Memorandum submitted by SEAaT (EMS08)
SEAaT is a cross-industry, pro-active and
self-funding group, whose mission is to encourage and facilitate efficient
reduction of harmful emissions to air from shipping.
SEAaT believes the shipping industry,
should be given the maximum freedom to achieve defined outcomes, using whatever
environmentally acceptable solutions it finds appropriate and cost effective.
There is potential for the reduction of emissions of shipping by innovation, in
improving the energy efficiency of ships by the use of abatement technologies
and performance improvements, both at an operational level and in the supply
chain. However these potentials will only be realised if there is financial
benefit for making the changes and a regulatory framework enables 'goal based'
solutions to flourish. To this end,
SEAaT encourages the use of the market based instrument of emissions trading to
facilitate performance improvement.
· Shipping CO2 emissions estimated:
o at between 0.8 and 1.2 billion tonnes of CO2 annually.
o to contribute to a mean figure of 2.7% of global anthropogenic emissions.
o estimated growth factor of 2.3 to 3.5 times compared to the 2007
o growth may be restricted by current global economic slowdown.
· Allocation of UK shipping emissions to UK emissions budget not
considered to be appropriate.
· Negative environmental and economic consequences may result from
policies that do not properly consider the differences in shipping sectors.
· Prospects of international agreement on shipping emissions
reductions are unclear
· Measures and controls being considered are:
o New build design index
o Recommended best practices
o Market based instruments
§ Bunker levy
§ Emissions trading (cap and trade)
· SEAaT considers emissions
trading (cap and trade) to be the most effective market based instrument
· Established technologies and operational measures exist to reduce
emissions from ships by up to 30 to 40%, including :
o Waste heat recovery
o Propeller design
o Hull forms
o Weather and tide routing
o Paint systems such as silicon coatings
o Trim optimisation tools
· In addition, innovative technologies are being developed which may
o Sky sails
o Air cavity systems (air lubrication)
o Twin propellers
· UK Government support for
a global emissions trading (cap and trade) will facilitate its adoption
2.0 Responses to Strategic Issues as Identified by the Committee
2.1 How significant is
global shipping's contribution to climate change? How is this projected
to change in the future?
The most significant gas emissions from
ships contributing to climate change are from combustion processes and VOCs
(volatile organic compounds) from tank venting on tankers. The emission under the greatest consideration at
the United Nations' body the International
Maritime Organisation (IMO), with respect to reducing the contribution to
climate change by shipping, is CO2.
Verified release data from across the
world's shipping fleet is not collated and is thus not analysed. However data
from a fleet of tankers suggests that the proportion of emissions is 97% from
combustion and 3% from tank venting.
The quantity of CO2 produced by
a ship's power plant is in direct proportion to the quantity of fuel burnt. For
every tonne of fuel consumed approximately 3 tonnes of CO2 are
The estimate of shipping's contribution to
the total CO2 emissions from shipping submitted to the IMO, as part
of the expert group study report2 on the
revision of MARPOL Annex VI, established a figure of 1.2 billion tonnes per annum.
A more recent study by Norwegian think-tank Marintec, for the IMO, whose
preliminary report was presented to the IMO Green House Gas Working Group in
June 2008, estimated the emissions from shipping as approx 0.8 billion tonnes
per annum. Both these estimates were established using a top down approach and
are based on ship size, engine size and an assumption of days steaming. A
bottom up estimation using actual fuel consumption data is currently not
possible,as there is no external reporting of fuel consumption data.
The Marintec report estimates the
contribution of shipping to to be 2.7% of the global total emissions.
Estimations of change in contribution are
directly proportional to changes in trading activity. The Marintec report
estimated a growth factor of 2.3 to 3.5 compared to the 2007 emissions
inventory. The recent reductions in economic growth may result in these
estimates being reduced.
2.2 How should the UK's share of international maritime emissions
be measured and included in UK
carbon budgets? How fast could this be done?
2.2.1 Deep Sea
The international nature of shipping makes
it inappropriate to allocate "shares" of international shipping emissions to
any particular nation. The trade in raw materials and finished goods often means
that material is imported, value is added, and the resultant goods then
exported. If the allocation was targeted at goods arriving at UK ports then use of UK ports as European 'entry ports' may
be jeopardised. It is more appropriate
for the international shipping industry to be considered as a contributing
entity in its own right, in much the same way as nation states are considered.
Nevertheless, the European Union has made it clear they will act autonomously
if the IMO do not provide acceptable measures for the reduction of CO2
Short Sea Shipping
If it was decided to try to allocate
shipping emissions to the UK,
one of the unintended negative consequences of any emissions controls may be to
drive modal shift from short sea shipping (another less CO2
efficient transport mode). The table below gives a comparison of the various
modes of transport.
