Memorandum submitted by Simon Brown, Director
of Business Development, Martek Marine Ltd
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
1. How can the UK's share of emissions from
ships be measured and included in the UK's carbon budget?
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 UK based marine solutions
supplier pioneered the first Type Approved on-board emissions
monitoring and recording system in April 2005. Since this date,
Martek have proven the following capabilities on-board:
| 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.
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II. | Capability to record totalised inventory in kgs and tons for each pollutant.
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III. | Capability to determine if the vessel is in compliance within a geographical region.
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IV. | Automated collection and recording of data from all installed sources on-board.
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V. | Capability to upload emissions data to a web portal via a GPS/satellite transmitter.
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| VI. | Capability to measure CO2 in line with the IMO CO2 indexing scheme (MEPC Circ 471).
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VII. | Capability to accurately record totalised CO2 for use in carbon offsetting or emissions trading schemes.
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VIII. | Capability to encrypt the data to prevent tampering by third parties.
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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 any "UK carbon
budget", monitoring systems can be installed on specific
vessels to automatically report emissions and provide accurate
totals.
Systems are usually available within 12 weeks from manufacturers
and the UK fleet could be equipped over a period of 24-36 months.
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.
SUMMARY
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.
15 September 2008
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