Memorandum submitted by SEAaT
1.0 INTRODUCTION
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.
1.1 SUMMARY
— Shipping CO2 emissions estimated:
— at between 0.8 and 1.2 billion tonnes
of CO2 annually;
— to contribute to a mean figure of
2.7% of global anthropogenic emissions;
— estimated growth factor of 2.3 to
3.5 times compared to the 2007 emissions inventory; and
— 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:
— New build design index.
— Recommended best practices.
— 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:
— Weather and tide routing.
— Paint systems such as silicon coatings.
— Trim optimisation tools.
— In addition, innovative technologies
are being developed which may reduce emissions:
— Air cavity systems (air lubrication).
— 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 three tonnes of CO2
are produced.
The estimate of shipping's contribution to the
total CO2 emissions from shipping submitted to the IMO, as part
of the expert group study report 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 Shipping
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 for shipping.
2.2.2 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.
A 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 carbon emissions.
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 Transport.
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 1960s, 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 shore.
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, December 2007.According to research commissioned
by the IMO, technologies could reduce fuel consumption and oil
usage by up to "30-40%".
Measure
no |
Description | Existing ships
gain %
| Newbuildings
gain % |
| 1 | Main Engine efficiency rating
| 2 | |
| 2 | Main Enginer optimisation
| | 2 |
| 3 | Waste Heat Recovery |
| 5-10 |
| 4 | Optimize hull shape, inc reduced Cb*
| | 3-10 |
| 5 | Optimized propeller |
2 | 3-6 |
| 6 | Maintenace of wetted hull surface
| 2-5 | 2-5 |
| 7 | Improved anti fouling paints
| 2-8 | 1-2 |
| 8 | Twin skeg + twin propeller
| | 5-8 |
| 9a | Trim optimisation—large Cb ships
| 1-2 | 1-2 |
| 9B | Trim optimastion—small Cb ships
| Max 10 | Max 10 |
| 10 | Misc Fuel saving devices
| 2-6 | 2-6 |
| |
| |
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.
It 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
outcome.
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 improvement.
3.0 SOX, NOX
AND PARTICULATES
EMISSIONS FROM
SHIPPING
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 marine
fuel.
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 operational costs.
A UK 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.
According 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 combustion air.
22 September 2008
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