# Cost Benefit Analysis to Support the Impact Assessm ent accompanying the revision of Directive 1999/32/EC o n the Sulphur Content of certain Liquid Fuels

Final Report

Report to Eur opean Commission

ED45756

Issue 3

23 rd December 2009Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

ii Title Cost Benefit Analysis to support the impact a ssessment accompanying the revision of Directive 1999/32/EC on the sulphur con tent of certain liquid

fuels

Customer European Commission

Customer reference ENV.C.5/FRA/2006/0071 – Service Request No. ENV C5/GK/em/Ares (08)

36661

Confidentiality, copyright and reproduction This Report has been prepared in response to Servic e Request ENV C5/GK/em/Ares (08) 36661 Under framework contract N o – ENV.C.5/FRA/2006/0071 between the Commission and AE A Technology.

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Authors Name Peter Bosch, Peter Coenen (TNO), Erik Fridell, Stefan Åström (IVL), Tom Palmer (AEA Technology), Mike
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Date 23 rd December 2009Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

iii

### Cost benefit analysis to support the impact assessm ent AEA/ED 

### 45756 /Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### iv 

# Table of contents

1 Summary 1

2 Introduction 5

3 Methodology 7

3.1 Overview of methods 7



## 4 Scenario Description 8

4.1 Description of the Baseline Scenario 8

4.2 Description of the Policy Scenarios 10



## 5 Dispersion results; concentrations and exceedance o f critical loads 14

5.1 Introduction 14

5.2 SEA1 15

5.3 SEA2 (applies only to 2015) 16

5.4 SEA3 17

5.5 SEA4 (2020 only) 17

5.6 SEA5 (2020 only) 18

5.7 Land based A 18

5.8 Land based B 18

5.9 ASEA1-BSEA1-ASEA4-BSEA4 18



## 6 Benefits assessment 19

6.1 Background 19

6.2 Methodology 19

6.3 Results 22



## 7 Cost analysis of the new IMO marine fuel and engine standards and a

potential 

## extension of emission control areas 34

7.1 Cost calculation method description 34

7.2 Abatement Technology Description 35

7.3 Unit abatement costs 37

7.4 Scenario abatement costs 42

7.5 Results 43



## 8 Comparing Costs and Benefits 52

8.1 Preliminary comparison of costs and benefits 52

8.2 Detailed uncertainty assessment 53

### Cost benefit analysis to support the impact assessm ent AEA/ED 

### 45756 /Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### v 8.3 Summary of the CBA results 58



## 9 Emission abatement equipment 59

9.1 Summary 59

9.2 Introduction 60

9.3 Abatement of sulphur oxides 61

9.4 A comparison between reducing SO 2 

### emissions with low sulphur fuel or scrubbers

62

9.5 Emission criteria for EGC 63

9.6 Wash-water criteria 63

9.7 Environmental assessments 65

9.8 Environmental impact related to the IMO wash water criteria 66

9.9 Monitoring 69

9.10 Conclusions and suggestions 70



## 10 Use of distillate fuels by ships at berth 73

10.1 Introduction 73

10.2 Outline of the problem 73

10.3 Types of ships where the risks may be relevant 74

10.4 Relevant number of ships 74

10.5 The nature of the risks 75

10.6 Technical solutions and costs 77

10.7 Conclusions 78



## 11 Requirements with regard to maximum sulphur content of heating

oil for condensation boilers 79

11.1 Objective 79

11.2 Introduction to oil fired condensation boilers 79

11.3 Heating oil quality and availability 79

11.4 Construction of condensation boilers 80

11.5 Condensation boilers and sulphur content of heating oil 80

11.6 Conclusions 81



## 12 References: 82

13 Appendix 1 - Emission factors used 86

14 Appendix 2 - Emission Figures by Scenario and Area Baseline 90

15 Appendix 3 - Relevant geographical representations of the dispersion

calculations 93

16 Appendix 4 - Results per EU member states 125

### Cost benefit analysis to support the impact assessm ent AEA/ED 

### 45756 /Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### vi 

## 17 Appendix 5 - Health Benefit Diagrams 153

18 Appendix 6 - Methodology for cost calculations 160Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 1 

# 1 Summary

This report documents the Cost Benefit Analysis to Support the Impact Assessment accompanying the revision of Directive 1999/32/EC on the Sulphur Con tent of certain Liquid Fuels.

Maritime activities constitute a significant fracti on of anthropogenic emissions of air pollutants in Europe. International shipping in the EU is expected to inc rease in the coming decade and there is a risk that

this will offset the effects of the current emissio n reduction legislation for maritime activities and the future emissions will surpass the target levels est ablished by the European Commission in its Thematic Strategy on Air Pollution for land based sources.

A number of ongoing developments will lead to reduc tions in emissions of sulphur oxides (SO

x ) and nitrogen oxides (NO

x ). In this report the effect of these developments is determined in order to inform the

Commission’s review of Directive 1999/32/EC relatin g to a reduction in the sulphur content of certain liquid

fuels.

This study has examined the effects of emission red uction measures (for the years 2015 and 2020) in maritime activities by: 1. Analysing the benefits of: the new IMO marine fu el and engine standards (SO 2 and NO

x reduction respectively), and the potential extensions of emission control areas. The benefits of different scenarios have been evaluated against a r evised NECD 2008 baseline scenario. The study did not take into account the effects of the current economic crisis (assuming this will only be temporary). The benefits were quantified with re spect to a baseline scenario for emissions, air quality (concentrations) as well as their impac t on human health. 2. Calculating the costs of emission reductions tha t result from the new IMO marine fuel and engine standards and the potential extension of emi ssion control areas. 3. Assessing the effects, costs, risks and technica l requirements that are associated with the use of emission abatement equipment and steam boilers b y ships as well as the use of condensation boilers for heating purposes.

Benefit analysis The following scenarios were investigated and were compared to a Baseline scenario (revised NECD 2008 baseline):

• Designation of the Baltic Sea, North Sea and the E nglish Channel SECAs (2015 1 and 2020 2 3 )

• Inclusion of Mediterranean as a SECA (2015)

• Inclusion of the Black Sea as a SECA (2015 and 202 0)

• Reduction of land based sources 4 by reduction of the S-content in gasoil to 0.05 % (2015 and 2020)

• Reduction of land based sources by reduction of th e S-content in gasoil to 0.001 % (2015 and 2020)

For each scenario the emissions of relevant air pol lutants were calculated, and the effects on ambient air quality were quantified using state of the art modelling tools. These concentrations were

used to determine the health benefits of the emissi on reduction using the methods developed in the

CAFE and EC4MACS studies for EC DG-ENV.

Cost analysis

The cost calculations for NO X and SO 2 abatement from shipping in this report contain two parts. The first consists of calculating unit costs (per PJ) f or each abatement option under consideration, the second the calculation of scenario specific costs b ased on the penetration of the low-NO X and low-SO 2

1 In all 2015 marine scenario’s Tier I & Tier II f or NOx reduction is assumed

2 In all 2020 marine scenario’s Tier I - III for N Ox reduction is assumed simulating the designation o f the Baltic Sea ,

North Sea , the English Channel and the Mediterrane an as NECA

3 For 2020 also scenario’s are elaborated with a r educed S content (0,5 %) in marine fuels used outsi de the SECA 4 Only for heating in households and agricultureCost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 2 technology options. The calculations allow for sce nario comparison and comparison of alternative technologies to reach the required standards.

For each scenario, costs are calculated, specifying high and low costs for NO X and SO 2 abatement. For

SO 2 abatement, separate cost calculations are presente d for scrubber costs and low S-fuel costs

Comparison of costs and benefits Annual costs and benefits (low and high estimates) for the different scenarios are given in the follow ing tables - taking the results directly from the analy sis. The low bound for costs is the lower estimate for fitting a scrubber to reduce SO 2 emissions together with the costs of NO

x control. The upper bound for costs is for the high estimate for using low sulphu r fuels to reduce SO 2 emissions and the costs of NO

x control. The range for benefits is based on use of either the value of a life year (VOLY, giving the lower bound) or the value of statistical life (VSL, givin g the upper bound) to value mortality.

In all cases there is no overlap between the estima tes for costs and benefits as shown above, indicati ng that for all scenarios benefits would exceed costs.

.

Further analysis was undertaken to assess the effec t of further uncertainties on the balance of costs and benefits. This found that the probability of b enefit exceeding cost can be described as very like ly / virtually certain, using terminology developed by t he Intergovernmental Panel on Climate Change (IPCC). With one slight exception (the last 2020 sc enario: All European seas Included in the SECA and reduced S-content outside the SECA ) the probabilit y of benefits exceeding costs can be described as likely, very likely or virtually certain even for w orst case assumptions on cost.

It is to be remembered that the probabilities calcu lated here are quantified only against benefits for improved health. The inclusion of impacts to mater ials (including cultural heritage) and ecosystems, in particular, would add to the benefits and further i ncrease the already high probabilities. Taking thes e issues together it is concluded that more detailed assessment of the limitations of the analysis finds that the initial conclusion, that benefits of the propos ed actions will exceed costs, is indeed robust. 2015 ( € billions) Baltic Sea , North

Sea and the English Channel

as SECA Inclusion of

Mediterranean in

the SECA Inclusion of the

Black Sea in the

SECA

Costs low 0.6 1.8 1.9
high 3.7 10 10

Benefits low 8 11 11
high 16 24 25

2020

( € billions) Baltic Sea , North

Sea and the English Channel

as SECA Inclusion of

Mediterranean and

the Black Sea in

the SECA Baltic Sea ,

North Sea and the English

Channel as

SECA

Reduced Scontent outside

the SECA Inclusion of

Mediterranean

and the Black

Sea in the SECA

Reduced Scontent outside

the SECA
Costs low 0.9 2.0 2.6 2.6
high 4.6 12 11 14

Benefits low 10 14 15 16
high 23 32 34 36Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 3 Comparison of the benefits of the land based scenar ios against the maritime scenario (Baltic Sea , North Sea and the English Channel as SECAs) shows t hat the additional health benefit from lowering

the S content in fuel on land amounts to 0.4 to 0.8 € billions (depending on the S content) in 2015. For

2020 the additional benefits are calculated at 0.6 € billions. These figures are only small compared to the benefits of the maritime scenario (which amount to 17-35 € billions) and therefore do not constitute an

alternative to the maritime emission reduction.

Technical criteria for exhaust abatement equipment Exhaust abatement equipment for the reduction of em issions of sulphur dioxide from ships is an

alternative to reduced S content in marine fuels. T he only technology available at present is scrubbin g. Scrubber units can be of two kinds, seawater scrubb ers and closed scrubbers, or a combination of two.

The use of scrubbers to clean the exhaust from mari ne engines using residual oil could in principle le ad to high concentrations of a number of harmful compo unds in the marine environment around the ships. The present situation is somewhat incongruous in th e sense that washwater limits for scrubbers are set by IMO while there still are no limits for the gase ous exhaust (except for SO 2 and NO X ). It is recommended that criteria are developed that promot e the abatement of PM. At least the levels of PM

reduction should be established to allow for volunt ary or market based reductions of PM emissions. Further, it is recommended, when possible, to keep the EU regulations in line with the IMO guidelines.

The present IMO washwater criteria contain limits f or PAH, pH, turbidity and nitrates. Of these all ex cept

the nitrate criterion are intended for continuous m onitoring onboard the ship. A major factor when formulating the criteria is that they should be pos sible to monitor online. However, it would also be possible to add more criteria that are to be tested during certification. This could give further assu rance that the units are environmentally safe and would n ot be constrained by the possibility to measure online in a simple way.

With the present criteria for pH it seems as if dil ution and buffering in the sea will rapidly give ac ceptable levels. Even in confined areas it is likely that th e effect is limited. However, it is recommended tha t

further studies are undertaken for brackish and riv er water and that the criteria then are reviewed. I t is suggested that the IMO guidelines are adopted for t he pH criteria but at the same time allowing for

revisions as more data becomes available.

The criteria for PAH are expressed as phenanthrene equivalents. This is not a well established concept and should be defined in the guidelines. It may be appropriate to use phenanthrene for monitoring purposes but the criteria ought to guarantee low em issions of a range of PAHs and thus it is necessary to establish how the measured value relates to e.g. PAH 16 or THC.

The criteria for turbidity may be used to establish that unwanted solid material is not formed in the scrubber unit. However this criterion is not approp riate to monitor PM reduction because there is no relation between particle concentration and turbidi ty. It is recommended that the concentrations of partic ulate matter, metals, and PAH are regulated and tested during commission, and, further, that the co rrelation to turbidity is investigated in order to have

continuous measurement available onboard.

The present criteria for nitrates could in principl e lead to large additional contributions of nitrate s to sensitive areas. The best way to deal with this iss ue is to use abatement technology for NO X reduction. It is recommended to set up new criteria regarding nitrate emissions which prevent increased nitrogen

loads to sensitive areas.

It seems appropriate to adopt the IMO guidelines re garding monitoring, i.e., allowing for the possibil ity of not using continuous monitoring of the SO 2 emissions. The reason is that there will be units that can be sufficiently monitored by other means.

There is only limited experience from trials with m arine scrubbers for SO 2 . It is important to follow the trials taking place and make sure that thorough env ironmental impact assessments are conducted in order to evaluate and develop the washwater criteri a.Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 4 Use of distillate fuels by ships at berth From 1 January 2010 ships using ports within the EU will be required to use low-sulphur fuel, maximum 0.1 wt% sulphur, while at berth, with an exception for those making only short stops (Directive 2005/33/EC). This will most likely make it necessar y to use distillate fuel while at berth. There are

concerns that there are risks associated with switc hing from residual oil to distillate fuel in boiler s.

One can state that there are real safety concerns w ith switching from HFO to MGO in existing boilers. The main safety concern is that a distillate fuel m ay vaporise in hot boilers with heated pipes. If th e boiler system has not been modified, there is—in th e case of flame failure and improper handling— an explosion risk. Although many boilers can be used w ith MGO, all boilers should be inspected before using MGO at berth.

There are technical solutions to solve these issues where fuel piping systems, burners, and flame inspection systems are modified. The control system may have to be modified and new handling routines established. For LNG ships, modifications are required. The costs range from 5 000 to 25 000 for small auxiliary boilers, around 150 000 € per ship for tankers and 70 000 to 1 400 000 € for LNG

tankers.

Requirements with regard to maximum sulphur content of heating oil for condensation boilers A typical issue concerning condensation boilers use d for space heating is use of the latent heat of th e water vapour in the exhaust gases. This increases t he fuel efficiency and therefore decreases the CO 2 emission by 6% compared to conventional boilers. Be cause the flue gases are cooled down below the dew point, condensation will occur on the heat exch anger in the boiler and using heating oil will caus e an acidic (and thus corrosive) condensate. It is su ggested that this phenomena sets limits for the maximum sulphur content of heating oil to be used i n condensation boilers. In this study its is established that heating oils with sulphur content up to the maximum allowed concentration of 1000 mg/kg can be used in condensation boilers. However , to maintain high efficiency, heat exchangers have to be cleaned more frequently than in conventi onal boilers. Using low sulphur oil will prevent th is.

Furthermore are there no technical obstacles which prevent the use of low sulphur heating oil in condensation boilers designed for “standard” heatin g oil.Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 5 

# 2 Introduction

Maritime activities constitute a significant fracti on of anthropogenic emissions of air pollutants in Europe. In 2000, SO 2 and NO

x emissions from international maritime shipping in Europe amounted to approximately 30 percent of the land based emission s in the EU-25. While legislation is in force to control emissions from international shipping, the expected increase in the volume of ship movements will offset the positive environmental impacts of t hese measures and will lead to further growth in sh ip emissions. Under business-as-usual assumptions, by 2020, emissions from maritime activities would come close to the projected baseline emission level s from land based sources and surpass the target levels established by the European Commission in it s Thematic Strategy on Air Pollution for land based

sources.

This anticipated increase in ship emissions will co unteract the envisaged benefits of the costly effor ts to control the remaining emissions from land based sou rces in Europe. While at present emissions from ships are responsible for 10 to 20 percent of sulph ur deposition in coastal areas, their contribution is expected, by 2020, to have increased to more than 3 0 percent in large areas in Europe, and up to 50 percent in coastal areas.

Analysis by IIASA in 2007 demonstrated that limitin g air pollution from shipping reduces the necessity to
further control emissions from land based sources a nd provides important cost savings in achieving air quality targets in Europe.

A number of ongoing developments will lead to reduc tions in emissions of sulphur oxides (SO

x ) and nitrogen oxides (NO

x ), these include:

• Annex VI of MARPOL and the Technical Code on Contr ol of Emissions of Nitrogen Oxides from Marine Diesel Engines (the new IMO marine fuel and engine standards) from the International Maritime Organisation (IMO) have been revised and f ormally adopted by the Marine Environmental Protection Committee (MEPC) of IMO in October 2008. These revisions set criteria for a gradual reduction in the maximum permitted sulphur content of marine fuels as well as the maximum permitted emissions of nitrogen oxides from marine diesel engines;

• Annex VI of the Marine Pollution Convention (MARPO L) defines Sulphur Emission Control Areas (SECAs) where stricter limits on sulphur emissions apply. As of now, two areas are classified as SECAs: the Baltic Sea and the North Sea/English Cha nnel. Article 7 of Directive 1999/32/EC requires the Commission to give consideration to pr oposals for the addition of SECAs.

• The possibility that European institutions will de signate emission control areas for NOx;

• The agreement by the European institutions on the Climate and Energy Package. (26 March 2009) The main purpose of this report is to determine the effects of these developments in order to inform t he

Commission’s review of Directive 1999/32/EC relatin g to a reduction in the sulphur content of certain liquid

fuels.

This study has examined the effects of emission red uction measures in maritime activities by:

• Analysing the benefits of the new IMO marine fuel and engine standards as well as the potential

extensions of the emission control areas. The benef its of different scenarios have been evaluated against a revised NECD 2008 baseline scen ario. All existing and foreseeable Community and national measures were taken into acc ount, as far as these have a direct impact on emissions and impacts on future activity are known. The study did not take into

account the effects of the current economic crisis. It has been assumed that the crisis is only temporary (noting apparent recovery of several majo r Member State economies in the second half of 2009) and that the economy will subsequentl y evolve as was expected before the crisis. The benefits were quantified with respect to the ba seline scenario for emissions, air quality (concentrations) as well as the impact on human hea lth.

• Calculating the costs of emission reductions that result from the new IMO marine fuel and engine standards and the potential extension of emi ssion control areas.Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 6 • Assessing the effects, costs, risks and technical requirements that are associated with the use of emission abatement equipment and steam boilers b y ships as well as the use of condensation boilers for heating purposes.Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 7 

# 3 Methodology

3.1 Overview of methods

In general terms the cost benefits analysis consis ts of the different steps illustrated in figure 3.1

.

Figure 3.1 Flow scheme for the cost benefit analysi s

EMISSIONS

tonnes/year DISPERSION

Increase in ambient concentrations in all affected regions

IMPACT

Using exposure-response curves, e.g. change in building erosion

BENEFITS

Heath benefits, Damage costs Stock at risk

e.g. inventory building materials, population distribution EXPOSURE

People, crops, materials

COSTS FOR

EMISSION REDUCTION 

### Base line & Policy scenarios

- Prices different fuel grades

- Abatement costs

COMPARISON of COSTS & BENEFITS EMISSIONS

tonnes/year DISPERSION

Increase in ambient concentrations in all affected regions

IMPACT

Using exposure-response curves, e.g. change in building erosion

BENEFITS

Heath benefits, Damage costs Stock at risk

e.g. inventory building materials, population distribution EXPOSURE

People, crops, materials

COSTS FOR

EMISSION REDUCTION 

### Base line & Policy scenarios

- Prices different fuel grades

- Abatement costs

COMPARISON of COSTS & BENEFITS

In the first step the baseline scenario is develope d. All other policy scenarios will be compared to t his

baseline. The emissions of SO 2 , NO

x , PM, CO and NMVOC for these scenarios are calculat ed and fed into the dispersion model. The scenario description s and emission estimates are given in section 4. Th e most relevant parameters for the dispersion modelli ng are given in section 5. The assessment of the

benefits is elaborated in section 6 and section 7 d escribes the cost calculations for the emission reduction. In section 8 a comparison is made betwee n costs and benefits based on the results of the two previous sections.Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 8 

# 4 Scenario Description

4.1 Description of the Baseline Scenario

The baseline for the study is traceable to the NEC6 /C&E package/current policies baseline scenario from IIASA/GAINS, which has been used as baseline f or simulations of the NECD plus the proposals for the Climate and Energy Package of the Commission of 23 January 2008. It includes the most up to date (Spring 2008) current control policies as laid down in legislation and those presently in the dec ision phase of European Institutions. It includes: 'Curre nt legislation' in all sectors plus: revision of th e IPPC Directive for large stationary combustion sources i n industry and power sector (less strict BAT case interpretation); Euro VI on heavy-duty vehicles and Ceilings from the NEC Directive. Assumptions are documented in detail in the NEC6 report, page 18 an d 19 (Amman et al, 2008).

As the NEC6 scenarios do not fully cover internatio nal shipping (they contain national maritime fuel consumption but not international bunkering) a sepa rate baseline has been developed for international shipping. The starting point for the fuel consump tion of international shipping is the 2000 fuel consumption - from Cofala et al. 2007 (page 11). T he fuel consumption is given by fuel type (MD/HF), vessel type (cargo/ferry) and regional sea. It is b ased on the 2000 inventory of emissions produced by ENTEC, which is in itself based on a detailed analy sis of four months of vessel movement data from the year 2000. Cofala applies an overall 2.5 per cent growth rate for cargo vessels and 3.9 per cent rate for passenger vessels in the baseline whereas, for this study, we adopt the baseline of the Ex-tremis mode l (Chiffi et al., 2007), which is based on a detailed model of shipping in EU27 countries and is differentiated for marine diesel and heavy fuel oil . The growth factors for bunker fuel consumption fr om Ex-tremis (for MD and HF) for EU ship movements are used to project the regionally detailed fuel consumption from international shipping in European seas in 2010, 2015 and 2020. Over the period up to 2020 the overall growth in HF use is 2.7% per ye ar, while use of MD decreases with 0.5% per year

We have also used the outcomes of the Ex-tremis bas eline to aproximate the fuel consumption by ship types and engine size. Ex-tremis only covers EU27 countries and misses the traffic over European seas generated by non-EU countries in Europe (Chiff i et al., 2007). Assuming, however, that the developments in transport and developments in the f leet in EU and outside EU will run in parallel, it is possible to apply the distribution of ship types (b ulk carrier, tanker, containership, general cargo, etc.), and engine class (gas turbine, high speed diesel, m edium speed diesel, slow speed diesel, steam turbine) in each of the years to the regional fuel consumption for international shipping in 2010, 201 5

and 2020.

Emission factors have been added by detailed ship-c lassification and by regional sea. The baseline i s a reference scenario and does not include any polic ies - it is based on fixed emissions factors and, f or instance, does not include the 1997 IMO protocol, i ntroducing Tier I for ships built after 2000 and wh ich

took effect in 2005. Neither does it include the T ier II regulations that apply for ships built after 2011. As

a result the emissions reductions in scenario SEA1 compared to the baseline suggest a relatively large r shift than would occur in reality. An overview of emission factors used is provided in Annex 1. It should be noted that the sulphur content of HF in the base line outside SECAs is 2.70% (according to TFEIP, 2009), which is the current worldwide average. Ins ide SECAs it is 1.45% representing the present regulation of 1.5%. This is used to be able to illu strate the impact of the agreed limit of 0.1% from 2015 that is used in one of the scenarios (SEA1).

