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December 2015 Issue

The Potential of Continuous Emissions Monitoring Technology
Chris Daw
In today’s shipping industry, emissions reduction targets and the associated regulations are placing a great degree of strain on shipowners and operators. The challenges that come with meeting the current targets, the uncertainty surrounding future limits, and the lack of clarity and uniformity around monitoring, reporting and policing are all taking their toll. It is inevitable that further Emissions Control Areas (ECAs) will come into force as a result of the global focus on decarbonizing the shipping industry. And with the European Union’s monitoring, reporting and verification (MRV) regulation already in force, the main challenge for shipowners is to ensure they are prepared for these regulations by having an accurate and reliable emissions monitoring solution in place to demonstrate compliance.

Despite strict emissions regulations, the industry remains divided on which emissions monitoring and reporting tools are fit for purpose. Several leading industry experts advocate the need for smart and reliable technologies, such as continuous emissions monitoring systems (CEMS), and organizations such as the Clean Shipping Coalition (CSC) have been involved in making submissions to the IMO, arguing that the most practical solution would be to require ships to maintain a continuous record of emissions for the entire duration of their journey. Despite this, at present, the bunker delivery note (BDN) remains the most applied method of proving compliance with emissions regulations. This potentially results from a lack of understanding of the potential of CEMS technology, or misplaced concerns over the cost of installing the analyzers. However, as the industry continues to invest significant sums in compliance solutions, the merits of accurate emissions reporting tools such as CEMS should be carefully considered by shipowners and regulators alike.

To ascertain whether a vessel is compliant with the ECA regulations already in force, the current standard practice is to inspect the BDN to determine the sulphur content of the fuel and the quantity burned. However, without a standard format for the BDN itself, it is far from tamper-proof, a concern echoed by organizations such as the Trident Alliance, a coalition of shipowners and operators advocating for robust enforcement of maritime sulphur regulations. Further analysis of the fuel will only take place if the BDN suggests a clear indication of noncompliance, and this leaves the shipowner open to the risk of significant fines should the inspecting authority take a stern approach to scrutinizing the available data and enforcing the regulation. Several Port State Controls (PSCs) have already openly stated a commitment to strict enforcement of the regulations, with the U.S. Environmental Protection Agency (EPA) warning that fines could reach $25,000 a day, a figure not dissimilar to the total cost of installing CEMS, and that providing U.S. federal officers with false information could result in a prison sentence of up to five years. Matters are further complicated in the EU due to the variation in the approach of each PSC in policing compliance. While some EU PSCs have yet to penalize a single vessel, others such as the Norwegian Maritime Authority have already fined multiple vessels for noncompliance.

In contrast to BDNs, CEMS provides accurate, real-time data covering the duration of the voyage. CEMS analyzers have the ability to monitor gasses from the combustion of residual and distillate fuels, including SO2, CO2 and NOx, which can be combined with automatic identification system (AIS) data to allow PSCs to confirm compliance no matter where the vessel is. The analyzers are connected to a data acquisition system, which displays data logs and retransmits the monitored concentrations and SO2:CO2 ratio in accordance with IMO regulations and without manual intervention. This, linked with the low maintenance requirements, makes it an ideal marine monitoring system.

Additionally, those analyzers that also comply with EPA requirements can be zero calibrated as often as required using certified test gas—without the use of additional testing equipment or the need to extract samples—and therefore can ensure that the data provided are wholly accurate. Through accurate and frequent calibration, deviations in data can be recorded and the analyzer returned to zero on board and in real time, ensuring that shipowners have immediate access to a continuous stream of reliable data.

By monitoring emissions continuously and not retrospectively, shipowners and operators who have already invested time and money in ensuring their vessels are compliant have the proof they need readily in hand. This mechanism also empowers the regulators to immediately target the rule breakers who are avoiding the expense of installing compliance solutions on their vessels, rather than inconveniencing those who have taken the time to ensure they are compliant. CEMS technology provides compliant vessels a safeguard from inspection, reducing the burden of legislation on both the shipowner and the regulator.

The only way to ensure that the shipping industry remains competitive across the board is through strict enforcement of the rules, creating a level playing field for all in the industry and driving down harmful emissions levels to increase global sustainability. To achieve this, an accurate, uniform and scalable approach to emissions monitoring and reporting needs to be agreed and adhered to by the industry as a whole.
Chris Daw is the business development manager at Parker Kittiwake-Procal. Working across the power generation, chemical, marine and biomass industries, he is responsible for the business development of the full range of continuous emissions monitoring products. Previously, Daw was a project engineer at Rank Taylor Hobson and co-founded Procal Analytics Ltd.


2015:  JAN | FEB | MARCH | APRIL | MAY | JUNE | JULY | AUG | SEPT | OCT | NOV | DEC
2014:  JAN | FEB | MARCH | APRIL | MAY | JUNE | JULY | AUG | SEPT | OCT | NOV | DEC

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Sea Technology is read worldwide in more than 110 countries by management, engineers, scientists and technical personnel working in industry, government and educational research institutions. Readers are involved with oceanographic research, fisheries management, offshore oil and gas exploration and production, undersea defense including antisubmarine warfare, ocean mining and commercial diving.