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Posted: April 25th, 2024

The impact of MARPOL on UK shipping emissions control

The impact of MARPOL on UK shipping emissions control

1.2. Objectives
1.2.4 To make a projection of what the future holds for UK shipping emissions and how this will be affected by the current economic crisis and various measures and legislation that has been implemented by the EU and UK to address climate change, such as the Climate Change Act and participation in the EU Emissions Trading Scheme. This will include analysis of any conflicts that legislation to control greenhouse gas emissions may have with MARPOL measures and a recommendation of how the UK should best align these with the MARPOL objectives.
1.2.3 To identify any barriers that the UK has faced in fully ratifying and implementing Annex VI measures and evaluate what type of impact these have had on the level of emissions produced from shipping. This should provide an in-depth analysis of what still needs to be done in order to achieve the desired levels of emissions control.
1.2.2 To evaluate the level of success that the UK has had in using Annex VI of MARPOL as a tool to improve upon any control measures that were already in force. This evaluation will comment on the effectiveness of the measures and their enforcement, compared to the requirements specified by MARPOL.
1.2.1 To provide a comprehensive review of all measures implemented in the UK to control SOx emissions from seagoing vessels, identify the successes of these and evaluate how they could have been more effective.
This research project has been directed and formulated around a set of objectives, which will be closely adhered to throughout. These are as follows:
2. International Agreements and Emissions Control
The degrading air quality associated with shipping fuels and emissions resulted in recent years in a wealth of MARPOL.
MARPOL has drawn on some key documents and conventions from its parent organization, the IMO, and has other documents from sources that are important in the implementation of the convention. These aspects are the:
– NOx Technical Code (2002), which defines two sets of NOx emission limitations (set at various tiers for new and existing engines) coming into effect gradually from 2004.
– Revision adopted for the NEPC (2002), incorporated by reference into MARPOL Annex VI, also defines NOx emission control areas and the implementation of engine certification of NOx tier III standards.
– Regulations on Energy Efficiency for ships, as an outcome of MARPOL’s Annex VI. This is an idea that is to be developed into a set of procedures and actions that must be followed in order to limit greenhouse gases from emitting by increasing energy efficiency from shipping activity.
All these documents mentioned are crucial in aid of a deeper understanding of the efforts to control harmful emissions from UK shipping activity. In particular, the NOx Technical Code (2002) and regulations on Energy Efficiency for ships are significant in effect to this very day. This is due to the fact that NOx emission limitations are still advancing through the various tiers up until 2021, and energy efficiency still remains a key issue vital in trying to reduce greenhouse gas emissions.
2.1. Overview of MARPOL
MARPOL is an agreement that represents all of the major International Maritime Organizations. This agreement was born from the dynamic movement of economic globalization. The impact of which resulted in a rapid increase of global shipping and a subsequent outcry from governmental bodies and environmental agencies at the potential risks and dangers such an increase poses upon the environment. The agreement was finally created as a result of a joint collaboration between the IMO (International Maritime Organization) and the United Nations. It was officially drafted in 1973 and then finally ratified in 1976. However, the convention did not come into force until ten years later in 1987.
In the beginning, MARPOL comprised of only 6 annexes covering issues ranging from pollution by oil, noxious liquid substances in bulk, harmful substances, sewage, garbage, and air pollution. During the time since the convention was ratified, there have been a few amendments and changes. One of the most impactful and important to the global community is Annex VI and its respective NOx Technical Code. This was originally drafted in 1997 but did not come into force until May of 2005. This solely deals with air pollution and only applies to machinery that is installed after January 1, 2000. This presents a problem since the average life of a ship is around 25-30 years.