The emission factors for particulate matter have be en adapted from Cooper and Gustafson (2004) and have been chosen according to the sulphur content o f the fuel and the speed of the engines. Table 3 in Annex 1 specifies the emission factors used in the emission calculations e.g. for slow speed diesel engines running on heavy fuel oil the reduction in the PM emission factor resulting from a decrease in sulphur content in HFO from 1.5% to 0.1% is 54%.

As it is difficult to model the introduction of scr ubbers, we have not introduced a detailed calculati on differentiating the part of the sulphur limit that can be reached by using scrubbers and the part that can be reached by using low sulphur fuels. For the calc ulation of the sulphur emissions the way emissions

reductions are realised does not make a difference. It does, however, create uncertainty in theCost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 9 calculation of PM emissions. Although there are few measurements to substantiate this, scrubbers reduce PM emissions roughly by half (see also Secti on 9.4). This reduction is in the same order of magnitude as the reduction in the emission factors for PM, when going from 1.5 to 0.1% S in HFO for the majority of the vessel; consequently the error introduced by not accounting for the share of

scrubbers in the PM calculation is limited.

The resulting baseline emissions per sea area are g iven in Table 4.1a.

Table 4.1a Baseline emissions international shippi ng this report, 2000 and 2020

2000 2020

Sea area SO 2 NO

x NMV

OC PMtotal SO 2 NO

x NMVO

C PMtotal

x 1000 tonnes

North Sea 417 664 23 22 399 1171 41 39

Black Sea 53 83 3 6 93 147 5 11

Mediterranean 1024 1593 56 118 1795 2805 98 210

Baltic Sea 177 283 10 9 169 498 17 17

NE Atlantic 472 742 26 56 829 1310 46 100

Total 2144 3365 118 212 3758 5931 207 377

The 2000 inventory of emissions produced by ENTEC w as used to distribute the emissions per sea area to generate the gridded data needed for the di spersion modelling. The national data from the IIASA-GAINS baseline are also gridded according to sector specific distribution patterns.

The land based emissions are the same as in the C&E package current policy scenario in Amman et al. (2008). The baseline sea-based emissions are more o r less comparable to those in Cofala et al. (2007). Differences, however, are caused by the split in sh ip types we have introduced by using Ex-tremis, which brings about a split in HF and MD that differ s from the split used by Cofala et al. (2007). Furt her differences are brought about by the larger differe ntiation in emission factors for NO

x , NMVOC, CO and PM which we have applied for different engine types . Cofala et al. (2007) assume lower sulfur and PM emissions in 2020 (See table 4.1a and 4.1b)

Table 4.1b Baseline emissions international shippi ng according to Cofala et al, 2007, 2000 and

2020

2000 2020

Sea area SO 2 NO

x NMV

OC PM2,5 SO 2 NO

x NMVO

C PM2,5

x 1000 tonnes

North Sea 443 648 24 50 406 946 nr 67

Black Sea 56 81 3 6 91 118 nr 10

Mediterranean 1069 1563 60 121 1714 2311 nr 198

Baltic Sea 187 278 10 21 171 404 nr 28

NE Atlantic 494 723 26 56 804 1048 nr 91

Total 2249 3293 123 254 3186 4827 nr 394

Note: nr = not reported.Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 10 4.2 Description of the Policy Scenarios

4.2.1 Overview

Policy scenarios have been designed to enable the c ritical comparison of the effects of policy measure s that restrict emissions by:

• The (already decided) designation of the Baltic an d the North Sea/English Channel as SECA

• The designation of the Mediterranean Sea as SECA

• The designation of the Black Sea as SECA

• Lowering the maximum sulphur content of maritime f uels outside designated SECA areas to

0.5%

• Application of the IMO Tier I and Tier II standard s

• Designating the Baltic, the North Sea/English Chan nel and the Mediterranean as NO

x emission control areas (in which IMO Tier III would apply to new engines from 2015)).

Additionally, two scenarios for decreasing the emis sions from land based sources have been elaborated in which the sulphur content in heating oil for use by households and agriculture has been assumed to be reduced to 0.05 % and 0.001% respectively (see T able 4.2 and 4.3).

Table 4.2: Scenario’s for 2015

Scenario Year S

- content

marine fuel

outside SECAs (by mass) S

- content

marine fuel in SECAs (by mass) NO

x Tier

Standards SECA regions

Baseline 2015 2.7 % 1.45%

SEA1 2015 2.94% 0.10% Tier I & II Baltic Sea North Sea / English Channel

SEA2 2015 2.94% 0.10% Tier I & II Baltic Sea North Sea / English Channel

Mediterranean Sea

SEA3 2015 2.94% 0.10% Tier I & II Baltic Sea North Sea / English Channel

Mediterranean Sea

Black Sea

The baseline and SEA1 scenario were also combined w ith reduced emissions for land based emissions

Land

based A 2015 0.05 % S in MD and Gasoil for use by Consumers and A griculture (Abase and ASEA1)

Land

based

B 2015 0.001 % S in MD and Gasoil for use by Consumers and Agriculture (Bbase and BSEA1)Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 11 Table 4.3: Scenario’s for 2020

Scenario Year(s) Max. S

- content

marine fuel

outside SECAs (by mass) Max. S

- content

marine fuel in SECAs (by mass) NO

x Tier

Standards SECA regions

Baseline 2020 2.7 % 1.45% Baseline scenario (Task A 1)

SEA1 2020 2.94% 0.10% Tier I & II,& III 1) Baltic Sea North Sea / English Channel

SEA3 2020 2.94% 0.10% Tier I & II,& III Baltic Sea North Sea / English Channel

Mediterranean Sea

Black Sea

SEA4 2020 0.50% 0.10% Tier I, II & III Baltic Sea North Sea / English Channel

SEA5 2020 0.50% 0.10% Tier I, II & III Baltic Sea North Sea / English Channel

Mediterranean Sea

Black Sea

The SEA4 scenario was also combined with reduced em issions for land based emissions

Land

based A 2020 0.05 % S in MD and Gasoil for use in Consumers and A griculture (ASEA4)

Land

based

B 2020 0.001 % S in MD and Gasoil for use in Consumers and Agriculture (BSEA4)

Note: 1) Simulation of NECA in the Baltic Sea, Nort h Sea/English Channel and the Mediterranean Sea (Ti er III standards for ships

constructed on or after 1 January 2016)

Comparing the scenarios with each other reveals the relative benefits of individual policy measures. F or example, the comparison of SEA1 with SEA2 illustrates the impact of designating the Mediterr anean Sea as SECA, the comparison of SEA1 with SEA3 illustrates the impact of designating the Mediterranean Sea and the Black Sea as SECA, the co mparison of SEA2 with SEA3 illustrates the additional impact of designating the Black Sea as S ECA, etc.

4.2.2 SEA1

The SEA 1 scenario uses the baseline for the land b ased emissions. For the sea based emissions the

maximum S content within SECAs is reduced from the 1.45%, which is the post 2006 standard, to a maximum of 0.1%; the designation of SECAs remain th e same as in the baseline scenario - namely the Baltic Sea and the North Sea/English Channel. It is expected that the additional demand for low sulphu r fuels for use in the SECAs will lead to a shift tow ards high sulphur fuel outside SECAs; a rough estimate, based on the worldwide fuel consumption i n and outside SECAs whereby the total amount of sulphur is kept constant, results in an increase of the current average sulphur content outside SECAs

from 2.7 to 2.9%.

The recently revised 5 IMO standards have been used for the NO

x emissions; for 2020 we have applied the Tier III standards for ships constructed after 1/1/2016 in the Baltic Sea, the North Sea/English

Channel and the Mediterranean Sea areas.

The age distribution of the population of ships has been estimated based on the age distribution of th e world merchant fleet by type of vessel as of 1st Ja nuary 2005 (Source: Chiffi et al 2007, Technical

5 Revised Annex VI of MARPOL and the revised NOx Tec hnical Code adopted in October 2008, these will en ter into force 1 July 2010.Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 12 Annex, Maritime Transport Inventory, Table 2.5). In the absence of better data it has been assumed tha t the age distribution will not change over the perio d up to 2020.

Ships constructed on or after 1 January 1990 but pr ior to 1 January 2000 (and with a displacement ≥ 90 litres per cylinder and rated output ≥ 5000 kW) will be required to comply with the NO

x emission limits in force today, subject to the availability of approve d engine upgrade kit (Tier I). After contacts with marine engine producers MAN and Wärtsila we estimated that about 1/3 of the pre-2000 engines are already in compliance with IMO Tier 1. Thus, for 70% of the sh ips constructed from January 1990 to January 2000 the baseline emission factors have been used, while for the rest of this age cohort Tier 1 emission factors have been applied 6

.

4.2.3 SEA2

The SEA2 scenario only differs from SEA1 in the des ignation of the Mediterranean as a SECA region; it has been calculated for 2015 only.

4.2.4 SEA3

The SEA3 scenario adds the Black Sea as a SECA in c omparison to SEA2. In the scenario run for 2020 it is additionally assumed that the Baltic Sea, the North Sea/English Channel and the Mediterranean wi ll be designated as NO

x Emission Control Areas, in which Tier III standard s apply.

4.2.5 SEA4

For the SEA4 scenario, which has been calculated fo r 2020 only, the sulphur content of fuels used

outside SECAs has been reduced to 0.5%. For the res t SEA4 is comparable to the 2020 run of SEA1, with only the Baltic and the North Sea/English Chan nel designated as SECAs and the Baltic, the North Sea/English Channel and the Mediterranean Sea desig nated as NO

x Emission Control Areas.

4.2.6 SEA5

The SEA5 scenario is the most advanced scenario: Th e sulphur content of fuels used outside SECAs has been reduced to 0.5%; all European seas (except the remaining part of the North Eastern Atlantic Ocean) have been designated as SECAs allowing a max imum sulphur content of 0.1% only. The Baltic Sea, the North Sea/English Channel and the Mediterr anean Sea have been designated as NO

x Emission Control Areas, implying IMO Tier III stand ards.

4.2.7 Land based A

Apart from regulating the quality of fuels used by maritime activities, Directive 1999/32/EC on the reduction of sulphur content of certain liquid fuel s, also covers medium distillates and gasoil used i n small scale combustion on land. Combustion in indus try falls under the large combustion plants directi ve (Directive 94/66/EC ). The current limit for gasoil in the fuel quality di rective is a sulphur content of 0,10 % (since 1 January 2008). Scenario Land based A ass umes a further reduction of the sulphur content used of gasoil by domestic heating and agriculture to 0.05%. As the baseline scenario includes emissions from all European countries, it is necess ary to mention that this reduction only has been applied for the EU27 countries only.

The LandA scenario has been combined with the basel ine sea emissions (ABASE) and the SEA1 scenario (ASEA1).

4.2.8 Land based B

The Land based B scenario takes the reductions a st ep further, limiting the sulphur content of gasoil by domestic heating and agriculture in EU27 to 0.001%. The Land based B scenario has been combined with the baseline sea emissions (Bbase) and the mos t stringent sea scenario SEA4 (BSEA4).

6 This results in a conservative estimate of the NOx emissionsCost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 13 4.2.9 SO 2 emissions in the different scenarios The emission figures for SO 2 in the different areas and scenarios as calculated in this study are summarised in the Tables 4.4.and 4.5. Appendix 2 g ives the detailed emission figures for all scenario s all areas and all pollutants.

Table 4.4 Sulphur dioxide emissions, 2000-2020, a ll scenarios

Baltic Sea Black Sea Remaining NE Atlantic ocean

x 1000

tonnes 2000 2015 2020 2000 2015 2020 2000 2015 2020

baseline 177 149 169 53 82 93 472 730 829

SEA1 10 12 58 90 102 795 903

SEA2 10 12 58 90 102 795 903

SEA3 10 12 2 3 3 795 903

SEA4 10 12 10 15 17 135 154

SEA5 10 12 2 3 3 135 154

Mediterranean Sea North Sea

X 1000

tonnes 2000 2015 2020 2000 2015 2020

baseline 1024 1582 1795 417 351 399

SEA1 1722 1955 24 28

SEA2 59 67 24 28

SEA3 59 67 24 28

SEA4 293 333 24 28

SEA5 59 67 24 28

Note: In SEA1 and SEA2 the sulphur emissions in non -SECAs are higher than in the baseline because it i s assumed that the demand for low sulphur fuels in SECAs will push up the average sulphur content in other seas.

Table 4.5 Sulphur dioxide emissions land based sour ces, baseline and scenarios

x 1000 tonnes 2000 2010 2015 2020

Baseline 16726 10324 9897 9734

Land based A 9851 9694

Land based B 9806 9665

Note: exclusive of emissions related to national ma ritime fuel consumption (e.g. fisheries), which are included in the GAINS-totals Source: GAINS Europe, NEC6, C&E package current poli cyCost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 14 

# 5 Dispersion results; concentrations and

exceedance of critical loads

5.1 Introduction

The LOTOS-EUROS model was used to compute (from the emission data as presented in the previous section) the atmospheric dispersion of ship emissio ns, and their effect on the European distribution o f sulphur- and nitrogen deposition, and on ground-lev el ozone and particulate matter concentrations.

The domain of the LOTOS-EUROS model (Schaap et al., 2005) runs from 10° West till 60° East and from 35° North till 70° North; it covers the whole of Europe (Iceland excluded) with a horizontal resolution of 0.5° latitude x 0.25° longitude (~30x 30 km). In vertical direction it extends to 2-3 km above the surface resolved in four layers: a planetary bo undary layer with a fixed surface layer of 25 metre height, and two reservoir layers on top of the plan etary boundary layer.

The background concentrations (from other parts of the world) are provided by a global model, TM5. Transport is assumed to be by advection and diffusi on and is based on analysed meteorological fields. The dispersion calculation uses1997 meteorology - to stay in line with two preceding studies in 2006 and 2007 concerning the trade of emissions of NO

x and SO 2 ; in addition 1997 was put forward by TNO (and supported by a.o. EMEP) as a year which repres ents an average atmosphere over Europe.

Dry deposition is described via a multiple serial a nd parallel resistance approach (surface-to-air, la minar and turbulent resistance) and wet deposition is des cribed by scavenging rates and precipitation data. The chemistry is based on a modified CBM-IV scheme in combination with a thermodynamic equilibrium module and it describes the chemistry for ozone, ac idification, eutrophication and aerosols.

Anthropogenic emissions of 7 species (NO

x , SO 2, NMVOC, CH 4 , PM 10 , PM 2.5 and NH 3 ) are based on Gains Europe (NEC report Nr. 6). Emissions of the r emaining component CO come from TNO’s own
emission database. Furthermore, the model accounts for natural emissions from trees (isoprene, terpene), and from soil (NO

x ).

The standard output (on an hourly basis) 7 is generated as a longitude-latitude grid which wa s subsequently converted into the EMEP grid. Ecosyste m burden is expressed in terms of the sulphur and nitrogen deposition and the average accumulated exc eedence (AAE) for acidification and eutrophication. The model also delivers: concentrat ions of primary PM 10 and PM 2.5 and secondary species as sulphate, nitrate and ammonium; concentr ations of ground-level ozone are expressed in the four ozone metrics - AOT40c, AOT40f, SOMO35 and ann ual mean.

The results of this modelling exercise will be disc ussed in the next paragraphs. Emphasis is laid on t he comparison between the baseline results and the spe cific scenarios and the difference between the scenarios and changes between 2025 and 2020.

The most relevant results in terms of geographic di stribution over Europe for the exceedence of critic al loads for eutrophication and acidification, the dis tribution of ozone and PM 10 are presented in maps in

7 The model has been used in several model inter-co mparison studies and it shows a good performance (R oemer et al.,

2003; van Loon et al., 2004). It was used in earli er studies on SO 2 and NOx emission trading (Roemer et al., 2006, van Harmelen et al 2007). During the first EU study the model output for 2010 (meteorology: 1997) was comp ared with the results from the EMEP model (See also appendix 3). LOTOS-EUROS showed somewhat (~20%) lower sulphur deposition, mainly caused by differences in the wet deposition. In a current study it appears that the difference in total sulphur deposition over Germany between LOTOS-EUROS and EMEP is very small. The nitrogen deposition is somewhat (+30%) higher in LOTOS-EUROS than in EMEP.

The PM 10 concentrations in LOTOS-EUROS are about a factor o f two lower than the measured values. Underestimati on of PM 10 values is a common problem for nearly all large sc ale models. The problem occurs with the primary PM1 0 concentrations (the part of PM 10 that is emitted directly). Quite a good comparison with measurements is seen for secondary PM 10 (sulphate, nitrate).Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 15 appendix 3. Appendix 4 includes tables of the dispe rsion calculations aggregated to the different EU

member states.

5.2 SEA1

The main feature of this scenario is the lowering o f the sulphur content in the Baltic and the North Sea/English Channel SECAs, and the implementation o f IMO Tier I and II for 2015. These measures result in a reduction of exceedance (level and area ) of the critical load for acidification in all vul nerable areas in Europe. In coastal areas (up to ca 100 km from the coast) of the Baltic and the North Sea the exceedances have been reduced considerably (by up t o 100%) whereas the reduction for inland areas is10-20%. In 2020, compared with 2015, acid deposit ion has further decreased, due to lower NO

x emissions, leading to a larger coastal area that is protected. In inland areas, the gains compared to the

2015 baseline are more limited.

As an effect of implementing IMO Tier I and II, the NO

x emissions decrease in all European seas, resulting in a similar decrease of eutrophication a ll over Europe (0-10%). Larger fractional reduction s are apparent in those coastal zones of the Mediterr anean where shipping is a major source of NO

x and exceedances of critical loads are already low - the absolute reduction, however, is the same as elsewhere in Europe. For 2020 additional reductions are expected as a result of implementing IMO Tier III in the Baltic, the North Sea and the Mediterran ean.

Both in 2015 and 2020, the concentrations of PM 10 are reduced by 20-30% (in the coastal areas around the North Sea, English Channel and Baltic Sea).

PM 10 concentrations in the northern part of Europe decr ease by up to 10 % but in the Mediterranean region PM concentrations rise as a result of increa sing, uncontrolled, sulphur emissions. The increase in sulphur emissions (as sulphate) outweighs the simul taneous decrease in NO

x (as nitrate).

All round the North Sea and the English Channel the concentrations of ozone show an increase, which is the result of the decreasing NO

x emissions due to the introduction of IMO Tier I an d II in a NO

x rich environment. Similar trends in modelled ozone respo nse to a limited decrease of NO

x emissions are

seen in urban environments and other NO

x rich conditions over land. In the Mediterranean, w here NO

x concentrations are much lower, the reduction in NO

x emissions leads to lower ozone concentrations - as expressed by SOMO35 and AOT40f. By 2020 the effect of introducing IMO Tier III can be clearly seen (Annex 2) in the Mediterranean Sea and the Baltic b ut less so in the North Sea because of the higher

ambient NO

x concentration.Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 16 5.3 SEA2 (applies only to 2015)

SEA2 differs from SEA1 in that the Mediterranean Se a too is designated as a SECA. By 2015 this

addition results in an extra reduction of the excee dance of eutrophication by 10% and acidification by

20%. In the Mediterranean area the reductions to eu trophication can be locally larger than 20 %

because maritime NO

x emissions here are a larger determining factor of ambient concentrations of NO

x .

The reduction of PM 10 concentrations in the Mediterranean area is also c onsiderable; on shipping routes in the southern part of the Mediterranean Sea reduc tions up to 70% are seen whereas the

concentrations over the rest of the Mediterranean S ea decrease by 30—40% and in coastal areas up to

20 %.

As a result of the significant reduction of SO 2 emissions, compared to SEA 1, the ozone concentrat ions in the whole Mediterranean area (land and sea) incr ease slightly (see difference between the following maps) as the result of heterogeneous chemistry in w hich sulphur reduction causes a slight increase of nitrogen oxides through the formation of additional N 2 O 5

.Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 17 5.4 SEA3

2015 SEA3, by comparison with SEA2, assumes that the Bla ck Sea is also designated as a SECA. Although this results in a relatively minor additional emiss ion reduction in Europe as a whole, and a negligibl e effect in Western Europe states, the reductions in exceedance of critical loads for acidification and eutrophication in areas close to the Black Sea (Rom ania and Bulgaria) is significant (up to 30% in som e grid cells).

Reduction of PM 10 is only significant over the sea and apart from a small reduction in PM 10 concentrations in Bulgaria it has a very small effe ct over the land. The ozone effect is also small an d resembles that of SEA2 on the Mediterranean area; t he Black Sea, however, is much smaller and the

rise in ozone concentration more limited.

2020

The SEA3 scenario in 2020 includes emission reducti ons (as compared to SEA1) in both the

Mediterranean Sea and the Black Sea. The effects ar e quite comparable to the effects of the two separate reductions combined as discussed under SEA 2 and SEA3 (2015).

5.5 SEA4 (2020 only)

The most important difference in SEA4 from the prec eding scenarios is the lowering of the sulphur

content of fuels used outside SECAs to 0.5%. In SEA 4 the non-SECA areas are the Mediterranean Sea, the Black Sea and the Remaining North-Atlantic. The measures result in a large reduction of the sulphu r emissions in these areas as compared to SEA1 scenar io. For acidification the effect of SEA4 is mainly seen in the UK, which is heavily influenced by the emissions in remaining North-Atlantic. Emission

reduction in the Mediterranean Sea and the Black Se a has little effect in reducing the exceedance of

acidification due to the location and distance of s ensitive ecosystems.

For eutrophication the benefits of SEA4 (as compare d to SEA1) are relatively small since NO

x emissions stay the same.

PM 10 concentrations are lowered as a result of the PM 10 emission reductions following the reduction in sulphur emissions. The largest changes are seen in the coastal areas of the three seas involved.

Due to the marked reduction in sulphur emissions th ere is a slight increase in the ozone (NOTE: this phenomenon was described under SEA2).Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 18 5.6 SEA5 (2020 only)

In SEA5, apart from the lower sulphur content outsi de SECAs, the Baltic, the North Sea/English Channel, the Mediterranean and the Black Sea have b een assumed to be SECAs, resulting in a further reduction of sulphur and PM emissions.

Of all the sea-based scenarios SEA5 yields the leas t exceedance of acidification and eutrophication an d

the lowest PM 10 concentrations. The ozone related parameters are s lightly increased but still less than

with the baseline ozone.

5.7 Land based A

2015

The emission reductions of the land-based measures are relatively small compared to the reductions achieved by most of the marine-based measures. The land-based measures apply only to one of the source categories of sulphur (domestic heating and heating in agriculture). In quite a few countries t his source contributes very little but in others it is larger.

Scenario A results in ~2-3% less sulphur deposition and a small decrease of the exceedance of acidification, the effect on levels of eutrophicati on is really very small, less than 0.5%; the PM 10 concentrations drop about 1% (as a result of less s ulphate formation and less direct PM emissions), an d the effects are negligible for ozone related parame ters.

5.8 Land based B

2015

The land based measures taken under Scenario B are relatively stringent; the reduction in the sulphur deposition is about twice that envisaged under Scen ario A.

Scenario B leads to ~4-6% less sulphur deposition, which results in a rather small decrease of the exceedance of acidification. For eutrophication the effects are less than 0.5%; PM 10 concentrations drop by about 2% (less sulphate and less direct PM emiss ions), and the effects are negligible for ozone related parameters.

