   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

        ANN ARBOR, MI 48105

December 2, 2009

                                                                        
                                        	      			                    
OFFICE OF 	                                                             
                                                                        
                       	               									             AIR AND
RADIATION

MEMORANDUM

SUBJECT:	Meeting with JSA and MLIT on June 29, 2009

FROM:	Mike Samulski

		Office of Transportation and Air Quality

TO:		Docket EPA-HQ-OAR-2007-0121

	On June 29, 2009, Mike Samulski, representing the U.S. EPA, met with
members of the Japanese Shipowners’ Association (JSA) and Japan’s
Ministry of Land, Infrastructure, Transport, and Tourism (MLIT).  Lynn
Nadon, representing Environment Canada, also participated in this
discussion.  The purpose of this meeting was to give an overview of the
U.S./Canada proposal to the International Maritime Organization for
designation of a North American Emission Control Area.  The following
persons were also in attendance:

Maruta Shinichi	Ministry of Land, Infrastructure, Transport, and Tourism

Shinichiro Otsubo	Ministry of Land, Infrastructure, Transport, and
Tourism

Tetsuya Senda		National Maritime Research Institute

Eiichi Muraoka	National Maritime Research Institute

Nobuyuki Tanaka	Japan Ship Technology Research Association

Toshihiro Osarakawa	Japan Ship Technology Research Association

Osamu Handa		Japanese Shipowners’ Association

Masao Yamasaki	Japanese Shipowners’ Association

Kenichi Adachi	NYK Logistics & Megacarrier

Tamio Kawashima	NYK Logistics & Megacarrier

Tadahiro Koshisaka	NYK Logistics & Megacarrier

Hideyuki Koyama	K Line

Toshihiro Fukuzawa	K Line

Hideki Mizoguchi	Sanko Line

	The materials for this meeting are attached.  The first attachment is
the presentation given by Mike Samulski and Lynn Nadon.  The second
attachment is a list of questions provided by the Japanese
representatives.

ATTACHMENT 1

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ATTACHMENT 2

Questions on the US/Canada ECA

Balance between the reduction of air pollutant and GHG emission)

In order to reduce one particular substance to ease environmental
burden, it is obviously effective if severe restriction is applied to
large area. However, such restriction often causes other negative
environmental effects (trade-off relation), which deserves careful
consideration. In terms of introduction of ECA for NOx, SOx and PM,
since the restriction of NOx, SOx and PM emission would cause the
increase in GHG emission, we should carefully consider the trade-off
with the GHG emission increase. The CO2 emission increase may consist of
the following four elements. We have obtained a preliminary estimate in
CO2 emission increase due to the 1st and 2nd factors.  The increase is
about 3% for ECA-affected shipping, which is not considered negligible
for global warming.  It should be noted that, as the size of the ECA
area is larger, the resulting increase in GHG emission would be greater.


-1 Refining of low sulphur fuel oil

   The production of low sulphur fuel oil needs more energy, thus
emitting more GHG, than the production of residual oil or high sulphur
oil (0.5%S or more), ECA proposed by US and Canada may cause large
amount of additional GHG emission.  Our preliminary estimation is that
the proposed ECA would result in approximately 1 million tons of CO2
increase.  

-2  Production of urea

    A common production process of urea for SCR needs specific materials
and synthesizing process under high temperature and pressure, which
leads to substantial GHG emission (our rough estimation is
350g-CO2/kg-urea).  The 200 n.m. ECA would result in a large amount of
additional GHG emission ( 0.3-0.4 million tons of CO2 increase)

-3  Fuel penalty of engines 

  It is reported that diesel engines would suffer 1% fuel penalty due to
pressure loss by operating an SCR.

-4   Effects of Rerouting (change in shipping route)

Due to high cost of fuel and urea, many ships would change shipping
route to take the shortest distance within the ECA. Such navigational
course is not necessarily the shortest route between ports, thus GHG
emissions may increase. 

Considering trade-off relations, we are of the view that ECA, in
general, should be limited to those coastal sea areas which are adjacent
to highly polluted land areas due to dense ship traffic. We would very
much appreciate if you could provide any analysis that you have made on
the trade-off relation between ECA designation and GHG emission
increase.

Questions from viewpoint of other environmental assessment

-1   The effects of ECA have been estimated as for the year of 2020 in
US-Canada proposal. The sulphur limit of Annex VI is scheduled to be
reduced to 0.5% all over the world in 2020. It is not clear to us that
this significant change and its influence are included in your
assessment. In addition, the tier II requirement of NOx will gradually
reduce the volume of NOx even after 2020 as new ships are put into
service.  

   Accordingly, volume of air pollutants may decrease in mid/long term
(e.g. 2030) because the total volume of air pollutant from ships is
expected to decrease by ever-increasing share of Tier II-compliant ships
as well as by global sulphur capping.  Your assessment on this issue
would be appreciated.   

-2   We understand that the United States has set its own environmental
standards of Ozone and PM2.5 which are different from WHO guidelines. 
However, the WHO guideline’s threshold values are used in the
proposal, of which reasoning would be helpful for our understanding. 

-3    We would like to question the necessity of as large as 200 n.m.
for ECA limit.  Even if ECA is smaller (this includes several options
such as designating area less than 100 nautical mile off the shore or
designating only bay or port areas etc. ), it seems that the threshold
values of WHO guidelines could be satisfied.  For instance, the
presented simulation results show that most of the air pollutant
concentration (PM2.5 etc.) in western Canadian area is below the WHO
guideline’s value, with some exception of Ozone in very limited area. 

-4       Although the proposed ECA includes Alaska and Hawaii, there is
no simulation result presented for these areas.  Relevant data would be
appreciated. 

-5       We could not evaluate the growth rates of the activity and the
changes of the emission factor between 2002 and 2020 applied in the
US/Canada proposal, due to the lack of the data. Additional information,
e.g. inventory data in 2002, would be helpful.  

-6       The assessment of human health influence is based on the case
where the whole 200-nm ECA is applied. However, since there is
considerable difference in air pollutant concentration in each region,
it seems more reasonable if the regional differences are considered in
the assessment.  Your views on this would be helpful.

-7   The relation between the deposition amount of pollutants and the
influence on the ecosystem is not quantitatively shown in the proposal. 
Is our understanding correct that such quantitative analysis is not
technically possible? 

Questions from viewpoint of implementation 

-1	 As mentioned in the proposal, fuel switching to low sulphur oils
need fuel oil line’s modifications. Since such modification would
require the work at dry-dock, it would be necessary to consider the
capacity of such work and lead time.  Relevant information on such
consideration of the implementation timing and capacity would be
helpful. 

-2	   We are of the view that due attention should be paid to whether
the ‘infrastructure’ of supplying low sulphur fuel oil and urea
solution is sufficiently established.  Any analysis in this respect
would be appreciated.

Other questions

	    We would like to know the relationship between the proposed ECA and
restriction and California State’s new regulation regarding low
sulphur fuel which starts on July 1st. Our understanding through the
communication with the US side is that the proposal and its early
adoption is of an absolute necessity to block US regional regulatory
initiatives, which we see as very positive element of the US/Canada
proposal.  However, it seems that California regulation would be
implemented anyway, being unaffected by the ECA proposal; further
explanation would be appreciated.

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