Memorandum submitted by Simon Brown, Director of Business Development, Martek Marine Ltd(EMS05)
Simon Brown is responsible for the development of 'MariNOx', the World's first Type Approved marine diesel engine emissions monitor and heads up the companies R & D into innovative environmental monitoring systems.
Acknowledged as an industry expert in on-board emissions measurement, he recent led a groundbreaking development in automated GPS web based marine emissions reporting software package to demonstrate the enormous benefits of 'real-time' monitoring on commercial shipping available over the internet
Having recently seen through the revisions of the NOx Technical Code in the capacity as Chairman of the 'NOx Code Working Group' at the IMO, this challenging task was made easier with the formation of a 'group of technical experts' who represented all aspects of the marine industry. The group were keen to improve and clarify those sections of the NOx Code which have caused issues since its introduction, and develop workable regulations in those areas which will provide the greatest challenges over the coming years.
Bullet Point Summary
· Pro-active emissions reduction initiatives must be based upon accurate measurements and recording of totalized emissions inventories.
· The marine industry's decision for a phased programme for diesel engine emissions reduction combined with geographically based Emission Control Areas has not provided incentives for investment in emissions reduction technology. CO2 emissions from shipping have not been addressed in the recent review of MARPOL Annex VI and the NOx Technical Code.
· Boilers and gas turbines fall outside the realms of MARPOL Annex VI but will contribute to the overall emissions inventory.
· IMO CO2 indexing scheme is based on empirical calculations from fuel usage, not accurate measurement technology.
· Guaranteed compliance cannot be achieved by the current method of 'rare' and 'random' port state inspections. Real-time, live data, available on the internet can provide evidence of vessel emissions compliance at all times.
· Environmental initiatives such as emissions trading will require accurate emissions measurement. The further benefits to realise the full benefits of investment in emission reduction technology.
Submission specifically aimed at the following questions raised;
2. How quickly can any proposed scheme be implemented?
3. What are the benefits of direct measurement in wider emissions trading schemes?
The worldwide shipping community has a serious number of challenges to face over the coming years. The revisions to MARPOL Annex VI and the NOx Technical Code have far reaching ramifications for ship owners, regulators, engine builders and technology providers alike.
This submission challenges the traditional marine industry 'resistance' to continuous emissions measurement, by demonstrating the significant benefits of 'what gets measured, gets done'.
The ability to measure each emission source installed on-board, including boilers and other fuel consuming units, is essential to provide a fully accurate emission footprint, however these emission sources have not been included within MARPOL Annex VI.
Martek Marine Ltd, a
I. Measurement of NOx, SOx and CO2 on board vessels from diesel engines and boilers in line with the specific requirements of IMO MARPOL Annex VI regulations 13 and 14.
II. Capability to record totalised inventory in kg's and tons for each pollutant.
III. Capability to determine if the vessel is in compliance within a geographical region.
IV. Automated collection and recording of data from all installed sources on-board.
V. Capability to upload emissions data to a web portal via a GPS/satellite transmitter.
VI. Capability to measure CO2 in line with the IMO CO2 indexing scheme (MEPC Circ 471).
VII. Capability to accurately record totalised CO2 for use in carbon offsetting or emissions trading schemes.
VIII. Capability to encrypt the data to prevent tampering by third parties.
The current emissions inventory schemes, as implemented within ISO14001 and IMO, are all based on empirical calculations of CO2 emissions based on fuel used. The factors used are different depending on fuel composition.
This method of calculation does not account for the efficiency of the emissions sources, thus the actual emissions reported are currently 'estimates'
Subject to shipping being included within
Systems are usually available within 12
weeks from manufacturers and the
Typical Emissions Report
Typical System Configuration
Benefits of Emissions Measurement within a wider emissions trading scheme
· Environmental innovators will derive a financial payback from investment in emissions reduction technology, whilst achieving the wider environmental objectives.
· CO2 being linked directly to efficiency and fuel consumption, measurement provides the ability to 'optimise' performance to given conditions and operating profile would reduce operating costs and the environmental impact.
· Transparent reporting ensuring accurate industry inventory.
Considerations of measurement within a wider trading scheme
· Land based operators such as power stations are required to use monitoring technology and are audited regularly for performance, currently no such scheme is required for shipping.
· Systems are now widely available in the market and environmental innovators are installing across their fleets worldwide.
Emissions monitoring technology must be included within wider environmental initiatives to provide the metrics which will allow accurate measurement of fleet performance.
Environmental innovators will only invest in emissions reduction technology, if it provides a realistic payback or competitive advantage, on-board measurement is a key instrument in validating the efficacy of any project.
Using automated measurement technology combined with GPS location, allows the fleet to be monitored and audited for continual compliance with regulations.
Direct on-board Measurement will provide the mechanism to allow operators to derive financial payback from investment in emissions reduction technology and emissions trading schemes.
15th September 2008