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Sulfur

Daily Mail: How 16 ships create as much pollution as all the cars in the world

from Fred Pearce of the Daily Mail:

Award-winning science writer Fred Pearce – environmental consultant to New Scientist and author of Confessions Of An Eco Sinner – reveals that the super-ships that keep the West in everything from Christmas gifts to computers pump out killer chemicals linked to thousands of deaths because of the filthy fuel they use.

We’ve all noticed it. The filthy black smoke kicked out by funnels on cross-Channel ferries, cruise liners, container ships, oil tankers and even tugboats.

It looks foul, and leaves a brown haze across ports and shipping lanes. But what hasn’t been clear until now is that it is also a major killer, probably causing thousands of deaths in Britain alone.

As ships get bigger, the pollution is getting worse. The most staggering statistic of all is that just 16 of the world’s largest ships can produce as much lung-clogging sulphur pollution as all the world’s cars.

Because of their colossal engines, each as heavy as a small ship, these super-vessels use as much fuel as small power stations.

But, unlike power stations or cars, they can burn the cheapest, filthiest, high-sulphur fuel: the thick residues left behind in refineries after the lighter liquids have been taken. The stuff nobody on land is allowed to use.

Thanks to decisions taken in London by the body that polices world shipping, this pollution could kill as many as a million more people in the coming decade – even though a simple change in the rules could stop it.

There are now an estimated 100,000 ships on the seas, and the fleet is growing fast as goods are ferried in vast quantities from Asian industrial powerhouses to consumers in Europe and North America.

The recession has barely dented the trade. This Christmas, most of our presents will have come by super-ship from the Far East; ships such as the Emma Maersk and her seven sisters Evelyn, Eugen, Estelle, Ebba, Eleonora, Elly and Edith Maersk.

Each is a quarter of a mile long and can carry up to 14,000 full-size containers on their regular routes from China to Europe.

Emma – dubbed SS Santa by the media – brought Christmas presents to Europe in October and is now en route from Algeciras in Spain to Yantian in southern China, carrying containers full of our waste paper, plastic and electronics for recycling.

But it burns marine heavy fuel, or ‘bunker fuel’, which leaves behind a trail of potentially lethal chemicals: sulphur and smoke that have been linked to breathing problems, inflammation, cancer and heart disease.

James Corbett, of the University of Delaware, is an authority on ship emissions. He calculates a worldwide death toll of about 64,000 a year, of which 27,000 are in Europe. Britain is one of the worst-hit countries, with about 2,000 deaths from funnel fumes. Corbett predicts the global figure will rise to 87,000 deaths a year by 2012.

Part of the blame for this international scandal lies close to home.

In London, on the south bank of the Thames looking across at the Houses of Parliament, is the International Maritime Organisation, the UN body that polices the world’s shipping.

For decades, the IMO has rebuffed calls to clean up ship pollution. As a result, while it has long since been illegal to belch black, sulphur-laden smoke from power-station chimneys or lorry exhausts, shipping has kept its licence to pollute.

For 31 years, the IMO has operated a policy agreed by the 169 governments that make up the organisation which allows most ships to burn bunker fuel.

Christian Eyde Moller, boss of the DK shipping company in Rotterdam, recently described this as ‘just waste oil, basically what is left over after all the cleaner fuels have been extracted from crude oil. It’s tar, the same as asphalt. It’s the cheapest and dirtiest fuel in the world’.

Bunker fuel is also thick with sulphur. IMO rules allow ships to burn fuel containing up to 4.5 per cent sulphur. That is 4,500 times more than is allowed in car fuel in
the European Union. The sulphur comes out of ship funnels as tiny particles, and it is these that get deep into lungs.

Thanks to the IMO’s rules, the largest ships can each emit as much as 5,000 tons of sulphur in a year – the same as 50million typical cars, each emitting an average of 100 grams of sulphur a year.

With an estimated 800million cars driving around the planet, that means 16 super-ships can emit as much sulphur as the world fleet of cars.

(more…)

CNN: Ship emissions blamed for worsening pollution in Hong Kong

by Grigory Kravtsov, reporting for CNN:

Smog is a common sight in Hong Kong, with the amount of polluted days increasing by 28 percent to 303 so far this year.

Hong Kongers would be quick to point the finger at Chinese factories across the border. Yet, research is increasingly indicating that the problem is much more localized, coming from emissions produced by shipping.

What we know in Hong Kong is that up to 50% of pollution [locally produced] sources come from marine vessels,” said Gina McCarthy, administrator at the U.S. Environmental Protection Agency.