5.9 ASEA1-BSEA1-ASEA4-BSEA4

The land based scenarios A and B are combined with the SEA1 scenarios (2015 and 2020) and with the SEA4 scenario (2020). The effects of these scenario s compared to the SEA1 and SEA4 scenarios (without additional land based measures) are as sma ll as the effects of the A and B scenarios in relat ion to the baseline (as discussed in the previous secti on).Cost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 19 

# 6 Benefits assessment

The objective of this stage of the study is to quan tify the health benefits of the scenarios described above in terms of reduced impact, and then to monet ise these benefits in order that they may be compared directly with costs. The focus here is on health impacts because these dominate the quantified (and monetised) benefits assessment. In the event that benefits do not exceed costs it woul d be appropriate to expand the analysis to bring in o ther effects such as those on building materials an d crops. It would also be appropriate to consider in a qualitative way how un-monetisable impacts, such as those on ecosystems and cultural heritage, would be likely to influence the balance of costs and

benefits.

6.1 Background

The benefits assessment model used in this study is ALPHA2 – the Atmospheric Long-range Pollution Health and environment Assessment model, version 2 (Holland et al, 2008). The original version of ALPHA was developed at AEA Technology in the 1990s, drawing extensively on the ExternE research programme, and was used to inform development of th e EC’s Acidification Strategy, the Ozone Directive, the National Emission Ceilings Directive and the Gothenburg Protocol to the UN/ECE Convention on Long Range Transboundary Air Pollutio n. The input data for the ALPHA2 programme are the outcomes of the dispersion modelling report ed in Chapter 5.

6.2 Methodology

The CAFE CBA methodology was described in three vol umes (Holland et al, 2005a, 2005b; Hurley et al, 2005) 8 and can be traced back to the beginning of the EC DG Research ExternE Programme that

started in 1991 and has continued more or less cont inually since. Further to this, the methodology use d here was the subject of intense consultation in 200 3 and 2004 with stakeholders from the European Union Member States, academic institutes, environme nt agencies, industry and non-governmental organisations. It was also subject to formal peer r eview by senior experts in the USA and Europe (the peer review report is available at the above websit e). Further work to refine the model is being carri ed out under the LIFE+ Programme’s EC4MACS Project 9 and the model as used here includes these developments.

The quantification of impacts and their subsequent monetisation follows the ‘impact pathway approach’ as shown in Figure 6.1. It is in essence a logical progression from emission, through dispersion and exposure to quantification of impacts and their val uation

.

8 http://cafe-cba.aeat.com/html/reports.htm

9 http://www.ec4macs.eu/home/reports/Interim%20Metho dology%20Reports/4_BenefitsAssessment_task_8.pdfCost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 20 Figure 6.1. Impact Pathway Approach, illustrated wi th the example of the effects of emissions of NO
x and

VOCs on ozone concentrations and crop yield

Impacts are generally calculated as:

Impact = Pollution x Stock at risk x Response funct ion

Pollution may be expressed in terms of concentratio n or deposition. The term ‘stock at risk’ relates t o the amount of sensitive material (people, ecosystem s, materials, etc.) present in the modelled domain. For the health impact assessment account is taken o f the distribution of population and of effects on demographics within the population, such as childre n, the elderly, or those of working age. Incidence rates considered representative of the rate of occu rrence of different health conditions across Europe are used to modify the stock at risk for each type of impact quantified. These incidence rates ensure that impacts are referenced to actual health data a nd hence should not be of an unrealistic magnitude. The health impacts quantified are listed in Table 6 .1 below. For the CAFE-CBA two sets of response functions were identified, those for which evidence was considered most robust which were grouped as the ‘core’ set and a group for which quantification was considered less robust, referred to as the ‘sensitivity’ set. In this study we start by applyi ng only the ‘core’ set of functions, reserving the ‘sensitivity’ set for the situation in which it cou ld be found that ‘core’ benefits do not exceed cost s.

Valuation is performed as follows:

Economic damage = Impact x Unit value of impact

Unit values seek to describe the full economic effe ct of the impacts that they are linked with. For he alth impacts, for example, which dominate the analysis, this will include elements associated with the cost s of health care, lost productivity amongst workers a nd aversion to premature death or ill health.

A more complete account of the methods used for hea lth impact quantification is provided in Volume 2 of the CAFE methodology (Hurley et al, 2005), thoug h the valuation data used here have been revised for the current study drawing on information from t he EC4MACS work (Table 6.1). The methodological issue that has received most debate over the years is the approach that should be taken to valuation o f mortality, whether it should be performed relative to the loss of life expectancy using the value of a lie year (VOLY) or the number of deaths that can be lin ked to pollution exposure using the value ofCost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 21 statistical life (VSL). Whilst the study team has a strong preference for use of the VOLY, we have us ed

both VOLY and VSL estimates to demonstrate sensitiv ity on this issue.

There are two main differences between the values s hown and those used in the CAFE-CBA work. First, values have been increased in line with pric es for the period 2000 to 2005, reflecting the diff erent price years used in this work compared to CAFE. Sec ond, the value of a life year (VOLY) has been

reduced from € 52,000 to € 40,000 reflecting the results of the recent NEEDS s tudy for EC DG Research. The result of the NEEDS work may be preferred for s everal reasons, including:

• Use of a larger total sample

• Consideration of a larger number of countries (9) compared to the 3 used for the earlier

estimate

• Inclusion of countries from the ‘new’ member state s (Poland, Czech Republic and Hungary) as well as from the original EU15

A further factor is that the mean estimate from the new work was found to be reasonably stable (not influenced by a small number of very large individu al estimates of willingness to pay) and so could be adopted as the best estimate of VOLY. In the earlie r NewExt study (the basis of the previous estimate of

€ 52,000 per VOLY), in contrast, the mean was not sta ble, and so two estimates of the VOLY, representing the mean and the median of the study p opulation, were adopted. Use of a single estimate clearly simplifies the analysis. A problem in basin g the VOLY purely on the results of the NEEDS proje ct is that it pays no attention at all to the results of the NewExt work. A final decision on the VOLY to be recommended under EC4MACS has yet to be made, thoug h it is currently likely that it will seek to

account for both the NewExt and NEEDS results. Basi ng the present analysis only on the NEEDS result leads to a lower estimate of benefits, making it le ss likely that benefits would exceed costs than if a higher VOLY estimate were applied. For the purposes of the current analysis we consider this conservative approach to be appropriate, partly as it makes very little difference to the comparison o f costs and benefits in Chapter 7: a prolonged discus sion here of whether or not a higher value should b e adopted for the VOLY would therefore add nothing to the present study. It is not recommended that the

€ 40k estimate is adopted more widely without further discussion.

The CAFE-CBA also adopted two estimates of the VSL, again reflecting the median and the mean of the study population. However, on reflection, this was considered unnecessary: whilst the NewExt mean for VSL was considered unstable, reference to the w ider European literature on characterisation of the VSL suggests that a best estimate in the region of € 1 million is appropriate.

Table 6.1. List of health impacts quantified with u nit values applied in this analysis. Impact / population group Pollutant Unit value ( € ) Acute Mortality (All ages) O 3 40,000 Respiratory Hospital Admissions (65yr +) O 3 2,364 Minor Restricted Activity Days (MRADs 15-64yr) O 3 42 Respiratory medication use (adults 20yr +) O 3 1 Chronic Mortality (30yr +) - as life years lost PM 2.5 40,000 Chronic Mortality (30yr +) as premature deaths PM 2.5 1,130,000 Infant Mortality (0-1yr) PM 2.5 1,695,000 Chronic Bronchitis (27yr +) PM 2.5 208,000 Respiratory Hospital Admissions (All ages) PM 2.5 2,364 Cardiac Hospital Admissions (All ages) PM 2.5 2,364 Restricted Activity Days (RADs 15-64yr) PM 2.5 97 Respiratory medication use (children 5-14yr) PM 2.5 1 Respiratory medication use (adults 20yr +) PM 2.5 1 Lower Respiratory Symptom days (children 5-14yr) PM 2.5 42 Lower Respiratory Symptom among adults (15yr +) wit h chronic symptoms PM 2.5 42

Uncertainties are of course present in all inputs t o the analysis. Particularly important are those re lating to the response functions used and the valuation da ta. These are accounted for later in the analysisCost benefit analysis to support the impact assessm ent AEA/ED45756/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

AEA 22 when benefits of the scenarios are compared against the costs: uncertainties are only important to the extent that they would change the conclusions drawn from the comparison of costs and benefits

.

6.3 Results

Scenarios are defined in Table 6.2 drawing on infor mation in preceding chapters. Impacts in terms of the change in incidence of ill health, loss of long evity, etc. are shown Table 6.3 for 2015 and in Tab le

6.4 for 2020.

Estimates of monetised morbidity and mortality impa cts for the EU27 are presented in Tables 6.5 and 6.6. Total health impacts are presented as a range, using the four different estimates of total annual damage. The health impacts of air pollution are dom inated by PM mortality, although PM related morbidity is also significant. The most important e ffects (in monetised terms) for PM related morbidit y are restricted activity days and cases of chronic b ronchitis.

Table 6.2. Scenario-run codes

Run Name Description Year

BASE_2015 Base 2015

SEA1_2015 Sea 1 Scenario 2015

SEA2_2015 Sea 2 Scenario 2015

SEA3_2015 Sea 3 Scenario 2015

ABASE1_2015 Land A Scenarios Base 2015

BBASE1_2015 Land B Scenarios Base 2015

AS1_2015 Land A Scenario and Sea 1 2015

BS1_2015 Land B Scenario and Sea 1 2015

BASE_2020 Base 2020

SEA1_2020 Sea 1 Scenario 2020

SEA3_2020 Sea 3 Scenario 2020

SEA4_2020 Sea 4 Scenario 2020

SEA5_2020 Sea 5 Scenario 2020

AS1_2020 Land A Scenario and Sea 1 2020

BS1_2020 Land B Scenario and Sea 1 2020

AS4_2020 Land A Scenario and Sea 4 2020

BS4_2020 Land B Scenario and Sea 4 2020Cost benefit analysis to support the impact assessmentAEA/ED45756/Issue 3accompanying the revision of Directive 1999/32/EC on thesulphur content of certain liquid fuelsAEA23Table 6.3. Estimated annual health impacts in 2015due to air pollution in the EU27End pointPopulationat riskImpactPollutantbase_2015Sea1_2015Sea2_2015Sea3_2015abase1_2015as1_2015bbase1_2015bs1_2015Acute Mortality (All ages) All Premature deathsO322,368 22,047 22,153 22,153 22,366 22,051 22,363 22,054Respiratory Hospital Admissions (65yr +) Elderly CasesO319,078 18,801 18,891 18,891 19,075 18,803 19,073 18,806Minor Restricted Activity Days (MRADs 15-64yr)Adults DaysO348,756,183 48,054,241 48,283,256 48,283,081 48,749,473 48,061,760 48,742,322 48,069,976Respiratory medication use (adults 20yr +) Adults DaysO38,920,808 8,791,789 8,834,138 8,834,103 8,919,611 8,793,172 8,918,283 8,794,675Chronic Mortality (All ages) All Life years lostPM2.52,153,682 2,032,021 1,979,544 1,977,795 2,147,341 2,025,435 2,141,099 2,018,649Chronic Mortality (30yr +) Infants Premature deathsPM2.5221,810 209,851 204,017 203,810 221,164 209,178 220,525 208,491Infant Mortality (0-1yr) Adults Premature deathsPM2.5362 344 337 336 361 343 360 342Chronic Bronchitis (27yr +) All CasesPM2.5105,552 99,769 97,096 97,007 105,244 99,449 104,94199,122Respiratory Hospital Admissions (All ages) All CasesPM2.535,800 33,777 32,905 32,876 35,694 33,668 35,590 33,555Cardiac Hospital Admissions (All ages) Adults CasesPM2.522,079 20,832 20,294 20,276 22,014 20,764 21,950 20,695Restricted Activity Days (RADs 15-64yr) Children DaysPM2.5195,942,769 184,937,515 180,227,493 180,058,414 195,373,880 184,346,764 194,814,191 183,738,495Respiratory medication use (children 5-14yr) AdultsDaysPM2.51,813,697 1,702,016 1,660,289 1,659,437 1,808,029 1,696,144 1,802,545 1,690,067Respiratory medication use (adults 20yr +) ChildrenDaysPM2.517,371,218 16,406,775 15,976,148 15,961,648 17,320,399 16,353,956 17,270,283 16,299,718LRS symptom days (children 5-14yr) Adults DaysPM2.581,377,920 76,544,732 74,661,618 74,603,414 81,132,661 76,290,976 80,893,458 76,026,855LRS among adults (15yr +) with chronicsymptomsAll DaysPM2.5173,956,597 164,208,588 159,928,445 159,785,506 173,446,398 163,678,293 172,943,386 163,132,904Note: Results are rounded to the nearest 100.Cost benefit analysis to support the impact assessmentAEA/ED45756/Issue 3accompanying the revision of Directive 1999/32/EC on thesulphur content of certain liquid fuelsAEA24Table 6.4. Estimated annual health impacts in 2020due to air pollution in the EU27End pointPopulation atriskImpactPollutantbase_2020Sea1_2020Sea3_2020Sea4_2020Sea5_2020as1_2020as4_2020bs1_2020bs4_2020Acute Mortality (All ages) AllPrematuredeathsO322,244 21,417 21,539 21,567 21,598 21,418 21,569 21,420 21,571Respiratory Hospital Admissions (65yr +) Elderly CasesO321,059 20,272 20,387 20,413 20,442 20,273 20,415 20,275 20,416Minor Restricted Activity Days (MRADs 15-64yr)Adults DaysO345,487,097 43,798,565 44,045,892 44,109,754 44,173,452 43,800,727 44,112,882 43,803,714 44,116,542Respiratory medication use (adults 20yr +) Adults DaysO38,722,895 8,398,086 8,445,792 8,457,617 8,469,909 8,398,511 8,458,240 8,399,083 8,458,951Chronic Mortality (All ages) All Life years lostPM2.52,006,114 1,844,775 1,784,037 1,766,272 1,756,678 1,839,089 1,760,318 1,835,106 1,756,075Chronic Mortality (30yr +) InfantsPrematuredeathsPM2.5213,937 197,499 190,441 188,774 187,660 196,898 188,143 196,476 187,697Infant Mortality (0-1yr) AdultsPrematuredeathsPM2.5316 293 285 282 281 292 282 292 281Chronic Bronchitis (27yr +) All CasesPM2.5101,238 93,329 90,158 89,302 88,801 93,046 89,006 92,848 88,795Respiratory Hospital Admissions (All ages) All CasesPM2.533,347 30,665 29,655 29,360 29,200 30,570 29,261 30,504 29,190Cardiac Hospital Admissions (All ages) Adults CasesPM2.520,566 18,912 18,289 18,107 18,009 18,854 18,046 18,813 18,003Restricted Activity Days (RADs 15-64yr) Children DaysPM2.5176,608,196 162,476,303 157,154,649 155,558,842 154,718,078 161,982,356 155,042,361 161,636,335 154,673,511Respiratory medication use (children 5-14yr)Adults DaysPM2.51,558,598 1,422,846 1,379,585 1,362,086 1,355,244 1,418,167 1,357,160 1,414,908 1,353,645Respiratory medication use (adults 20yr +) ChildrenDaysPM2.516,466,061 15,161,445 14,654,192 14,512,750 14,432,597 15,115,158 14,464,269 15,082,675 14,429,751LRS symptom days (children 5-14yr) Adults DaysPM2.570,418,108 64,527,840 62,543,893 61,835,829 61,523,051 64,323,547 61,621,863 64,181,827 61,468,607LRS among adults (15yr +) with chronicsymptomsAll DaysPM2.5163,596,876 150,535,695 145,515,226 144,094,510 143,301,342 150,073,885 143,610,879 149,749,932 143,266,489Note: Results are rounded to the nearest 100.Cost benefit analysis to support the impact assessmentAEA/ED45756/Issue 3accompanying the revision of Directive 1999/32/EC on thesulphur content of certain liquid fuelsAEA25Table 6.5. Monetised annual health impacts under each scenario in 2015 in the EU27 (€billion)End PointPollBASE_2015SEA1_2015SEA2_2015SEA 3_2015AS1_2015BS1_2015Acute Mortality (All ages) O30.89 0.88 0.89 0.89 0.880.88Respiratory Hospital Admissions (65yr +) O30.05 0.04 0.04 0.04 0.040.04Minor Restricted Activity Days (MRADs 15-64yr) O32.05 2.02 2.03 2.03 2.022.02Respiratory medication use (adults 20yr +) O30.01 0.01 0.01 0.01 0.010.01Total O3 Mortality3.002.952.972.972.952.95Chronic Mortality (30 yr+) VOLY valuation PM2.586.15 81.28 79.18 79.11 81.0280.75Chronic Mortality (30yr +) VSL valuation PM2.5250.65 237.13 230.54 230.31 236.37235.6Infant Mortality (0-1yr) PM2.50.61 0.58 0.57 0.57 0.580.58Chronic Bronchitis (27yr +) PM2.521.95 20.75 20.2 20.18 20.6920.62Respiratory Hospital Admissions (All ages) PM2.50.08 0.08 0.08 0.08 0.080.08Cardiac Hospital Admissions (All ages) PM2.50.05 0.05 0.05 0.05 0.050.05Restricted Activity Days (RADs 15-64yr) PM2.519.01 17.94 17.48 17.47 17.8817.82Respiratory medication use (children 5-14yr) PM2.50.002 0.002 0.002 0.002 0.002 0.002Respiratory medication use (adults 20yr +) PM2.50.02 0.02 0.02 0.02 0.020.02LRS symptom days (children 5-14yr) PM2.53.42 3.21 3.14 3.13 3.23.19LRS among adults (15yr +) with chronic symptoms PM2.57.31 6.9 6.72 6.71 6.876.85Total PM damage (low, VOLY valuation)139131127127130130Total PM damage high, VSL valuation)303287279279286285Total PM+O3 damage high, VSL valuation)142134130130133133Total PM+O3 damage (low, VOLY valuation)306290282281289288Cost benefit analysis to support the impact assessmentAEA/ED45756/Issue 3accompanying the revision of Directive 1999/32/EC on thesulphur content of certain liquid fuelsAEA26Table 6. 6. Monetised annual health impacts under each scenario in 2020 in the EU27 (€billion)End PointPollbase_2020SEA1_2020SEA 3_2020SEA4_2020SEA 5_2020AS1_2020AS4_2020BS1_2020BS4_2020Acute Mortality (All ages) O30.890.860.860.860.860.860.860.860.86Respiratory Hospital Admissions (65yr +) O30.050.050.050.050.050.050.050.050.05Minor Restricted Activity Days (MRADs15-64yr)O31.911.841.851.851.861.841.851.841.85Respiratory medication use (adults 20yr+)O30.010.010.010.010.010.010.010.010.01Total O3 Mortality2.862.752.772.772.782.752.772.752.77Chronic Mortality (30 yr+) VOLYvaluationPM2.580.2473.7971.3670.6570.2773.5670.4173.4070.24Chronic Mortality (30yr +) VSL valuation PM2.5241.75223.17215.20213.31212.06222.50212.60222.02212.10Infant Mortality (0-1yr) PM2.50.540.500.480.480.480.500.480.490.48Chronic Bronchitis (27yr +) PM2.521.0619.4118.7518.5718.4719.3518.5119.3118.47Respiratory Hospital Admissions (Allages)PM2.50.080.070.070.070.070.070.070.070.07Cardiac Hospital Admissions (All ages) PM2.50.050.040.040.040.040.040.040.040.04Restricted Activity Days (RADs 15-64yr) PM2.517.1315.7615.2415.0915.0115.7115.0415.6815.00Respiratory medication use (children 5-14yr)PM2.50.0020.0010.0010.0010.0010.0010.0010.0010.001Respiratory medication use (adults 20yr+)PM2.50.020.020.010.010.010.020.010.020.01LRS symptom days (children 5-14yr) PM2.52.962.712.632.602.582.702.592.702.58LRS among adults (15yr +) with chronicsymptomsPM2.56.876.326.116.056.026.306.036.296.02Total PM damage (low, VOLYvaluation)129119115114113118113118113Total PM damage high, VSL valuation)290268259256255267255267255Total PM+O3 damage high, VSLvaluation)132121117116116121116121116Total PM+O3 damage (low, VOLYvaluation)293271261259258270258269258Cost benefit analysis to support the impact assessmentAEA/ED45756/Issue 3accompanying the revision of Directive 1999/32/EC on thesulphur content of certain liquid fuelsAEA27Table 6.7. Monetised annual health benefits compared to the relevant baseline under each scenario in 2015 in the EU27 (€billion)End pointPollutantSEA1_2015SEA2_2015SEA3_2015AS1_2015BS1_2015Acute Mortality (All ages) O30.010.010.010.01 0.01Respiratory Hospital Admissions (65yr +) O30.000.000.000.00 0.00Minor Restricted Activity Days (MRADs 15-64yr) O30.030.020.020.03 0.03Respiratory medication use (adults 20yr +) O30.000.000.000.00 0.00Total ozone benefit0.040.030.030.040.04Chronic Mortality (30 yr+) VOLY valuation* PM2.54.876.977.040.25 5.13Chronic Mortality (30yr +) VSL valuation* PM2.513.5120.1120.340.73 14.27Infant Mortality (0-1yr) PM2.50.030.040.040.00 0.03Chronic Bronchitis (27yr +) PM2.51.201.761.780.06 1.27Respiratory Hospital Admissions (All ages) PM2.50.000.010.010.00 0.01Cardiac Hospital Admissions (All ages) PM2.50.000.000.000.00 0.00Restricted Activity Days (RADs 15-64yr) PM2.51.071.521.540.06 1.12Respiratory medication use (children 5-14yr) PM2.50.000.000.000.00 0.00Respiratory medication use (adults 20yr +) PM2.50.000.000.000.00 0.00LRS symptom days (children 5-14yr) PM2.50.200.280.280.01 0.21LRS among adults (15yr +) with chronic symptoms PM2.50.410.590.600.02 0.43Total PM benefit (low, VOLY valuation)7.7911.1811.298.218.65Total PM benefit (high, VSL valuation)16.4424.3224.5917.3618.29Total PM+O3 benefit (low, VOLY valuation)7.8311.2011.328.258.69Total PM+O3 benefit (high, VSL valuation)16.4824.3524.6217.4018.34Cost benefit analysis to support the impact assessmentAEA/ED45756/Issue 3accompanying the revision of Directive 1999/32/EC on thesulphur content of certain liquid fuelsAEA28Table 6.8. Monetised annual health benefits compared to the relevant baseline under each scenario in 2020 in the EU27 (€billion)End pointPollutantSea1_2020Sea3_2020Sea4_2020Sea5_2020as1_2020as4_2020bs1_2020bs4_2020Acute Mortality (All ages) O30.03 0.030.030.03 0.03 0.03 0.030.03Respiratory Hospital Admissions (65yr +) O30.00 0.000.000.00 0.00 0.00 0.000.00Minor Restricted Activity Days (MRADs 15-64yr) O30.07 0.060.060.06 0.07 0.06 0.070.06Respiratory medication use (adults 20yr +) O30.00 0.000.000.00 0.00 0.00 0.000.00Total ozone benefit0.110.090.090.080.110.090.110.09Chronic Mortality (30 yr+) VOLY valuation* PM2.56.45 8.889.599.98 6.68 9.83 6.8410.00Chronic Mortality (30yr +) VSL valuation* PM2.518.58 26.5528.4329.69 19.25 29.15 19.7329.65Infant Mortality (0-1yr) PM2.50.04 0.050.060.06 0.04 0.06 0.040.06Chronic Bronchitis (27yr +) PM2.51.65 2.302.482.59 1.70 2.54 1.752.59Respiratory Hospital Admissions (All ages) PM2.50.01 0.010.010.01 0.01 0.01 0.010.01Cardiac Hospital Admissions (All ages) PM2.50.00 0.010.010.01 0.00 0.01 0.000.01Restricted Activity Days (RADs 15-64yr) PM2.51.37 1.892.042.12 1.42 2.09 1.452.13Respiratory medication use (children 5-14yr) PM2.50.00 0.000.000.00 0.00 0.00 0.000.00Respiratory medication use (adults 20yr +) PM2.50.00 0.000.000.00 0.00 0.00 0.000.00LRS symptom days (children 5-14yr) PM2.50.25 0.330.360.37 0.26 0.37 0.260.38LRS among adults (15yr +) with chronic symptoms PM2.50.55 0.760.820.85 0.57 0.84 0.580.85Total PM benefit (low, VOLY valuation)10.3214.2315.3715.9910.6815.7510.9316.02Total PM benefit (high, VSL valuation)22.4431.9034.2135.7123.2535.0723.8335.68Total PM+O3 benefit (low, VOLY valuation)10.4214.3215.4616.0710.7915.8411.0416.11Total PM+O3 benefit (high, VSL valuation)22.5431.9934.3035.7923.3635.1623.9335.76*Alternative estimates, not to be combined

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 29 In addition to the impacts by scenario, a key consi deration is the location of the benefits that arise

from each scenario.

