UPDATE ON THE REVISION OF
MARPOL ANNEX VI
NORTH AMERICAN PANEL
March 17, 2008
Stamford, CT
IMO Process in 2008
• February - BLG finalised its contributions
• April - MEPC 57 to approve the revision
• October - MEPC 58 to adopt the revision
• Enforcement – earliest February 2010
Outcome from BLG 12
SOx and PM emissions
• Three options
• Option 1 – Global Sulphur cap
– 4.50%
– 1.00% as from 1 January 201[2]
– 0.50% as from 1 January 201[5]
– Prior to 1 January 201[2] only:
• SECAs sulphur cap of 1.50%
• Fuel change over procedures & timing recorded
• Scrubbers/abatement technologies could be used
as a means of compliance
Outcome from BLG 12
SOx and PM emissions
• Option 2 – Global/Regional
– Global S cap 4.50%
– SECA S cap
• 1.50%
• 0.10% as from 1 January 201[2]
– Emissions limits for use of scrubbers:
• 6.0 g SOx/kWh
• 0.4 g SOx/kWh as from 1 January 201[2]
• waste streams cannot be discharged in ports
unless documented it would not have an adverse
impact on the local eco-systems (IMO issues
guidelines with criteria for such an assessment)
Outcome from BLG 12
SOx and PM emissions
• Option 3 – Global/Regional with Local
Emissions Control Areas (LECAs)
– Global S cap
• 4.50%
• 3.0% from 1 January 201[2]
– SECA S cap
• 1.50%
• 1.00% from 1 January 201[0]
• 0.50% from 1 January 201[5]
– Emissions limits for use of scrubbers :
•
•
•
•
6.0 g SOx/kWh
4.0 g SOx/kWh as from 1 January 201[0]
2.0 g SOx/kWh as from 1 January 201[5]
waste streams cannot be discharged in ports unless
documented it would not have an adverse impact on the
local eco-systems (IMO issues guidelines with criteria for
such an assessment)
Outcome from BLG 12
SOx and PM emissions
• Option 3 – Global/Regional with LECAs
• Proposed limits for LECAs:
– up to [24] nm off the coast; better definition
yet to be developed
– conditions for declaring a LECA yet to be
developed
– S cap 0.10% (no date given so far)
– scrubbers/abatement technologies allowed
with the limit at 0.4 g SOx/kWh
Opinions submitted to MEPC 57
SOx and PM emissions
• INTERTANKO supports Option 1
• INTERTANKO also suggests that as from 1
January 201[5], Annex VI should also add
limitiations to lower the PM emissions such as
– carbon residue content in the fuel used by ships
– ash content in the fuel used by ships
• OCIMF, ICS and BIMCO support Option 3
• IPIECA supports Option 2 but with a S cap in
SECA set at 1.00%
• Governments we believe support Option 1:
Norway, Germany, Sweden, Finland, Italy,
Ireland, Greece, European Commission.
Possible outcome from MEPC 57?
SOx and PM emissions
• Possible agreement on a hybrid solution:
– It might start with an Option 2 – like scenario
– It then might translate into Option 1 – like scenario
• Other comments:
– Greece indicated at BLG 12 they disagree that
scrubbers are identified as a specific alternative
compliance
– Marshall Islands seem to share that opinion
– Australia and Canada seem also to support Option 1
– UK suggests supporting Option 3 but it proposes
amendments which may lead close to Option 1
Outcome from BLG 12
NOx emissions – Pre-2000 engines
• Measures on engines installed onboard
ships constructed between 1 January
1990 and 31 December 1999
• The NOx emissions at Tier I level
• Applicaton date
– at the first intermediate or renewal survey; or
– [1 January 2010], which one occurs later
• Compliance through:
– in engine modification (MEPC 57 has to
choose between two options); or
– abatement technologies
Outcome from BLG 12
NOx emissions – Pre-2000 engines
• Option 1
– applies to all (i.e. 1990 – 1999) engines
– if compliance through in-engine
modifications not possible, a Port State
could:
• require the ship to use distillate fuel; or
• deny port entry
• Option 2
– applies to larger (1990 – 1999) engines only
([displacement of and over [30/60/90] liters]
or [power output of > 5000 kW])
– use of a certified ”upgrade kit”
NOx emissions – Pre-2000 engines
INTERTANKO fleet
ships built before 1/01/2000
1,367
103,192,185
(47.5%)
(43.7%)
ships built on & after
1/01/2000
1,512
132,742,706
(52.5%)
(56.3%)
TOTAL
2,879
235,934,891
168 Member Companies operating these ships
(total # of members 263)
Assuming 1 M.E. & 3 A.E. /ship there would be at least
913 M.E. and some 2, 739 A.E. (a total of at least 3,652
engines) to be modified in 3 or 4 years!!!!!