Smog levels within the city of over 7 million reached hazardous levels earlier this week, with particles in one urban area, Sham Shui Po hitting a PM2.5, hitting 91.7 micrograms per cubic meter of air. Anything above 71 is classified as “very dangerous” according to the World Health Organization guidelines.

Maritime pollution in Hong Kong is blamed for the most sulfur dioxide-related deaths within the region. According to a recent report jointly compiled by the Civic Exchange and The University of Science and Technology, Hong Kong saw 385 deaths caused by the hazardous chemical, for which shipping is to blame.

The city lacks regulations in tackling maritime pollution, as there is no legislation or requirements for shipping companies to switch to cleaner fuel when entering Hong Kong waters.

(more…)

Lack of Emissions Control Area in HK waters will continue to leave Hong Kong blanketed in smog

Less than a week after favourable weather cleared the skies of Hong Kong, the city is covered again in particles. It has become a common refrain for city officials to sing of their achievements in switching out diesel engines from the roads, and after that for Legco members to debate to no end as to how (un)successful their measures have been in improving the city’s air quality.

It is also commonly known, albeit with less attention paid, that cargo ships – especially ocean-going vessels – are a major contributor to pollutants as they move through the waters of Hong Kong. In addition to Hong Kong’s own Kwai Chung terminal, ships docking at Shenzhen’s Yantian and Shekou terminals pass through channels east and west of Hong Kong respectively, meaning Hong Kong bears the brunt of the emissions whichever way the prevailing winds blow.

Thus far, Hong Kong’s policymakers have only implemented a weak policy – incentivising ships docking at Kwai Chung to switch to cleaner fuels when moving in Hong Kong, transitioning into a compulsory requirement by Sep 2014. Meanwhile, there are already complaints that this would ‘hurt competitiveness’ of the Kwai Chung terminal in comparison with Shenzhen’s terminals (of which Hong Kong’s Hutchison Whampoa, and the Wharf, are shareholders).

The situation can be greatly improved if Hong Kong officials can push for the implementation of an Emissions Control Area, which will effectively make the same clean fuel requirements for Shenzhen’s terminals. This may call for cross-border co-operation between policymakers in order for the policy to be strictly enforced, but if Hong Kong officials wish to display some real work done, there can be no better opportunity.

Clear The Air has prepared a brief document on this issue.

Shipping lines complain about expensive clean fuel requirements

Ocean-going vessels, burning bunker fuels with 2.75-4% sulphur content, is a major contributor of air pollutants to Hong Kong. Prevailing winds bring sulphur particles into the ‘urban canyons’ of Hong Kong, where the concentration of particles are increased, posing a huge health hazard to Hong Kong residents.

Shipping lines are now complaining that the requirements imposed by the Hong Kong government to use cleaner fuels will increase their cost of business, and demands that the government extends a subsidy scheme that incentivises the use of cleaner fuels (the scheme does not end until Sep 2015). Alarmist warnings about ‘competitiveness’ with Shenzhen are being sent out, aiming to panick and pressurize the authorities to provide more incentives for doing what is right, even though they can share the extra costs with their clients as per usual business practices.

Of note is that Hong Kong is ‘the only Asian city to impose such a requirement’. Hong Kong should not step backwards from the rare occasion of being the lead in an environmentally-friendly policy, with developing economies increasingly adopting environmental technologies and policies ahead of Hong Kong.

from Anita Lam of the SCMP:

Ships calling at Hong Kong will face higher costs when legislation requiring vessels to switch to cleaner marine fuel upon berthing is passed next year.

Some carriers may, as a result, switch to neighbouring ports in Shenzhen.

To prevent this, shipowners said, the government should consider extending a scheme that subsidises shipping lines – many of which are expected to suffer losses this year – for the extra cost of the clean fuel.

However, a government official said, an extension is unlikely.

(more…)

AirClim: Shipping air pollution costs €60 billion per year

From Christer Ågren of Air Pollution & Climate Secretariat:

Total health-related costs in Europe caused by air pollutant emissions from international shipping are expected to increase from €58 billion to €64 billion between 2000 and 2020.

The total health-related costs of air pollution in Europe are calculated to have been more than €800 billion per year at the pollution levels of year 2000. This figure is estimated to decrease to €537 billion in 2020, provided that EU countries reduce their emissions from land-based sources in line with what is needed to achieve the environmental targets of the EU’s 2005 Thematic Strategy on Air Pollution, and provided that the sulphur emission standards for international shipping are complied with.

Air pollution is estimated to have been responsible for around 680,000 premature deaths in the whole of Europe in the year 2000, a figure that is expected to come down to approximately 450,000 in 2020.

