USCG preparing for MEPC.59

Dennis L. Bryant sent me the link to the proposed Shipping Coordinating Meeting in Washington, DC on June 26, 2009.

The purpose of the meeting is to prepare for the 59th session of the International Maritime Organization (IMO) Marine Environment Protection Committee (MEPC.59) to be held at IMO's London head quarters July 13-17, 2009. One of the agenda items of the June 26 meeting is the ECA proposal, which the USA submitted jointly with Canada.

Ecological is economical, in oily water

In the engine room bilge water and oils collect. The more leaks and drips there are, the more bilge water is accumulated. The more bilge water there is, the more complex it tends to be and the more difficult it is to get it overboard. The more bilge water there is, the more time has to be allotted to bilge water separation, more parts and consumables tend to be used as well. In the worst case there is too much bilge water and not enough time to process it. In this case the crew may be tempted to "increase the efficiency" of the bilge separator by by-passing the oil content meter or the system altogether. In other words, lax (costly) shipboard practices create large quantities of bilge water, which are expensive to remove. Managing bilge water by following best practices and the "Integrated Bilge Water Treatment System", as per IMO guidelines results in a twofold cost saving. Managing the inflows tends to reduce waste, reduced quantities reduce time and wear on equipment as well as the frequency to discharge waste oil to shore. Green Marine provides an excellent guide. A company that operates at level 4 in "oily water" limits oily water quantities and is cost effective in bilge water processing. At level 4 the company is environmentally friendly and operates economically.

Prevention of air pollution from ships

IMO Document MEPC 59/INF.15 submitted by the United States informs the Committee of a recently-released, important study that is directly pertinent to the Committee's work on prevention of air pollution from ships. The study is the first to provide a global estimate of maritime shipping's total contribution to air particle pollution based on direct measurements of emissions from ships. The results confirm that ships contribute a significant amount of air pollution, including almost half as much particulate matter pollutants as the total amount released by the world's on-road vehicles, and thus adversely affects local air quality and human health.

If the United States apply the same standard to particulate emissions as Canada, then dust pollution from paved and unpaved roads are considered "open source pollution", meaning they are not road transport related.

2006 Environment Canada data gives the following totals for particulate matter:

• Marine transportation: 10,404.9 tons
• H.D diesel vehicles: 6,771.9 tons
• Off-road diesel: 35,738.6 tons
• Tire wear and brakes: 5,051.7 tons
  
• Dust from paved roads: 3,248,367.6 tons
• Dust from unpaved roads: 8,202,814.4 tons

Joint ECA submission USA/Canada

The United States submitted a document in support of the proposal to designate an Emission Control Area for specific portions of the coastal waters of the United States and Canada. It provides references and other information considered in developing the proposal.

The document is listed MEPC 59/INF.13, dated April 9, 2009. It was posted on the IMO Documents Website May 11, 2009

Hercules Beta

Hercules Beta is the second leg of a joint research effort between MAN- Diesel and Wartsila. The project's aim is to develop future generations of optimally efficient and clean marine diesel engines; i.e. reduce marine diesel engine fuel consumption by 10% and improve the efficiency of the marine diesel propulsion system to more than 60%, thereby significantly reducing CO2 emissions. A further aim of the project is to target ultra-low exhaust emissions by eliminating 70% of NOx and 50% of particulates from marine engines by 2020.

More on climate change

I have a hard time accepting an East Coast ECA, while excluding the Arctic, because the Arctic is the most vulnerable environment with the least buffering. It is the region most affected by climate change already, as average temperature changes there are outpacing all other regions on the globe.

The World Health Organization (WHO) is concerned about the fate of low lying coastal areas and low lying Pacific Islands, which are already seriously affected by rising sea levels. In their document titled "Health and Environment: Managing the Linkages for Sustainable Development", WHO provides “A Tool Kit for Decision Makers”. WHO discuss major environmental risk factors with quantifiable disease impacts, attributing 150,000 excess deaths annually to climate change.

