R

oyal

B

elgian

S

hipowners

A

ssociation (RBSA)

MISSION :     Protect common interests of all shipowners and ships’ managers established in Belgium.

Operational support and clarification concerning:     fiscal social

environmental

and maritime legislation.

Promotion of the sector as attractive employer Close cooperation with all relevant national and international parties.

VISION :

As Belgium’s maritime knowledge centre, the RBSA hopes to play a pioneering role in the continuing expansion and long-term growth of the sector of international maritime transport by sea.

In its role of forward-looking opinion maker, the RBSA hopes to serve as the ideal discussion partner for all parties concerned.

RBSA 23 MEMBERS

EXMAR

• TRANSPORT LPG en LNG • REGASIFICATION

URS

• TUGBOATS

DELPHIS

• CONTAINERSCHIPS • ONE OF THE STRONGEST PLAYERS IN SHORT SEA SHIPPING

EURONAV

• TRANSPORT CRUDE OIL

BOCIMAR

• TRANSPORT DRY BULK

FASTLINES

• SSS • TRADES IN BALTIC SEA

RBSA MEMBERS ACTIVE WORLDWIDE

RBSA member of...

EUROPEAN COMMUNITY OF SHIPOWNERS’ ASSOCIATION

ECSA

(BRUSSELS)

INTERNATIONAL CHAMBER OF SHIPPING

ICS

(LONDON)

RBSA

BOARD OF DIRECTORS COMMITTEES (on technical, social, legal issues)

MEMBERS FEDERAL ADMINISTRATION

ENVIRONMENTAL TOPICS:

From 2016 ?

2015 – 2020 – 2025 : SULPHUR DILEMMA

7 CHANGE TO MGO

Run full time on Marine Gas Oil (MGO).

+ Convenient No change over

EXISTING SHIPS

High operating Cost

LNG ( other low flashpoint fuels, e.g. Methanol?)

+ A solution which also reduces NO x and particulates

NEW BUILDS (in general) (methanol – option for existing ships)

Investment cost LNG availability

USE SCRUBBERS

Install an exhaust gas cleaning system (scrubber).

+ Works with high sulphur fuel oil fuel oil price difference between low sulphur fuel oil and high sulphur fuel oil RELIABILITY !

IMPACT ON CO2 EMISSIONS ( MGO : life cycle ! LNG : methane slip ! SCRUBBER : 1-3% additional fuel consumption !

IMO Marine Environmental Protection Committee (MEPC) dominated by the GHG Debate

RELATIVE - ABSOLUTE

“shipping is the most energy-efficient transport mode”

IMO GHG Study of 2009: GHG emissions from international shipping in 2007 is estimated about 870 Million tones (consumption of 270 Million tones fuel). About 2.7% of global emissions of CO2.

270 Mio tonnes of fuel = 870 Mio tonnes of CO2 !

(2.7% = CO2 emissions from Germany in 2007)

CO

2

– WHAT IMO HAS DONE SO FAR

 

Responsilibity given to IMO from UNFCCC to find a solution

• • •

Since 2005:

United Nations Framework Convention on Climate Change E

nergy

E

fficiency

O

perational

I

ndicator = EEOI



calculated from actual operational parameters (fuel, cargo, distance) from existing ships E

nergy

E

fficiency

D

esign

I

ndex = EEDI



calculated from technical desings charachteristics (ONLY for new builds !)

Market Based Instruments MBIs (work in progress....???)

MBMs EEOI + EEDI +

FOCUS ON EXISTING SHIPS IMO EEDI and SEEMP not engough...!

Monitoring

Reporting

Verification

1. E NERGY E FFICIENCY O PERATIONAL I NDICATOR (EEOI): EXISTING SHIPS !

=Measure for the energy efficiency of an EXISTING SHIP , calculated from real operational data :

• • • Fuel consumption (multiplied by a carbon factor) Load Distance

FOR ALL VOAYGES DURING A YEAR

Available in voyage/noon report (commercially sensitity information, especially the cargo) !

THE NUMBERS TELL THE TALE...