Comparing the health impacts from shipping with those from land-based sources shows that in the year 2000 emissions from international shipping were responsible for an estimated seven per cent of the total health damage from air pollution in Europe, and that its share will increase to twelve per cent by 2020.

(flickr.com/ecstaticist/cc by-sa)

The number of annual premature deaths in Europe linked to air pollution from international shipping is estimated to increase from 49,500 to 53,400 between 2000 and 2020.

These figures come from a Danish study1 using the EVA (Economic Value of Air pollution) computer model. The research project aims to map the true costs of damage caused by air pollutant emissions from various sectors. Different scenarios assessing the human health impacts and associated external costs from different emission sectors have been investigated for the years 2000, 2007, 2011 and 2020 (see Table).

Table: Estimated total number of annual premature deaths in Europe caused by different emission sources

2000 2007 2011 2020
All sources 681,100 575,500 572,600 450,000
International shipping 49,500 48,300 46,000 53,400
Int. shipping in the North Sea and Baltic Sea 20,400 16,200 14,100 13,200

Air pollutant emissions from ships operating in the North Sea and the Baltic Sea were responsible for annual health damage in Europe valued at €22 billion at the emission levels of year 2000. By 2020, this figure is expected to come down to €14.1 billion, as a result of implementation of the stricter ship fuel sulphur standards agreed by the International Maritime Organization (IMO) in 2008 (see Box).

International ship emission regulations

The International Maritime Organization (IMO), under ANNEX VI of MARPOL 73/78 (the International Convention for the Prevention of Pollution from Ships), has adopted controls on sulphur in marine fuels.

The global fuel sulphur limit is currently 3.50% and will be lowered to 0.50% by 2020 (or possibly 2025, subject to a review in 2018). In specially designated sulphur emission control areas (SECAs), the current limit is set at 1.00% sulphur. It will be tightened to 0.10% by 2015.

Through the revision of the EU’s sulphur-in-fuels directive (2012/33/EU), which was finalised last year, these sulphur standards are part of binding EU legislation.

In Europe there are currently only two existing SECAs: the Baltic Sea and the North Sea (including the English Channel). Most of the coastal waters – within 200 nautical miles of the coast – of the USA and Canada have been designated as “combined” ECAs for both SO2 and NOx.

It should be noted that exhaust gas cleaning systems (e.g. scrubbers) that achieve equivalent sulphur emission reductions may be used as an alternative to low-sulphur fuels to fulfil the sulphur requirements.

However, since these stricter fuel standards apply only in designated Sulphur Emission Control Areas (SECA), and the Baltic Sea and the North Sea so far are the only such areas in Europe, and ship traffic overall is expected to continue to increase, the total health-related costs in Europe of international ship traffic are expected to increase from €58.4 billion in the year 2000 to €64.1 billion in 2020.

In the intermediate years (2007 and 2011), smaller decreases in the health damage from ship pollution occurred as a result of stricter sulphur standards in the SECA area. The subsequent increase up to 2020 results from an overall projected increase in ship traffic worldwide.

It is noted by the authors that a similar study performed by the US Environmental Protection Agency estimated that by 2020 air pollution from shipping would still cause 21,000 annual premature deaths within the USA, with related health costs amounting to USD47–110 billion.

Specifically for Denmark, it is estimated that the total annual health-related air pollution damage amounted to €4.5 billion in year 2000. By 2020, this figure is expected to come down to €2.5 billion.

Air pollutant emissions from international shipping in the Baltic Sea and the North Sea are responsible for health damage in Denmark valued at more than €620 million per year (year 2000), decreasing to €360 million in 2020. The authors conclude that the SECA regulation that limits the sulphur content in ship fuel to a maximum of 0.1 per cent as from 2015, is expected to significantly reduce the external costs, and that “a similar regulation of international ship traffic in the whole world would have a significant positive effect on human health.”

It is however noted that the health impacts from ship emissions in the SECAs will remain significant after 2015. The reason being that the emissions of nitrogen oxides (NOx) from ship traffic are not regulated by the SECA standard, and in the scenario used, NOx emissions from international shipping are therefore expected to continue to increase more or less in line with the projected increase in shipping activities.

1 Assessment of past, present and future health-cost externalities of air pollution in Europe and the contribution from international ship traffic using the EVA model system (March 2013). By J. Brandt et al. Published in Atmospheric Chemistry and Physics Discussion 13, 6 March 2013.

