The Shipping Industry and Environmental Legislation Janet Strode General 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

Ballast Water Management Noise Prevention Double Hull Requirements EEDI HNS Convention Ship Recycling Energy Efficiency Biofouling Ballast Water Management Control of Harmful Anti-fouling Systems Sulphur limits in ECA’s

(1912) Titanic SOLAS (1914…..)

Torry Canyon (1967) MARPOL Convention (1973…..)

MARPOL 73-78 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

Ballast Water Management Air Pollution Harmful Anti-Fouling Paint

Ballast Water Management

BWM Convention Entry into Force Currently: 44 States 35% of world tonnage 12 months Entry into Force BWM Convention Currently: 44 States 32.86% of world tonnage Entry into force creeping ever closer

Effective Dates as per Assembly Resolution 1088 In an effort to encourage ratification, the 28th IMO Assembly passed a resolution encouraging states to allow ships some breathing space to install BWM systems. It looks complicated, but as time goes on and more of the dates pass without the convention entering into force it gets much simpler. I the required number of ratifications is achieved this year (as seems likely), the convention will enter into force in 2016. Ships will then be required to have treatment systems installed by the first renewal survey after either their anniversary date in 2016 or the date of entry into force in 2016. The intention was that the compliance dates would be staggered in order to avoid a bottleneck in the yards. Source: ABS

Type Approval Process Concern 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

“Early adopters” not to be penalised 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 The MEPC further agreed that so-called “early adopters” should not be penalised. A subsequent announcement by one of the industry representatives that they were changing their policy of not encouraging ratification of the convention has been widely interpreted as industry endorsement of full ratification. IPTA, however, together with a number of other industry representatives has made it clear that we would like to wait for the results of the correspondence group reviewing the standards before endorsing any such action. In particular we would like to see it clearly stated that owners who install systems approve to the current standards will not be required to replace them for the life of the vessel, (providing they are operated and maintained properly).

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

What does a responsible owner do? 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?

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 approval 3 currently undergoing testing Not yet known when any system is likely to be granted approval

Reduction of Sulphur Emissions

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)

Flashpoint US 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 21 EU MRV IMO

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 MRV From 1 January 2018 ships above 5,000 grt must report on an annual basis: Total annual consumption of each type of fuel Total aggregated CO2 emissions CO2 emissions from all voyages between EU ports voyages coming into and departing from the EU CO2 emissions at berth in EU ports Total distance travelled and time spent at sea

All data will be made publically available 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 will be made publically available

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 type Transport work Distance travelled? Cargo weight/volume? Service hours? Not yet decided whether voluntary or mandatory

Distance travelled Berth 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.

Service Hours US proposes should cover Does not take into account when vessel underway (i.e. berth to berth) Ballast and laden voyages equally Does not take into account Fuel used at berth Fuel used for heating, tank cleaning etc. when underway Will ships that do not routinely perform ballast legs be disadvantaged?

Source: American Bureau of Shipping

Cargo Reflects operational efficiency How to aggregate on annual basis? Verification? Market forces? Maintaining confidentiality?

DWT as Proxy for Cargo Easy to verify No confidentiality issues Not a true reflection of operational efficiency Treats laden and ballast legs equally

Confidentiality Administrator 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…..”

28 years serving the chemical tanker industry Thank you for your attention 28 years serving the chemical tanker industry www.ipta.org.uk