IMO Working Group on Air Pollution from ships - Progress Report

The IMO Working Group on Air Pollution from ships had its intersessional meeting this week in Oslo. The scope of the meeting was to further assess the results of the correspondence activity since it was previously convened at the 10th session of IMO's Bulk Liquids and Gases Sub-Committee (BLG 10) (April 2006), and to possibly streamline some of the proposals for alternative provisions that would constitute amendments to the current MARPOL Annex VI. The Working Group also addressed some more general submissions, which brought a few additional proposals for forthcoming amendments (see INTERTANKO submission in Weekly NEWS No. 42/2006 of 20 October 2006).


The INTERTANKO objective at this intersessional meeting was to bring to the Working Group's attention a few valid and essential alternative means which would assist in achieving efficient and simpler reduction of air pollution from ships. These comprise:


-         a switch to distillate fuels only with a lower sulphur cap;

-         removing SECA provisions;

-         including in the MARPOL Annex VI regulation a provision for the proper definition of the fuel specification;

-         including concrete operational and technology measures to control VOC emissions.


All were discussed and are included in the alternative options for amendments to MARPOL Annex VI or as suggestions that will be further discussed. A summary of the outcome of the intersessional meeting is as follows:


1. Sulphur oxide (SOx) and Particulate Matters (PM) emissions


The main options for Regulation 14 of MARPOL Annex VI:


A. Status Quo - No change from the current requirements of Regulation 14


B. Sulphur Emissions Control Area (SECA) - Keep the current structure of Regulation 14 with:


·         A global sulphur cap (unchanged or lower value)

·         SECA sulphur cap lowered in two tiers as follows:

·         1.0%  in [2010]

·         0.5% in [2015]

C1. Change to distillate fuels (re. INTERTANKO submission) - As a fuel solution which would require:


·         Use of distillate fuels for all ships as follows

·         A global sulphur cap

·         1.0% in [2012] (date adjusted from 2010 to allow additional time to address supply concerns but also give advance notice to ship operators to prepare their ships and adjust contracts to such a new regime)

·          0.5% in [2015]

·         Include in MARPOL Annex VI the specification for the distillate fuel to be used by ships.


C2. Global cap – As specified in option C1 but which would allow for the use of residual fuel provided the fuel meets the specified sulphur content or uses an alternative mechanism (such as an exhaust gas cleaning system) to obtain an equivalent level of emission reduction.


Finally, the Working Group reluctantly agreed to include a proposal from Denmark for further consideration stating that "Ports that establish measures to address air emissions from ships must notify the IMO at least 6 months before the effective date of such requirements". INTERTANKO expressed concern that such a provision may give the wrong signals and would encourage, endorse or tacitly accept local requirements beyond the international agreements.


2. Nitrogen oxide (NOx) emissions - the progress made this week can be summed up as follows:


  1. There is general agreement on two further tiers of reductions in NOx limitations: Tier II with some 15% to 20% reduction from the current Annex VI NOx limitation (which is considered as the Tier I reduction) and a Tier III with a yet to be specified reduction target. Both Tier II and Tier III will apply to new engines as per the dates of their respective application. Although these have not been determined, the indication is 2010 for Tier II and 2015 for Tier III.


  1. Existing engines (post 2000) which comply with the Tier I limitation would not be subject to newer limitations.


  1. However, there seems to be a general agreement that pre-2000 existing engines would be required to consider some specific engine modifications (e.g. installing slide valves) as a measure to lower their unspecified NOx emissions. This measure would apply to all pre-2000 engines irrespective of their current NOx emissions. This was a better solution which, to some extent, could counteract a suggestion from Japan to set up stringent standards for pre-2000 engines on NOx emission compliance with the consequence that those not being able to meet the standards should be phased-out.


  1. There was a proposal to subject gas turbines and tanker boilers to NOx emission limitation. This was not agreed upon but the proposal is expected to be raised again at a future meeting in April 2007.


  1. Volatile Organic Compound (VOC) emissions - Norway has previously requested that the current regulation on VOC emissions be expanded to consider management plans for retention or limitation of VOC emissions during transportation and use of technologies during loading.


In light of this request, INTERTANKO has submitted a specific proposal to address an operational procedure. This would imply that regulations define a minimum cargo Reid Vapour Pressure from which VOCs are expected to occur - and when onboard operations need to be initiated - and a maximum cargo Reid Vapour Pressure at which the cargo tank structure and p/V (pressure/vacuum) valves could not contain the VOCs, and releases into the atmosphere would take place. The latter value would imply that the IMO has to decide whether cargoes with a Reid Vapour Pressure over the maximum value need to be prepared by the cargo owner before transportation, or whether it would be acceptable that, for such instances, VOC releases would occur due to the nature of the cargo and its temperature as per the ambient environment under which it is transported.  This issue will be further considered and INTERTANKO will participate in a possible joint assessment prior to the next IMO meeting.


Also, on  behalf of INTERTANKO, Per Lothe from Knutsen OAS gave a presentation on the KVOC (Knutsen VOC technology) loading system which, as tested on many of  Knutsen's shuttle tankers, can control the cargo loading pressure and keep it constant with the excellent result of avoiding VOC occurrence during loading. As a consequence of no, or minor, VOC occurrence at the loading, and in combination with a VOCON valve, these tankers have minimised VOC emissions by 80% and more. The Working Group, however, did not make any specific progress on this issue.


  1. Particulate Matters (PMs) – There was no decision taken, or indication given, on what might be the limits in this new criterion. The only specific proposal to reduce PM emissions from ships was in the INTERTANKO submission.


  1. Fuel Quality – The Working Group noted the INTERTANKO proposal for adding provisions in MARPOL Annex VI to define the specification of fuels used by ships and agreed to invite proposals on possible parameters.


The next round of debates will take place at BLG 11 due to be held in London in April 2007. As far as INTERTANKO is concerned, we believe that from now and until April 2007, the industry should give high priority to identifying the best possible solutions for a long-term and predictable regulatory regime which would, on the one hand, reduce air emissions from ships and, on the other, ensure that new engines are designed and built to meet foreseeable tighter regulatory regimes on emissions from ships. INTERTANKO has already made this one of its main priority activities.


Contact: Dragos Rauta