3 Oct 2013

Background brief on “Mandatory fuel switch at berth for ocean going vessels in Hong Kong waters” prepared by the Legislative Council Secretariat

Download (PDF, 143KB)

UPDATE ON NORTH AMERICAN EMISSION CONTROL AREA ENFORCEMENT AND FUEL AVAILABILITY GUIDANCE

http://www.blankrome.com/index.cfm?contentID=37&itemID=2850

Maritime New Development

Enforcement of the North American Emission Control Area (“ECA”) begins August 1, 2012. All vessels subject to MARPOL, with certain exceptions, will be required to utilize fuel oil with a sulfur content not exceeding 1.00% (10,000 ppm) while operating in the North American ECA or install and use an equivalent compliance method approved by its flag State. Recent Environmental Protection Agency (“EPA”) guidance provides insight on EPA’s intentions with regard to addressing ECA compliant fuel oil availability. The following is a summary of the key enforcement guidance and EPA’s guidance on fuel oil availability.

Background

The North American ECA was established in 2009 pursuant to Annex VI of the International Convention for the Prevention of Pollution from Ships (“MARPOL”), which is implemented domestically through the Act to Prevent Pollution from Ships (“APPS”). The North American ECA encompasses most of the United States and Canada’s coastal waters out to 200 nautical miles from the coastline. It does not include the Pacific U.S. territories, smaller Hawaiian Islands, the Commonwealth of Puerto Rico and the U.S. Virgin Islands, the Aleutian Islands and Western Alaska, and the U.S. and Canadian Arctic. In 2011, the U.S. Caribbean ECA was established and includes the waters adjacent to the Commonwealth of Puerto Rico and the U.S. Virgin Islands out to approximately 50 nautical miles from the coastline. However, the U.S. Caribbean ECA requirements will not be enforceable until January 2014.

Further information regarding creation of the North American and U.S. Caribbean ECAs may be found in our previous advisories:

“United States and Canada Propose 200 Nautical Mile ‘Emission Control Area’ Under MARPOL Annex VI”; “EPA Finalizes Emissions Standards for Category 3 Marine Diesel Engines and Implements North American ECA”; and “Update on Compliance Requirements – EPA’s Vessel General Permit and MARPOL Annex VI.”

ECA Requirements

All vessels subject to MARPOL operating within the North American ECA, with limited exceptions, will be required to use fuel oil with a sulfur limit not exceeding 1.00% (10,000 ppm). In the alternative, vessels may install and use equivalent methods that are approved by its flag State in accordance with MARPOL Annex VI Regulation 4 and 40 C.F.R. § 1043.55, such as an exhaust gas cleaning device. On January 1, 2015, the sulfur limit will be further reduced to 0.10% (1,000 ppm).

In addition, marine diesel engines on vessels constructed on or after January 1, 2016 will be required to have Tier III NOx after-treatment controls when operating within an ECA. The after-treatment controls must meet a NOx emission limit of 3.4 grams per kilowatt hour for engines operating below 130 revolutions per minute (“rpm”) and 2.0 grams per kilowatt hour for engines operating above 2,000 rpm. Engines running between 130 and 2,000 rpm will be required to meet NOx limits on a sliding scale.

Vessels operating in the North American ECA will also be required to meet certain requirements to demonstrate compliance with ECA standards, including:

• Bunker delivery notes on vessels 400 gross tons or more;
• Representative fuel oil samples, taken at the time of delivery;
• Written fuel changeover procedures establishing how and when fuel oil changeover is to be done to comply with ECA requirements; and
• A fuel changeover logbook, which includes the date, time, and position of the ship when the changeover is completed, as well as the volume of compliant fuel oil in each tank.

Coast Guard/EPA Enforcement

On June 27, 2011, the U.S. Coast Guard and EPA entered into a Memorandum of Understanding (“MOU”) setting forth the terms by which the Coast Guard and EPA will cooperate in connection with compliance and enforcement of MARPOL Annex VI, as implemented by APPS. Both the Coast Guard and EPA have the authority and responsibility under APPS for fuel oil quality and availability. The MOU provides that EPA will verify compliance with fuel oil availability and quality and maintain a register of local fuel oil suppliers. The Coast Guard will examine bunker delivery notes and records during its routine port State control inspections. The two agencies will share information about inspections, examinations, and investigations. In addition, EPA may, either on its own or at the Coast Guard’s request, attend or assist with flag State and port State control inspections. When a violation is suspected, the agency with the relevant expertise will investigate. The Coast Guard and EPA must mutually agree on which agency will initiate enforcement action.

Also on June 27, 2011 the Coast Guard and EPA issued a joint letter to industry as a reminder of MARPOL Annex VI and ECA requirements. The letter explains that violation of such requirements may result in criminal liability for knowing violations or a civil penalty of up to $25,000 per day of violation, with each day the violation continues constituting a separate offense. The Coast Guard previously published CG-543 Policy Letter 09-01 (February 4, 2009), on MARPOL Annex VI compliance guidelines.