EEOI STUDY (publication 2009)

E

NERGY

E

FFICIENCY

O

PERATIONAL

I

NDICATOR - RESULTS

EEOI of 43 Belgian flagged ships (4 ship types)

    

It is very difficult to determine what causes the variation in the EEOI (too much information in one index). Operational variations mainly



caused by:

cargo transported efficiency of the ships (engine condition, hull and propeller fouling, etc...) variations in speed !

weather and currents errors in measurement and registration ….

EEOI very much depends on the economical situation ! Not a good indication of the energy-efficiency of the ship while at sea .

EEOI STUDY 2009: PROPOSAL TO FINE-TUNE THE EEOI

20 10 0 60 50 40 30 Bulk dry Port EEOI Ballast EEOI Cargo EEOI (unit =g.CO2) (unit =g.CO2/nm) Crude oil tanker General cargo LNG tanker LPG tanker

Might be interesting if the owner pays for the fuel !

2. E

NERGY

E

FFICIENCY

D

ESIGN

I

NDEX (EEDI): NEW BUILDS !

(g.CO2/ton.nm) EEDI: MEASURE FOR THE ENERGY-EFFICIENCY OF NEW BUILD SHIPS CALCULTED FROM TECHNICAL PARAMETERS The Energy Efficiency Design Index (EEDI) is mandatory for new ships (since 2013). New chapter added to MARPOL Annex VI !

EEDI REFERENCE LINES (BENCHMARK)

Reduction factors will be applied in different phases starting from 01/01/2013.

3. S

HIP

E

NERGY

E

FFICIENCY

M

ANAGEMENT

P

LAN (SEEMP) NEW BUILD AND EXISTING SHIPS

mandatory for ships over 400 GT at the first renewal or intermediate survey after this 01/01/2013

.

EEDI and SEEMP enough ?

NEXT STEPS...

IMO – UNTILL NOW NO PROGRESS ON EXISTING SHIPS

IMO :

   

US proposal

focusing on data collection !

OPPORTUNITY TO TURN THE ATTENTION FROM THE POLITICAL DEBATE ON MARKET BASED MEASURES (Emission trading – tax on fuel)

RBSA one of the strongest proponent to be more active ON DATA COLLECTION !

Group of flag states looking into what can be done for existing ships (US proposal forms the basis of the discussion).

During MEPC 64 (Okt. ) 2013: Press release from the European Commission MRV NECESSARY STARTING POINT TO ADDRESS MARITIME EMISSIONS



At EU level, we consider several options, including market-based mechanisms. A simple, robust and globally-feasible approach towards setting a system for monitoring, reporting and verification of emissions based on fuel consumption is the necessary starting point. This will help make progress at global level and feed into the IMO process. It's therefore our joint intention to pursue such a monitoring, reporting and verification system in early 2013. At the same time, we will continue the debate with stakeholders on which measure can successfully address the EU's greenhouse gas reduction objectives.



The shipping industry itself is best placed to take the lead in delivering fast and effective greenhouse gas emission reductions – thereby cutting cost and making the sector fit for the future. The Commission is ready to play its part, in the EU and at IMO level.

CO

2

– BARRIERS (Inertia ?)

UPTAKE OF ENERGY EFFICIENT MEASURES DEPENDS ON MANY VARIABLES:



Type and age of ship



Economy



Political developments



Speculation on future technological improvements



FUEL PRICE



SPLIT INCENTIVE

source: Deltamarin

SURVEY REPORT – MARKET BARRIERS (UNIVERSITY COLLEGE OF LONDON) Study EC Directorate General Climate (2012): “We project that speed reduction can reduce marine GHG emissions by over one third by 2020 (at the given fuel cost and fully compensatory charter rates)“

EUROPEAN COMMISSION M ONITORING, R EPORTING, V ERIFICATION (MRV)

       On 28 June 2013 the European Commission published a proposal for a Regulation on monitoring, Reporting and verification (MRV) of CO2 emissions

from ships over 5,000 GT.

