Letter to Commissioners-Designate Hedegaard and Potočnik:
This letter is an appeal from three environmental organisations for your support to
strengthen future work on reducing air pollution from ships both at EU level and at the
IMO.
Transport & Environment (T&E), the European Environmental Bureau (EEB) and the Air
Pollution and Climate Secretariat (AirClim) represent leading European environmental
civil society groups campaigning to minimise the environmental and health burden of
maritime atmospheric pollution.
Air pollution from shipping contributes significantly to several major health and
environmental problems and emissions are projected to increase. With land based
emission sources being continually reduced, ship emissions may well exceed land
based sources by 2020.
The European Commission has a vital role in supporting EU efforts to steer Member
State action in this field. While we fully support the change towards a separate
Commissioner for Climate Action, we ask you to ensure that in the coming
reorganisation of Commission the existing policy focus and staff expertise on air
pollution from ships, particularly at the international level are preserved or even better,
strengthened.
We have outlined below the EU’s priorities concerning global and European measures to
cut air pollution from ships. It requires action at the Commission and EU level as well as
a long-term and coordinated European approach to the work of the International
Maritime Organisation (IMO) and its Marine Environment Protection Committee (MEPC)
whose 60th session will be held in London in March.
Given the importance and magnitude of the challenges ahead, effective management by
the Commission will require a strengthened allocation of resources for ship air pollution
policy work.
We foresee the following urgent priorities for the Commission and the EU in 2010:
1. Ensure the early implementation in EU law of the 2008 IMO MARPOL Annex VI
revisions concerning the maximum permissible sulphur content in marine fuels and
nitrogen oxide emission standards for new ship engines.
2. Work in the IMO to strengthen standards for nitrogen oxides for both existing and
new ships. The standards agreed in Annex VI are too weak to reduce future
emissions as they only apply to new ships and the stricter Tier III standards apply
only in Emission Control Areas (ECAs).
3. Act on the landmark MARPOL VI revision to expand existing and establish new
Emission Control Areas (ECAs) so that all European seas become combined sulphur
oxide/particulate matter/nitrogen oxide ECAs. Currently only the Baltic Sea and the
North Sea have ECA status and this is limited to sulphur oxide control. There is an
urgent need for the north-eastern Atlantic, the Mediterranean, and the Black Sea to
be designated as full ECAs as well. The Commission needs to take the initiative with
appropriate feasibility studies and consultations within the EU and with EU
neighbouring states. Europe is visibly lagging behind the US and Canada in following
through on the years of hard work culminating in the MARPOL VI revisions.
4. Ensure reductions of sulphur dioxide and particulate matter by introducing in early
2010 a proposal for the revision of Directive 2005/33 on the sulphur content of
marine fuels. Sulphur content reductions induce further benefits through reductions
of particulate matter. The EU should examine the range of options available and not
be limited by current IMO provisions.
5. Investigate the development of a directive to cut emissions of nitrogen oxides by
establishing mandatory nitrogen oxide emission standards for ships entering EU
ports.
6. Establish EU particulate matter standards for ship emissions following a review of
available control measures. Update urgently the emissions database to identify for
example whether action out to the 12 mile limit might prove effective in reducing
emissions. At present there are no shipping PM standards anywhere. EU action can
be a catalyst for regional and global (IMO) action.
7. Adopt an EU Directive to regulate the quality of marine fuels. At present there is no
mandatory international or EU marine fuel specification or control that will ensure the
quality of marine fuels, such as there is for example for EU road transport fuels.
Consequently, there is an obvious risk of marine fuels being contaminated by waste
oil, heavy metals, solvents, and other chemical waste products, resulting in danger to
health, environment and ship safety.
8. To speed up the introduction of low-emission ship engines and cleaner fuels, EU
regulation should be complemented by market-based instruments that apply fair and
efficient Community pricing principles to the marine sector. Therefore:
9. The Commission could adopt an EU Directive that makes all Member States
introduce charges that are related to the amounts of pollutants emitted, and set so as
to make it financially worthwhile – at least for ships that regularly frequent the area –
to use cleaner fuels and/or to invest in techniques needed to ensure a distinct
reduction in emissions.
The Commission should make sure that any measure would be accompanied by
Member States compliance monitoring, not only of sea-going vessels, but also marine
fuel trading barges and onshore selling points.
