California Contributing Editor
keith@pacmar.com
Water borne transportation is one of the most efficient known methods of transporting cargo and passengers, easily undercutting air and land transportation methods.
However, since the early 1990s, the world fleet of cargo, passenger, and maritime industry vessels has come under increased government scrutiny as serious contributors to global air pollution – especially in coastal and port-area communities.
A primary focus of this scrutiny has been the link between the fuel used to power these vessels and the harmful emissions these fuels generate when burned.
Ironically, while some of the most technologically advanced transportation vehicles in the world are ocean-going vessels, these vessels also burn some of the dirtiest fuel of any transportation sector.
According to the US Environmental Protection Agency, cargo, passenger and maritime industry vessels generate 6 percent of the nation’s annual volume of oxides of nitrogen, or NOx, 10 percent of the diesel particulate matter, or PM, and 40 percent of the oxides of sulfur, or SOx.
This has led to the creation and implementation over the past decade of numerous international, national and regional regulations that impact the choice and usage of fuel by the maritime industry.
International Efforts
In two treaties adopted in the 1970s, the United Nations developed the first comprehensive international standards on marine pollution. Known as the International Convention for the Prevention of Pollution from Ships, or MARPOL (for marine pollution), the 1973 treaty covered the discharge and handling of oil, chemical, sewage, garbage and packaged harmful substances aboard marine vessels.
In 1978, additional standards related to oil tanker design and operation were added and incorporated into the five 1973 MARPOL protocols. These are known MARPOL Annex I through V.
In 1997, the UN developed MARPOL Annex VI--the first international standards aimed at curbing harmful air pollution from the world fleet of more than 80,000 marine vessels over 400 dead weight tons. These MARPOL standards, which entered into force worldwide in May 2005, were further amended in 2005, 2008 and in 2010.
MARPOL Annex VI regulations are now accepted as the base minimum for permissible vessel fuel quality and air emissions by 136 signatory countries representing 98 percent of the world’s shipping tonnage.
The ANNEX VI regulations apply to all vessels traveling into MARPOL signatory-member waters and to all vessels flying under signatory nation flags. Even a non-signatory nation’s vessel entering the national waters of a MARPOL signatory state are required to adhere to the Annex VI regulations. In addition, Annex VI provides that vessels must also follow any national, regional or local regulations of the state whose waters they are entering, if the state’s regulations are more stringent than the international standards.
MARPOL Annex VI Regulations
MARPOL’s Annex VI, except in specific situations, does not specify the use of one marine fuel over another. Instead, the Annex VI regulations set various limits on fuel oil sulfur content, quality of fuel oil, and limits on the permissible amounts of two primary pollutants that can be emitted by vessels. This last set of regulations effectively eliminates certain fuel oils from being used because these fuel oils cannot be burned without surpassing the Annex VI emission limits.
The Annex VI regulations on fuel oil sulfur content state:
• The worldwide cap on fuel oil sulfur content is set at 4.5 percent. This will fall to 3.5 percent in 2012 and progressively to 0.5 percent in 2020.
• Within Annex VI-specified Sulfur Emission Control areas, or SECAs (Baltic, North Sea, English Channel, coasts of Canada/United States), fuel oil can contain no more than 1 percent sulfur. This falls to 0.1 percent in 2015.
• Pollution after-treatment technology, such as smokestack scrubbers, can be used on vessels in lieu of low sulfur fuel as long as the technology achieves the Annex VI goals.
The Annex VI fuel oil quality standards state:
• Fuel oil must be blends of hydrocarbons derived from petroleum refining.
• Fuel oil cannot contain inorganic acids or other added substances.
• Fuel oil must be regularly sampled by fuel oil suppliers for quality.
The Annex VI marine emission regulations cover two primary pollutants:
• Oxides of Nitrogen (NOx) – group of pollutants that are smog and acid rain precursors.
• Oxides of Sulfur (SOx) – group of pollutants that are acid rain components and linked to various respiratory illnesses.
