The North American ECA and Short Sea Shipping – An Analytical Assessment

GREENTECH 2013 Green Marine Annual Conference, Vancouver BC

May 30, 2013

Dr. Ranajit (Ron) Sahu, Consultant

sahuron@earthlink.net

626.382.0001

The North American ECA and Short Sea Shipping – An Analytical Assessment A Lesson

in the Law of Unintended Consequences

GREENTECH 2013

Green Marine Annual Conference, Vancouver BC

May 30, 2013

Dr. Ranajit (Ron) Sahu, Consultant

sahuron@earthlink.net

626.382.0001

Topics

- The North American ECA (briefly)

- Fuel sulfur requirements

- The 200 mile requirement

- Air Pollutants (SO2, NOx, PM // CO2, other GHGs)

- Short-sea Shipping

- ECA Equivalence

- Establishing a credible distance requirement via modeling

- Unintended (but forseeable) Consequences

- Modal shift

- Climate // Energy Adverse Impacts

ECA - Requirements

THE CSL GROUP INC_____________

THE CSL GROUP INC_____________

THE CSL GROUP INC_____________

Air Pollutants

A. Regional/Local

- SO2 (also fine-PM precursor)

- NOx (also ozone and fine-PM pre-cursor)

- PM (various sizes)

Controlled based on health-protective standards (e.g., US

National Ambient Air Quality Standards, etc.)

- for SO2, the most stringent NAAQS is the 1-hour standard

Source-Receptor Distance Matters!

B. Global

- GHGs, including CO2

Source-Receptor Distance Does Not Matter

Short Sea Shipping

• Short Sea Shipping (SSS) is any movement of cargo by any vessel

type occurring in direct competition with rail or truck. This occurs in

the Inland Waters and Coasts of both Canada and the U.S.A.

• The Marine Highway (SSS) is vital to the US and Canadian trading

relationship.

• A 7 day trip – entirely within the ECA is the

norm

• A recent economic study shows Short Sea

Shipping (Seaway) to provide for:

• $34.6 billion in economic activity

• 227,000 US and Canadian Jobs

• $4.7 billion in taxes paid

(Canada and US Federal/States)

Short Sea Shipping is

Sustainable Shipping

Short Sea Shipping…

• is inherently more environmentally sound than other transportation options;

• aligns with MARAD’s Marine Highway Program; &

• reduces land based congestion & emissions.

Short Sea Shipping is

Sustainable Shipping

Miles per gallon of fuel – Panamax Coastal

• Short-sea shipping provides the most fuel efficient freight

transport mode on a ton-km basis (Laker/Handy Bulker)

Even Greater Efficiency

Short Sea Shipping Routes

within ECA

Deficiencies in ECA Analysis

• Did not consider short-sea shipping or potential modal

transfers.

• Impacts analysis is dominated by large vessels, oil tankers,

etc. for which modal shift is not a possibility or an issue.

• Analysis uses 2002 as a base year and projects economic

variables and emissions through 2020 – this does not

recognize major economic disruptions in recent years.

• As a result, the negligible impacts due to short-sea shipping

are not apparent.

• Bottom line: 200 nm ECA is not technically justified or

economically sustainable to Short Sea Shipping.

Updated Science:

• Focuses on short-sea shipping.

• Uses EPA approved modeling tools.

• Focuses on sulfur dioxide (SO2), the main pollutant emitted

that is directly a consequence of sulfur levels in the fuel –

and hence the pollutant directly related to fuel choices.

• Focuses on East Coast and West Coast shipping routes.

• Used historical meteorological data on East & West coasts.

Scope of Study

Scope of Study

East Coast Study Zones

Shore Concentrations vs. Vessel

Distance from Shore (km)

-0,20000

0,00000

0,20000

0,40000

0,60000

0,80000

1,00000

1,20000

1,40000

0 50 100 150 200 250 300 350 400

Narragansett

Sandy Hook

Cape May

Cape Henry

Cape Lookout

Cape Romain

Savannah

Jacksonville

Cape Canaveral

0 40 80 120 160 200 240 280 320 360

0,00E+00

1,00E-01

2,00E-01

3,00E-01

4,00E-01

5,00E-01

6,00E-01

7,00E-01

8,00E-01

16

014

0

12

0

10

0

80

60

40

20

0

-20

-40

-60

-80

-100

-120

-140

-160

Vessel Distance from Shore (km)

Normalized Concentration

Distance Along Shore (km) Cape Henry = 0

Shore Concentration Profile - Cape Henry

Ship Selection Criterion 20000 hp 20000 hp

Vessel Location (affects Load) Port-40 km 80 - 320 km

SO2 Level in Fuel ECA Modified ECA

Engine Size (kW) 15000 15000

Engine Load 0.30 0.75

SO2 Rate (gram/kW-hr/%S) 3.81 3.81

SO2 Level in Fuel (%) 0.1 1.0

SO2 Emission Rate (kg/hr) 1.7 42.9

Highest 1-hr Shore Conc. (ug/m3//kg/hr) 1.1560 0.0251

(Location) Cape Canaveral Cape May Highest 1-hr Expected Shore SO2 Conc.

(ug/m3) 2.0 1.1

EPA 1-hr SO2 NAAQS (ug/m3) 196 196

Highest SO2 / NAAQS 1.01% 0.55%

Model Prediction and

SO2 NAAQS

Commitment to ECA

• Support the North American ECA.

• Support 1% sulfur fuel within a 200 mile ECA.

• Support 0.1% sulfur fuel within a 50 mile (80 km) ECA.

Caribbean ECA

Modal Shift

As it becomes more expensive to transport low-value cargos

via Short-Sea routes, some of the cargo will transfer to less-

efficient land-based routes such as rail or truck….

- for example, in the US East Coast along I-95 corridor and in

the US West Coast along the I-5 corridor

- exposing large populations to higher levels of emissions

(including additional toxic air pollutants) at much shorter

distances

- adding to transport congestion

- Increasing safety risks

The I-95 Corridor Coalition is a partnership of state departments of transportation, regional

and local transportation agencies, toll authorities, and related organizations, including public

safety, port, transit, and rail organizations, from Maine to Florida, with affiliate members in

Canada.

Climate Concerns

• Policy makers must recognize Short Sea Shipping as the most environmentally

advantageous means of moving cargo. Canada and the U.S.A have a distinct

Short Sea (Marine Highway) trading relationship.

• Policy makers should understand the economic advantage of Short Sea Shipping to

both Countries and the Jobs that are provided within this transportation sector.

• International rules need to be adapted to work when applied to Short Sea Shipping.

• Reducing ECA size for Short Sea Shippers allow the continued use of this

mode of cargo transport while maintaining all of the environmental benefits.

• We recommended a sustainable standard of 50 miles, similar to Emission

Control Areas worldwide such as the Puerto Rico/Caribbean ECA.

• We recommend a 1% ECA standard out to 200 miles and a 0.1% standard out

to 50 miles for SSS vessels less than 20,000 H.P.

Conclusion &

Recommendations