The following tables demonstrate the health benefit s in Euros millions (high, VSL valuation) by Member State against the baseline case in 2015 and 2020. These results are roughly twice as large as the equivalent results based on use of the VOLY for mortality valuation. The main purpose of these tables is to demonstrate the way t hat benefits are distributed across Member States. An overview of the impact by scenario is p rovided below:

SEA 1 The impacts under SEA1 are primarily felt by those Member States that are closely located to the North Sea/English Channel, with the greatest impact s being experienced in the United Kingdom, Germany, France and Netherlands. This is in part dr iven by the SECA and the high population densities of the Member States. There are also sign ificant health benefits around Baltic Sea, the other SECA region.

SEA 2

Under the SEA2 scenario the Mediterranean Sea also becomes a SECA region. This impact is seen immediately with significant health benefits b eing seen in Italy, Greece and Spain. France also experiences higher health benefits from the ne w SECA.

SEA 3 Under the SEA3 scenario, the Black Sea now becomes a SECA. The result of the scenario increases the health benefits in Bulgaria, Romania, and Greece. However, the impact under SEA 3 is minimal to the change occurring under SEA1 and SEA2

AS1 and BS1

The AS1 scenario includes SEA 1 and the land based scenario (0.05% S). The difference against

the SEA1 scenario is a € 400m increase, compared to the changes in sea scena rio only. This results in slightly higher health benefits in Germa ny, France, Italy, Netherlands, Belgium, Poland and the United Kingdom.

The BS1 scenario includes SEA 1 and the more restri ctive land based scenario (0.001% S). The overall impact is almost double (approximately € 800m increase) that of the impact of AS1 against SEA1 (approximately € 400m increase). The impact occurs primarily in the same countries as

identified under AS1.

AS4 and BS4 (2020 only)

The AS4 scenario includes SEA 4 and the land based scenario (0.05% S). The difference against the SEA1 scenario is again minimal € 400m increase, compared to the changes in sea scena rio only. This results in slightly higher health benefi ts in Germany, France, Italy, Netherlands, Belgium, Poland and the United Kingdom.

The BS4 scenario includes SEA 4 and the more restri ctive land based scenario (0.001% S). The overall impact is almost is an increase of approxim ately € 300m against the AS4 scenario. The impact occurs primarily in the same countries as id entified under AS4

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 30 Table 6.9 Member State Net Benefits by Scenario ( € Million) - (high, VSL valuation)

Member State SEA1_2015 SEA2_2015 SEA3_2015 AS1_2015 BS1_2015

Austria 121 176 176 134 151

Belgium 891 910 911 957 1,007

Bulgaria 30 127 202 33 37

Cyprus 0 8 8 0 0

Czech Republic 192 250 250 209 227

Denmark 675 690 690 681 689

Estonia 34 36 36 35 35

Finland 73 77 77 73 75

France 1,827 2,372 2,370 1,972 2,147

Germany 3,605 3,782 3,786 3,870 4,145

Greece -6 1,133 1,166 8 24

Hungary 152 237 238 165 179

Ireland 89 91 91 94 100

Italy 501 3,714 3,716 593 676

Latvia 33 36 36 33 34

Lithuania 122 131 131 124 126

Luxembourg 11 12 12 12 13

Malta -2 45 45 -2 -2

Netherlands 1,774 1,800 1,798 1,829 1,881

Poland 1,074 1,222 1,226 1,125 1,186

Portugal 1 141 141 6 7

Romania 134 257 418 151 163

Slovakia 63 92 93 68 74

Slovenia 21 37 37 25 27

Spain 92 1,956 1,951 145 154

Sweden 470 483 483 471 481

United Kingdom 4,500 4,530 4,536 4,586 4,702

Grand Total 16,480 24,345 24,624 17,399 18,337

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 31 Table 6.10 Member State Net Benefits by Scenario ( € Million) – 2020, (high, VSL valuation)

Member

State SEA1_20

20 SEA3_20

20 SEA4_20

20 SEA5_20

20 AS1_20

20 AS4_20

20 BS1_20

20 BS4_20

20

Austria 182 247 252 264 194 266 204 273

Belgium 1,197 1,220 1,290 1,291 1,247 1,341 1,282 1,378

Bulgaria 60 252 226 254 62 231 64 233

Cyprus 0 10 9 10 1 9 1 9

Czech Republic 267 334 345 356 280 361 293 372

Denmark 851 866 886 889 856 892 861 897

Estonia 40 42 43 43 41 43 41 44

Finland 90 94 95 96 90 96 91 96

France 2,486 3,132 3,395 3,491 2,621 3,543 2,707 3,647

Germany 4,914 5,121 5,468 5,512 5,138 5,701 5,298 5,848

Greece 22 1,394 1,193 1,399 39 1,210 52 1,223

Hungary 192 295 289 303 208 300 213 307

Ireland 120 123 254 255 126 261 132 267

Italy 1,035 4,732 4,270 4,843 1,122 4,362 1,195 4,438

Latvia 39 42 43 43 40 43 40 43

Lithuania 153 166 172 175 154 174 156 175

Luxembo

urg 16 16 18 18 17 19 18 19

Malta -1 57 48 57 0 48 0 49

Netherlan

ds 2,378 2,408 2,540 2,545 2,427 2,592 2,456 2,623

Poland 1,421 1,594 1,647 1,676 1,472 1,698 1,502 1,739

Portugal 16 162 632 650 20 637 22 643

Romania 211 534 498 547 228 509 237 517

Slovakia 0 0 0 0 0 0 0 0

Slovenia 28 47 46 48 30 49 33 50

Spain 299 2,480 2,881 3,247 321 2,923 338 2,938

Sweden 577 594 605 611 583 610 585 614

United Kingdom 5,860 5,909 7,032 7,038 5,951 7,110 6,017 7,188

Grand

Total 22,456 31,871 34,178 35,662 23,267 35,030 23,837 35,630



### Results by Member State are shown graphically by Me mber State in Appendix 2.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 32 Benefits outside of the EU27

In addition to the EU27 Member States the ALPHA mod el also includes the following 4 additional countries:

• Croatia

• Norway

• Switzerland

• Turkey The impact of the additional countries differs by s cenario. However the additional 4 countries if included in the analysis are able to contribute an additional € 1.3billion in health benefits under the SEA3 Scenario 2020, equating to an additional 9% be nefit (low, VOLY valuation). The reason for the additional health benefits under SEA3 in partic ular is the result of the additional SECA regions; Mediterranean and Black Seas. This is comb ined with the high population densities that exist in Turkey that result in a net benefit of app roximately € 1.27bn under this scenario.

The health impacts in Croatia, Norway and Switzerla nd are minor and are each comparable to the results demonstrated by Slovakia. There is only a minor change in the results by scenario as a result of having relatively small populations.

The table below demonstrates the additional impact for countries outside the European Union. The results in this table can be compared against T able 6.10.

Table 6.11 Member State Net Benefits by Scenario ( € Million) – 2020, (high, VSL valuation)

Member State SEA1_2020 SEA3_2020 SEA4_2020 SEA5_2020 AS1_2020 AS4_2020 BS1_2020 BS4_2020

Croatia 59 133 127 138 65 132 67 135

Norway 29 29 31 33 29 33 29 33

Switzerland 129 157 173 176 141 183 148 191

Turkey 141 2,171 1,882 2,183 159 1,893 169 1,904

Total 358 2,490 2,214 2,530 393 2,240 413 2,262

Total EU27 22,456 31,871 34,178 35,662 23,267 35,030 23,837 35,630

Total EU27 +4 22,814 34,361 36,392 38,193 23,661 37,270 24,250 37,892

Difference 1.6% 7.8% 6.5% 7.1% 1.7% 6.4% 1.7% 6.3%

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 33 Summary

A summary of the net health benefits, against the b aselines are provided below. These figures of course omit benefits arising from effects on other receptors including ecosystems, agriculture and buildings including cultural heritage.

Table 6.12. The range of total health benefits rela tive to baseline for the EU27, € billions



### Run Name Net Health Benefit Range (2015) Net Health Benefit Range (2020)

SEA1 8 to 16 10 to 23



### SEA2 11 to 24

- 

### SEA3 11 to 25 14 to 32



### SEA4 - 15 to 34



### SEA5 - 16 to 36



### AS1 9 to 17 11 to 23



### BS1 9 to 18 16 to 35



### AS4

- 11 to 24



### BS4

- 16 to 36

Note: Low = VOLY valuation, High = VSL Valuation

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 34 

# 7 Cost analysis of the new IMO marine fuel and engine standards and a potential

extension of emission control areas

This section of the report estimates the cost impac t of the new IMO marine fuel and engine standards and potential extension of the Sulphur Em ission Control Areas. Furthermore, the costs for

stricter control of NO

x 

### emissions from shipping are explored.

The scenarios developed are aimed at illustrating t he impact of varying the stringency of emission controls in the sea regions under consideration. I n the cost analysis, the scenarios represent altering either: the SO 2 

### content of fuels (thereby changing the fuel costs) or introducing SO 2 

### abatement technology (scrubbers), as well as the in troduction of NO X 

### control technologies classified into Tier I, II and III emission standar ds.

7.1 Cost calculation method description

The cost calculations for NO X 

### and SO 2 

### abatement from shipping in this report have two pa rts. The first part consists of calculating unit costs for t he abatement option under consideration. In the second part scenario specific costs are calculated - based on the penetration of low-NO X

### and lowSO 2 

### technology options. The cost calculations are pres ented in low and high cost settings. In the calculations, technologies that may, but are not ce rtain to, reach the emission reduction levels stipulated by the Tier standards are considered. Th e calculations also allow for scenario comparison between closed loop scrubbers, open scru bbers and low sulphur fuels.

The unit costs are calculated per petajoule (PJ), c orresponding to the heat of combustion of the fuel used, for each fuel and engine category. The u nit costs are based on the costs for installation, maintenance, operation and fuel penal ties for using the equipment. These costs take into consideration the relevant technology-specific cost parameters. Furthermore, the technologies and associated costs are split into th e NO X 

### emission standard categories Tier I, Tier II and Tier III, as well as between retrofitted and new scrubbers. In the scenario where low sulphur fuel is used instead of scrubbers, the cost s for SO 2 

### emission abatement are calculated as the difference in costs between the high and low fu el qualities. The costs are subject to scenariospecific estimates on hours of use for the technolo gies. In this report scenario-specific operating hours are of specific relevance for sulphur scrubbi ng options - because the regions considered as

SECA varies between scenarios. For NO X 

### , the Tier III technologies are for all relevant sc enarios implemented in the Baltic, Mediterranean, and North Seas.

For each scenario, costs are calculated, specifying high and low costs estimates for NO X 

### and SO 2 

### abatement. For SO 2 

### abatement, separate cost calculations are presente d for scrubber costs and

low S-fuel costs.

All costs are given in € 2005 

### . Adjustments of literature values and expert est imate values to inflation and currency exchange rates have been mad e when necessary. In the central analysis, a

4 % investment interest rate has been used.

In obtaining the costs the following economic assum ptions have been made:

The dynamics of supply / demand on price have not b een considered

. The actual price of fuels or emission abatement equ ipment is dependent on the future market price for the equipment. The costs estimates given in this study represent the costs that are found today, and do not adjust for the future market pric es.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 35 The economies of scale are unknown and so have not been considered The prices given in this report are all based on fa irly small production volumes of abatement equipment. Given that emission standards become mor e strict by 2016 and 2020, the market volume for abatement technologies will increase, th is may lead to lower unit prices due to learning and economies of scale. This effect is not taken into account in this report.

No price effects on demand for transport or transpo rt modal shifts have been considered. This report does not consider any modal shifts away from marine shipping as a consequence of increased shipping prices following costs for intro ducing emission abatement.

7.2 Abatement Technology Description

This section briefly describes the technical option s for implementing regulations for SO 2 

### emissions to meet the standards corresponding to 0. 1 and 0.5% S in the fuel. Further, different options to reach Tier II and Tier III NO X 

### emissions are described. The costs for the differe nt abatement options are discussed below.

Sulphur oxide abatement

Low sulphur fuel The emission of sulphur dioxide is directly proport ional to the sulphur content in the fuel, the sulphur is oxidised in the combustion chamber and t he mass of emitted SO 2 

### is twice that of the sulphur (S) in the fuel used. Thus, a reduction in the S-content in the fuel can, in principle, meet the lower emissions sought. Most of the high sulphu r fuel (with a sulphur content of 1-3.5%) used in ships today is heavy fuel oil or residual fuel. The fuel currently available with 0.1% S is typical ly marine gasoil; it is likely that the fuel with this sulphur content, which will be required in SECA areas after 2015, will be similar to it. Fuel with a sulphur content of 0.5% can be residual fuel that has been de-sulphurised or marine diesel formulated from a mixture of residual oil and distillates. Purvin & Gertz (2009) have described a number of sc enarios in which the quality of the 0.5% S fuel varies; the lowest priced fuel in that study h ad a high content of heavy oils.

Scrubbers An alternative low sulphur fuel is to use an abatem ent technology which reduces the SO 2 

### emissions by an equivalent amount. While several te chnologies might be discussed well established data is only available for wet scrubbin g – a technique widely used for SO2 reduction from land based combustion plants. The principle of operation is that the exhaust gas is brought into contact with water with a buffered alkalinity such that SO 2 

### is trapped and converted to sulphate ions.

Scrubbers for marine applications can be divided in to open (seawater) scrubbers and closed (freshwater) scrubbers. The former utilises the nat ural alkalinity of sea water for the scrubbing and neutralisation process, the residual SO 2 

### emission following scrubbing depend on the sulphur content of the fuel, the pH of the seawater and the flows of exhaust and scrubber water. These systems have been shown to achieve a high efficienc y of SO 2 

### emissions reduction. There are certain wash-water criteria which likely can be met in the future (and the sea water may require treatment before being returned to sea). The system s may also be custom designed for specified geographical areas and fuel qualities, i.e., areas with low alkalinity could be excluded and there could be specified maximum sulphur content in the f uel used. The closed scrubbers use freshwater with an added neutralising agent (normal ly caustic soda); these systems have been

demonstrated to meet the emission criteria and the wash-water criteria. In the future it is anticipated that combined systems will be developed where seawater is used in open waters with a strong buffering capacity together with a closed loop operational mode for use in ports,

estuaries and seas with brackish water.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 36 Nitrogen oxides

Marine engine manufacturers will be able to meet th e Tier II specifications from 2011 for new engines by improving the control of fuel injection and other engine related modifications. There are several, different, options for meeting the Tie r III specifications - from 2016. The main approaches are based either on selective catalytic reduction (SCR) or exhaust gas recirculation (EGR) in combination with other measures. SCR has a lready been demonstrated to reach Tier III emission levels on many ships while the EGR alterna tives are still in the development phase.

SCR In SCR a reducing agent, normally urea, is mixed wi th the exhaust gases in the presence of a catalyst. For marine applications the catalyst is u sually composed of vanadium and titanium oxides. Under these conditions the urea is decompos ed to ammonia which then selectivity reacts with nitrogen oxides to produce nitrogen gas. The S CR systems require a minimum exhaust gas temperature to operate effectively, this is normall y around 300 °C but the temperature depends on the sulphur content of the fuel. Consequently SC R is less effective at low loads and for twostroke engines; in these cases it may be necessary to put the SCR between the cylinders and the turbo in order to achieve the required temperature. The SCR operational costs include: urea purchase and catalyst replacement; in practice cata lysts need to be replaced after a few years due to deactivation - likely to have been caused by : the formation of sulphur compounds, impurities in the urea, or by thermal deactivation. On the other hand the reduction of nitrogen oxides in the SCR is so effective that the engine m ay be tuned for low fuel consumption with increased engine NO X 

### emissions thus saving some fuel. The SCR system mu st, however, be designed to avoid slip of ammonia with the exhaust - this can be achieved by means of an oxidation catalyst after the SCR.

EGR/engine combinations Alternatives to SCR are being developed to reach Ti er III. While engines can be modified through improved fuel injection systems and improved turbo systems these alone will not be enough to reach Tier III and so additional methods are requir ed. The main track seems to be to use exhaust gas recirculation (EGR) in combination with other t echniques. EGR means that some of the exhaust is re-circulated into the engine leading to lower cylinder temperatures and reduce

formation/emission of NO X 

### . The potential for NO X

### reduction is likely to be around 50%. The recirculated gas must not contain excessively high co ncentration of SO 2 

### or soot. Therefore a low sulphur fuel (around 0.1%) would be needed or alter natively exhaust cleaning integrated with the circulation system - this could be either a scrubbe r or a particulate filter (if low sulphur fuel is used); EGR may also impose a fuel consumption penal ty. In order to reach Tier III EGR may have to be combined with some other technique - in all likelihood direct water injection (DWI), or use of a fuel-water emulsion. These methods may req uire freshwater - implying a further fuel penalty, there may also be a practical limit on the maximum sulphur content in the fuel.

Tier I-III

In the cost calculations two alternative means are used to reach Tier III - SCR and EGR in combination with engine modifications and DWI (simi lar costs are expected with water emulsion instead of DWI). Tier II is assumed to be reached b y engine modifications. Retrofit costs for Tier0 engines produced between 1990 and 2000 to reach Tie r I standards have also been estimated.

Compatibility As mentioned above there are problems with using hi gh sulphur fuel in combination with NO X 

### abatement technologies. EGR requires very low sulph ur content in the fuel or an internal scrubber. SCR performance can fall away due to cata lyst poisoning with high sulphur fuel and the techniques using water injection or emulsion may al so impose limits on the fuel sulphur content. Consequently there are unresolved design issues wit h combining NO X 

### reduction techniques with

scrubbers: if scrubbers are combined with SCR the e xhaust gas may need to be reheated after the scrubber to reach the operating temperature of the SCR, if the SCR is put in front of the scrubber it will be exposed to a high sulphur gas.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 37 7.3 Unit abatement costs

The abatement costs are presented as costs per peta joule of the heat value for the fuel used (PJ); the costs are also presented as costs per to nne emission reduced - to facilitate comparison

with other cost estimates. The costs for the differ ent control standards are dependent on which technology can reach these standards. Abatement cos ts have been calculated for NO X 

### and SO 2 

### abatement using previous literature values (Entec 2005, UK Maritime and Coastguard Agen cy 2009, US-EPA 2009) and information resulting from d irect communications with main engine and equipment manufacturers,.

Sulphur oxides In order to calculate costs for reducing sulphur em issions the following options have been

considered:

Table 7.1: SO 2 abatement options


### SO 2 

### Comment

New Scrubber In combination with high sulphur fuel (2.94 % )

Retrofit Scrubber In combination with high sulphur fuel (2.94 % ) Low sulphur HF, 0.5 % - Low sulphur MD, 0.1 % -

The scenarios developed in this study separate cost s for scrubbers from costs of low sulphur fuels. The following text presents the costs for fu el shifts and scrubbers respectively.

Fuels The costs of fuel shifts depend mainly on the proje cted future fuel prices for different sulphur categories. The main parameters influencing the cos ts of fuel relate to sulphur content of crude oils as well as the necessary investments in refine ry capacities. The vessels using the fuels are assumed to be subject to the relatively small costs of adapting to the different fuels. The fuel costs used in this report are based on the fuel pri ce projections in Purvin & Gertz (2009). The fuel shift costs, specified as a cost per PJ of heat val ue in the fuel is given in the table below:

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 38 Table 7-2: Fuel costs in 2020, adapted from Purvin & Gertz, 2009 and corresponding SO 2 associated
abatement cost.



### Option (%S in fuel) Low

cost [$ / tonne] High cost

[$ / tonne] Low cost

[k € 2005 

### / PJ] High

cost [k € 2005 

### / PJ] Low SO 2



### abatement cost [ € /

ton SO 2 

### ] Low SO 2



### abatement cost [ € /

ton SO 2 

### ]

Fuel shift (2.94 → 1.5) 20 20 359 359 510 510

Fuel shift (2.94 → 1) 30 30 538 538 568 568

Fuel shift (2.94 → 0.5) 120 170 2 152 3 049 1 806 2 559

Fuel shift (2.94 → 0.1) 280 330 4 510 5 370 3 621 4 268

Fuel shift (0.5 → 0.1) 160 160 2 753 2 753 14 692 14 692

The fuel cost for heavy fuel with 2.94 % sulphur co ntent is projected to be $ 420 / tonne in Purvin & Gertz 2009. The fuel costs per tonne are converte d to costs per PJ by considering the specific

heat value of the fuel and the conversion rate betw een euro and dollar.

Scrubbers The most important parameters deciding the costs fo r scrubbers are whether the technology

would be installed in a new vessel or retrofitted t o an existing vessel, and whether an open or closed circuit scrubber system is chosen. The fuel penalty when using a scrubber is considered to be 2% (Krystallion), which is used in the cost calc ulations. In closed loop systems, costs for maintenance, purchase of NaOH and fresh water are a lso taken into consideration. For open systems, only maintenance is considered relevant fo r the cost calculations in addition to the fuel penalty. The cost for disposal of sludge is include d in the cost estimates but is relatively small and could decrease even further following construction of new sludge disposal facilities and higher rates of usage of these facilities. For closed scru bber systems, the amount of fresh water and NaOH used depend on the sulphur content of the fuel , and the costs will vary accordingly.

The market price for NaOH has varied over the last couple of years. In our central cost estimate, a price for 2005 of € 0.5 / litre 50% NaOH is used. This price estimate i s high but engine manufacturers estimate NaOH prices will range betwe en 0.1 - 2 € / litre, so the price is on the lower boundary of other estimates. In 2007 the pric e for different grades of NaOH was 0.2 - 0.25

€ / litre.

The price for urea is also subject to variation, bu t the engine manufacturer experts are closer in their estimates on urea prices with a price range o f 0.15 - 0.25 € / litre. In our central estimate we use an urea price of € 0.2 / litre.

Cost parameters for the unit costs used in this rep ort are given in Table 7.3.

