The Shipping Industry and Environmental Legislation

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The Shipping Industry and Environmental
Legislation

• Janet Strode
• General Manager
• International Parcel Tankers Association

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IPTA

• International Parcel Tankers Association
• Formed 1987
• Consultative status at IMO 1997
• Project leader on IMO workshops
• CDI chemicals
• FOSFA vegetable oils
• EQUASIS Editorial Board Vice Chair

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Double Hull Requirements
Noise Prevention
EEDI
HNS Convention
Ship Recycling
Energy Efficiency
Biofouling
Ballast Water Management
Control of Harmful Anti-fouling Systems
Sulphur limits in ECAs
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MARPOL 73-78

• Annex I Oil 1983
• Annex II NLS 1983
• Annex III Packaged Goods 1992
• Annex IV Sewage 2003
• Annex V Garbage 1988
• Annex VI Air Pollution 2005

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Ballast Water Management
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BWM Convention

• Currently
• 44 States
• 32.86 of world tonnage

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Effective Dates as per Assembly Resolution 1088
Source ABS
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Type Approval Process

• Concern expressed that individual systems may not
  operate correctly in
• Different salinities (fresh, brackish, marine)
• Different water temperatures (cold, temperate,
  tropical)
• Different sediment loads
• Where flow rates are less than Treatment Rated
  Capacity
• Ship held responsible for working of treatment
  system

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MEPC agreed to review of the G8 standard, to
include following elements

• Testing using fresh, brackish and marine waters
• testing considering the effect of temperature in
  cold and tropical waters
• specification of standard test organisms for use
  in testing
• challenge levels set with respect to suspended
  solids in test water
• type approval testing discounting test runs that
  do not meet the D-2 standard
• the results of test runs being "averaged"
• type approval testing realistically representing
  the flow rates the system is approved for
• differences between type approval protocols of
  Member States
• Early adopters not to be penalised

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MEPC 68 - Roadmap

• Shipowners who have installed, prior to the
  application of the revised Guidelines , ballast
  water management systems approved in accordance
  with the Guidelines , should not be required to
  replace these systems due to the application of
  the revised Guidelines (G8) with systems approved
  in accordance with the revised Guidelines (G8).
• Shipowners who have installed, maintained and
  operated correctly BWMS approved in accordance
  with the Guidelines (G8) (MEPC.174(58)) should
  not be required to replace these systems, for the
  life of the ship or the system, whichever comes
  first, due to occasional lack of efficacy for
  reasons beyond the control of the shipowner and
  ship's crew. 

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United States
Vessel Ballast Capacity Compliance Date
Constructed on or after 1 December 2013 All Delivery
Constructed before 1 December 2013 lt 1,500 m3 First scheduled drydocking after 1 Jan 2016
Constructed before 1 December 2013 1,500 5,000 m3 First scheduled drydocking after 1 Jan 2014
Constructed before 1 December 2013 gt 5,000 m3 First scheduled drydocking after 1 Jan 2016
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• Treatment systems must be approved by USCG
• Currently no systems approved
• Some 45 systems given approval as alternate
  systems, for up to 5 years
• Some estimates are that first approvals will not
  come out until mid-2016
• What does a responsible owner do?

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MEPC 68 IPTA/WSC Submission

• What a shipowner needs is the ability to procure
  and install a BWMS that will allow the vessel to
  both meet the established D-2 standard and be
  accepted in any port the ship may call, including
  the United States.
• The fact is that today there is no BWMS that an
  owner can purchase, install and operate with
  confidence that the system will be in compliance
  with the D-2 standard and will be accepted for
  use on a global basis. Given the magnitude of
  investments to be made and the consequences of
  installing systems that may fail to meet the D-2
  standard, the conundrum facing vessel owners
  requires further efforts if it is to be resolved.
  