James E. Hansen has written many articles on the subject of air pollution. In his 2003 piece "As pure as snow" he explains the effect dirt on snow. When I saw the ECA submission I asked him whether we should be concerned about PM emissions from more ships sailing into Churchill. Two of his colleagues came back and concurred that we should be concerned. One of them, Mark Flanner in his e-mail reply said "I am currently working with some folks here at NCAR [National Center for Atmospheric Research, Boulder, Colorado] and NOAA [National Oceanographic and Atmospheric Administration] to quantify impacts on sea-ice of future Arctic shipping. Also, shipping emission scenarios (including Arctic sources) are currently being drawn-up for inclusion in studies for the next IPCC [Intergovernmental Panel on Climate Change] report." – These are people who know; maybe Canada should listen to science and consider the WHO concerns about climate change. Maybe we should look for an ECA solution that doesn't divert traffic into the Arctic?

Bill C-16

My first piece in Canadian Sailings was on whether a Canadian owner should be concerned about the approach by the Dept. of Justice in the USA in regards to fraudulent entries in the Oil Record Book (ORB). Under US law, presenting an ORB with untrue entries to a Coast Guard inspector is a criminal offense, regardless of where and when these entries were made in the ORB. You present such an ORB and you have defrauded the USA.

A company facing the courts in such a situation is typically assessed a few million dollars in fines, the company is put on 5 year probation and is required to implement an Environmental Compliance Plan (ECP) for all the ships in its fleet or under management.This ECP covers all waste streams and usually requires annual auditing of 75% of the fleet. We were involved with a couple of cruise lines and their implementation of the ECP. Their shipboard audits were carried out by third parties (typically marine consultants) in 3-5 day cruises by a team of 2-3 persons, at considerable cost.

Bill C-16 seems to introduce the above mentioned method in dealing with pollution offenders. By adding "directing the offender to implement an environmental management system that meets a recognized Canadian or international standard specified by the court" in paragraph 66 (1)(c) the company will have to implement a court imposed ECP.

We find a company is better served by implementing a voluntary, vigorously managed ECP. This helps to demonstrate due diligence and thereby helps to shield the corporation, its managers and directors from the implied liabilities in paragraphs 50 and 51 of the proposed bill-16.

CMAC meetings

I sat in on two days meetings on the environmental side of this spring’s CMAC meeting in Ottawa, April 28&29.

In the Ballast Water working group a comment was made that no ballast Water Treatment System had been tested, specifically in fresh water. The assumption was voiced that therefore reliable performance of such systems was not guaranteed. RWO have submitted their application for approval and it is expected that approval will be issued at the July MEPC session.

• The system was tested in Bremen, Germany, a fresh water port, and it performed as expected.

In the Air Emissions working group, Environment Canada summarized the benefits from an ECA, referring to some 159 lives saved with total health benefits of $ 900 Million per annum.

The health problems are, to a large degree, caused by particulate matter. The latest Environment Canada statistic shows PM from marine transport at 10,404.9t out of 18,377,707.2t for all of Canada. Marine represents 0.056% of the total. Dust from paved and unpaved roads (generated primarily by vehicle traffic) is about 11,450,000t or 62.3%, which is considered an “open source”. PM totals for vehicles including tire break lining wear (but without open sources) comes to about 13,800t, which is about the same as marine transport. What I see is that the ECA proposal addresses the proverbial "straw that broke the camel's back" in pollution, ignoring the potential increase in greenhouse gas emissions from a modal shift and also ignoring the increased PM emissions for road and rail traffic. With the ECA submission, we address a narrow emission sector and ignore the climate changing millions of tons of PM, which accelerate the shrinking of snow and ice cover.

Environment Canada gives some interesting graphs on Canadian pollution, which may provide some additional reference as to how skewed the ECA proposal is.

At the standing committee on the environment, Environment gave a presentation on the current Bill C-16. Below is the link to the bill, and underneath a link to an opinion by one of the marine lawyers.

Bill C-16

Osler opinion

If the industry was concerned about Bill-15, the amendment to the migratory bird act, I feel 16 indicates that this is Bill 15 on steroids.