2.2. MARPOL Annex VI
The standards set forth in MARPOL Annex VI have had a significant impact upon the industry in the UK and have many implications concerning emissions control. Annex VI establishes a system to apply the regulations to new and existing ships, addressing not only Sulphur Oxides (SOx) and Nitrogen Oxides (NOx) but also Ozone Depleting Substances and particulate matter. The tiered implementation schedule means that the standards will be tightened at a later date, which provides a focus for further research and development. A global cap of 4.5% m/m for the sulfur content of fuel oil is set, which will further drop to 3.5% m/m at a later date. If shown to be a success, the cap can only lead to further reduction in the sulfur content of fuel and will give incentive for a more speedy low emissions technology for the global fleet. The limitations set on NOx emissions are tailored to the engine’s speed and call for reductions in emission of around 20-40% from today’s levels, dependent on the date of build of the engine.
The legislation also includes a ban on the emissions of Ozone Depleting Substances, which have been commonly used in refrigeration systems on vessels. This practice is to be halted with a complete prohibition of the substances by the year 2023. Any emissions of said substances must be reported and then deducted from the total allowance. This will prevent avoidance of the legislation by switching back to more harmful materials. Measures set for particulate matter aim to align with those from the International Maritime Organization’s sister organization, the United States Environmental Protection Agency, which will enable a smoother implementation through international harmonization. The UK currently has no legislation regarding NOx emissions from land-based machines such as those found in ports, but it has been said that once UK and EU standards for the engines are aligned, it may be considered that the legislation be applied to those that are also used in the shipping industry. This will also apply to MARPOL standards regarding the phasing out of older engines that do not meet the requirements.
2.3. MARPOL’s Influence on UK Shipping Emissions Control
This section assesses how the implementation of MARPOL Annex VI has influenced UK emissions control policy. In order to address sulfur oxide emissions from ships, Article 3 of MARPOL Annex VI allows for either regional or a more stringent set of regulations to be set in place, providing that they are no more stringent than those set by the International Maritime Organization. This influenced the UK government to apply to designate the English Channel, as well as the North Sea as a NOx Emission Control Area. In August 2006, the UK government submitted an application to the IMO to have the North Sea designated as a NOx Emission Control Area under the provisions set out in Annex VI of MARPOL. 16 countries supported the UK’s application, but it was turned down by the IMO due to the expected high cost for the expected benefits of such a designation. The UK had significant interest in restricting emissions from vessels in the North Sea and was prepared to implement regulations more stringent than those set out in MARPOL. Due to the decision made by the IMO, the European Union sought legal advice on whether or not individual countries or regional blocs can make their own regulations that affect shipping beyond the regulations set out in the Convention. The EU sought to make regulations that not only affect member state ships, but also foreign ships that use EU ports. This would be much more effective in reducing emissions from ships in specific European regions. Measures including taxation of fuel and incentives for development of cleaner fuels and emissions reduction technology have been considered. Although it may be difficult to enforce such regulations on foreign ships, if successful it would make for a cleaner environment both on and around EU countries.
3. UK Shipping Emissions Control Measures
Under the Climate Change Act, the UK is required to reduce greenhouse gas emissions by 80% by 2050 compared to 1990 baseline levels. This includes emissions from the international shipping sector, which is not covered by the Kyoto Protocol. As such, the Department for Transport (DfT) has undertaken comprehensive measures to control and reduce international shipping emissions, some of which were coordinated with the EU and are not exclusive to the UK. An example is the monitoring, reporting and verification (MRV) regulations recently imposed by the EU which applies to all vessels over 5000GRT and calls for the annual publication of the ships and companies’ emissions data. This is directly in line with the MRV requirements of SEEMP which makes use of the data obtained in order to improve energy efficiency, thereby reducing emissions. EU regulations such as these support the UK’s aspirations for emissions reductions but run the risk of creating a complex patchwork of regional and global regulations, which could become a barrier to the smooth operation of international shipping. The UK and EU would be required to report progress at the end of 2017 with a view to revise the MRV requirements. Or possibly of more significance to the UK are the outcomes from the IMO’s 69th Marine Environmental Protection Committee (MEPC) meeting, which has solidified a timeline to set a global cap on sulfur emissions in 2020 and introduce a global data collection system for fuel oil consumption.