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• Called on US to present a report on
• its expectation of when and how many BWMS type
  approval applications it expects to receive
• a projected time frame for its consideration of
  such applications and
• when United States law will require the
  installation of United States type approved
  systems on vessels calling the United States
• US response
• 17 manufacturers indicated their intention to
  submit systems for type approval
• 3 currently undergoing testing
• Not yet known when any system is likely to be
  granted approval

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Reduction of Sulphur Emissions
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MARPOL Annex VI

• Adopted 1997
• Entered into force 2005
• Amendments adopted 2008
• Entered in force 2010
• Sulphur limit in ECAs now 0.1
• 2020 global sulphur limit 0.5
• Review of availability of fuel to be completed by
  2018
• If not enough fuel, EIF put back to 2025
• (EU will enforce in 2020 regardless)

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Flashpoint

• US and Canada propose to MSC 95 that SOLAS be
  amended to reduce flashpoint limit for bunker
  fuel from 600C to 520C in order to make more fuel
  available
• MSC rejects proposal
• Should be dealt with under IGF Code
• Need better understanding of which fuels might be
  involved
• Submissions invited in order to create goals and
  functional requirements to mitigate known hazards
• Accepted that cannot have less stringent
  requirements for fuel than for cargo

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Reduction of GHG Emissions

• COP 21
• EU MRV
• IMO

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COP 21 - Paris

• Treaty to replace Kyoto Protocol
• Green Climate Fund
• 100 billion per year by 2020
• To finance mitigation and adaptation for
  developing countries
• Funds to be raised from a mix of public and
  private resources
• EU Environment Committee
• Climate finance to be included in any agreement
• To include revenues from taxes on aviation and
  shipping emissions
• IMO to agree on measures to cut GHG from
  international shipping before end 2016

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EU Position

• .. a global, fair, ambitious and legally binding
  international treaty that will prevent global
  warming from reaching dangerous levels
• Global emissions need to
• peak by 2020 at the latest
• be reduced by at least by 50 by 2050 compared to
  1990 and
• be near zero or below by 2100
• when using 2010 as base year, the 50 target
  translates to 60 by 2050
• consistent with the EU objective of reducing
  emissions by 80-95 by 2050 compared to 1990 by
  developed countries as a group.

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Negotiating Text already inserted by EU

• Mitigation
• Parties agree on the need for global sectoral
  emission reduction targets for international
  aviation and maritime transport and on the need
  for all Parties to work through the International
  Civil Aviation Organization (ICAO) and the
  International Maritime Organization (IMO) to
  develop global policy frameworks to achieve these
  targets.
• Finance
• Encourage the International Civil Aviation
  Organization and the International Maritime
  Organization to develop a levy scheme to provide
  financial support for the Adaptation Fund.

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EU MRV

• From 1 January 2018 ships above 5,000 grt must
  report on an annual basis
• Total annual consumption of each type of fuel
• Total aggregated CO2 emissions
• CO2 emissions from all voyages
• between EU ports
• voyages coming into and departing from the EU
• CO2 emissions at berth in EU ports
• Total distance travelled and time spent at sea

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• Total transport work,
• distance travelled multiplied by amount of cargo
  carried
• Average energy efficiency, calculated as
• Annual fuel consumption / total distance
  travelled
• Annual fuel consumption / total transport work
• CO2 emissions / total distance travelled
• CO2 emissions / total transport work
• All data will be made publically available

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Methods of Measuring Fuel Consumption

• BDN
• Onboard fuel tank monitoring
• Flow meters
• Direct CO2 emissions measurements

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IMO Energy Efficiency Measures

• Proposals for global data collection system
• Vessels above 5,000 grt to report
• Total annual fuel consumption, by fuel type
• Transport work
• Distance travelled?
• Cargo weight/volume?
• Service hours?
• Not yet decided whether voluntary or mandatory

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Distance travelled

• Berth to berth
• Easy to collect / verify
• Assumes fuel is only consumed for propulsion
  purposes
• Assumes every mile covered is equal
• i.e. does not take into account
• Weather, currents, etc.
• Whether ship laden or in ballast
• Does not account for fuel used for heating, tank
  cleaning etc.

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Service Hours

• US proposes should cover
• when vessel underway (i.e. berth to berth)
• Ballast and laden voyages equally
• Does not take into account
• Fuel used at berth
• Fuel used for heating, tank cleaning etc. when
  underway
• Will ships that do not routinely perform ballast
  legs be disadvantaged?

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Source American Bureau of Shipping
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Cargo
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DWT as Proxy for Cargo
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Confidentiality

• Administrator of database?
• IMO Secretariat?
• Access to data available to
• IMO Secretariat only?
• IMO Secretariat and Member States?
• IMO Secretariat, Member States and third parties
  (e.g. consultants?)

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IMO High Level Action Plan

• Resolution A.1061(28) Strategic Direction 8
• IMO will seek to ensure that measures to promote
  safe, secure and environmentally sound shipping
  do not unduly affect the efficiency of
  shipping..

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• Thank you for your attention
• 28 years serving the chemical tanker industry
• www.ipta.org.uk