1. The Shipping Industry and Environmental Legislation
Janet Strode
General Manager
International Parcel Tankers Association

2. 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

3. 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

4. (1912)
Titanic
SOLAS (1914…..)

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

6. MARPOL 73-78 Annex I Oil 1983 Annex II NLS 1983
Annex III Packaged Goods 1992
Annex IV Sewage
Annex V Garbage
Annex VI Air Pollution

7. Ballast Water Management
Air Pollution
Harmful Anti-Fouling Paint

8. Ballast Water Management

9. 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

10. 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 The intention was that the compliance dates would be staggered in order to avoid a bottleneck in the yards.
Source: ABS

11. 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

12. “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).

13. 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. ”

14. 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

15. 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?

16. 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.

17. 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

18. Reduction of Sulphur Emissions

19. 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)

20. 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

21. Reduction of GHG Emissions
COP 21
EU MRV
IMO

22. 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

23. 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 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.”

24. 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.”

25. 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

26. 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

27. Methods of Measuring Fuel Consumption
BDN
Onboard fuel tank monitoring
Flow meters
Direct CO2 emissions measurements

28. 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

29. 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.

30. 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?

31. Source: American Bureau of Shipping

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

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

35. 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?)

36. 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…..”

37. 28 years serving the chemical tanker industry
Thank you for your attention
28 years serving the chemical tanker industry