Comments and considerations regarding current EEDI proposalregarding current EEDI proposal

Teus van Beek

Wrtsil Netherlands BV

24 September 2010

24.9.20101 Wrtsil 1 Wrtsil

Contents

What is EEDI? Proposal for

Wrtsil opinion about EEDI

EEDI considerations and features EEDI considerations and features Loopholes in current rules

24.9.20102 Wrtsil

What is EEDI?What is EEDI?

24.9.20103 Wrtsil

IMO energy efficiency

CO2 emissions from shipsThe IMO Marine Environment Protection Committee has already developed a package of measures for reducing shippings CO2 emissions, with an agreed timetable for adoption.

Energy Efficiency Design Index (EEDI) for new ships Energy Efficiency Operational Index (EEOI) for all ships Energy Efficiency Operational Index (EEOI) for all ships Ship Energy Efficiency Management Plan (SEEMP) for use by all

ships Maritime Emission Trading Scheme (METS) International Compensation Fund (ICF), to be financed by a levy on

marine bunkers.

24.9.20104 Wrtsil

EEDI purpose

Purpose Reduce CO2 emissions from new ships

Improve energy efficiency of new vessels Incentives for technology development

Compare vessels Compare vessels

The EEDI is a design and technical measures and is separate from the other operational and commercial measures

24.9.20105 Wrtsil

IMO Energy Efficiency Design Index (EEDI)

EEDI =CO2 emissions

24.9.20106 Wrtsil

EEDI =Transport work

6 Wrtsil

IMO Energy Efficiency Design Index (EEDI)

24.9.20107 Wrtsil

EEDI breakdown

24.9.20108 Wrtsil 8 Wrtsil

EEDI and how it is supposed to be applied

The attained index for a new ship should be below the baseline for the ship type in question

24.9.2010

Source: Impacts of the Energy Efficiency Design Index on future designs of RoRo and RoPax ferries, Lennart Pundt, Stefan Krger, Hamburg University of Technology Institute of Ship Design and Ship Safety, Interferry 2009

9 Wrtsil

Definition of the baseline

Data of all vessels built from January 1998 to December 2007 is taken from IHS - Fairplay database. Ship data is divided into different categories.

The average index values are used as basis for calculating an exponential regression line for each of the ship categories.

Baseline value = a * capacity -cBaseline value = a * capacity

Outliers which are more than two standard deviations from the regression line are excluded.

24.9.2010

Draft baselines are defined in IMO GHG-WG 2/2/7.10 Wrtsil

EEDI applicability

The current EEDI proposal is applicable to the following ship types with conventional propulsion systems (main engine mechanical drive): Passenger ship Dry cargo carrier Gas tanker Tanker Containership Containership Ro-ro cargo ship: Vehicle carrier Ro-ro cargo ship: Volume carrier Ro-ro cargo ship: Weight carrier General cargo ship Ro-ro passenger ship

24.9.201011 Wrtsil

EEDI application

The EEDI is intended to ensure that new ships are designed to be energy efficient it sets the max CO2 emissions per transport work that a ship is allowed to emit

EEDI does not promote any further improvements beyond the min required baseline

EEDI is not suitable to use for emission trading It does not take into account anything about the actual operation of

the vessel Actual emitted emissions Operating time Actual transported cargo

24.9.201012 Wrtsil

Proposal for:Wrtsil opinion about EEDIWrtsil opinion about EEDI

24.9.201013 Wrtsil

Wrtsil view:

Wrtsil supports the intention of EEDI: Reduce CO2 emissions from ships Promote and stimulate the introduction of more efficient ships trough

Application of efficient designs and solutions Development of more efficient machinery technology Development of more efficient ship design features Development of more efficient ship design features

24.9.201014 Wrtsil

Wrtsil view (2)

However, we feel that the current proposed formula does not achieve the goal in the best possible way: The current formula is more affected by the ship speed than the

actual efficiency improvement of the ship technology It is almost impossible for fast (and already moderate speed) ships to meet

the required limit The rule does not promote any further improvement in efficiency than The rule does not promote any further improvement in efficiency than

what is needed to get the EEDI value below the base line Slow ships do not need any efficiency improvement

24.9.201015 Wrtsil

Wrtsil view (3) The formula might have especially harmful impact on the Short sea

shipping segment Short sea shipping, such as RoRo and Ferries, often operate on

routes with a fixed itinerary. The speed is selected to offer an attractive schedule. If sufficient speeds

are no longer possible to achieve with new ships, suitable departure and arrival times can no longer be offered. Then there is a risk that the cargo trades will select alternatives transport routes, such as land based alternatives and airfreight.. alternatives and airfreight..

If new ships can not achieve sufficient speeds while staying below the base line limit, the old tonnage not covered by EEDI, will stay in traffic and no improvement in energy efficiency is achieved.