The regulation will apply to ships traveling to, from and between EU ports. The purpose of the regulation is

primarily to obtain reliable information on greenhouse gas emissions from shipping.

From August 31, 2017, the responsible party (owner of the “Document of Compliance ") must submit a monitoring plan to an independent verifier. This monitoring plan must list the emission sources (number and power of main engines and auxiliary engines, boilers and inert gas generators) on board.

This monitoring plan must also list the procedures for the monitoring of fuel consumption. The DOC holder is free to choose how to monitor the fuel consumption (BDN, flow meters, direct emissions monitoring) From 30 April 2019, the parties will need to monitor the activities (distance travelled, CO2 emitted, time spend at sea, cargo carried, transport word) of the previous calendar year (and calculate the EEOI)

and submit a report to a verifier

.

If the report meets the requirements laid down in the Regulation, the party receives a "Document of Compliance“ .

PUBLICATION OF INFORMATION !

“The proposed EU system of MRV for shipping emissions is designed to contribute to building an international system. First steps in this direction have already been taken at the IMO, with active support from the EU and partner countries”

PUBLICATION OF INFORMATION

POSITION RBSA ON MRV



LEGAL IMPLICATIONS:

Is it legally permitted under the port station control regime for countries to collect data that refer to activities outside the territorial water. The EU MRV proposal must not evolve to a proposal focusing only on intra European routes (ref. EU-ETS aviation)!



EARLY MOVERS

: The last few years our members have been further improving the energy performance of their existing ships. Any MRV proposal (and consequential further measures) must not penalize early movers.



DIFFERENTIATION BETWEEN SHIP TYPES

: Monitoring of fuel consumption data on a per voyage basis might be easier for some ship types (e.g. bulkers, tankers, containerships) than others (ro-ro, ro-pax). Moreover, our EEOI 2009 study showed that the definition of a voyage is not that straightforward. The current proposal does not take into consideration the specificities of the shipping sector.



DIFFERENTIATION BETWEEN TRADES

: It is commonly known that for liner shipping (fixed trades and fixed ports) it will be much easier to determine indicators for energy performance than for tramp shipping (no fixed routeing and available at short notice). As a matter of fact the liner shipping industry has under the umbrella of the Clean Cargo Working Group (CCWG) developed benchmarks for containership trade lanes. The commercial differences between tramp and liner shipping will need serious consideration during the co-decision process.



PUBLICATION OF INFORMATION (art 21):

A study from DG Clima on Market Barriers (Madox, 2012) stated:

commercial implications of the publication of data on fuel consumption could therefore be considerable

The commercial mechanisms in the marine industry have created a “split incentive” issue in which the party responsible for implementing a marine GHG solution (i.e., the ship owner) may not realise the financial benefits of the solution. The

ANALYSIS OF THE ENERGY PERFORMANCE OF THE BELGIAN MERCHANT FLEET – FOLLOW UP STUDY 2013 !

  In the context of the discussions on the monitoring of fuel consumption the Board of the RBSA decided in March 21, 2013 to repeat the exercise that was done in 2009.

WHY ?

“The high fuel price and rising environmental awareness combined with the ever recurring overcapacity within the shipping industry has indisputably had a huge impact on the energy management policy of shipping companies. It is time for the

international shipping community to demonstrate the exact amount of GHG emissions that have been reduced through measures such as slow steaming, propeller adjustments, and new generation of hull coatings ” (RBSA, position paper onMRV).

WHAT ?

The purpose of a follow-up study would be to make a comparison between the EEOI for the year 2007 and the following years not only for all vessels that were studied initially in 2009 (41 ships under the Belgian flag) but all Belgian owned ships and to try to identify tendencies, taking e.g. into account the economic recession. Possibly a software program can be developed that will allow to centralize the data and to assess those data to the formulas that will be

developed within IMO and at the European level.

2 PHASES

PHASE I: data collection and input – 6 months starting from july 2013 PHASE II: analysis – 6 months starting from Q1 2014

THANK YOU !

Ludovic Laffineur Environmental Policy Advisor Royal Belgian Shiponwers Association [email protected]

www.brv.be