The Shipping Industry and Environmental Legislation Janet Strode General Manager International Parcel Tankers Association
Jan 17, 2016
The Shipping Industry and
Environmental Legislation
Janet StrodeGeneral Manager
International Parcel Tankers Association
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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Ship Recyclin
g
Ballast Water
Management
Sulphur limits in ECA’s
Double Hull Requirement
s
Control of Harmful Anti-
fouling Systems
EEDI
Biofouling
Noise Preventio
n
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HNS Convention
Energy Efficiency
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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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MARPOL 73-78
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Ballast Water Management
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Currently: • 44 States
• 32.86% of world tonnage
BWM Convention
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Effective Dates as per Assembly Resolution 1088
Source: ABS
Type Approval ProcessConcern 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. ”
United States
Vessel Ballast Capacity Compliance Date
Constructed on or after 1 December 2013
All Delivery
Constructed before 1 December 2013
< 1,500 m3 First scheduled drydocking after 1 Jan 2016
1,500 – 5,000 m3 First scheduled drydocking after 1 Jan 2014
> 5,000 m3 First scheduled drydocking after 1 Jan 2016
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.
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 approval3 currently undergoing testingNot yet known when any system is likely to be
granted approval
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 ECA’s 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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FlashpointUS 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
Reduction of GHG Emissions
COP 21EU 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
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.”
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.”
EU MRVFrom 1 January 2018 ships above 5,000 grt must report on an annual basis:
Total annual consumption of each type of fuelTotal aggregated CO2 emissions CO2 emissions from all voyages
between EU portsvoyages coming into and departing from the EU
CO2 emissions at berth in EU portsTotal distance travelled and time spent at sea
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 WİLL BE MADE PUBLİCALLY AVAİLABLE
Methods of Measuring Fuel Consumption
BDN
Onboard fuel tank monitoring
Flow meters
Direct CO2 emissions measurements
IMO – Energy Efficiency Measures
Proposals for global data collection system
Vessels above 5,000 grt to report:Total annual fuel consumption, by fuel typeTransport work
Distance travelled?Cargo weight/volume?Service hours?
Not yet decided whether voluntary or mandatory
Distance travelledBerth 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.
US proposes should cover when vessel underway (i.e. berth to berth)Ballast and laden voyages equally
Does not take into accountFuel used at berthFuel used for heating, tank cleaning etc. when
underway
Will ships that do not routinely perform ballast legs be disadvantaged?
Service Hours
Source: American Bureau of Shipping
Cargo
DWT as Proxy for Cargo
ConfidentialityAdministrator 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?)
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
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