The end result might be opposite to what the intention of the rule is.

24.9.201016 Wrtsil

Wrtsil view (4)

The current EEDI proposal calculates CO2 emissions based on installed main engine power. We think that this method penalises ships with special power margins. Safety power margins will increase EEDI and new ships will therefore

most likely take all margins to a minimum. Redundant machinery and safe return to port arrangements will be

penalised with higher EEDI value.penalised with higher EEDI value. Extra power margins to allow for operation in ice covered arctic areas

will increase EEDI. Safe ice operation might not be possible with new ships.

The EEDI formula might lead to less safe ships and this must not be allowed according to us.

24.9.201017 Wrtsil

Wrtsil view (5)

The EEDI calculation principle should be changed in the following way: The CO2 emission production should be calculated based on the

actual power demand for a specific speed (or operating profile) defined for each ship type instead of the installed power Safety margins would not be penalised safe ships are allowed Attractive itineraries (schedules) can also be offered by new ships

The CO2 from the aux power should be based on actual electric The CO2 from the aux power should be based on actual electric power demand and not installed main engine power Promote also hotel load energy saving improvements Avoid loopholes in formula

The definition of capacity for ferries should be changed to be based on both cargo capacity and superstructure weight Achieve better accuracy and avoid loopholes

24.9.201018 Wrtsil

EEDI considerations and featuresEEDI considerations and features

24.9.201019 Wrtsil

EEDI the speed limit

The EEDI is penalising speed to a highdegree

A ships EEDI value is more dependenton the speed than on how well the shiphas been designed

EEDI is a power limit and therebyvirtually a speed limit at seavirtually a speed limit at sea

Can it cause an undesired modal shiftaway from sea transportation to landbased transportation for timesensitive cargo?

What about ice operation? Can shipshave enough power for safenavigation?

24.9.201020 Wrtsil

Speed relation for ferry Power Efficiency IndexPower Efficiency Index - Gross Tonnage

0,080

0,100

0,120

0,140

P

o

w

e

r

e

f

f

i

c

i

e

n

c

y

i

n

d

e

x

[

k

W

h

/

(

n

m

*

G

T

)

]

Froude's nr 0.35 - 0.40

Froude's nr 0.30 - 0.35

Froude's nr 0.25 - 0.30

Froude's nr 0.20 - 0.25

S

l

o

w

-

F

a

s

t

24.9.2010

0,000

0,020

0,040

0,060

0 10000 20000 30000 40000 50000 60000Gross Tonnage [GT]

P

o

w

e

r

e

f

f

i

c

i

e

n

c

y

i

n

d

e

x

[

k

W

h

/

(

n

m

*

G

T

)

]

Froude's nr 0.20 - 0.25

21 Wrtsil

LoopholesLoopholesWhat can we do to artificially lower EEDI

24.9.201022 Wrtsil

EEDI loopholes

Means for reducing a ships EEDI value without reducing the actual CO2 emissions: Install large PTO generators that are not used Switch power from main engine to aux engine

Have PTI that is officially only intended for emergency operation Artificial increase of capacity (GT) for medium and large pax vessels Artificial increase of capacity (GT) for medium and large pax vessels Remove all engine driven pumps

24.9.201023 Wrtsil

Main engine power (PME) reduction with PTO

The power of the main engines in the EEDI formula is defined as follows: PME = 0,75 * ( MCRME PPTO) PPTO is 75% output of the shaft generator installed divided by the

relevant efficiency of the that shaft generator

24.9.201024 Wrtsil

Power reduction with PTO generators

Installation of large PTO generators will reduce the main engine power that the EEDI assume is used for propulsion. The main engine power (PME) is reduced by 56,25% (0,75*0,75) of the

installed PTO generator power

24.9.2010

The PTO power is not included anywhere else in the formula!!! The PTO:s do not need to be used in real operation

Large PTO:s will reduce the EEDI index!!!

25 Wrtsil 25 Wrtsil

Removing engine built on pumps

Using main engine driven pumps will increase installed engine power but not the speed attained

Alternatively, the pumps may affect the fuel consumption of the engine Driving pumps with electric power from the aux engines will not affect

the EEDI index (cargo vessels) The calculation of PAE is based on installed main engine power The calculation of PAE is based on installed main engine power

(MCR) (valid for cargo vessels only) In ships with large electric load (e.g. passenger vessels), the PAE

should be estimated from the actual consumed electric power

It will be beneficial to avoid all main engine driven pumps in cargovessels

24.9.201026 Wrtsil

Calculation of PAE

24.9.201027 Wrtsil

Conclusion

Wrtsil support the introduction and use fo the EEDI However not in all cases it has the desired effect:

Speed effect PTO Ship with special power margins (ice, dredgers) How auxiliary power is handled How auxiliary power is handled

It is recommended that the legislator support clever application of the rules

24.9.201028 Wrtsil