Updated Marine Regulations to Reduce Emissions
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The International Maritime Organization (IMO) developed MARPOL Annex VI to reduce air pollution from ships through regulating emissions such as nitrogen oxides (NOx) and sulfur oxides (SOx). In terms of SOx emissions, MARPOL Annex VI set a compromised global sulfur cap of 4.5% (the IMO average being 2.7% at the time) and a 1.5% limit in designated SOx emission control areas (ECA), which currently are the Baltic and North Sea, including the English Channel.
As opposed to most other statutory instruments, MARPOL Annex VI places responsibility for compliance not only on the ship, but also the marine fuel suppliers. However, unclear regulations and lack of enforcement from Flag and Port States significantly complicate compliance. Compared with what was anticipated when MARPOL Annex VI was adopted in 1997, there has been a significant growth in seaborne trade, installed power on new ships and increased service life of ships. Air emissions from ships have increased, leading to a series of unilateral regulatory schemes from the European Union (EU), US-CARB and Norway (NOx tax). Together with increased pressure from the EU, United States and environmental organizations, the IMO revised MARPOL Annex VI soon after its implementation.
After a series of debates and proposals within the organization, the Marine Environmental Protection Committee 57th session concluded on the revision of MARPOL Annex VI April 5, 2008.
Nitrogen oxide emission for new ships will be reduced by about 15% compared with existing regulations for ships constructed on or after 2011, and for new ships operating within ECAs, the reduction is 80% as of 2016. Existing ships built between 1990 and 1999 will ideally have to comply with existing NOx regulations, although a series of clauses makes it uncertain whether compliance will be required for the majority.
With respect to SOx (and thus indirectly particulate matter), the revision led to the lowering of the ECA sulfur limit in marine fuel to 1% as of 2010 and 0.1% as of 2015. The global sulfur cap in marine fuels is reduced to 3.5% (the IMO average for 2007 is 2.42%) as of January 2012 and to 0.5% as of 2020 or 2025 (pending a study on availability of such fuels to be performed by 2018).
As an alternative to the sulfur caps in marine fuels, abatement technology may be accepted. The revision does, however, consider abatement technology to be “equivalent measures” and not a generally accepted alternative as in the initial regulations. The international air pollution certificates would normally have to be endorsed to that effect. Formally, this implies each individual maritime administration has to approve the abatement technology and acknowledge it has an equivalent efficiency in terms of SOx, particulate matter and NOx compared with the regulatory limits (under all load conditions), can operate within the requirements of the IMO guidelines (under all load conditions) and that it does not harm the environment.
The practical consequences of the regulations are somewhat uncertain. It is expected there will be significant development in terms of NOx and SOx abatement technology to ensure it is able to meet the regulatory limits under all load conditions and also be able to operate simultaneously. It is also expected a significant number of ships constructed after 2016 will be equipped with NOx abatement technology to maintain commercial flexibility to operate within ECAs.
A major challenge is whether the oil industry will initiate the upgrade of refineries to meet the increased demand for low-sulfur marine fuels (0.10% fuel within current and future ECAs as well as 0.50% fuel on a global scale) or await the possible penetration of SOx abatement technology.
During the debate, it has been acknowledged any sulfur limit below 1% will mean the end of heavy fuel oil and the re-introduction of distillates as marine fuel. This presumably implies refineries will have to increase ongoing investments in residue upgrading processes. It should be noted the 0.5% limit might give the black-diesel (ISO grade DMC) a new renaissance.
Prior to the MARPOL Annex VI revision completion, the EU and environmental organizations put pressure on the IMO to turn its attention to greenhouse gas emissions, particularly carbon dioxide (CO2). Recently, the EU has indicated it will act unilaterally unless the IMO develops regulations limiting CO2 emissions from shipping.
The significant increase in seaborne trade and installed power means fuel consumption and thus CO2 emissions from shipping have increased. Carbon dioxide will therefore be the IMO’s next hurdle.
There will be a fast-track development of possible CO2 regulations for ships. The alternatives seem to be the introduction of a CO2 tax on fuel or maximum CO2 emissions for ships. The latter will require the development of ship design CO2 and/or operational CO2 indices with permissible levels for new ships and incentives or penalties for existing ships. These indices could also form a basis for market-based mechanisms such as a global levy or emission-trading regime.
The developments should force ship owners, shipyards, engine builders and hopefully charterers to re-think hull and machinery designs, alternative fuels, propulsion systems, optimum speed, voyage planning, charter party clauses, anti-fouling systems, dry-docking intervals and other facets of shipbuilding and operations.
Olav Tveit is based in Høvik, Norway, in DNV Maritime (ship classification) as a principal engineer in the section for cargo handling, piping system and gas tankers.
