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

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Control of Harmful Anti-

fouling Systems

EEDI

Biofouling

Noise Preventio

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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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