Don’t delay NECAs!

Shipping will probably be the largest emitter of NOx in Europe by 2020. Photo: © pipehorse -

Delaying agreed NOx standards would have several extremely negative consequences, including increased emissions and subsequent damage to health and ecosystems.

In 2008 the International Maritime Organization (IMO) unanimously adopted a set of stricter air pollution standards for nitrogen oxides (NOx) emissions from international shipping, to be gradually introduced in different steps between 2011 and 2016.

This decision came after three years of negotiations that resulted in amendments to IMO’s MARPOL Annex VI. The agreed new global NOx standards – known as Tier II –provide only for roughly 20 per cent reductions for new ships as from 2011. More ambitious Tier III standards that require an 80 per cent reduction for new ships as from 2016 were also agreed, but they apply only in designated NOx Emission Control Areas (NECA). So far there are only two NECAs, the North American emission control area, which covers the coast of the United States and Canada out to 200 nautical miles, and the US Caribbean area.

Over the last few years, the countries surrounding the Baltic Sea and the North Sea have been preparing submissions to the IMO in a move to get these two sea areas – which are both already designated as Sulphur Emission Control Areas (SECA) – also designated as NECAs. The Baltic Sea submission was finalised last year, but a decision to submit it to the IMO has been blocked by Russia. The North Sea submission is still under preparation.

Last year, a surprise move initiated by Russia resulted in a recommendation to delay the implementation of the Tier III standards from 2016 to 2021. The adoption of this delay will be decided upon at an IMO meeting in early April.

The recommendation was adopted despite the conclusions of an IMO expert group that concluded that a variety of readily available technologies exist to achieve the Tier III standards, and therefore there is no need to delay the 2016 implementation date.

According to the Clean Shipping Coalition (CSC), accepting a delay in the Tier III standards would have several extremely negative consequences, including:

  • Damage to the environment and to the health of millions of citizens in areas that are or may be designated as NECAs;
  • Economic harm to engine and after-treatment manufacturers who have in good faith invested substantial sums to design and produce ships that will meet the Tier III standards;
  • Damage to the reputation of the IMO as a legitimate, rational and dependable regulatory body, making future negotiations at IMO more difficult and protracted, as negotiators will have no assurance that agreements made today will be respected tomorrow;
  • Damage to the reputation of the shipping industry itself, resulting from IMO backtracking and the resultant additional delay in reducing excess shipping emissions that will, for example, cause shipping to be the largest emitter of NOx in Europe by 2020;
  • In the absence of reliable international regulation, the likely proliferation of various and possible disparate national or regional regulatory requirements that will be needed to protect health and the environment in coastal areas around the world.

Similar arguments and conclusions have also been set forth in a joint submission by Canada, Denmark, Germany, Japan and the United States, in which they oppose the delay. A submission by EUROMOT, a trade group of ship engine manufacturers, confirms that the technology is available to meet the Tier III standards on schedule.

To add to the confusion, Norway and the Marshall Islands in a joint submission propose what they call a “compromise”, which is to keep the 2016 implementation date for the existing North American and Caribbean NECAs, but delay it by five years in any new NECA.

According to the CSC, this proposed compromise should be rejected, because it will jeopardise the expected benefits from the existing NECAs, as well as from potential future NECAs. Furthermore CSC points out that it will not address the environmental concerns of affected countries, primarily because shipowners will be motivated to segregate their fleets, using more polluting pre-2016 non-Tier III ships in NECAs. The proposed compromise will thus substantially reduce demand for Tier III technology on new ships and effectively delay its widespread use.

Moreover, it will signal to shipowners and manufacturers of engines and after-treatment technologies that the IMO rulemaking process is arbitrary and that adopted IMO regulations cannot be relied on but should be treated as provisional only.

A final decision on whether or not to adopt the five-year delay will be taken by the IMO at a meeting of its Marine Environment Protection Committee (MEPC) in London during 30 March and 4 April.

Christer Ågren

Sources: Submissions to the IMO MEPC 66 by the Clean Shipping Coalition; by Canada, Denmark, Germany, Japan and the United States; by EUROMOT; and, by Norway and the Marshall Islands.

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