Table 7.3: Central cost parameters 

### Tier operating hours at sea 4000 h/year
Scrubber operating hours at sea 4000 h/year

Urea price 0.2 € 2005 /

litre

NaOH price 0.5 € 2005 /

litre

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 39 Costs for different scrubber solutions are presente d in Table 7.6. The costs in the Table are given for medium sized SSD-RO engines running on residual oil fuel with 2.94 % sulphur content as specified above. However, in the scenario calculat ions, costs for other engine categories are also included. Low and high cost options are presented . These two options represent the costs associated with either using fresh water in combina tion with NaOH, or sea water in the scrubber. The investment costs (2005) are in the range 100 - 200 € / kW for new installations and 200 - 400

€ / kW for retrofit installations, which is in line w ith manufacturer estimates (Wärtsilä 2009, Marine and Energy Consulting 2009). The costs for scrubber operation vary with the required SO 2 

### content in the exhaust gases - and the different am ounts of NaOH that will be needed. The costs are therefore presented as costs for installations corresponding to certain sulphur content in the fuel that would give the same SO 2 

### emission. For example, Scrubber-0.1 corresponds to emissions from low sulphur fuels with 0.1 % sulphur content. The NaOH consumption needed to reduce sulphur emissions from high sulphur fuel (2. 94 %) to a level corresponding to 0.1 % S fuel is estimated as 15 litres per MWh installed engine capacity. If trying to reach a 0.5 % S fuel
emission level, it is assumed that 12 litres / MWh are needed. For a 1.5 % S fuel emission level, 6 litres / MWh is assumed. The lifetime of the equipm ent is estimated to be the same as in the ENTEC reports (ENTEC 2005).

Scrubber sludge disposal costs ENTEC(2005) looked at the production of sludge when using a scrubber and the permitted amount of sludge for disposal according to the stan dard tariff used at the port of Rotterdam. ENTEC (2005) indicated that the amount of sludge pr oduced would be within the current allocations/ tariffs of a port like Rotterdam. Meec h (2009) indicates that the costs associated with sludge disposal could be small and Wärtsilä (2009) do not take the costs of sludge disposal specifically into consideration. Nevertheless, usi ng the Gothenburg harbour port tariffs as a reference, based on the Gross Tonnage (GT) of the v essel of maximum 0.4 € / GT, and assuming that vessels spend 500 hours between sludge dischar ge in ports, we have calculated that a maximum cost of sludge disposal could be ~10 000 eu ro for a small vessel.

Table 7.4 Sludge disposal costs for Port of Götebor g 

### Scrubber sulphur sludge disposal cost estimates - b ased on the Gothenburg port charges in 2009

Vessel GT SEK2009 /

GT € 2005 /

GT Number of

calls per year Annual cost for sludge

disposal
Small 3,000 0.45 0.37 8.15 9,080

Medium 15,000 0.45 0.37 8.15 45,398
Large 50,000 0.45 0.37 8.15 151,326

These costs are much exaggerated since they allocat e all sludge disposal costs to the scrubber sludge, which would constitute only one part of tot al amount of sludge produced at the vessel.

Another price estimate for scrubber sludge disposal have been given by CE Delft (2006), who used the contemporary fees at the port of Oslo (whi ch were 0.12 € / litre at the time), to calculate the costs for sludge disposal. The study indicated that a large (40 MW installed power) container ship would produce 0.8 tonne of scrubber sludge dur ing 30 operating hours. This corresponds to an hourly cost of 2.9 € . A medium vessel (15 MW) would produce some 0.4 to nne over 40 operating hours, corresponding to a cost of ~1 € / hour. No estimates are given for small vessels. Wärtsilä (2009) specifies that some scrubbers produ ce 1.3 litres sludge per MWh. By using these numbers, the following sludge disposal costs are ca lculated for scrubbers,

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 40 Table 7.5. Sludge disposal costs.



### Vessel type Sludge production [litres / MWh] Sludge disposal cost / litre [ € ] Annual disposal costs in the central analysis [ € ]

Small 1.3 0.12 1,600

Medium 1.3 0.12 5,300 Large 1.3 0.12 13,300

These costs correspond to 0.9 - 3.1 % of the total scrubber costs for a new scrubber (0.6 - 1.7 % for retrofit).

The costs for sludge disposal are included in the O &M column in the table below. The table presents the scrubber costs associated with a mediu m sized vessel reaching a sulphur content of the flue gases corresponding to 1.5, 0.5, or 0.1 % S content in fuel.

Table 7.6: Scrubber costs used in this study



### SCRUBBER COSTS

Tech Tech spec Investment [k € /vessel] Lifetime

[year] O&M

[k € /vessel] Fuel cost

[k € /vessel] Annual

cost [k € ] Costs /

tonne
SO 2 

### [ € ]

New Scrubber1.5 open scrubber 1,148 15 28 41 167 1,035

New Scrubber1.5 Closed

scrubber - high

cost 2,296 15 198 41 441 2,680

Retrofit Scrubber1.5 open scrubber 2,296 12.5 28 41 301 1,840

Retrofit Scrubber1.5 Closed

scrubber - high 4,592 12.5 198 41 708 4,290

New Scrubber0.5 open scrubber 1,148 15 28 41 167 590

New Scrubber0.5 Closed

scrubber - high 2,296 15 198 41 543 1,875

Retrofit Scrubber0.5 open scrubber 2,296 12.5 28 41 301 1,045

Retrofit Scrubber0.5 Closed

scrubber - high 4,592 12.5 198 41 811 2,785

New Scrubber0.1 open scrubber 1,148 15 28 41 167 500

New Scrubber0.1 Closed

scrubber - high 2,296 15 198 41 595 1,730

Retrofit Scrubber0.1 open scrubber 2,296 12.5 28 41 301 885

Retrofit Scrubber0.1 Closed

scrubber - high 4,592 12.5 198 41 862 2,505

Following the simulated impact of retrofit costs an d the impact of NaOH use, the costs for scrubbers vary with a factor of 5 between the least expensive open scrubber option and the most expensive retrofit close circuit scrubber option. T his large variation is a consequence of the relatively expensive NaOH costs used in these cost estimates.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 41 NO X 

### The cost for reduction of NO X 

### emissions in the scenarios studied is only applica ble as a replacement of Tier II technologies with Tier III t echnologies. There is currently much research ongoing by engine manufacturers to reach Tier III s tandards by methods other than SCR. It is likely that these other methods will be associated with comparatively lower costs but it is still uncertain whether they will able to reach Tier III standards.

SCR When calculating the costs for SCR, the cost assume d for urea is important. Its price, like that of fuel, is heavily dependent on future supply and dem and; recent fluctuations show that the future price is uncertain. One potential advantage of SCR is that the emission reduction efficiency is potentially so large that the engine can be modifie d for optimal fuel performance - the NO X 

### emissions increase but remain within the capacity o f the SCR system. However, this is not considered in this study since there are different findings regarding this issue from different engine manufacturer experts.

EGR (Exhaust Gas Recirculation) combinations

Lower cost options to SCR feature a combination of engine alterations (such as turbo charging) and EGR and water injection. The latter come in sev eral different forms - Humid Air Motors, HAM; Direct Water Injection DWI; and Water Emulsion WE. The fuel efficiencies of the individual measures act in opposing directions, EGR reduces fu el efficiency while turbo charging may improve it. The net effect of EGR combinations in o ur study is assumed to imply a 2% fuel penalty.

The Tier I and Tier II costs are based on the estim ates from ENTEC (2005). In addition,

communication with manufacturers has indicated that these costs may be even lower and will only require marginal additions for most engines.

The following list presents the emission standards and main technologies considered in the cost

calculations for NO X



### abatement.

Table 7.7: NO X control standards considered in this study


### NOx % Removal Comment

Tier I retrofit 5 % NO X 

### For ships constructed before the year 2010

Tier II new 20 % NO X 

### Built after 2011

Tier III new 80 % NO X 

### Built after 2016 for NO X 

### ECAs

For a typical vessel with a medium sized SSD-RO eng ine using residual oil with a 2.94 % sulphur content, using the main and auxiliary engines at so me 4500 hours per year (4000 hours at sea), the following unit costs are obtained in the cost c alculations.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 42 Table 7.8: Tier cost estimates used in this study



### Tier

Costs Inv [k € / vessel] Lifetime

[year] O&M

[k € /vsl] Fuel

cost [k € /vsl] Annual

cost [k € ] Costs /

tonne
NO X 

### [ € ]

vintage Tech Tech

spec

Retrofit Tier I Basic IEM 9 2.5 0 0 4 8

New Tier

II Adv. IEM 129 25 0 0 8 17

New (0.1% S) Tier

III EGR+WIF 743 25 15 103 166 340

New (0.5% S) Tier

III EGR+WIF 743 25 22 103 173 350

New (1.45%S) Tier

III EGR+WIF 743 25 39 103 190 390

New (2.7% S) Tier

III EGR+WIF 743 25 65 103 215 440

New Tier

III SCR 949 25 169 0 297 600

In the data set used for cost calculations, Tier I, Tier II and Tier III (SCR) are assumed to have the same cost regardless of sulphur content of the fuel . The annual cost for SCR is, however, dependent on the sulphur content of the fuel - beca use the sulphur in the exhaust gases negatively affects the performance and lifetime of the catalytic elements of the SCR. The additional costs when using high-sulphur fuels is n ot completely established as of yet. However, in the scenario calculations performed here, SCR wi ll only be used in combination with either scrubbers or low sulphur fuels. The additional cos ts associated with high sulphur content in the

fuel are therefore not invoked in our calculations. For EGR + WIF solutions, the sulphur content in

the fuel will be of most concern because the exhaus t gases re-circulated into the engine will be unaffected by the installation of a main scrubber. In these options, an 'internal scrubber' is used which de-sulphurises the exhaust gas that is re-cir culated. The costs for this internal scrubber is dependent on the amount of NaOH used which is in tu rn dependent on the sulphur content of the fuel. This impact on costs is illustrated in the ta ble above by the four different price estimates for

EGR + WIF.

The costs for Tier III equipment and consumables ar e within the range of the cost estimates in ENTEC (2005) and by the USEPA (2009). The USEPA stu dy presents significantly higher costs per ton NO X 

### abated with Tier III technology. The reason for th is difference lies in the fact that the USEPA study allocates the total cost of the abateme nt equipment to the relatively small amounts

of NO X 

### that will actually be abated in the US coastal zon e that is suggested for NO X 

### -ECA.

In the scenario cost calculations used in this stud y are based on the cost per PJ. Having the cost per PJ for each fuel/vessel/tech combination, scena rio specific abatement costs can be calculated based on the fuel and technology choices made for each region and year.

7.4 Scenario abatement costs

In step two of the cost calculations, scenario-spec ific fuel use and abatement technology penetration is used to calculate the total costs fo r NO X 

### and SO 2 

### abatement associated with the

scenarios.

The specifics of the scenarios analysed are as foll ows:

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 43 For SO 2 

### : the maximum sulphur content of marine fuels is 0. 10% (by mass) for SECAs and 2.94 % (by mass) outside SECAs. A reduction of the maxim um S-content to 0.50% outside SECAs will

also be taken into account for some 2020 scenarios. In the baseline, a sulphur content of 1.45 in

SECA and 2.6 outside SECA is considered.

For NO X 

### : Marine diesel engines with a power output that ex ceeds 5,000 kW and a per cylinder displacement at or above 90 litres are upgraded as follows:

• Tier I standards for 30 % of the ships constructed between 1 January 1990 and 1 January 2000;

• Tier I standards for ships constructed between 1 J anuary 2000 and 1 January 2011;

• Tier II standards for ships constructed on or afte r 1 January 2011; and

• Tier III standards for ships constructed on or aft er 1 January 2016 and sailing in the Baltic Sea, North Sea/English Channel and/or the Mediterra nean Sea (only applicable to the 2020 scenarios)

7.5 Results

The following results are presented per scenario in aggregated and disaggregated form. First the aggregated results are presented in tables 7.10 – 7 .15, followed by region specific results in tables 7. 16 – 7.20. Given the assumptions of the s cenarios, it is assumed that scrubbers are not

used to reach the 1.45 % S content emission standar ds, therefore in the scrubber scenarios costs

for scrubbers will be associated with fuel cost sav ings that represent the difference in costs for

1.5 and 2.94 % S fuel for the Baltic Sea and North Sea.

Parameters of major importance for the cost results are as follows:

Table 7.9: Central parameters for cost estimates, 2 020



### Central parameters, 2020

Tier operating hours at sea 4000 h / year
Scrubber operating hours at sea 4000 h / year
Urea price 0.2 € 2005 / litre
NaOH price 0.5 € 2005 / litre

NOTE: 4000 operating hours per year corresponds to a bit less than 50 % of the vessels running time wi thin a SECA or

NO X Emission Control Area.



### The baseline scenario

The baseline scenario is described in Section 2 and is compared with the other scenarios (SEA1 - SEA5).

Table 7.10: Scenario results - total baseline costs [million € 2005 ]



### BSL 2015 2020

Fuel 17 970 21 547

In the baseline scenario, no NO X 

### removal is assumed. The costs for fuel represent t he total fuel costs for all sea regions considered in the report.

Readers should note that Table 7.10 is the only cos t result table that indicates total annual costs. In the following tables estimates all relate to the costs of the baseline scenario. In order to get th e total costs of each scenario, the costs of the base line should be added to the costs presented in

the tables below.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 44 Table 7.11: Scenario SEA1 - Total annual abatement costs on top of baseline [million € 2005 ]



## SEA1 2015 2015 2020 2020

low high low high

Alternative 1 Scrubber - scrubber

costs 683 2 003 682 2 088

SO2 Fuel cost compared to baseline -120 -120 -278 -278

Sum Alt 1 563 1 883 404 1 810

Alt 2: low S fuel cost 3 024 3 622 3 279 3 957

NOx Tier I - III 76 76 452 645

Following the introduction of Tier III NO X 

### control in the Baltic, Mediterranean and the North sea, the annual costs for NO X 

### emission removal range between 452 and 645million € 2005 

### . In the scrubber scenario, the introduction of scrubbers in the Baltic and North Sea allows for the use of high sulphur fuels, which are less expensive than t he 1.5 % S fuel used in the baseline. Therefore, the costs for high S fuel given in the t able are negative. If reaching the SO 2 

### emission levels by shifting to low sulphur fuels instead of using scrubbers, the costs are, at a minimum, twice as high.

Table 7.12: SEA2 - Total annual abatement costs on top of baseline [million € 2005 ] 

## SEA2 2015 2015 2020 2020

low high low high

Alternative 1 Scrubber

- scrubber costs 1 838 5 390

SO 2 

### Fuel cost compared to

baseline -104 -104 n.c. n.c.

Sum Alt 1 1 734 5 286 n.c. n.c.

Alt 2: low S fuel cost 8 365 9 978 n.c. n.c.

NO X 

### Tier I - III 76 76 n.c. n.c.

Note: n.c. – not calculated



### In SEA2, only covering the year 2015, the Mediterra nean Sea is considered as a SECA. The fuel costs increase significantly following the large fu el use in the Mediterranean. In the scrubber scenario, the fuel savings are smaller relative to SEA1. The reason is that the marine diesel used

in the Mediterranean will contain 0.1% S rather tha n 0.5% S (as in the base case) which implies

extra costs.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 45 Table 7.13: SEA3 - Total annual abatement costs on top of baseline [million € 2005 ] 

## SEA3 2015 2015 2020 2020

low high low high

Alternative 1 Scrubber

- scrubber costs 1 898 5 566 1 899 5 807

SO 2 

### Fuel cost compared to

baseline -104 -104 -261 -261

Sum Alt 1 1 794 5 462 1 638 5 547

Alt 2: low S fuel cost 8 642 10 308 9 634 11 521

NO X 

### Tier I - III 76 76 393 645

In SEA3, both the Mediterranean and the Black Sea a re considered as SECAs. In addition to this

the Mediterranean is considered as a NO X 

### ECA. The low cost estimate on Tier III (EGR+WIF) i s lower than in SEA1 following that the Mediterranean is included in the SECA in SEA3, which

reduces the amount of NaOH needed for the internal scrubber.

Table 7.14: SEA4 - Total annual abatement costs on top of baseline [million € 2005 ] 

## SEA4 2015 2015 2020 2020

low high low high

Alternative 1 Scrubber

- scrubber costs 2 432 7 069

SO 2 

### Fuel cost compared to

baseline n.c. n.c. -278 -278

Sum Alt 1 n.c. n.c. 2 154 6 792

Alt 2: low S fuel cost n.c. n.c. 7 631 10 123

NO X 

### Tier I - III n.c. n.c. 401 645

Note: n.c. – not calculated



### In SEA 4, the permitted sulphur content in the area s outside SECA is reduced to 0.5 %. The Mediterranean and the Black Sea are again outside S ECA. The Mediterranean Sea is together

with the Baltic and North Sea considered as a NO X 

### Emission Control Area. The low cost

estimates for Tier III is lower than in SEA1 but hi gher than SEA3, following the allowed sulphur content of 0.5 % (0.1% in SEA3).

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 46 Table 7.15: SEA5 - Total annual abatement costs on top of baseline [million € 2005 ]



## SEA5 2015 2015 2020 2020

low high low high

Alternative 1 Scrubber

- scrubber costs 2,432 7,328

SO 2 

### Fuel cost compared to

baseline n.c. n.c. -261 -261

Sum Alt 1 n.c. n.c. 2,172 7,067

Alt 2: low S fuel cost n.c. n.c. 10,962 13,402

NO X 

### Tier I - III n.c. n.c. 393 645

Note: n.c. – not calculated



### In SEA5, all sea regions but the North East Atlanti c are considered as SECAs (as in SEA3), and the North East Atlantic has a maximum sulphur conte nt of 0.5 %. This results in the highest sulphur removal costs of all scenarios. The low cos t estimates on Tier III are again following the sulphur content of the low sulphur fuel scenario fo r the Mediterranean. The inclusion of the

Mediterranean and the Black Sea is not visible in t he low scrubber estimates (sea water scrubber) compared with SEA 4, since the costs for this type of scrubber is assumed to be similar

for removal to SO 2 

### emissions corresponding to either 0.1% or 0.5%.

Disaggregated into regions, the costs for the diffe rent scenarios are as follows:

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 47 Table 7.16: SEA1 - Regional annual abatement costs on top of baseline [million € 2005 ] 

## SEA1 - specified per region 2015 2015 2020 2020

low high low high

Baltic SO 2 

### Alternative 1 Scrubber -

scrubber costs 204 597 203 623

Fuel cost compared to

baseline -36 -36 -83 -83

Sum Alt 1 168 561 120 540

Alt 2: low S fuel cost 901 1,080 977 1,180

NO X 

### Tier I - III 6 6 41 70

Black SO 2 

### Alternative 1 Scrubber -

scrubber costs 0 0 0 0

Fuel cost compared to

baseline 0 0 0 0

Sum Alt 1 0 0 0 0

Alt 2: low S fuel cost 0 0 0 0

NO X 

### Tier I - III 2 2 2 2

Med SO 2 

### Alternative 1 Scrubber -

scrubber costs 0 0 0 0

Fuel cost compared to

baseline 0 0 0 0

Sum Alt 1 0 0 0 0

Alt 2: low S fuel cost 0 0 0 0

NO X 

### Tier I - III 36 36 291 389

NE Atl SO 2 

### Alternative 1 Scrubber -

scrubber costs 0 0 0 0

Fuel cost compared to

baseline 0 0 0 0

Sum Alt 1 0 0 0 0

Alt 2: low S fuel cost 0 0 0 0

NO X 

### Tier I - III 17 17 21 21

North SO 2 

### Alternative 1 Scrubber -

scrubber costs 479 1,406 479 1,465

Fuel cost compared to

baseline -84 -84 -195 -195

Sum Alt 1 395 1,322 284 1,271

Alt 2: low S fuel cost 2,123 2,543 2,302 2,778

NO X 

### Tier I - III 15 15 97 163

ALL REGIONS SO 2 

### Alternative 1 Scrubber -

scrubber costs 683 2,003 682 2,088

Fuel cost compared to

baseline -120 -120 -278 -278

Sum Alt 1 563 1,883 404 1,810

Alt 2: low S fuel cost 3,024 3,622 3,279 3,957

NO X 

### Tier I - III 76 76 452 645

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 48 Table 7.17: SEA2 - Regional annual abatement costs on top of baseline [million € 2005 ] 

## SEA2 - specified per region 2015 2015 2020 2020

low high low high

Baltic SO 2 

### Alternative 1 Scrubber -

scrubber costs 204 597 n.c. n.c.

Fuel cost compared to

baseline -36 -36 n.c. n.c.

Sum Alt 1 168 561 n.c. n.c.

Alt 2: low S fuel cost 901 1,080 n.c. n.c.

NO X 

### Tier I - III 6 6 n.c. n.c.

Black SO 2 

### Alternative 1 Scrubber -

scrubber costs 0 0 n.c. n.c.

Fuel cost compared to

baseline 0 0 n.c. n.c.

Sum Alt 1 0 0 n.c. n.c.

Alt 2: low S fuel cost 0 0 n.c. n.c.

NO X 

### Tier I - III 2 2 n.c. n.c.

Med SO 2 

### Alternative 1 Scrubber -

scrubber costs 1,155 3,387 n.c. n.c.

Fuel cost compared to

baseline 16 16 n.c. n.c.

Sum Alt 1 1,171 3,403 n.c. n.c.

Alt 2: low S fuel cost 5,341 6,356 n.c. n.c.

NO X 

### Tier I - III 36 36 n.c. n.c.

NE Atl SO 2 

### Alternative 1 Scrubber -

scrubber costs 0 0 n.c. n.c.

Fuel cost compared to

baseline 0 0 n.c. n.c.

Sum Alt 1 0 0 n.c. n.c.

Alt 2: low S fuel cost 0 0 n.c. n.c.

NO X 

### Tier I - III 2 2 n.c. n.c.

North SO 2 

### Alternative 1 Scrubber -

scrubber costs 479 1,406 n.c. n.c.

Fuel cost compared to

baseline -84 -84 n.c. n.c.

Sum Alt 1 395 1,322 n.c. n.c.

Alt 2: low S fuel cost 2,123 2,543 n.c. n.c.

NO X 

### Tier I - III 15 15 n.c. n.c.

ALL REGIONS SO 2 

### Alternative 1 Scrubber -

scrubber costs 1,838 5,390 n.c. n.c.

Fuel cost compared to

baseline -104 -104 n.c. n.c.

Sum Alt 1 1,734 5,286 n.c. n.c.

Alt 2: low S fuel cost 8,365 9,978 n.c. n.c.

