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There Are No Shortcuts to Compliance

There Are No Shortcuts to Compliance

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There Are No Shortcuts to Compliance

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  1. There Are No Shortcuts to Compliance

  2. Marine environmental regulations Development towards 2030 Stricter regulations on SOX and NOX GHG emissions - Technical, operational and market-based measures Ballast water and recycling conventions Regulation on new issues - black carbon, underwater noise, bio-fouling and VOC Local marine environmental requirements Drivers Public opinion and awareness – public pressure Health hazards in populated coastal areas Climate change Invasion of alien species Barriers Cost of administration and compliance Unclear science (black carbon and noise) Developing/developed country conflict (GHG)
  3. Existing Emission Control Areas
  4. New ECAs – fact or fiction? Turkish Straitsin 2018? Hong Kong / Guangdong? Mexicoin ‘17/’18?
  5. SOx
  6. Tightening sulphur emission requirements Global sulphur ECA sulphur EU sulphur Requirement 2020 / 2025*; Sulphur < 0.50% * Date TBD pending MEPC review, end-2018 latest Requirement 2010; Sulphur < 1.0% 2015; Sulphur < 0.1% Requirement 2012; updated ECA reqs. in EU law 2020*; Sulphur < 0.50% * All EU waters; EEZ (200NM)
  7. Scrubber systems – maturing and scaling >44 SOx Exhaust Gas Cleaning systems on 20 DNV classed ships and NB projects
  8. NOx
  9. NOx emissions – MARPOL Annex VI NOx NECA - Baltic NECA – North Sea 2011: NOx Tier 2, -20% 2016: NOx Tier 3, -80%* * New builds, only in existing North American / U.S. Caribbean NECA. New NECAS define own date HELCOM working on issue. EC and EU Council pushing, member states split Submission date uncertain Consultations on-going but slow moving – must be seen in conjunction with Baltic NECA activities Submission date uncertain
  10. MEPC 66 Update - Gas engines and NOx regulations An amendment to the definition of fuel oil and marine diesel engine was approved to include gas and gas fuelled engines respectively Gas fuel will be subject to the Fuel Oil Quality requirements in MARPOL Annex VI regulation 18.3 Gas turbines and other forms of combustion engines other than internal combustion engines are still not covered by MARPOL Annex VI The amendments are expected to be adopted at MEPC 67 in October 2014
  11. CO2
  12. GHG policy status IMO - EEDI and SEEMP key instruments while MBM is dead in the water. Focus on energy efficiency along with increasing activity on emission Monitoring, Reporting and Verification (MRV) US - Work on efficiency standards remains key US focus area; “data collection” (“MRV”) key first step EU - Focus shifted from regional MBM to regional MRV; regulation likely adopted in 2014 UNFCCC – Working on global climate deal by 2015 with 2020 as effective target date; outcome & implications remain uncertain Developing countries – Generally opposed to MBM & MRV, but positions may be softening slightly. UNFCCC principles remain key issue
  13. EEDI – new phases driving ship design changes Schedule and/or levels may change subject to IMO reviews in 2015 and 2022, debate related to 2015 review starting
  14. MEPC 66 update - Further ship types covered by EEDI requirements
  15. EU Monitoring, Reporting and Verification scheme Ships above 5000 GT (all flags) have to report CO2 emission on voyages to, from and between EU ports Regulation expected in effect January 1 2018 Four methods Bunker Fuel Delivery Note (BDN) and periodic stocktakes of fuel tanks; Bunker fuel tank monitoring on board; Flow meters for applicable combustion processes; Direct emissions measurements Efficiency metric still undecided (nm vs. tonne-nm) Has to be negotiated and approved with EU Council and Parliament (late 2014 likely) EU sees this as a step toward a global system and further reduction requirements for shipping
  16. Regulations summary – air emissions SOx ECA requirements will remain unchanged though global 0.5% may be delayed until 2025 – but note EU waters in 2020 Limited near-term spread of new ECAs, prime candidates are Bosporus / Marmara, Hong Kong / Guangdong, Mexico NOx ECA requirements effective in North American waters from 2016 NOx NECA application for North Sea and Baltic possible this decade, but politically challenging. Effective date will depend on applications. CO2 MRV for the EU likely this decade, may possibly be superseded by IMO MRV CO2 pricing in the 2020’s at the earliest, potential UNFCCC deal remains a dark horse
  17. Ballast Water
  18. Ratification date of the Ballast Water Convention still uncertain As of 2014-04-07, the required 35% of the world fleet tonnage flagged by the signatories was not reached. With ratification of one Flag State with 6% gross tonnage (e.g. Panama), BWM Convention becomes mandatory 12 months later. 33 BWT systems have obtained full IMO type approval. 46 BWT manufactures are in the certification process. (basic approval IMO May 2013)
  19. The implementation schedule has been harmonised and relaxed Compared to the initial IMO schedule, we see a relaxation suggested for vessels with small BW volume and constructed before 2009: 2 more years* vessels with small BW volume and constructed after 2009 and before EiF: 5 more years* vessels with large BW volume and constructed after 2012 and before EiF : 5 more years* But the US-requirements for BW treatment are already in force! *) years before BWT system installation becomes mandatory for all ships
  20. Emerging regulations
  21. Emerging regulations - summary Hull bio-fouling Particles, “Black Carbon” Underwater noise Expect regulations to be agreed within the next 5 – 10 years, effective some time later And if considering Arctic operations; keep an eye on IMO Polar Code developments…