CO2 -EFFICIENCY OF TRANSPORT MODES
Source: Swedish Network
for Transport and the Environment and Danish Shipowners' Association.
further negative consequence might be the development of ports outside the UK at
which the journey is broken. The purpose of this would be to reduce the mileage
between the "last port" and the UK.
Although this might reduce the amount of CO2, the UK accounting for it would not contribute
to the reduction of global CO2 emissions and may, depending on the
vessels used to bring goods to the UK, actually cause an increase.
2.3 What are the prospects of international
agreements to control and reduce carbon emissions from global shipping, or to
bring it within wider emissions trading schemes? How well is the UK
Government playing a role in developing such agreements?
It is necessary to consider agreements concerning
measures to reduce carbon emissions separately from agreements to control
2.3.1 Measures to reduce carbon emissions
Currently the IMO is considering two main
measures to bring about a reduction in carbon emissions from global shipping.
The first measure is a design index for new buildings. The index is generated
from a formula, taking into account a vessels size, installed engine power, and
a number of other factors establishing a theoretical emissions index . All new
ships from an implementation date would be required to conform to or better
this index. The second measure is a list of best practices which when implemented
will reduce the emissions from ships. These best practices, include both
technical and operations aspects of vessel operation. SEAaT
supports these two IMO initiatives.
2.3.2 Measures to Control Carbon Emissions
The IMO is considering market based
instruments to achieve control of emissions reduction. Two basic types of
instrument are currently being looked at. One is a bunker levy, acting in effect
as a Pigovian tax, to drive operational behaviour to reduce emissions. The
other is an emissions cap and trade system. A preference for either system
amongst the parties to the IMO is not presently clear.
The prospect of agreement to the adoption
of any mandatory measure to reduce and control carbon emissions from shipping
on a global basis appears, on the evidence of the outcome of the IMO Green
House Gas Working Group held in Oslo
in June 2008, to be unclear. The discussion to a large extent was dominated by
the issue of the Kyoto Protocol's common but differentiated responsibilities. Some non Kyoto Annex 1 countries feel strongly
that any measures to reduce and control emissions from ships should not apply
to them. This is at variance with the views of the IMO Secretary General, who
feels that in order to maintain a level playing field with international
shipping all reduction measures and controls should apply to all shipping
regardless of flag.
The UK government is ably represented
at the IMO by staff from the Maritime Coastguard Agency and the Department of
2.4 What are the prospects for developing new
engine technologies and fuels, as well as more fuel-efficient operations?
What more could the Government do to assist these developments?
In terms of thermal efficiency the most commonly
used engine type in international shipping, the slow speed marine two stroke
engine, is approaching its theoretical maximum. These engines have a thermal
efficiency of approximately 53%. No other current propulsive power plant
configurations can match this. Of the developing technologies there appears to
be none that can match the slow speed marine two stroke engine for its
particular application. Fuel cell technology producing power on the scale
required for marine propulsion appears to be a considerable distance away.
Nuclear power, although proven to work in the 1960's, would not be commercially
viable or socially acceptable. If nuclear power was to be considered it may be
more acceptable and efficient to use this power to synthesise marine fuels on
The best technological prospect for
increasing the overall fuel efficiency of ships is to focus on waste heat
recovery systems; hull forms and coatings; and propeller designs. However, take
up of these units by the world shipping fleets is limited by costs of purchase
and installation. These technologies are well known in the industry. Take up
tends to be limited by cost of purchase and installation, and, up until present
fuel cost rises, the poor return on investment these technologies represent.
The table below from IMO
Bulk Liquid Gases Report, P.16, Dec. 2007 According to research
commissioned by the IMO, technologies could reduce fuel consumption and oil
usage by up to '30-40%'.
However, some of these measures have been
adopted by industry and results have reportedly not been meeting expectations.
There are non-conventional technologies currently
being appraised for applicability, such as the sky sail concept, twin propeller
and the under hull air cushion.
The developer of a kite system asserts their system
may reduce a ship's fuel consumption by 10-35% on annual average, depending on
wind conditions. Although recent tests
have the mark at the lower end of the spread. Under optimal wind conditions,
fuel consumption can temporarily be reduced by up to 50%. Developers of innovative propeller technology
estimate a reduction in fuel consumption of up to 17% on some vessel types -
considerably more than the IMO advisory group's estimation of 5-8%. A system to
blow air bubbles under the ships hull to reduce fuel is said to cut fuel consumption
by between 8 and 15%. The patented "Air Cavity System" improves the fuel
efficiency of ships by reducing the frictional resistance of the hull surface.