NO X 

### Tier I - III 61 61 n.c. n.c.

Note: n.c. – not calculated

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 49 Table 7.18: SEA3 - Regional annual abatement costs on top of baseline [million € 2005 

### ] 

## SEA3 specified per region 2015 2015 2020 2020

low high low high

Baltic SO 2 

### Alternative 1 Scrubber -

scrubber costs 204 597 203 623

Fuel cost compared to

baseline -36 -36 -83 -83

Sum Alt 1 168 561 120 540

Alt 2: low S fuel cost 901 1,080 977 1,180

NO X 

### Tier I - III 6 6 41 70

Black SO 2 

### Alternative 1 Scrubber -

scrubber costs 60 176 60 184

Fuel cost compared to

baseline 0 0 0 0

Sum Alt 1 60 177 60 184

Alt 2: low S fuel cost 277 330 313 373

NO X 

### Tier I - III 2 2 2 2

Med SO 2 

### Alternative 1 Scrubber -

scrubber costs 1,155 3,387 1,157 3,535

Fuel cost compared to

baseline 16 16 17 17

Sum Alt 1 1,171 3,403 1,173 3,552

Alt 2: low S fuel cost 5,341 6,356 6,042 7,191

NO X 

### Tier I - III 36 36 231 389

NE Atl SO 2 

### Alternative 1 Scrubber -

scrubber costs 0 0 0 0

Fuel cost compared to

baseline 0 0 0 0

Sum Alt 1 0 0 0 0

Alt 2: low S fuel cost 0 0 0 0

NO X 

### Tier I - III 17 17 21 21

North SO 2 

### Alternative 1 Scrubber -

scrubber costs 479 1 406 479 1 465

Fuel cost compared to

baseline -84 -84 -195 -195

Sum Alt 1 395 1,322 284 1,271

Alt 2: low S fuel cost 2,123 2,543 2,302 2,778

NO X 

### Tier I - III 15 15 97 163

ALL REGIONS SO 2 

### Alternative 1 Scrubber -

scrubber costs 1,898 5,566 1,899 5,807

Fuel cost compared to

baseline -104 -104 -261 -261

Sum Alt 1 1,794 5,462 1,638 5,547

Alt 2: low S fuel cost 8,642 10,308 9,634 11,521

NO X 

### Tier I - III 76 76 393 645

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 50 Table 7.19: SEA4 - Regional annual abatement costs on top of baseline [million € 2005 

### ] 

## SEA4 - specified per region 2015 2015 2020 2020

low high low high

Baltic SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 203 623

Fuel cost compared to

baseline n.c. n.c. -83 -83

Sum Alt 1 n.c. n.c. 120 540

Alt 2: low S fuel cost n.c. n.c. 977 1,180

NO X 

### Tier I - III n.c. n.c. 41 70

Black SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 60 171

Fuel cost compared to

baseline n.c. n.c. 0 0

Sum Alt 1 n.c. n.c. 60 171

Alt 2: low S fuel cost n.c. n.c. 149 212

NO X 

### Tier I - III n.c. n.c. 2 2

Med SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 1 157 3 290

Fuel cost compared to

baseline n.c. n.c. 0 0

Sum Alt 1 n.c. n.c. 1,157 3,290

Alt 2: low S fuel cost n.c. n.c. 2,875 4,073

NO X 

### Tier I - III n.c. n.c. 239 389

NE Atl SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 534 1,520

Fuel cost compared to

baseline n.c. n.c. 0 0

Sum Alt 1 n.c. n.c. 534 1,520

Alt 2: low S fuel cost n.c. n.c. 1,328 1,881

NO X 

### Tier I - III n.c. n.c. 21 21

North SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 479 1,465

Fuel cost compared to

baseline n.c. n.c. -195 -195

Sum Alt 1 n.c. n.c. 284 1,271

Alt 2: low S fuel cost n.c. n.c. 2,302 2,778

NO X 

### Tier I - III n.c. n.c. 97 163

ALL REGIONS SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 2,432 7,069

Fuel cost compared to

baseline n.c. n.c. -278 -278

Sum Alt 1 n.c. n.c. 2,154 6,792

Alt 2: low S fuel cost n.c. n.c. 7,631 10,123

NO X 

### Tier I - III n.c. n.c. 401 645

Note: n.c. – not calculated

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 51 Table 7.20: SEA5 - Regional annual abatement costs on top of baseline [million € 2005 ] 

## SEA5 - specified per region 2015 2015 2020 2020

low high low high

Baltic SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 203 623

Fuel cost compared to

baseline n.c. n.c. -83 -83

Sum Alt 1 n.c. n.c. 120 540

Alt 2: low S fuel cost n.c. n.c. 977 1,180

NO X 

### Tier I - III n.c. n.c. 41 70

Black SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 60 184

Fuel cost compared to

baseline n.c. n.c. 0 0

Sum Alt 1 n.c. n.c. 60 184

Alt 2: low S fuel cost n.c. n.c. 313 373

NO X 

### Tier I - III n.c. n.c. 2 2

Med SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 1,157 3,535

Fuel cost compared to

baseline n.c. n.c. 17 17

Sum Alt 1 n.c. n.c. 1,173 3,552

Alt 2: low S fuel cost n.c. n.c. 6,042 7,191

NO X 

### Tier I - III n.c. n.c. 231 389

NE Atl SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 534 1,520

Fuel cost compared to

baseline n.c. n.c. 0 0

Sum Alt 1 n.c. n.c. 534 1,520

Alt 2: low S fuel cost n.c. n.c. 1,328 1,881

NO X 

### Tier I - III n.c. n.c. 21 21

North SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 479 1,465

Fuel cost compared to

baseline n.c. n.c. -195 -195

Sum Alt 1 n.c. n.c. 284 1,271

Alt 2: low S fuel cost n.c. n.c. 2,302 2,778

NO X 

### Tier I - III n.c. n.c. 97 163

ALL REGIONS SO 2 

### Alternative 1 Scrubber -

scrubber costs n.c. n.c. 2,432 7,328

Fuel cost compared to

baseline n.c. n.c. -261 -261

Sum Alt 1 n.c. n.c. 2,172 7,067

Alt 2: low S fuel cost n.c. n.c. 10,962 13,402

NO X 

### Tier I - III n.c. n.c. 393 645

Note: n.c. – not calculated

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 52 

# 8 Comparing Costs and Benefits

The comparison of costs and benefits is carried out in two parts. First, a straightforward comparison is made of the results from the previous sections. Results from this preliminary comparison are then used to frame a more detailed c omparison that takes more thorough account of the uncertainties that are present.

8.1 Preliminary comparison of costs and benefits

Annual costs and benefits (low and high estimates) for the different scenarios are given in the following tables, taking the results directly from the preceding analysis. The low bound for costs is the lower estimate for fitting a scrubber to reduce SO 2 

### emissions together with the costs of NO

x 

### control. The upper bound for costs is for the high estimate for using low sulphur fuels to reduce

SO 2 

### emissions and the costs of NO

x 

### control. The range for benefits is based on use o f either the VOLY (lower bound) or VSL (upper bound) to value mo rtality.

Table 8.1 Summary of costs and quantified benefits for the 2015 scenarios ( € billions)

Table 8.2 Summary of costs and quantified benefits in the EU27 for the 2020 scenarios ( € billions)



### In all cases there is no overlap between the estima tes shown above: in other words that benefits exceed costs for all of the cases shown. However, t he ranges shown to this point are simply indicative – they do not account for all of the unc ertainties that could affect the analysis, particularly on the side of the benefits estimation . Without more detailed analysis of the uncertainties that are present it is therefore uncl ear how robust the conclusion that benefits exceed costs actually is (even though the results a ppear conclusive). To illustrate the problem, the surplus of benefit over cost would grow were ot her benefits, to ecosystems, crops and the built environment to be added in. However, if certa in key aspects of the analysis are overestimated, in particular elements relating to t he quantification of benefits of reduced mortality using the lower bound (VOLY) approach, benefits wou ld in turn be overestimated. It is therefore clearly appropriate to consider the uncertainties i n the analysis in greater detail. This is done in the next section which applies Monte Carlo analysis to examine more closely the effects of different assumptions on the distribution of both c osts and benefits. Table 8.3 summarises the

uncertainties accounted for and not accounted for i n the ranges shown to this point, and how they

can be dealt with in the assessment that follows.

SEA1 SEA2 SEA3

Costs low 0.6 1.8 1.9
high 3.7 10 10

Benefits low 8 11 11
high 16 24 25

SEA1 SEA3 SEA4 SEA5

Costs low 0.9 2.0 2.6 2.6
high 4.6 12 11 14

Benefits low 10 14 15 16
high 23 32 34 36

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 53 Table 8.3 Uncertainties included and excluded from the ranges shown in Table 7.2

Element Uncertainty Accounted for? Costs Response to legislation in terms of option ap plied Yes Variability in operating costs Yes

Economies of scale No

Price effect on demand for transport or specific transport modes No

Price dynamics relating to supply / demand of fuels or abatement equipment No

Benefits Method for valuation of mortality Yes

Health incidence rates, response functions,

valuation data No, can be assessed using

Monte Carlo Exclusion of impacts on ecosystems and cultural heritage (would increase benefits) No

8.2 Detailed uncertainty assessment

It is important to be clear about the purpose of th e more detailed comparison of costs and benefits. The analysis in the preceding section alr eady suggests that it is very likely that costs wil l be less than benefits. The uncertainty analysis the refore needs to consider how robust this conclusion is and whether there could be any ground s for coming to a different conclusion. As will be shown, some uncertainties can be addressed quantitatively and in a lot of detail, whilst others need to be addressed more qualitatively.

In some situations it is reasonable to estimate the possible spread of data by combining extreme outcomes (e.g. adding or multiplying all high estim ates together). However, when this involves the combination of a large number of variables, or when it involves variables which have a large range around them, it can provide only weak informa tion about probable values for two reasons: 1. It does not account for the potential of errors in different parameters to cancel out against

each other

2. It does not account for the distribution of valu es within a range, whether they are all equally likely or whether values somewhere towards the centre of the range are more likely than others. The result generated using these extreme outcomes m ay therefore be one possible outcome, but it may also be extremely unlikely to happen. On thi s basis the use of extremes to generate ranges is not helpful for informing policy development unl ess it demonstrates unequivocally that the range for two parameters of interest (e.g. total co st and total benefit) do not overlap.

It has been observed that the ranges given in Table s 8.1 and 8.2 do not overlap. However, for the benefits in particular the ranges shown account onl y partially for the uncertainties that are present, as they show the effect of using a best es timate of the VOLY or a best estimates of the VSL to value mortality. They do not account for unc ertainty in these best estimates or in the other parameters used in the quantification of impacts an d monetary benefits.

This section factors in the uncertainties in the es timation of benefits relating to the population at risk, the incidence of ill health, concentration-re sponse functions and unit values for each of the health impacts that have been quantified. This gene rates not only a range around the final estimate of benefit, but also the probability distr ibution within that range. Extreme values may arise, but they can be shown to be of very low prob ability compared to values closer to the centre

of the distribution.

The ranges described for costs in the previous chap ter account for all available data accessed during the project. These ranges are adopted for co mparison with the newly-computed ranges for

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 54 benefits. However, we have only limited information to tell us how values are distributed within the cost ranges. It is therefore necessary to make some assumptions on the shape of the distributions. General options are shown in Figure 8.1, illustrating log normal, normal, triangular and uniform distributions (note that the figure is illustrative and that the exact values and probabilities shown are not important to the result s of the present study). Other distributions are possible, but are broadly similar to those shown. I n cases where there is a reasonable amount of information it may be appropriate to assume a detai led distribution like the lognormal or normal case. In the present situation, however, we have on ly limited information and so it is appropriate to adopt a simpler assumption with the distribution around cost estimates assumed to be triangular or uniform. Choices made below reflect, in part whether a worst case or average/best case situation is under investigation.

0.0 0.1 0.2 0.3 0.4-4-20246810 0.0 0.1 0.2 0.3 0.4-4-20246810 0.0 0.1 0.2 0.3 0.4-4-20246810 0.0 0.1 0.2 0.3 0.4-4-20246810Probability



### Value Lognormal Normal Triangular Uniform



### Figure 8.1 Examples of possible distributions for v ariables

Once distributions have been determined for the inp ut variables the Monte Carlo analysis is
runover 10,000 iterations. At each iteration a valu e is selected at random from within each of the defined probability distributions that have been in put to the model. The resulting distributions can be used to assess the extent of overlap in the dist ribution of cost and the distribution of benefit, telling us the probability that quantified benefits will exceed costs.

The analysis is focused on the scenarios for the ye ar 2020 rather than 2015 to account for more complete implementation of the policies under inves tigation.

Describing the uncertainties in cost estimates

Three options have been considered for sulphur cont rols, the use of open or closed loop scrubbers and the use of low sulphur fuels. For eac h technique a range of costs was derived taking into account various uncertainties (see the preceding chapter), and these ranges were used for the preliminary comparison of costs and be nefits above. It should be pointed out that the low range scrubber costs are for sea water scrubber s. It is still unclear under what regulations these will operate (see Section 9). A likely scenar io is that scrubbers operate with seawater at open sea and as closed scrubbers or with low-sulphu r fuel close to shore. It may also be that seawater scrubbers are not used in sea regions with low alkalinity (i.e., parts of the Baltic Sea and the Black Sea. Therefore, a probable cost for s crubbers could be in the middle or higher part of the range given here for scrubbers. Various tech niques were investigated for NO

x 

### control, as

listed in Table 7.6. Total annual costs for 2020 ar e shown in Table 8.4 from which the following
are apparent:

• Costs are dominated by controls on sulphur, the co sts of controls on nitrogen being an order of magnitude less (with the partial exception of SEA1)

• The extent of variation in the NO

x 

### estimates is small compared to variation in the SO 2 

### control costs

• Despite a significant level of variation in costs for the two S control options, there is no overlap in their ranges.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 55 Table 8.4 Summary of annual abatement costs given i n Chapter 6, € million



### SO2, scrubbers SO2, low sulphur

fuel NOx

SEA1, 2020 400 – 1,800 3,280 – 3,960 450 – 650 SEA3, 2020 4,640 – 5,550 9,630 – 11520 390 – 650 SEA4, 2020 2,150 – 6,790 7,630 – 10,120 400 – 650 SEA5, 2020 2,170 – 7,070 10,960 – 13,400 390 - 650

These observations imply that the main focus of the uncertainty analysis should be on the

variation in SO 2 

### control costs. They also raise questions about the appropriate shape for the probability distribution to be associated with the costing, with the following variations considered:

• Best case: Triangular or uniform distributions based on the s um of NO

x 

### control costs with the low range for SO 2 

### control costs (using scrubbers).

• Average Case: Triangular or uniform distributions across the ful l ranges shown, which would assume that ship owners opt for a mixed appro ach to new regulations. A uniform distribution is applicable where all values within a range are considered equally likely, whilst a triangular distribution applies when it is thought most likely that the true value lies towards the centre of the range.

• Worst Case 1: Triangular or uniform distributions based on the s um of NO

x 

### control costs with the high range for SO 2 

### control costs (using low sulphur fuel).

• Worst Case 2: A point estimate for costs at the upper end of the range: if this worst case generates a high probability of producing a net ben efit there is no need to be concerned about other parts of the cost range as they would s imply further increase the probability.

For the first case we apply a triangular distributi on with the most likely value assumed to be in the centre of the range. For the second case we assume a triangular distribution with the most likely estimate in the middle of the range on the assumpti on that some ships would use scrubbers and some would use low sulphur fuel. For the third case we assume a uniform distribution, as this seems likely to give a lower probability of attaini ng a net benefit (remembering that it is intended as a worst case) given the observed relationship be tween costs and benefits from Tables 8.1 and 8.2. Resulting distributions can be compared for sc enario SEA5 in Figure 8.2. The two worst cases are shown to be significantly more pessimisti c than the average case.

Triang(2.416, 4.99, 7.564)

0.00 0.15 0.30 0.45 0.6003691215 Uniform(11.513, 13.953)

0.00 0.15 0.30 0.45 0.6003691215 Uniform(11.513, 13.953)

0.00 0.15 0.30 0.45 0.6003691215 Triang(2.4, 8.2, 14)

0.00 0.15 0.30 0.45 0.6003691215



### Value 1.0 1.0 1.0

0.45

0.30

0.15

0 1.0 Triangular (2.42, 4.99. 7.56) Triangular (2.4 2, 8.2, 14) Uniform (11.5, 13.9) Point estimate (13.9)

Cheapest Most expensive Best case Average case Worst case 1 Worst case 2

1.0

0.45

0.30

0.15

0 1.0

0.45

0.30

0.15

0 1.0

0.45

0.30

0.15

0

0 3 6 9 12 15 0 3 6 9 12 15 0 3 6 9 12 15 0 3 6 9 12 15Probability density



### Figure 8.2 Probability distributions used for the s ensitivity cases on costs (examples are all for scenario SEA5).

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 56 Uncertainties in benefit estimates

As noted above, account is taken here of uncertaint ies in the population at risk, the incidence of ill health, concentration-response functions and unit v alues for each of the health impacts that have been quantified. Ranges and associated probability distributions for each parameter are defined by Holland et al (2009). Bringing these data togeth er is found to generate a log-normal distribution as shown in Figure 8.3 which takes the example of scenario SEA5 in 2020. The results in this form provide us with a mean value a nd confidence intervals – the 90% interval being shown which covers a range from € 9.23 billion/year to € 26.9 billion/year. Using these results it is now possible to compare against the c ost ranges shown in Figure 8.2.



## Value ( € billion/year)Probability density



## 0.000 0.010 0.020 0.030 0.040 0.050 0.060 0.070 0.080 0.090 0.100
Mean=16.6



## 0 11 22 33 44 55

5% 90% 5%


## 9.23 26.9 Mean=16.5



## Value ( € billion/year)Probability density



## 0.000 0.010 0.020 0.030 0.040 0.050 0.060 0.070 0.080 0.090 0.100
Mean=16.6



## 0 11 22 33 44 55

5% 90% 5%


## 9.23 26.9 Mean=16.5Probability density



## 0.000 0.010 0.020 0.030 0.040 0.050 0.060 0.070 0.080 0.090 0.100
Mean=16.6



## 0 11 22 33 44 55

5% 90% 5%


## 9.23 26.9 Mean=16.5

Figure 8.3 Calculated probability distribution for the benefits of Scenario SEA5 in 2020, with mortality valued using the VOLY

Comparing costs and benefits accounting for uncerta inties

Results from the Monte Carlo analysis showing the p robability of gaining a net benefit for each SEA scenario accounting for 8 sensitivity cases are shown in Table 8.5 and Figure 8.1 considering the set of uncertainties that have been addressed t this point. The following

observations are made:

:

• Using the VSL to value mortality the probability o f deriving a net benefit is more than 98% for all SEA scenarios, even for Worst case 1 (the e xtreme worst case).

• Using the VOLY for mortality valuation the lowest probability of gaining a net benefit is 65% for the SEA5 scenario (compare Worst Case 2 in Figure 8.2 with the distribution calculated for benefits in Figure 8.3).

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

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### AEA 57 • For the best case assumptions (lower range for S c ontrol costs with full range for N control costs) there is a more than 99% probability of deriving a net benefit even when applying the VOLY.

• For SEA1 the probability of gaining a net benefit is greater than 98% in all cases.

• Perhaps most importantly, for the average case sce nario there is a probability greater than 94% of gaining a net benefit for all SEA scena rios.

The precise probability estimates reported in the t able are themselves a function of assumptions made in the uncertainty analysis. What is importan t therefore is not the precise figures shown, but the overall perspective that when further uncer tainties are taken into account, the view that benefits of the proposed actions are very likely to exceed the costs is unchanged.

Table 8.5 Probability of deriving a net benefit und er various sensitivity cases



### Worst 1 Worst 2 Average Best

VOLY estimates

SEA1 98.7% 99.2% 99.8% 100.0%

SEA3 66.3% 75.2% 95.6% 99.8%

SEA4 79.7% 88.3% 96.9% 99.5%

SEA5 65.3% 75.5% 94.8% 99.7%

VSL estimates

SEA1 99.8% 99.8% 99.9% 100.0%

SEA3 98.1% 98.8% 99.7% 99.9%

SEA4 99.0% 99.3% 99.7% 99.8%

SEA5 98.1% 98.7% 99.6% 99.8%

0 0.2 0.4 0.6 0.8 1 1.2

Worst 1 Worst 2 Average BestProbability of benefit>cost



### VOLY estimates

SEA1

SEA3

SEA4

SEA5

VSL estimates

SEA1

SEA3

SEA4

SEA5



### Figure 8.1 Probability of deriving a net benefit un der various sensitivity cases.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

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### AEA 58 8.3 Summary of the CBA results

Results presented in this section demonstrate that the probability of benefits exceeding costs for all of the different scenarios investigated is high , in all cases greater than 65%. The IPCC (Houghton et al, 2002) provides some guidance on th e interpretation of probabilities, as follows: <1% Extremely unlikely 1–10% Very unlikely 10–33% Unlikely

33–66% Medium likelihood 66–90% Likely 90–99% Very likely >99% Virtually certain

For the cost ranges that we consider most reliable from the sensitivity analysis presented above (the average or best cases, rather than the worst c ases) the probability of benefit exceeding cost can therefore be described as very likely / virtual ly certain, irrespective of the approach taken to mortality valuation. With one slight exception (SEA 5 with mortality valued using the VOLY) the probability of benefits exceeding costs can be desc ribed as likely, very likely or virtually certain even for the worst case assumptions on cost.

It is to be remembered that the probabilities calcu lated here are quantified only against benefits for improved health. The inclusion of impacts to ma terials (including cultural heritage) and ecosystems, in particular, would add to the benefit s and further increase the already high probabilities. Economies of scale, as the use of ab atement techniques becomes more widespread have also been excluded from the analysi s. These would tend to reduce costs from

the levels used here which are based on data from c urrent suppliers.

It is more difficult to make a qualitative appraisa l of the effect of other uncertainties that have been excluded from the current analysis, for exampl e price effects on demand for transport and the potential for modal shift in response for legis lation, or price dynamics of supply/demand for fuels, equipment, etc. Some account has been taken of such variation, for example in the costs of abatement reagents such as NaOH and urea. It is, ho wever, not beyond possibility that there could be even more significant variation in cost th an that considered here in the future, and that this would lead to a net cost being incurred. Howev er, from observations made here on the

balance of costs and benefits we consider this unli kely for the following reasons:

• There is a high probability of gaining a net benef it even against the upper range for

abatement costs

• The upper range for costs is about a factor 2 grea ter than the lower range

• We consider it likely that actual costs would be i n the lower range than the upper range

The following should also be considered:

• Alternative methods for reaching the same goals ha ve been identified. If the costs of one option were to increase significantly it may theref ore be appropriate to switch to a different option

• A conservative best estimate was adopted for the V OLY.

The challenge of accounting for all possible uncert ainties in this analysis, given the number of inputs and factors that need to be accounted for, i s great. It would undoubtedly be possible to make alternative assumptions in some areas to those taken here and this would change the probability of gaining a net benefit. However, as t he ranges etc. used here have been derived from discussion with a number of manufacturers (on the cost side) and on several occasions with stakeholders (on the benefits side), the principal conclusion reached, that benefits are very likely to exceed costs, seems robust.

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accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 59 

# 9 Emission abatement equipment

9.1 Summary

This section of the report discusses technical crit eria for exhaust abatement equipment for the reduction of emissions of sulphur dioxide from ship s. The only technology available at present is scrubbing. Scrubber units can be of two kinds, seaw ater (open) scrubbers and freshwater (closed) scrubbers, or a combination of these. Crit eria for the SO 2 

### to CO 2 

### ratio for emissions to air have been presented by the IMO. Also criteria for t he wash-water have been developed which are discussed in this report.

At present there are criteria for wash-water but no regulations regarding emissions to air from shipping (except for sulphur dioxide and nitrogen o xides); this is unfortunate from an environmental point of view and better optimised ab atement units could be developed if the regulations covered both the emissions to air and t o water.

