The North American ECA and Short Sea Shipping – An Analytical Assessment
GREENTECH 2013 Green Marine Annual Conference, Vancouver BC
May 30, 2013
Dr. Ranajit (Ron) Sahu, Consultant
626.382.0001
The North American ECA and Short Sea Shipping – An Analytical Assessment A Lesson
in the Law of Unintended Consequences
GREENTECH 2013
Green Marine Annual Conference, Vancouver BC
May 30, 2013
Dr. Ranajit (Ron) Sahu, Consultant
626.382.0001
Topics
- The North American ECA (briefly)
- Fuel sulfur requirements
- The 200 mile requirement
- Air Pollutants (SO2, NOx, PM // CO2, other GHGs)
- Short-sea Shipping
- ECA Equivalence
- Establishing a credible distance requirement via modeling
- Unintended (but forseeable) Consequences
- Modal shift
- Climate // Energy Adverse Impacts
Air Pollutants
A. Regional/Local
- SO2 (also fine-PM precursor)
- NOx (also ozone and fine-PM pre-cursor)
- PM (various sizes)
Controlled based on health-protective standards (e.g., US
National Ambient Air Quality Standards, etc.)
- for SO2, the most stringent NAAQS is the 1-hour standard
Source-Receptor Distance Matters!
B. Global
- GHGs, including CO2
Source-Receptor Distance Does Not Matter
Short Sea Shipping
• Short Sea Shipping (SSS) is any movement of cargo by any vessel
type occurring in direct competition with rail or truck. This occurs in
the Inland Waters and Coasts of both Canada and the U.S.A.
• The Marine Highway (SSS) is vital to the US and Canadian trading
relationship.
• A 7 day trip – entirely within the ECA is the
norm
• A recent economic study shows Short Sea
Shipping (Seaway) to provide for:
• $34.6 billion in economic activity
• 227,000 US and Canadian Jobs
• $4.7 billion in taxes paid
(Canada and US Federal/States)
Short Sea Shipping is
Sustainable Shipping
Short Sea Shipping…
• is inherently more environmentally sound than other transportation options;
• aligns with MARAD’s Marine Highway Program; &
• reduces land based congestion & emissions.
• Short-sea shipping provides the most fuel efficient freight
transport mode on a ton-km basis (Laker/Handy Bulker)
Even Greater Efficiency
Deficiencies in ECA Analysis
• Did not consider short-sea shipping or potential modal
transfers.
• Impacts analysis is dominated by large vessels, oil tankers,
etc. for which modal shift is not a possibility or an issue.
• Analysis uses 2002 as a base year and projects economic
variables and emissions through 2020 – this does not
recognize major economic disruptions in recent years.
• As a result, the negligible impacts due to short-sea shipping
are not apparent.
• Bottom line: 200 nm ECA is not technically justified or
economically sustainable to Short Sea Shipping.
Updated Science:
• Focuses on short-sea shipping.
• Uses EPA approved modeling tools.
• Focuses on sulfur dioxide (SO2), the main pollutant emitted
that is directly a consequence of sulfur levels in the fuel –
and hence the pollutant directly related to fuel choices.
• Focuses on East Coast and West Coast shipping routes.
• Used historical meteorological data on East & West coasts.
Shore Concentrations vs. Vessel
Distance from Shore (km)
-0,20000
0,00000
0,20000
0,40000
0,60000
0,80000
1,00000
1,20000
1,40000
0 50 100 150 200 250 300 350 400
Narragansett
Sandy Hook
Cape May
Cape Henry
Cape Lookout
Cape Romain
Savannah
Jacksonville
Cape Canaveral
0 40 80 120 160 200 240 280 320 360
0,00E+00
1,00E-01
2,00E-01
3,00E-01
4,00E-01
5,00E-01
6,00E-01
7,00E-01
8,00E-01
16
014
0
12
0
10
0
80
60
40
20
0
-20
-40
-60
-80
-100
-120
-140
-160
Vessel Distance from Shore (km)
Normalized Concentration
Distance Along Shore (km) Cape Henry = 0
Shore Concentration Profile - Cape Henry
Ship Selection Criterion 20000 hp 20000 hp
Vessel Location (affects Load) Port-40 km 80 - 320 km
SO2 Level in Fuel ECA Modified ECA
Engine Size (kW) 15000 15000
Engine Load 0.30 0.75
SO2 Rate (gram/kW-hr/%S) 3.81 3.81
SO2 Level in Fuel (%) 0.1 1.0
SO2 Emission Rate (kg/hr) 1.7 42.9
Highest 1-hr Shore Conc. (ug/m3//kg/hr) 1.1560 0.0251
(Location) Cape Canaveral Cape May Highest 1-hr Expected Shore SO2 Conc.
(ug/m3) 2.0 1.1
EPA 1-hr SO2 NAAQS (ug/m3) 196 196
Highest SO2 / NAAQS 1.01% 0.55%
Model Prediction and
SO2 NAAQS
Commitment to ECA
• Support the North American ECA.
• Support 1% sulfur fuel within a 200 mile ECA.
• Support 0.1% sulfur fuel within a 50 mile (80 km) ECA.
Modal Shift
As it becomes more expensive to transport low-value cargos
via Short-Sea routes, some of the cargo will transfer to less-
efficient land-based routes such as rail or truck….
- for example, in the US East Coast along I-95 corridor and in
the US West Coast along the I-5 corridor
- exposing large populations to higher levels of emissions
(including additional toxic air pollutants) at much shorter
distances
- adding to transport congestion
- Increasing safety risks
The I-95 Corridor Coalition is a partnership of state departments of transportation, regional
and local transportation agencies, toll authorities, and related organizations, including public
safety, port, transit, and rail organizations, from Maine to Florida, with affiliate members in
Canada.
• Policy makers must recognize Short Sea Shipping as the most environmentally
advantageous means of moving cargo. Canada and the U.S.A have a distinct
Short Sea (Marine Highway) trading relationship.
• Policy makers should understand the economic advantage of Short Sea Shipping to
both Countries and the Jobs that are provided within this transportation sector.
• International rules need to be adapted to work when applied to Short Sea Shipping.
• Reducing ECA size for Short Sea Shippers allow the continued use of this
mode of cargo transport while maintaining all of the environmental benefits.
• We recommended a sustainable standard of 50 miles, similar to Emission
Control Areas worldwide such as the Puerto Rico/Caribbean ECA.
• We recommend a 1% ECA standard out to 200 miles and a 0.1% standard out
to 50 miles for SSS vessels less than 20,000 H.P.
Conclusion &
Recommendations