0 12/31/2010 12/31/2011 12/31/2012 12/31/2013 12/31/2014 1.6E+09 speed factor (the relationship between design and operating speed shown below, note higher operating speeds lead to lower values of speed factor), if all else is equal, greater speed factor results in lower EEOI. transport work (the total tonnes nautical miles of loaded cargo work done by the ships) Transport work (tnm) 1.4E+09 1.2E+09 1E+09 800000000 600000000 400000000 200000000 0 12/31/2010 12/31/2011 12/31/2012 12/31/2013 12/31/2014

UCL Study for INTERTANKO non-dimensional allocative utiliszation 0.9 0.8 0.7 0.6 0.5 0.4 0.3 0.2 0.1 0 12/31/2010 12/31/2011 12/31/2012 12/31/2013 12/31/2014 0.9 allocative utilisation (the average time in loaded condition vs. ballast condition), if all else is equal, greater allocative utilisation results in lower EEOI payload utilisation (the average cargo carried when loaded), if all else is equal, greater payload utilisation results in lower EEOI non-dimensional payload utilisation 0.8 0.7 0.6 0.5 0.4 0.3 0.2 0.1 0 12/31/2010 12/31/2011 12/31/2012 12/31/2013 12/31/2014

UCL Study for INTERTANKO 35.0 30.0 25.0 R² = 0.6149 EEOI (gco2/tnm) 20.0 15.0 10.0 5.0-0.00 0.10 0.20 0.30 0.40 0.50 0.60 0.70 0.80 0.90 speed factor x allocative utilisation x payload utilsation Whilst a good correlation can be observed, confirming that these parameters in combination can explain some of the variability in EEOI, The calculated R^2 is 0.61, which means that only approximately 60% of the variability has been captured in these parameters.

CONCLUSIONS This fleet provides an excellent case study for investigation of the collection of data and its use to calculate different indicators/metrics For these 11 ships, over the period 2010-2014, large variations in annual emissions (13,000-18,000 tonnes) and annual EEOI (14-22 gco 2 /t-nm) Variability both year-on-year and between ships. A given ships EEOI or total CO 2 emissions in one year provide little indication of its EEOI or total CO 2 emissions in the following year The variability in EEOI can be partially explained through the variability in transport work (caused by variability in loaded days, allocative utilisation and payload utilisation), and variations in operating speeds, between ships and years of operation

CONCLUSIONS Ships with highest fuel consumption could have the best result on an assumed calculated operational efficiency, BUT ALSO Ships with lowest fuel consumption could have the worse result for an assumed operational efficiency A logic consequence to the fact that approximately 60% of the variability in EEOI is attributable to parameters that are predominantly beyond the ship operator s control and are more commonly determined by the voyage environmental conditions and commercial conditions Although a vessel can be managed in a consistent manner, it may still have significant inter-year variations

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BUNKER QUALITY

BUNKER QUALITY IMO CORRESPONDENCE GROUP FOLLOWING BEST PRACTICES APPROACH GUIDANCE FOR SUPPLIER AND FLAG ADMINISTRATIONS / COASTAL STATES FOR THE FUEL DELIVERED TO THE SHIP GUIDANCE FOR PURCHASER / SHIP LR FOBAS STUDY FOR INTERTANKO ON BUNKER QUALITY Analysis of the recent experience linked to poor quality fuels delivered to ships that led to damages/incidents

FOBAS - FUEL QUALITY STUDY Risk of receiving off-spec HFO: 4.7% Risk of receiving off-spec MGO: 4.2% (data from samples during first half of 2015) Off-spec causes for HFO (a) excessive viscosity, 14% of these required increase injection temperature > 6 Celsius, (b) water content, 33% of cases with water content > 1% (9% of cases, the water content > 2%) (c) high abrasive content 26%> 100 mg/kg; 80 mg/kg < 35% < 100 mg/kg; (d) asphaltene instability Causes for MGOs sulphur content > 0.10% max limit as required Noticeable consistency of the above observation with observations in 2012-2014. The occasional incidence of deleterious chemical contamination continues to occur. It can only be investigated once the problem has manifested itself.

FOBAS - FUEL QUALITY STUDY Study includes a number of concrete cases of damages casued by poor quality and offspec bunkers investigated by FOBAS INTERTANKO submited the study to IMO for assessment on its work for Bunker Quality