The wash-water criteria developed by IMO covers pH, PAH content, turbidity and nitrate content. While the criterion for pH seems to limit the amoun t of water that will be affected by low pH during scrubber operation to a reasonable amount specific attention is needed for waters with low alkalinity. The criteria for PAH is set in "phenant hrene equivalents"; it is not clear how this is

defined but it seems to mean that the concentration of phenanthrene is monitored. The criterion corresponds to an emission of 2.2 mg/kWh of phenant hrene, this seems to be a high limit and widespread use of scrubbers emitting wash-water wit h PAH concentrations close to this limit could pose a risk to the environment. The criteria for turbidity can be a way to show that the scrubber is operating correctly but the method has not been shown to be a reliable measure of the concentration of particulate matter emitted wit h the wash-water. There is also a criterion for

nitrate content in the wash-water. A scrubber unit on a ship operating close to this limit could, depending on the sea area, increase the ships' cont ribution to the nitrate load in the sea. It is suggested that regulations are constructed so that this can be avoided in sensitive areas.

The IMO regulations allow two monitoring schemes. I n one the SO 2 

### -emission to air is measured continuously and in the other the scrubber’s operat ional parameters are monitored to check its efficiency of operation; it is suggested that the l atter is applied because there will be scrubbers, notably closed scrubbers, where the operation can b e monitored without continuously measuring

the SO 2 

### concentration in the exhaust gas.

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### AEA 60 9.2 Introduction

Emission of sulphur dioxide from burning of fossil fuels is still the most significant source of sulphur pollution to the atmosphere. These emission s have historically been the most important

source for the acidification of lakes and soils lea ding to deterioration of soils, collapsing ecosystems and loss of forest production. Sulphur e missions also lead to the formation of particulate matter. High levels of particulate matt er are a major health concern in large parts of Europe. In many parts of the world the emission of sulphur has recently decreased due to policy measures such as lower use of coal-burning, cleanin g of exhaust gases, sulphur limits on diesel and gasoline for road transportation, etc.

One sector that, until recently, has been unaffecte d by regulations regarding sulphur emissions is shipping. Here it is customary to use residual oil that contains high levels of sulphur in addition to e.g., high levels of aromatics. In principle, all s ulphur in the fuel ends up as emission of sulphur oxides (SO X 

### ) after combustion in the engine. Some of this SO 2 

### is then oxidized further and may then form particles. There is a clear connection be tween the sulphur content in the fuel and particle emissions (Winnes 2009). Eyring et al. ( 2005) estimate that the worldwide annual SO 2 

### emission from shipping is 12.0 Mtonne (almost three times more than for all road traffic).

There is now a maximum allowed sulphur level of 4.5 % agreed on worldwide. Further, so called SECA areas, (from 2006 the Baltic Sea, and from 200 7 also the North Sea and the English Channel) have a limit of 1.5% sulphur. In view of t he environmental and health impacts of sulphur

emission IMO have decided on future reduction in th e sulphur content in marine fuels according

to Table 9.1.

Table 9.1. Sulphur limits in marine fuels



### From year Max S-content

(wt%) in fuel Area

2005 4.5 Worldwide

2006 1.5 SECA 2010 July 1 1.0 SECA

2012 Jan 1 3.5 Worldwide

2015 Jan 1 0.1 SECA

2020 Jan 1* 0.5 Worldwide *may be postponed to 2025

In addition to these regulations there are some reg ional limits for sulphur in marine fuels. Within the European Union ships at berth and ships using i nland waterways must use a fuel with less than 0.1% sulphur from 2010. Ferries within the EU must use a fuel with less than 1.5% sulphur. In the waters outside California ships have not bee n able use heavy fuel oil since July 1, 2009 and the sulphur content is restricted. In Sweden a system of lower fairway dues for shipping using low-sulphur fuel has been in use for a number of ye ars.

There are two principle approaches to reducing SO 2 

### emissions from shipping. The first alternative is to use a low sulphur fuel - either desulphurised residual oil or marine gasoil. The second is to remove the sulphur oxides by exhaust gas cleaning; this allows for the continued use of the relatively less expensive high-sulphur heavy fuel o il together with an SO 2 

### abatement system. The most practical abatement method is gas scrubbing, a technique where the sulphur oxides react with water and are captured as sulphates. This is a n established technique that has been used for many years for land-based power plants etc. Scr ubbers are also frequently used on large tankers as a way to produce inert gas that is used while unloading the cargo. The water used for scrubbing can be either re-circulated with a contin uous addition of alkali, or alternatively, sea water - where the natural alkalinity of sea water i s utilised for the capture of SO 2 

### . The removal efficiency is normally high but depends on the alka linity of the water. The latter also decides the acidity of the effluent water together with factors like the scrubber water flow in relation to exhaus t

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### AEA 61 flow. The scrubber will also remove a significant p art of the particles and a minor part of the nitrogen oxides (NO

x 

### ) from the exhaust. The seawater is by various mean s filtered before disposed into the sea, producing sludge that should be treated on land.

The regulations stating the sulphur limits in Table 9.1 allow for the use of abatement technologies, such as scrubbers, as an alternative to low-sulphur fuel. This is stipulated in Regulation 4 of Annex VI to MARPOL 73/78 and in art icle 4C of 2005/33/EC. The "equivalence

clause" states that an alternative method should be at least as efficient in terms of emission reduction as the use of low sulphur fuel would be. Thus, the use of abatement of SO 2 

### in

combination with HFO should be such that the enviro nmental and health impacts are less than what they would have been had low-sulphur fuel (acc ording to Table 9.1) been used.

9.3 Abatement of sulphur oxides

Scrubber systems have been used since the 1930s in order to remove SO 2 

### from flue gases. The basic principle is that SO 2 

### reacts with substances in a spray of water, which e ssentially keeps pollutants in the exhaust from being emitted to air by capturing them in the liquid. In many land based systems, SO 2 

### is treated with limestone to form gypsum but some facilities utilise the natural alkalinity of sea water for sulphur scrubbi ng. On land, installations of SO X 

### -scrubbers are relatively common because land based industries do not have the same constraints of space and complexity as ship based equipment. Alternatively f reshwater, in combination with caustic soda, can be used as the scrubbing agent. The solid parti cles that end up in the water are allowed to settle in a sludge tank and the wash-water is treat ed before being disposed into the sea. If this treatment is not carried out, particulates and othe r pollutants will reach the sea water.

The most important chemical reactions that take pla ce during the desulphurisation process are the following.



## SO 2 

## (gas) + H 2 

## O + 1⁄2O 2 

## ==> SO 4 2- 

## + 2H +



## HCO 3 - 

## + H + 

## ==> CO 2 

## + H 2 

## O

SO 2 

### absorbed in seawater reacts with oxygen to form su lphate ions and hydrogen ions. Increased concentration of hydrogen ions means increased acid ity and decreased pH. Bicarbonate ions (HCO 3 - 

### ) from the seawater react with hydrogen ions and th ereby neutralise the acidity and raise the pH. SO 2 

### consumes oxygen to form sulphate and SO 2 

### concentration therefore corresponds to a certain Chemical Oxygen Demand (COD).

In addition to the capture of SO 2 

### some NO

x 

### and CO 2 

### may be removed from the exhaust gas in the

scrubber. For NO

x 

### it is mainly the NO 2 

### fraction that is captured and it will be emitted w ith the

wash-water as nitrates. While some CO 2 

### may be captured and emitted with the wash-water th is gives no net capture of CO 2 

### because the balance between CO 2 

### in sea and air will be reestablished by CO 2 

### emission from the sea.

The alkalinity of the water is thus a key factor fo r the acidity of the effluent water. Furthermore, the efficiency of the scrubber process increases wi th higher alkalinity. There are two principle designs of marine scrubbers: seawater or open scrub bers and fresh water or closed loop scrubbers. In a marine seawater scrubber the flue g as either passes through a spray of seawater or is bubbled through seawater. The alkalinity of s eawater is used to capture the sulphur and neutralise the wash-water. The sulphur is discharge d into the sea with the treated wash-water

which is acidic. In a freshwater scrubber the alkal inity is maintained through the addition of

caustic soda and a bleed off of the scrubber water is emitted to the sea after treatment. There are also the possibility to combine the two types so th at, for example, closed loop operation can be used in waters with low alkalinity and seawater ope ration at open sea. A number of trials have

been undertaken with seawater and freshwater scrubb ers onboard ships (see Skema 2009).

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### AEA 62 Three principle functions can be identified. 1. scr ubbing of the flue gas where SO 2 

### , particles and other constitutes are trapped in the seawater. 2. F iltering the seawater and dilution before disposal overboard. This leaves a sludge that is ke pt onboard for disposal at shore. 3. Demisting and heating of the exhaust gas after the scrubber u nit in order to prevent a mist with low pH.

9.4 A comparison between reducing SO 2 

### emissions with low sulphur fuel or scrubbers

The intention of the equivalent clause described ab ove is to allow for abatement technologies to be used in combination with heavy fuel oil which ma y be economically advantageous. At the same time, the environmental impact when using the abatement technology should be less or equal to what would be the case if low-sulphur fuel were used. The writing specifically emphasizes emissions of sulphur dioxide but there a re also other factors to consider. It can be useful to consider impacts which may be expected fr om the use of scrubbers in combination with high-sulphur heavy fuel oil and compare to the impa ct from use of low sulphur fuel oil.

The abatement of SO 2 

### emissions required to be equivalent to certain sul phur content in fuel has been calculated by IMO and is expressed as a ratio between SO 2 

### and CO 2 

### concentrations in the exhaust gas. Thus, the SO 2 

### emissions for a ship using scrubbers, when fulfill ing these criteria, will be lower or equal to what it would be with the stip ulated fuel sulphur content. However, in many cases scrubber equipment would be able to reduce th e SO 2 

### emissions significantly further, for example when the ship is used outside SECA areas. S ince there is a running cost for a scrubber system, due to power consumption in pumps and, for closed loop systems, consumption of NaOH, it is likely that the scrubbers will be used so that the regulations are just fulfilled. Consequently there is potential for further reducti on in SO 2 

### emissions that may be accessed through policy initiatives.

In the production of low-sulphur fuel the sulphur f rom the refineries can be used for other products. There is a fuel (and thus CO 2 

### ) penalty in producing low sulphur fuel the magnitu de of which depends on a number of factors in the refiner y design and the crude oil that is used. For ship-based scrubbers the sulphur is emitted to the sea as sulphate ions; these will not constitute any significant addition to the sulphates already p resent. However, the acidity of the effluent may be an issue – see above, its neutralisation is ach ieved either using the natural alkalinity of the sea water (open scrubbers) or by an alkaline chemic al (closed scrubbers). In both cases there

will be a net CO 2 

### emission, either during the production of NaOH or from the sea when carbonate and bicarbonate ions neutralise the sulphuric acid.

The emission of particulates will be significantly reduced if the sulphur content in the fuel is low because there will be less sulphate-based particula te matter produced. If at the same time there

is a switch from residual oil to distillate fuel th en the PM emission will be reduced even further since the high concentrations of polyaromatics and ashin the residual oils result in high emissions of particles. A scrubber unit, as well as removing SO 2 

### , has the potential of capturing a large

fraction of the PM that would otherwise be emitted to the air; this approach reduces emission of soot particles and a range of metals and PAH. If t he scrubber wash-water were not treated, however, the particulate matter would be discharged into the sea which is common for for scrubbers used to produce inert gas for some ships. The level of wash-water contamination for sulphur abatement scrubbers would be sufficiently h igh that it should be treated before being discharged to the sea in order to avoid risk to the local marine environment. Treating the effluent will produce sludge that must be taken ashore for s afe disposal. However, since the regulations focus on using scrubbers for sulphur abatement only , they are not well adapted to utilize the potential of scrubbers as PM abatement systems; thi s is because a scrubber system that has not been designed, specifically to abate exhaust gas pa rticulate can more easily comply with the wash-water criteria - less PM will be present in th e wash-water and less treatment is needed. A potential solution would be to combine wash-water c riteria and PM exhaust emission criteria in order to require that the scrubber units abate PM f rom the exhaust gas and treat the wash-water effectively. The two main alternatives to comply w ith the sulphur emission regulations in a SECA

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### AEA 63 area after 2015 are to use marine gasoil with 0.1% sulphur or to use scrubbers; the latter option then allows the use of high sulphur residual oil. T he first alternative is likely to give a reduction in PM emissions of about 90% (on mass basis) relative to residual oil with 1.5% sulphur. For outside SECA areas after 2020 heavy fuel oil with a sulphur content of 0.5% is likely to be used. This will give a reduction of around 65% relative to heavy fu el oil with around 3.5% sulphur. The reduction

of PM emissions for the scrubbers that have been te sted for marine applications has varied between 0 and 85%. The scrubbers were designed for SO 2 

### abatement and while a high PM abatement efficiency may be possible it is not a tr ivial matter to measure the PM trapping efficiency -when the temperature and humidity varie s greatly between the measurements. In summary, the use of marine gas oil with low sulphur content will significantly reduce the emission of PM compared with the situation today. This will reduce the deposition to the seas as well as

the contribution to the concentration of PM in the air over land. The use of scrubbers can also reduce the emissions of PM depending on the design of the unit. The emissions to water would be higher if the effluents were not treated. With e ffective treatment sludge will be produced and disposed at land. At present there are no real inc entives to make scrubbers an effective abatement technology for PM.

Regarding nitrogen oxides, scrubbers are likely to capture the NO 2 

### -fraction in the exhaust and may be designed to capture NO as well. Doing so ma y cause an emission of nitrates into the sea

with the scrubber water – which is unwanted in area s at risk of eutrophication. NO

x 

### emitted with the exhaust gas is distributed over sea and over la nd so a scrubber that captures NO

x 

### may redistribute the N deposition between the land and the sea, it would also decrease the contribution to particle formation from nitrates.

Another difference between the two alternative meth ods of reducing SO 2 

### emissions - scrubbers and low sulphur fuel - is that ships would carry di fferent fuels. In the case of an accident or with diffuse oil spills there could be either HFO or MGO present, each with somewhat different properties and different harmful effects, likely mo re severe in the case of HFO. Furthermore, a greater and more efficient use of scrubbers will pr oduce sludge, for ports to handle, that is potentially toxic.

9.5 Emission criteria for EGC

The emissions to air of SO 2 

### can be monitored as the SO 2 

### to CO 2 

### ratio from which corresponding fuel-sulphur content can be obtained. Since there may be capture of CO 2 

### in the scrubber, or

release of CO 2 

### from the chemical reactions involved in the buffer ing, the CO 2 

### concentration

should be measured before the scrubber unit. All sulphur compounds emitted to air should be measured and aggregated – care should be taken to e nsure that the more highly oxidised sulphur compounds are accounted for. The SO 2 

### to CO 2 

### ratios corresponding to certain fuel-sulphur level s have been calculated by IMO (see Table 9.2). No oth er emissions to air are regulated in the IMO guidelines for sulphur abatement technologies.

Table 9.2. SO 2 /CO 2 ratio corresponding to certain fuel-sulphur levels



### Fuel-sulphur content (wt %) SO 2 

### (ppm)/CO 2 

### (%) ratio in exhaust

4.50 195.0

3.50 151.7

1.50 65.0

1.00 43.3

0.50 21.7

0.10 4.3

9.6 Wash-water criteria

The IMO Wash-water criteria are stipulated in secti on 10 of Annex 5 to MARPOL 73/78. We refer here to the preliminary guidelines dated July 16, 2 009. The values that are to be monitored should include pH, PAH, turbidity and temperature. There are also limits on the nitrate content in

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### AEA 64 the discharged wash-water. The text in this version of the guidelines implies that the wash-water criteria apply everywhere. However, in earlier vers ions the criteria were only applied to harbours, estuaries and ports. It is uncertain, at present, i f separate limits will be developed for operation a t

open sea.



## pH
pH is a measure of the acidic or basic (alkaline) n ature of a solution. The concentration of the hydrogen ion [H + 

### ] in a solution determines the pH. Ocean water usua lly has an excellent buffering system, with interaction of carbon dioxide and wate r, and pH generally varies between 7.5 and 8.5. Neutral water has a pH of 7 while acidic subst ances are less than 7 (down to 1, which is highly acidic) and alkaline substances are more tha n 7 (up to 14, which is highly alkaline). Anything either highly acid or alkaline would sever ely affect marine life but the oceans are usually very stable with regards to pH. According to USEPA the criteria for pH for effluents emitted to
marine waters should be 6.5-8.5, but no more than 0 .2 units outside of normally occurring range

. Alkalinity is a measure of the buffering capacity o f a solution and molecules, e.g. carbonates and bicarbonates, take up hydrogen from a solution.

In the IMO wash-water criteria regarding pH it is s tated that the wash-water should comply with one of the following:

· The discharge wash-water should have a pH of no le ss than 6.5 measured at the ship’s overboard discharge with the exception that during manoeuvring and transit, the maximum difference between inlet and outlet of 2 pH units is allowed measured at the ship’s inlet and overboard discharge.

· During commissioning of the unit(s) after installa tion, the discharged wash-water plume should be measured externally from the ship (at res t in harbour) and the discharge pH at the ship’s overboard pH monitoring point will be re corded when the plume at 4 metres from the discharge point equals or is above pH 6.5. The discharged pH to achieve a minimum pH units of 6.5 will become the overboard p H discharge limit recorded.



## PAH
Polycyclic aromatic hydrocarbons (PAH) are the larg est known group of carcinogenic substances and include many individual chemical substances con taining two or more condensed aromatic rings. The biological effect of PAH is linked to th e planar structure of the molecule and its ability to

affect DNA in the cell nucleus. PAH are formed whe n coal, oil, or other hydrocarbons are heated under anoxic conditions, i.e. with insufficient oxy gen, and are the products of incomplete combustion. PAH are not usually present as individ ual compounds but occur in mixtures. PAH are fat soluble and might be bio-accumulative (in f atty tissues). In the aquatic environments, PAH are usually bound to particles which transport to s ediment. Many PAH compounds accumulate in invertebrate organisms. Fish eggs and fry exp osed to PAH have been found to suffer mutation, bleeding, heart conditions, reduced growt h and increased mortality. A group of 16 PAHs are usually measured and analysed, but in the IMO wash-water criteria, PAH phe 

### or phenanthrene equivalence is used. Phenanthrene is a member of the PAH group and is

insoluble in water. PAH is sometimes used as an in dicator of the total emissions of hydrocarbons.

The IMO wash-water criteria regarding PAH:

· The maximum PAH concentration in the wash-water sh ould not be greater than 50 μ g/l

PAH phe 

### above the inlet water PAH concentration. The PAH co ncentration should be measured downstream of the water treatment equipmen t.

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### AEA 65 · The 50 μ g/l limit is normalized for a wash water flow rate through the EGC unit of 45 tonne/MWh. The limit has to be adjusted upward for lower wash water flow rates per MWh to get a limit of 2.25 mg/kWh of PAH phe



### .

· For a 15-minute period in any 12-hour period, the PAH concentration may exceed the limit described above by up to 100%.



## Turbidity
Turbidity is a measure of the amount of particles i n the water, or rather the cloudiness caused by suspended solids. Turbidity in open water can be ca used by several different reasons, e.g. phytoplankton or high levels of sediment in the wat er. In lakes and shallow areas the turbidity can decrease the amount of light reaching the lower dep ths and thereby affect submerged plants and in the end also species that are dependent on the a mount of plants. Turbidity is measured in FTU (Formazin Turbidity Unit) or FNU (Formazin Nephelom etric Units).

The IMO wash-water criteria regarding turbidity:

· The maximum continuous turbidity in wash-water sho uld not be greater than 25 FNU or 25 NTU above the inlet water turbidity.



## Nitrates
Nitrogen oxides, i.e. the sum of NO and NO 2 

### , are produced during combustion at high temperatures. The oxides can contribute to acid rai n and other environmental effects. Nitrate (NO 3 - 

### ) is the most highly oxidised form of nitrogen and excess nitrate concentrations in aquatic systems can lead to algae blooms and eutrophication

.

The nutrient concentration in seawater usually decr eases during springtime and all processes in the nitrogen cycle are seasonally dependent. When o xygen is present, ammonia can be oxidised to nitrate (via nitrite) in a process called nitri fication.

The IMO Wash water criteria regarding nitrates:

· Nitrates should be monitored. The wash-water treat ment system should prevent the discharge of nitrates beyond that associated with a 12% removal of NO

x 

### from the exhaust, or beyond 60 mg/l normalized for wash-wate r discharge rate of 45 tonnes/MWh whichever is greater.

9.7 Environmental assessments

Behrends and Liebezeit (2003) presented an environm ental impact analysis of sea water scrubbers. Laboratory tests with mixtures of seawa ter and sulphuric acid solution at pH 4, to mimic scrubber wash-water, were performed where the resulting pH was studied. A mixture of 1:10 in seawater was found to give a pH increase of around 0.1. This is compared to the EPA

limit of 0.2 that is considered safe. For brackish water a higher change in pH was observed initially. In another report by Hufnagl et al. (20 05) sampling was carried out of scrubber water and water from ports where a trial with a seawater scru bber onboard the Pride of Kent was undertaken. A decrease in pH of maximum 2 in the e ffluent was observed together with increased nitrate content. No impacts on seawater o r increased toxicity were reported.

Buhaug et al. (2006) discussed wash-water criteria for scrubbers and performed an environmental analysis. They suggested using a PNEC (Predicted No Effect Concentration) value for pH of 0.2. A set of criteria are suggested for three different levels of safety. The criteria are for THC and a set of metals. They also propose that no limits are required for pH and COD. The criteria are given in mass per volume of effluent w ater under the assumption that 45 kg water/kWh is used in the scrubber. They also sugges t that the PNEC value for total hydrocarbons (THC) is set to 40 μ g/l. Values recalculated to mass per engine output are given in Table 9.3.

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### AEA 66 Buhaug et al. use the concept of near field, outsid e which no effect concentration should be

reached. This is set to 50 m from the stern for a m oving ship and to 20 m for quay side manoeuvring.

Table 9.3. Wash-water criteria after Buhaug et al. in mg/kWh 

### Component safety level 1 safety level 2 safety level 3 PNEC

THC 200 20 2 1.8

Cu - 1.8 0.2 0.13

Ni - 1.3 0.1 0.09

V -

- 6.6 4.4

Pb -

- 0.5 0.37

Karle and Turner (2007) analysed the amount of wate r needed for scrubbing of SO 2 

### as well as the dilution of this water required for reaching a pH of 6.5 for different water types and temperatures. They showed that the amount of water needed to capture the SO 2 

### is significantly higher in river water than at open sea and with bra ckish water in between. They also showed that the wash-water with a pH of 6.5 will quickly be neu tralised to reach a delta pH of 0.2 and that both the capture of SO 2 

### and the buffering (i.e. the dilution needed) are t emperature dependent

processes.