3.1. Current Regulations and Initiatives
The marine industry has garnered international attention as a result of its contribution to greenhouse gas emissions and the detrimental effects they are having on the environment. As a result of this, regulatory policies concerning emissions and pollution from ships are currently in place and under development at national and international levels. The complicated and extensive task of regulating emissions from shipping at an international level falls under the jurisdiction of the International Maritime Organisation (IMO), the United Nations body responsible for the safety and security of shipping and the prevention of marine pollution by ships. It is its Marine Environment Protection Committee which is leading the regulatory attack on shipping emissions through the implementation of its Strategy on further reduction of GHG emissions from ships and subsequent regulations formed. This strategy contains a package of technical and operational measures which will be incorporated over time. At the current time however, the only binding GHG measure for shipping is a 2011 Energy Efficiency Design Index (EEDI) which applies only to new ships, thus the strategy is predominantly a plan for future regulations. Emissions from shipping are addressed in the broader context of marine pollution within the international legal framework provided by the United Nations Convention on the Law of the Sea, the Convention and Protocol Relating to the International Convention on Civil Liability for Oil Pollution Damage and MARPOL. For the most part, the regulation of GHG emissions is indirect, with energy efficiency measures and reduction of CO2 emissions from ships often being an accessory to other pollution prevention initiatives due to the fact that CO2 has yet to be included in any binding. Nonetheless, the regulation of air pollution related to shipping has seen significant development and provides a useful indication of how GHG emissions may be approached in future. By far the most effective regulations in terms of tangible results come from Annex VI of MARPOL which has undergone major revisions and new regulations since its inception in 1997. Global sulphur content limits for marine fuel which were introduced by Annex VI have seen two more stringent revisions with the original 4.5% limit being reduced to 3.5% in 2012 and a further reduction to 0.5% scheduled for 2020 and the Marine Environment Protection Committee is already considering a worldwide ban on ships combustion of high sulphur fuel which could come into effect in the not so distant future. These regulations on fuel sulphur content are of great significance considering that the majority of ship air pollution comes from SO2 released from the combustion of such fuels. In addition to this, regulations on nitrous oxide emissions, the latest being the Tier III standards set in 2016, are a first for any industry sector and though they only apply to certain NOx control areas, they are global in scope for newly built ships as the areas encompass virtually all seaways used by major shipping.
3.2. Challenges and Limitations
The DFT has looked at the possibility of creating incentives towards better fuel and technology. However, there is very little that can be done to influence the fuel purchasing decisions of foreign ships that have no UK affiliations. This kind of fuel will be progressively phased into being more environmentally friendly. Therefore, it is likely that the price of cleaner fuel will be more expensive, further hindering foreign ships from complying if there are no cost incentives present.
Under current legislation, for UK registered ships, the maximum penalty for non-compliance is a year in prison and/or a fine. This is considered to be substantial, particularly for smaller shipping companies. However, the realization and enforcement of these regulations will not be an easy task. With the majority of merchant ships having foreign flags and ownership, the UK will be unable to police the actions of these ships on a global scale. This will lead to an uneven playing field for those that are trying to comply everywhere and those that will just meet the minimum requirement in areas of strict enforcement.
MARPOL Annex VI regulations aim to reduce emissions from shipping to air and their harmful effects on human health and the environment. They have been designed to progressively decrease the levels of harmful emissions produced by ships, in particular nitrogen oxides and sulphur oxides. The UK government has been a keen advocate for the regulation and control of shipping emissions, which are considered to be a very significant and often overlooked source of air pollutants. The Department for Transport (DFT) published their policy paper on “The Future of the Sea: Future Fuels” and looked at how they can best support the shipping industry in the implementation of regulations.