Further information regarding the MOU may be found in our previous advisory: “Update on Compliance Requirements—EPA’s Vessel General Permit and MARPOL Annex VI.”

ECA Compliant Fuel Oil Availability

EPA expects that ECA compliant fuel oil will be available from fuel oil suppliers serving vessels that operate in the North American ECA, particularly as it has reportedly been available for vessels operating in North Sea and Baltic ECAs since July 2010. Recognizing, however, that it is possible some vessels may not be able to obtain ECA compliant fuel prior to entering the North American ECA, EPA published “Interim Guidance on the Non-Availability of Compliant Fuel Oil for the North American Emission Control Area” on June 26, 2012 to describe how vessels can make fuel oil non-availability notifications. The guidance may be found at:

Best Efforts

Vessels are required to make “best efforts” to obtain ECA compliant fuel prior to entering the North American ECA. When it is expected that a vessel will enter the North American ECA, the vessel owners and operators must take care in voyage planning to ensure that reasonable efforts are made to obtain ECA compliant fuel oil at every port along the intended voyage. Vessels are not required to deviate from their intended voyage to obtain ECA compliant fuel oil. However, having to change berths or anchor within a port to receive compliant fuel oil is not considered a deviation.

EPA also does not require vessels to use a fuel oil with viscosity less than 11 centistokes to meet the sulfur standards. Although EPA stated that it does “expect distillate fuels of various grades to be used as blending agents” to produce an ECA compliant fuel oil blend, EPA does not require vessels to blend their own ECA compliant fuel oil blend onboard. Thus, owners and operators are not expected to purchase distillate fuel to meet ECA fuel oil requirements.

If a vessel is unable to obtain ECA compliant fuel oil prior to entering the North American ECA, it must ensure that it obtains the lowest sulfur fuel oil available prior to entering the North American ECA. It must also obtain compliant fuel oil at the first U.S. port-of-call at which it is available in a sufficient quantity to allow it to complete its voyage in the North American ECA.

Furthermore, if the vessel, owner, or operator is aware that the vessel will be returning to the North American ECA in the future and likely will not be able to obtain ECA compliant fuel oil prior to re-entering, the vessel must obtain a sufficient quantity of compliant fuel oil from a U.S. port-of-call to make the return trip.

Unavailability

If, despite best efforts, a vessel is unable to obtain ECA compliant fuel oil prior to entering the North American ECA, the owner or operator of the vessel must notify the Coast Guard and the vessel’s flag Administration before entering the North American ECA.

Notification should be made to the Coast Guard Sector at the vessel’s U.S. port of destination. Notification should also be made to EPA via e-mail at marine-eca@epa.gov

In addition, the owner or operator should submit a Fuel Oil Non-Availability Report as soon as it becomes aware that it will not be able to procure and use ECA compliant fuel oil in the North American ECA, but in any event no later than 96 hours prior to entering the North American ECA. Fuel Oil Non-Availability Reports are not required; however, they should be submitted if the owner or operator wants the EPA to consider its efforts to obtain ECA compliant fuel when determining what enforcement action to take in response to a violation. The filing of a Fuel Oil Non-Availability Report does not mean a vessel is deemed in compliance with MARPOL Annex VI. However, the EPA will review the information provided in the report and will consider the following in determining whether to impose a penalty:

• Whether the sulfur content of the fuel used was the lowest sulfur available at the time of purchase and along the vessel’s intended voyage;
• Whether the vessel obtained ECA compliant fuel oil at its first port call in the United States and continued to use ECA compliant fuel oil for the remainder of its voyage in the North American ECA;
• How many Fuel Oil Non-Availability Reports have been previously filed;
• Whether owners or operators of other vessels on similar voyages submitted Fuel Oil Non-Availability Reports; and
• Any other relevant factors.

The EPA is in the process of creating an electronic system to receive Fuel Oil Non-Availability Reports. Prior to implementation of an electronic system, the reports should be sent to marine-eca@epa.gov.

Conclusion

Owners and operators with vessels that operate in the North American ECA should review the MARPOL Annex VI requirements and applicable Coast Guard and EPA compliance guidelines, including the recently published guidance on ECA compliant fuel oil availability, to help ensure compliance in light of the August 1, 2012 enforcement date.

Notice: The purpose of this Advisory is to identify select developments that may be of interest to readers. The information contained herein is abridged and ¬summarized from various sources, the accuracy and completeness of which cannot be assured. The Advisory should not be construed as legal advice or opinion, and is not a substitute for the advice of counsel.