NOx emissions – Pre-2000 engines
INTERTANKO fleet
TA
PT
CH
CH/Oil
PG
OBO/OO
FPSO/FSO
Bitumen
Asphalt
TOTAL
398
170
205
67
43
19
9
1
1
913
62,549,816
7,458,058
4,194,729
2,180,373
1,223,916
1,680,977
1,079,853
7,000
4,993
80,379,715
Outcome from BLG 12
NOx emissions – Tier II (new engines)
• Tier II standards (emission reductions
related to Tier I limits):
– 15.5% reduction (engines with n<130 rpm)
(i.e. 14.36 g/kWh)
– reductions between 15.5% and 21.8%
depending on the engine’s rpm (engines with
130 rpm < n < 2,000 rpm)
– 21.8% reduction (engines n > 2,000 rpm) (i.e.
7.66 g/kWh)
• Applies to engines installed on ships
constructed on and after 1 January 2011
Outcome from BLG 12
NOx emissions-Tier III (new engines)
• Tier III standards – 80% emission reductions from
Tier I limits
• Tier III limits apply ONLY to engines:
– power output of > 600 kW
– installed on ships constructed on & after 1 January 2016
– (a Party to Annex VI can apply the above limits to new engines
of 130 kW and above)
• Tier III limits in ECAs only
• Outside ECAs - Tier II limits
• Emission levels for Tier III are as follows:
– 3.40 g/kWh (engines with n<130 rpm)
– 9*n(-0.2) g/kWh (engines with 130 rpm < n < 2,000 rpm)
– 1.96 g/kWh (engines n > 2,000 rpm
Outcome from BLG 12
Fuel Oil Quality
• Small but possible important changes
• The fuels required to be ”fit for purpose”
• MEPC 57 to clarify the meaning of ”fit for
purpose” from a quality point of view
• IMO to invite ISO to revise marine fuels
specifications in ISO 8217
• Define fuel specification for a Global solution
• Possible inclusion of limitations of other
parameters to reduce PM emissions
• BLG developed a standard procedure to
interpret the actual test results of the sulphur
content of the MARPOL sample
CONCLUSIONS
• Possible hybrid solution for SOx and PM
– starting with Option 2 (with a higher S cap in SECAs,
say 1.00% from say 201[2])
– followed by Option 1
• Early dates (i.e. 2015/2016) for enforcing
Option 1 would be hard to negotiate
• INTERTANKO would be determined to avoid an
outcome along the lines of Option 3
• Fuel Oil Quality – INTERTANKO would make
efforts to seek that the revised MARPOL Annex
VI provides a better definition of the quality of
the fuels delivered to ships
CONCLUSIONS
• NOx limits for existing engines - not an easy task
• Use of MDO would give NOx reduction by 10% to 15%
BUT without a global use of MDO, the penalty on old
ships would be too high
• NOx Tier II - possible and rests with manufacturers
• NOx Tier III implies use of SCRs/abatement
technologies
• Prudent that new ships consider compliance with Tier
III and install SCRs/abatement technology prior to 2016
• Still to be assessed
– SCRs - the only technology to give an 80% reduction; . . . BUT
– existing SCR technology not efficient at low engine loads
– can compliance be achieved in ECAs irrespective of the engine
load (close to port, through estuaries and straits ships slow
down)?
Questions?
[email protected]