The concentration of these exhaust gases varies depending on a vessel’s engine type, engine settings, and fuel type. However, due to the high cost of engine replacement or modification, and the economic disinclination by shipping lines to vary established running speeds and schedules, fuel type is the primary variable most often altered to meet the Annex VI regulations.
Specifically, Annex VI specifies the following levels:
- SOx levels are addressed by the fuel oil sulfur content regulations listed above.
- NOx levels are determined by engine type: Existing engines as of 2010 are required to cut NOx emissions by 15 percent to 20 percent from 2008 levels.
- New engines installed after Dec. 31, 2010 will be required to cut NOx emissions by 20 percent.
- New engines on vessels operating in SECAs must cut NOx emissions by 80 percent starting in 2016.
According to a 2008 study conducted by the ports of Long Beach and Los Angeles, There are five main types of marine fuel oil available worldwide, each consisting of various different fractions of distilled crude oil. These five types come in many different blends and grades. In various parts of the world, these five types can go by differing names, but the following names are generally recognized throughout the world:
- Residual Oil (RO): The cheapest and thickest of the marine fuels. Due to its thickness, it must be heated to flow properly. It contains high levels of pollutants and produces dark smoke when burned. Also known as heavy fuel oil.
- Intermediate Fuel Oil (IFO) 180: A mix of 98 percent of residual oil and 2 percent of thinner and more heavily refined distillate oil.
- IFO 380: A mix of 88 percent of residual oil and 12 percent of distillate oil. Due to a higher distillate content, it is more expensive than RO and IFO180.
- Marine Diesel Oil (MDO): A distillate oil with a trace of residual oil. MDO has a lower sulfur content than residual oil, IFO 180, and IFO 380. Various grades are also known as DMB and DMC.
- Marine Gas Oil (MGO): A pure distillate oil that contains the lowest sulfur content. Also known as DMA.
In the European Union, fuel oils are grouped into three main types, each based on the sulfur content.
EU Quality 1 fuel is a low-sulfur variant of MGO. EU Quality 2 is equivalent to MDO and EU Quality 3 is equivalent to the IFO grades.
Annex VI Impacts on Marine Fuel Selection
The Annex VI regulations, through the sulfur content limits, have effectively eliminated the worldwide use of residual oil fuels since 2007. Currently, the IFO varieties are the highest sulfur content fuels permissible.
Within the various Sulfur Emission Control areas, vessels cannot use IFO, DMA, DMB, or DMC fuels due to sulfur levels outside the Annex VI SECA limits.
In 2015, when new SECA sulfur limits go into effect, DMX and at least one type of low-sulfur MGO will also be barred.
In Europe, many of these fuels are already banned. Since 2008, the EU has limited sulfur content of purchased fuel to 0.1 percent – effectively barring the use of EU Quality 2 and EU Quality 3 fuels.
National and Local Marine Fuel Regulations
Above and beyond the international MARPOL standards, various nations have also adopted additional regulations that apply to marine vessel emissions or fuel.
In the United States, the federal Environmental Protection Agency is charged with the development of air emission standards.
The EPA was the primary advocate behind setting up the coasts of Canada and the United States as an Annex VI Sulfur Emission Control area. In addition, the EPA has adopted regulations that require all marine fuel produced or sold in the United States to have a sulfur content no greater than 0.1 percent, with flexibility for the Great Lakes and St. Lawrence Seaway areas.
So, while the current Annex VI sulfur levels within the Canada/U.S. are set at 1 percent, the EPA has reduced this even further by only making fuel with a content of 0.1 percent currently available within the U.S.
The California EPA also established rules limiting the use marine fuel with sulfur content above 1 percent, however this rule is currently enjoined awaiting a determination by the United States Ninth Circuit Court of Appeals.
As mentioned above, the European Union already enforces tighter rules than the Annex VI regulations, requiring the use of fuels with sulfur content no greater than 0.1 percent.
Enforcement
Worldwide, the enforcement of Annex VI regulations fall to various MARPOL-approved authorities. These are typically local agencies that have been given authority to act as agents of the U.N. in regards to Annex VI regulations.
In the United States, the United States Coast Guard ensures compliance with Annex VI and domestic emission control rules.
