Sulphur emissions by ships
Written evidence from the European Cruise Council (SES 04)
1. The European Cruise Council represents 30 of the leading cruise ship operators in Europe and has 32 associate members. Last year the European cruise industry contributed over €35 Billion to the economies of Europe, employing more than 300,000 people and embarked 5.2million passengers on their cruise from a European port.  Our objective is to promote the interests of cruise ship operators within Europe, working closely with the EU Institutions on policy related to transport, environment, health, consumer affairs, tax and tourism. The European Cruise Council (ECC) and its members stand for quality shipping, upholding high environmental and safety standards for the benefit of our passengers, coastal areas, the sea and society at large.
2. The ECC notes that the Transport Committee has invited written evidence on the implementation of IMO and EU regulations on sulphur emissions by ships and is particularly interested in steps which the UK Government could take to assist the maritime sector meet its obligations under Marpol.
3. The ECC is strongly supportive of the submission made to the Committee by Maritime UK and, in particular, its recognition that there are ‘ways of mitigating the costs to shipping that are entirely regulatory by nature and so present no cost to Government.’ While the Maritime UK submission briefly mentions the concept of ‘sulphur averaging’ (see their para 11) it does not go into detail and purpose of this submission is to provide more background on this concept in case the Committee wish to pursue this line of enquiry.
Use of Averaging as an Equivalent Method
4. Annex VI includes provisions for equivalencies if they are "at least as effective" as use of fuel complying with ECA standards. We believe that environmental protection consistent with the goals of the ECA can be achieved via a more flexible regulatory approach that allows for the averaging of fuel sulphur "credits." For example:
a) Single Vessel Averaging: Cruise ships typically have multiple diesel electric engines which can be used in any combination to satisfy required propulsion and auxiliary loads and different engines can be run on different fuels with sulphur contents less than (for example, via use of gas turbine engines) or greater than the ECA requirement. Some engines such as gas turbines are inherently cleaner; some others may be fitted with aftertreatment devices (e.g. exhaust gas cleaning systems or ‘scrubbers’); while others may not depending on space and scrubber capacity constraints. Benefits of zero emissions when using shore power at berth can also be folded into the averaging calculation. Vessel operations can thus be configured to achieve average emissions equivalent to the use of ECA compliant fuel in all engines.
b) Multiple Vessel Averaging: The concept of single vessel averaging can be extended to averaging over multiple vessels operating on similar itineraries, thereby further increasing the range of available options for achieving compliance.
c) Distance-Weighted Averaging: Replacement of higher sulphur residual fuel oil with the distillate fuel needed to meet ECA limits will reduce population exposures to particulate matter from ships operating near shore. Substitution of residual fuel oil with distillate fuel when operating further out but still within the ECA zone will result in limited additional public health protection. A more flexible approach to compliance allows weighted averaging of fuel sulphur content, with the weighting factors based on distance of the ship from the greatest potential for public health exposure impacts.
5. Equivalence with the ECA requirements can be demonstrated by tracking fuel consumption rates and other operating parameters and calculating resulting emissions for a particular itinerary. Equivalence is demonstrated when weighted average emissions for vessels operating on a given set of itineraries are less than or equal to what they would have been had the vessels simply used ECA compliant fuel. Emissions weighting factors can be assigned to different segments of the itinerary when calculating averages to account for the degree of potential public health exposure from emissions occurring along those segments. For example, in the above figure, emissions occurring within Segment A would have a high weighting factor as compared to those occurring in Segment B. Dispersion modeling, based on existing government methodology, is used to assign appropriate weighting factors to each segment of the voyage. Voyage data and weighting factors are input into an emissions calculator which computes weighted average emissions for comparison to emissions produced by simply using ECA compliant fuel.
6. The UK Government was strongly supportive of including language that allowed for equivalent compliance options during the negotiation of the revised MARPOL Annex VI and this manifested itself in Regulation 4 of that Annex. While the European Commission’s proposed amendments to the Sulphur Directive largely incorporate the text of Regulation 4 there are other are a number of other articles throughout the proposal whose current wording might seriously impede the development and use of such alternative compliance options.
7. It should be recognised that alternative compliance options may not only prove a means of compliance in themselves but will encourage and hasten the development of alternative technologies (by reducing the necessary capital expenditure) and reduce demand for supplies of distillate fuel.
8. The ECC therefore asks the Transport Select Committee to ensure the Government is satisfied that the full range of compliance options envisaged under the revised MARPOL Annex VI are permitted under the proposed amendments to the EU’s Sulphur Directive.
 See: ‘Contribution of Cruise Tourism to the Economies of Europe 2011 Edition’ at www.europeancruisecouncil.com