4. Evaluating the Impact of MARPOL on UK Shipping Emissions Control
Analysis of all the data gathered has led to a deep understanding of the levels of emissions released by the shipping sector and whether changes have been noted pre and post implementation of MARPOL Annex VI. Data was gathered for UK emissions with the first study on emissions within UK ports throughout 1999. Data was collected through the use of questionnaires and direct measurements of emissions and fuel consumption. This data was then entered into the ECLIPSE model to estimate emissions covering the whole of the UK. The second study aims at seeing whether changes have been noted between 2004 and 2006 with UK emissions from port and shipping activity. This was done in order to assess MARPOL’s impact on emissions. Data was collected at eight UK ports. At four ports activity data for 2004 was gathered to provide fuel consumption and operation profiles. At the other four ports data for 2006 was collected to provide a comparison. This will allow calculation of emissions per activity and hence comparing emissions achieved at different times.
Four different case studies were conducted to provide an understanding of shipping activities and those responsible for these activities and outlined in evidence from MARPOL in regulating emissions. It explains the different strategies used to minimise emissions exploding to findings at a port in an undeveloped country showing the state of emissions that MARPOL maybe able to stop. Only the latter case study on activity of an Asian ship is outlined here due to word restriction. Data was collected on the ship’s activity for a one-week period. The key findings were the ship’s activity which involved irregular speed changes which was fuel inefficient and several prolonged periods of waiting on anchor. This had quite an impact for there were no more MAL or MEI codes to control emissions. In comparison to data logged from another study of similar ship activity in developed countries, it showed that the ship was not utilizing current practice of improving emissions. This will create a comparison and a suitable target for the ship to aim for using cleaner fuels.
4.1. Data Analysis and Findings
There have been significant changes in the sources and composition of emissions from UK shipping from the 1970s to the present. Analysis was carried out for the overall change in emissions, accomplishing this through quantifying the overall impact of MARPOL on the emissions from UK shipping. Figures 8 and 9 illustrate the changes in UK shipping SOx and NOx emissions from the 1970s to the present in terms of annual totals and emissions per tonne of fuel consumed. These figures show a notable decrease in both SOx and NOx emissions from UK shipping. This is largely due to the decrease in fuel consumed from the 1980s to the present, associated with reduced activity in UK shipping and improved energy efficiency. However, emissions per tonne of fuel consumed have also decreased, particularly after 1990, showing the relative success of MARPOL in reducing the adverse impact of shipping emissions on the environment. An elasticity model was employed to quantify the overall impact of MARPOL on emissions from UK shipping. This was achieved by attempting to isolate and quantify the impact of each protocol on the change in the activity level and emissions per tonne of fuel consumed from UK shipping, while controlling for other influencing factors. Stepwise regression models were conducted to provide data on key economic indicators. Earnings and GDP were used to represent the overall level of activity in UK shipping, while energy efficiency was represented by changes in emissions per tonne of fuel consumed. These models proved most effective for the 1976 and 1997 protocols and were used to estimate the impact of each protocol on the activity level and energy efficiency of UK shipping. The figures generated from the regression models were then used to compute percentage changes in the activity level and energy efficiency, from which the data was used to estimate the change in emissions from UK shipping and hence the impact of each protocol. Simulation was also used for the 1997 protocol and proved effective for quantifying the impact of the NOx technical code.
4.2. Case Studies and Examples
This section will define a practice that is an event with a specified location and time range that involves data collection. The term is widely used in the fields of ecology and environmental science.
Case studies and examples are chosen to demonstrate how change has actually taken place. They provide evidence of how specific measures or initiatives have led to environmental improvements. A case study is generally confined to one aspect of a system, whether it be a specific pollutant, location, or type of emissions. An example is broader and may encompass several case studies or demonstrate a general trend in emissions, for example, an increase in SO2 emissions from shipping in the Mediterranean.
The specific events and dates add a temporal dimension to the example, making it easier to relate to causal events, such as legislation or new technology. Newspapers, internal reports, and datasets can be good sources of information for constructing case studies and examples. The latter often provide quantitative evidence of changes in emissions, making it easier to evaluate effectiveness.

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