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UPDATE ON THE REVISION OF MARPOL ANNEX VI

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.

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UPDATE ON THE REVISION OF MARPOL ANNEX VI

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  1. UPDATE ON THE REVISION OF MARPOL ANNEX VI NORTH AMERICAN PANEL March 17, 2008 Stamford, CT

  2. 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

  3. 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

  4. 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)

  5. 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)

  6. 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

  7. 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.

  8. 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

  9. 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

  10. 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”

  11. NOx emissions – Pre-2000 enginesINTERTANKO fleet 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!!!!!

  12. NOx emissions – Pre-2000 enginesINTERTANKO fleet

  13. 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

  14. 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

  15. Outcome from BLG 12Fuel 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

  16. 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

  17. 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)?

  18. Questions? dragos.rauta@intertanko.com

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