With respect to alternative fuels, only
liquefied natural gas is a serious contender for supplanting traditional fuels.
The complexity of on vessel storage and containment systems and the shore-side infrastructure
required for resupply severely limits the adoption of this fuel. The
operational range of vessels using LNG is limited by the fuel tank size and
boil off rates. LNG is considered by industry to be more suitable for short sea
traffic than the deep sea trade. Indeed,
some ferry routes with dedicated supply and shore-side infrastructure in Scandinavia currently use LNG for main propulsion fuel.
The shipping industry is a diverse one, and
provides many different services to society. This spread of services militates
against the adoption of proscriptive solutions targeted at the industry as a
whole. Such a policy may have unintended negative consequences. There is a real
possibility that requiring reductions of emissions from short sea shipping,
causing increases in operating costs, will result in modal shift to land transport. This would increase rather than reduce
emissions of transport related CO2.
A recent fire in the Channel Tunnel,
demonstrates the need for a strategic mix of transport modes. Should
environmental policies create modal shift away from short sea shipping, bring
about a loss of capacity, then any restriction of use of the tunnel would not
be as easy to mitigate as is currently the case. The result on the UK
economy would be negative.
is for this reason SEAaT considers it vital the issue of emissions from
shipping, and their reduction, is considered in terms of social utility, the
various sectors provide and their position in the supply chain. Failure to do
this may result in damage to a vital industry and an overall negative environmental
2.5 SEAaT Proposal
The members of SEAaT believe market
based instruments in the form of a "cap and trade scheme"; applied where appropriate;
will provide additional financial incentives to shipping companies to adopt the
emission reduction measures most suitable to their sector of the business.
The design of such a trading system is
vital to its success. SEAaT advocates a global, open trading system, with an
emissions reduction trajectory linked to global emissions reductions
aspirations. The initial emissions cap
being set by historical emissions levels. The allocation method is recommended
to be initially a free allocation based on historical data with a gradual
transition to an auction allocation system over a number of years.
In supporting a global emissions trading
scheme for the appropriate sectors of the shipping industry, the UK
government would aid the effort to establish an emissions reduction
facilitation tool that encourages change and rewards improved environmental
3.0 SOx, NOx and Particulates Emissions from
SOx, NOx and Particulates
Emissions from shipping sources differ from CO2; in that it creates
localised environmental impacts where as CO2 is a uniformly mixed
emission and acts globally.
3.1 Sulphur Oxides
Sulphur oxides (SOx) are major air
pollutants and precursors for secondary particle formation in coastal areas.
The emissions quantity is directly proportional to the sulphur content in
Reductions in SOx emissions can be achieved by
either reducing the sulphur content of the fuel used, or by removing SOx from
the exhaust stream by using scrubbing technologies. Both approaches are
permitted by MARPOL Annex VI. Switching to a lower sulphur content fuel,
although the simplest option incurs cost penalties related to the differential
between high sulphur and low sulphur marine fuels. Abatement by scrubbing
allows cheaper high sulphur fuel to be used but incurs installation and
scrubber manufacturer estimates that 50% of the current tanker fleet could find scrubbing more
economical than a diesel switch, which equates to a potential tanker market
opportunity of 5,893 ships by 2015 for scrubber manufacturers. For vessel
owners looking to future-proof their vessels against future regulation at new
build stage, the economics of fitting a scrubber could be attractive.
to the manufacturer, as many as 23,905 vessels from a global fleet target total
of 71,758 could find scrubbing to be a more viable option than switching to
diesel fuel by 2015 - equating to a potential market of over $7 billion based
on average scrubber size and costs.
Other developing scrubbing systems include the
use of chemicals such as caustic soda in their cleansing process.
A benefit of the use of scrubbing technologies
is that they also abate the emission of particulates.
3.2 Particulate Emissions
The combustion of all fuels leads to the
emissions of particulate matter to a greater or lesser extent. Particulates
associated with shipping emissions are soot and ash, polycyclic aromatic
hydrocarbons, and SOx aerosols. These
emissions have an adverse effect on the health of exposed populations, with
residents in port areas being the most exposed. Reduction of particulate
emissions can be achieved by burning lower sulphur fuel and/or using exhaust
gas scrubbing technologies.
3.3 NOx Emissions
These emissions are subject to the controls
imposed by the NOx regulations contained in MARPOL Annex VI. A phased reduction
of NOx emissions is required by these regulations. Early phase reductions may
be achieved by using in engine technologies where as the later phase reductions
will require the use of exhaust gas or combustion air technologies such as
scrubbing using catalysts in exhaust gas or adding water vapour to the
22 September 2008