GESAMP have commented on the wash water criteria in MEPC 59/4/19. No objections were raised to the choice of parameters to be monitored but they recommended that dissolved oxygen

should be measured in addition. GESAMP also recomme nded that a generalised marine environmental risk assessment should be developed i n the future when it is possible that many ships use scrubbers. According to GESAMP, the wash -water quality criteria appear to adequately reflect the hazards posed by wash-water discharge to the local marine environment. pH reflects the acidifying properties of dissolved SO

x 

### and its potential for acute effects on biota. PAH represents any oily discharge, NO

x 

### reflects any tendency towards eutrophication and turbidity is intended to safeguard against particul ate matter (heavy metals and ash). GESAMP stated that an environmental benefit in reducing SO

x 

### emissions to the atmosphere only can be achieved if the discharge do not create further ris ks to the aquatic environment. One remark by GESAMP was that IMO should consider the potential c ontribution to ocean acidification of the large scale application of SO 2 

### capture from ships.

The reference value for a safe change in pH used in the studies is 0.2 which originally comes

from EPA. It has been found that wash water emissio ns from scrubbers is quickly diluted and buffered to reach this level, both in measurements and modelling. No clear data is given for how large zone around a ship is needed to reach this le vel (in ports or at sea) although the amount of

dilution needed can be obtained from Karle and Turn er. The PAH criteria is intended as a measure of oil and other hydrocarbons emitted with the wash water - this is the parameter where Buhaug et al. obtained emission values that a re high and close to the PNEC; it is not clear from these reports how a PAH phe 

### concentration is related to the emission of THC. Hufnagl et al. report that phenanthrene is the dominating PAH in t he wash water and thus the best candidate for analysis. Turbidity is not discussed except tha t GESAMP regards it as a way to monitor particulate matter. Elevated nitrate levels were ob served by Hufnagl et al. and they actually note that up to 20% of the NO

x 

### may be captured and released as nitrates. In addit ion GESAMP suggests that COD should be monitored and Buhaug et al. suggest that emissions of Ni, V, Cu, Pb and THC should be regulated.

9.8 Environmental impact related to the IMO wash wa ter criteria

The potential impact of aqueous discharges to the m arine environment require information on both the potential toxic effects on representative marine organisms to different concentration levels of the discharged water in sea water, and th e sensitivity of the marine environment in the region of concern. This should, furthermore, be re lated to the discharge conditions and the

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### AEA 67 resulting rate of dilution and spatial extent of th e plume formed by the discharge after disposal to the sea. There is a risk for locally high concentra tions of a number of harmful substances if there are no adequate wash-water criteria in force.



## pH
Hufnagel et al. have analyzed the environmental imp act of a seawater scrubber for two harbours, Calais and Dover. They took samples from the seawat er scrubber system and the samples partially showed values lower than pH 3. The buffer ing system increased the pH. Experiments showed that a mixture containing 40 % of seawater a cidified to a pH of 4 (comparable to what happens in a seawater scrubber) only changed pH abo ut 0.2 units. The lowest pH measured in the overboard discharge was 6.2. The US EPA, as men tioned earlier, has passed a guideline concerning the introduction of acids which states t hat outside the initial mixing zone the pH change is not allowed to be more than 0.2 units. Un der the circumstances stated, the pH would

not reach a value that is harmful to the marine env ironment. This is dependent on the dilution, volume of water and the specific area of concern. B uhaug et al. (2006) stated that discharges from a single ship are rapidly diluted when the shi p is moving, but expected to be much slower when the ship is not moving.

Karle and Turner calculated the amount of water nee ded for scrubbing SO 2 

### and dilution to first obtain pH of 6.5 and then a delta pH of 0.2. In add ition they looked at further dilution to reach a maximum of 1% reduction in oxygen concentration. Th ey considered different water types and temperatures for a 12 MW engine using a fuel with 3 % sulphur. Adding all these factors gives an indication of the amount of seawater affected by a scrubber. Table 9.4 gives an indication of these amounts when scrubbing to a SO 2 

### emission corresponding to 0.1% fuel-S. The nominal flow rate of scrubbing water used by MEPC is around 45 tonne/MWh giving about 540 tonne per hour for a 12 MW ship. This should primarily be com pared with the water needed for scrubbing in

Table 9.4

Table 9.4 Approximate amount of seawater affected by a scrubber for a 12 MW engine using 3% Sfuel and with a seawater temperature of 10°C for sc rubbing to a SO 2 emission corresponding to 0.1%S fuel. After Karle and Turner (2007). Open sea Baltic Proper River freshwater Water for scrubbing 700 900 2500 tonne/h Water for dilution to pH

6.5 1400 1700 15000 tonne/h

Factor for dilution to delta pH 0.2 3 3.5 2.5

Sum 6300 9100 44000 tonne/h



### The results in table 9.4 show that almost 7 times m ore water for dilution is needed when scrubbing takes place in fresh water, compared to o pen sea.

As an example we can look at the port of Hamburg. In 2000 115.5 ktonne of CO 2 

### and 1.9 ktonne

of SO 2 

### were emitted corresponding to a fuel consumption o f about 36.3 ktonne with a sulphur content of 2.6% (Whall et al. 2002). If all of thes e ships were to use open scrubbers around 21 tonnes/s of water would be needed for the scrubbing and buffering, this can be compared with the flow in the Elbe, which is around 720 tonne/s.



## PAH
The criteria for hydrocarbon emissions with the eff luent water is given as PAH in phenanthrene equivalents. The reason seems to be that measuring PAH is a means to monitor hydrocarbons and phenanthrene was found to be the most abundant PAH in the analysis by Hufnagl et al. (2005). However, the concept "phenanthrene equivale nts" is not well established and needs to be explained or replaced. Assuming that it simply mean s that the phenanthrene concentration is measured, the criteria correspond to about 2.2 mg/k Wh of PAH phe 

### . Cooper et al. (1996) analysed

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### AEA 68 PAH in the exhaust from two ships and found phenant hrene levels in the gas to be 71 and 250

μ g/kWh respectively. The lower value refers to an en gine using HFO. Thus, the wash-water criterion seems to be set rather high - considering that the scrubber water should be treated before the samples for the PAH analysis are taken. A 12 MW engine could, with the suggested limit, emit around 26 g phenanthrene per hour and i n addition unknown amounts of other PAHs.

According to Buhaug et al. (2006) OSPAR have develo ped Ecotoxicological Assessment Criteria (EAC) for a large range of chemicals, including PAH s. This was done to make the evaluation of monitoring data on toxic substances in the marine e nvironment easier. The EAC can be applied as PNEC (Predicted No Effect Concentration) values. The EAC-water for phenanthrene is proposed to 0.5 – 5 (μg/l) (provisional value). The PNEC value is the maximum permissible

concentration that can be sustained over time. The Predicted Environmental Concentration (PEC) equals the proposed wash-water criteria multiplied by the dilution (if inlet concentration is assumed to be zero). Since the wash-water criterion is set to 50 μ g/l PAH phe 

### (for a scrubber water flow of 45 l/kWh) the wash-water must be diluted 10 – 100 times to reach this PNEC concentration. Furthermore, the background concentr ation should also be considered, which may

lead to further limits on the emissions. In Directi ve 2008/105/EC EQS (Environmental Quality Standards) have been set for priority substances. The EQS are not applicable for PAH as a group but for identified substances e.g. for Benzo( a)pyrene, the sum of Benzo(b)fluoranthene and Benzo(k)fluoranthene, and the the sum of Benzo( g,h,i)perylene and Indeno(1,2,3-cd)pyrene; the Directive does not include EQS for phenanthrene

.

It is still to be established, furthermore, that th e PAH criteria used will ensure that the levels of total hydrocarbon compound (THC) emissions are at s afe levels. The criteria for THC developed by Buhaug et al. are 4500, 450 and 45 μ g/l for the three "Safety Margins" that they use. T his is under the assumption of a wash-water flow of 44 ton ne/MWh. These levels would correspond to 200, 20 and 2 mg/kWh. Thus the IMO criteria which a pplies only to phenanthrene is set to about the same as the THC value by Buhaug et al. for safe ty margin 3.

If we look at the port of Hamburg again, the amount of PAH phe 

### emitted were all ships to use scrubbers and allowing the scrubber water to be at the criteria limit would be around 400 kg
phenanthrene per year



## .

Turbidity
Turbidity is chosen as a means to measure the suspe nded solids in the water – and because it a simple method for on-line analysis. Turbidity can b e a useful indicator of the status of the scrubber, i.e. that suspended particles are not bei ng formed in the scrubbing process or the wash water treatment. However, turbidity is not a direct method of determining the number of exhaust particles that end up in the wash water - there is no direct correlation between turbidity and particle concentration. Further, turbidity values are strongly dependent on the size of particles in the water and smaller particles are likely to have significantly less influence the measured turbidity than larger ones. Studies are required to correlate the turbidity measurements with concentrations of particulate matter, ash, metals e tc in the wash water before this criteria can be considered an indication of particulate levels in t he wash-water. These uncertainties make it

hard to make an environmental assessment of the tur bidity criteria.



## Nitrates
The criteria for nitrates are motivated by the incr eased contribution to eutrophication that will be

the result of increased emissions of nitrates with the effluent water. Since scrubbers are likely to capture the NO 2 

### in the exhaust the 12% maximum capture requirement of NO

x 

### will normally be met. Hufnagl et al. (2005), however, report a capt ure fraction of up to 20%. To analyse what the

12 % criteria could mean it is of interest to look at the Baltic Sea, which is heavily trafficked, it is a SECA area and it is highly affected by eutrophicati on and large efforts are made to decrease the

flow of nutrients into the Baltic. The total emissi on of NO

x 

### from shipping in the Baltic according to a recent Helcom study (Jalkanen 2009) is around 400 ktonne per year at present. EMEP

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### AEA 69 modelling (Benedictow 2009) has calculated how much of the emissions from a certain area is deposited in another area, from this work it can be concluded that about 13% of the NO

x 

### emitted from shipping in the Baltic Sea is deposited in the Baltic Sea - the rest is deposited over land or (to a smaller extent) in other sea regions. Consequ ently ~ 107 ktonne per year is deposited in the Baltic Sea from shipping in the Baltic Sea calculat ed as nitrates. If all of these ships were to use scrubbers and all of these scrubbers captured 12% o f the NO

x 

### in the exhaust and released this as nitrates in the scrubber water the total deposition would increase to 193 ktonne, i.e., an increase of about 86 ktonne per year. This is, of course, an unrealistically high number considering that not all ships will have scrubbers and that the capture fraction will, in practice, be lower. Further, a certain fraction of the nitrates deposited over lan d would return to the Baltic Sea with rivers etc.; it does give, however, a maximum possible contribution increase of nitrates. Further, of the total load of nitrogen to the Baltic Sea 25% comes from d eposition and the rest via rivers and direct waterborne discharges. Thus the hypothetical maximu m increase in load of nitrates, if all ships were to use scrubber, would be about 2%.

COD, the chemical oxygen demand, is a measure of th e theoretical oxygen consumption of a water sample, i.e. the amount of oxygen needed to b reak down the organic matter in it. According to Buhaug et al. there are no environment al standards for COD. Tolerance to reduced dissolved oxygen varies between organisms, life sta ges and environmental conditions. While Buhaug et al. concluded that COD was not a matter o f concern under the circumstances of their study. Karle and Turner used a criterion that the COD should be less than 1% of the available free oxygen, which they found to be met when their criteria for pH were met.

9.9 Monitoring

In directive 2005/33/EC, article 4c it is stated th at ships using abatement technology to achieve

low SO 2 

### emissions must be fitted with continuous monitorin g equipment for SO 2 

### emissions in

order to establish that the emissions at all times are lower or equal to that which would have been obtained by using fuel with the stipulated sulphur content.

In the "revised guidelines for exhaust gas cleaning systems" from MEPC dated 16 July 2009 there are two permissible schemes, Scheme A (unit c ertification with parameter and emission checks) and Scheme B (continuous monitoring with pa rameter checks).

In Scheme A the unit should be certified to meet th e limit values for SO 2 

### /CO 2 

### concentration in the exhaust. The fuel that may be used, including sulph ur level, must be specified together with other operational parameters such as gas flow, water flow , and salinity of sea water or fresh water elements necessary to provide adequate neutralisati on agents. A SO X 

### emission compliance

certification must be obtained from the administrat ion. There must also be a certification procedure established for use during surveys. The s ystem must automatically record that the abatement equipment is in use by monitoring wash wa ter pressure and flow rate at a frequency of at least 0.0035 Hz. Further, daily spot checks of t he SO 2 

### /CO 2 

### ratio are "recommended". If the manufacturer is unable to provide assurance that th e unit will meet the certified value this way,

Scheme B is recommended.

In Scheme B compliance is demonstrated by continuou s monitoring. Thus SO 2 

### and CO 2 

### concentrations are to be measured after the abateme nt equipment with a frequency of at least 0.0035 Hz. In this scheme parameters such as exhaus t gas flow rate and water flow rate are to be checked daily. There should be a technical manua l where it is stated, for example, the

minimum and maximum water flow rate and minimum inl et water alkalinity and other parameters for the operation of the unit. The manual should be approved by the administration.

The procedure for emission testing and data recordi ng is described and the same for both schemes. The recording equipment must be tamper pro of. For both schemes the ship must have

a SO X 

### emission compliance plan showing how the equipment should be used to comply and how

this is demonstrated.

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### AEA 70 In addition, both schemes will require continuous m onitoring of the wash-water criteria discussed above, i.e., pH, PAH concentration, turbidity and t emperature.

Thus, in Scheme A the function of the abatement equ ipment is certified by continuously recording operational parameters such as water flow and press ure as well as wash-water parameters. In Scheme B the compliance is verified through direct measurements of the SO 2 

### emission together with the wash-water parameters. Only Scheme B comp lies with the wording in Directive

2005/33/EC.

The advantage with continuous monitoring of the SO 2 

### /CO 2 

### ratio is that compliance with regulations is directly monitored at all times. The re are also some disadvantages: continuous monitoring of exhaust from engines can be expensive and technically problematic, this is discussed by CIMAC in a report from 2005 and by Joh nsen et al, the measurement systems may also be affected by the high temperatures and the h igh particle load in the exhaust. Further, vibrations, variation in ambient temperature, spray of liquids and fluctuation in voltage may influence the measurements and the monitoring syste ms may then require much maintenance and calibration in order to function properly.

Continuous monitoring can be of great value especia lly if the conditions that may influence the performance of the abatement equipment are likely t o change. For sea water scrubbers this may be when moving in areas with seawater of varying al kalinity. In waters with low alkalinity more seawater is required to meet the required SO 2 

### emissions and further, more dilution will be required to meet the wash water limit for pH.

For closed loop scrubbers the function is not depen dent on the characteristics of the surrounding seawater since the operation of the equipment invol ves fresh water and an added neutralising
agent.

The requirements in the MEPC guidelines make it pos sible to use Scheme A for closed scrubbers, it may also be suitable for some sea wat er scrubbers. During certification the feasibility of using Scheme A should also be invest igated, i.e., by showing that the monitoring of the system parameters gives evidence that the SO 2 

### emission and wash-water requirements are met. There may well be cases where a scrubber is no t certified, for example, for use in rivers or brackish water systems and then the functionality c an be expected to be more stable. If a system, during certification, is found to have too low a ca pacity under certain conditions, such as alkalinity, sea water temperature etc, it is possib le to certify the unit using Scheme B. Since it is possible that there will be a number of systems tha t can be monitored satisfactorily using Scheme A it is recommended that the IMO regulations regard ing monitoring are incorporated also in the EU regulations.

With the use of either scheme it is of great import ance that the SO 2 

### emissions and wash-water criteria are controlled. This might be achieved via regular certification measurements required by administrative provisions. Further surveillance of the SO 2 

### emissions can be made by authorities using remote sensing of the SO 2 

### /CO 2 

### ratio in the exhaust plume – from the land or from airplanes, there is an ongoing program for the deve lopment of such systems at the JRC. Mellqvist et al. (2008) have demonstrated such a me thod with surveillance from airplanes. The uncertainty in such a measurement is expected to be around 10% and thus scrubber units that

are defective or turned off should be detectable. O ne problem may be that scrubbers can capture

some CO 2 

### and thus the SO 2 

### /CO 2 

### in the exhaust may show values that over-represent the actual

SO 2 

### emissions. This problem could be circumvented by l isting the scrubber units' CO 2 

### capture capacity during certification.

9.10 Conclusions and suggestions

The use of scrubbers to clean the exhaust from mari ne engines using residual oil could in principle lead to high concentrations of a number o f harmful compounds in the marine environment around the ships. The use of scrubbers in combination with high sulphur residual oil

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### AEA 71 may be an economically attractive option in SECA ar eas and also worldwide from 2020 and so, as a consequence, a large number of ships would use scrubbers; consequently it is of great importance that measures are taken to assure that t he marine environment is protected. There should be mechanisms to prevent the use of scrubber s in certain areas if there is a risk to marine ecosystems. The technology allows for the use of c losed systems - making it possible to limit the wash-water discharged in areas with limited water c irculation or especially sensitive environmental conditions. Scrubbing systems can be used to abate particulate emissions. The present situation is somewhat incongruous in the se nse that wash-water limits for scrubbers have been set up while there are only limits for the gas eous emissions of SO 2 

### and NO

x 

### – a situation

that does not reflect current concerns related to t he health impacts of PM. It is recommended that criteria are developed that promote the abatem ent of PM with, as a minimum, limits set to allow either voluntary or market based reductions o f PM emissions; it is suggested, furthermore, that where/when possible, EU regulations are kept i n line with the IMO guidelines.

The wash-water criteria include limits for PAH, pH, turbidity and nitrates. Of these all except the

nitrate criterion are intended for continuous monit oring onboard the ship. So, a major factor to be considered when formulating the criteria is that th ey should be suitable for online monitoring. However, it would also be possible to add additiona l criteria that are to be tested during certification. This could give further assurance th at the units are environmentally safe and would not have to be constrained by the need to measure o nline. The wash-water criteria apply everywhere but it is possible that additional, sepa rate, criteria can be developed for open sea.

With the present criteria for pH it would appear th at the dilution in the sea and natural buffering will rapidly give acceptable levels - even in confi ned areas. It is recommended, however, that

further studies are undertaken for brackish and riv er water and that the criteria are then reviewed accordingly. It is suggested that the IMO guidelin es are adopted for the pH criteria while, at the same time, allowing for revision as more data becom es available. If the criteria for open sea were relaxed then more acidic scrubber water may be emit ted to the sea - however, the same volume

of water would be affected because less water would be used for dilution within the ship.

The PAH criteria in the IMO guidelines are expresse d as phenanthrene equivalents. This is not a well established concept and should be further defi ned in the guidelines. The criteria correspond to an emission of phenanthrene of 2.2 mg/kWh which could, in principle, lead to large emissions

of PAH from marine scrubber units. The criterion wa s probably chosen in order to be easy to measure with continuous monitoring. While it may be appropriate to use phenanthrene for monitoring purposes the criteria ought, nevertheles s, to ensure a low discharge of a range of

PAHs – so how the measured value relate to the PA H 16, for example, or its correlation to THC needs to be established during certification; this correlation may differ for different scrubber systems and fuels. It is suggested that the PAH cr iteria that are used are in line with Directive 2008/105/EC. The criteria for THC suggested by Buh aug et al. could be used for commissioning. It is yet to be established that PAH phe 

### is an adequate measure of the concentration of oil or THC

in the wash-water.

The criteria for turbidity may be suitable for esta blishing that unwanted solid material is not formed in the scrubber unit but it is unlikely to b e appropriate as a measure of the proportion of particulate matter from the exhaust gas that captur ed and discharged with the effluent water. There is no simple relation between particle concen tration and turbidity and the turbidity measure is strongly dependent on particle size. It is sugg ested that: the concentrations of particulate matter, metals, and PAH are regulated and tested du ring commissioning, and that the correlation to turbidity is investigated in order to allow cont inuous measurement onboard. Pending the delivery of data from on-going trials it is suggest ed that the turbidity criteria from IMO are used, alternatively the criteria suggested by Buhaug et a l. could be applied.

The criteria for nitrates could in principle lead t o large additional discharges of nitrates to sensit ive areas. The best way to deal with this issue would b e to use exhaust gas NO

x 

### abatement technology. Taking the Baltic example described ab ove, an engine with an emission factor of 17

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### AEA 72 g NO

x 

### /kWh should reduce its emission to about 9.4 g/kWh (if 12% of the NO

x 

### is emitted as nitrates with the scrubber water) in order not to i ncrease the nitrate load when using a scrubber. It is recommended that provisions are made when settin g criteria for nitrate emissions so that increased loads can be prevented in sensitive areas

.

Since there is limited data on the performance of m arine scrubbers for SO 2 

### , it is important to follow on-going trials in order to ensure that thor ough environmental impact assessments are conducted when evaluating and developing wash-water criteria. A larger introduction of scrubbers could lead, potentially, to high concentrations of e.g. PAH if the units actually emit PAH in

concentrations close to the criterion limit. There is also the opportunity of studying the impact of inert gas scrubbers on the marine environment; thes e are frequently used though smaller than exhaust gas scrubbers made to comply with sulphur e mission regulations. It is also important to obtain more data on the properties and amounts of t he sludge produced. This will be needed in order to develop facilities for handling of the slu dge by ports.

It seems appropriate to adopt the IMO guidelines re garding monitoring, i.e., allowing for the possibility of using alternatives to continuous mon itoring of the SO 2 

### emissions on the basis that there will be units that can be adequately monitore d by other means.

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### AEA 73 

# 10 Use of distillate fuels by ships at berth

10.1 Introduction

From 1 January 2010 ships using ports within the EU will be required to use low-sulphur fuel, maximum 0.1 wt% sulphur, while at berth, with an ex ception for those making only short stops (Directive 2005/33/EC). The regulations apply also to ships that are anchored. The fuel switch should be done as soon as possible after arrival an d as late as possible before departure. This regulation applies to all engines and to all boiler s, including auxiliary boilers.

These regulations will most likely make it necessar y to use distillate fuel while at berth. There are

concerns that there are risks associated with switc hing from residual oil to distillate fuel in boiler s.

This report has been drafted under the project “ Service contract for a Cost Benefit Analysis to support the Impact Assessment accompanying the revi sion of Directive 1999/32/EC on the sulphur content of certain liquid fuels 

### ”, which was undertaken for the Commission by a tea m including TNO, IVL and AEA under an AEA-led framework contrac t. It tries to clarify the risks associated with the problem outlined above and aims to address the following questions:

• Identify the type of ships where these risks may b e relevant.

• Estimate the number of such ships in 2010 and 2020

.

• Describe the nature of these risks.

• Indicate technical solutions and assess the costs of these.

The study has been undertaken through literature se arches and searches on the internet as well as through interviewing representatives of industry and relevant authorities. We have had contact with manufacturers of boilers and accessories, repr esentatives of ship-owners, port authorities, and maritime administrations. There are only a few reports that address the problem.

10.2 Outline of the problem

Boilers that are constructed for the use of Heavy F uel Oil (HFO) cannot, in general, be used with Marine Gas Oil (MGO) without modifications. A switc h from HFO to MGO in a boiler that is designed for HFO use could lead to operational prob lems with potential flame failure and an increased risk of a boiler explosion. To avoid thes e problems, boilers may have to be modified before a switch from HFO to MGO can take place in a safe way. The modifications needed must be assessed for each boiler individually. The exact number of boilers that will need modification,

as well as the costs and time needed for these modi fications, are difficult to assess because the figures are not well known by the ship-owners.

Boilers are typically used at berth and tankers, in particular, use large boilers for heating the cargo and for steam-driven cargo pumps.

A number of LNG-carriers use boilers for propulsion where boil-off cargo is used as fuel in combination with HFO. These boilers, which are also used at berth for cargo transfer, need to be modified before they can be used with MGO.

In order to comply with Directive 2005/33/EC, ship- owners must assess what boilers need to be modified, to what extent, and have these modificati ons done before the end of 2009. Some shipowners have made the assessments and taken steps to do the necessary modifications but many ships still need to be investigated. The process s eems to have been started during 2008 and, in most cases, activity intensified in 2009. The reaso n that the industry has not acted earlier seems to be multifold. Some ship-owners anticipated that the EU directive would be brought in line with the IMO directives of Marpol Annex 6 and that the 0 .1 sulphur-limit would be implemented in 2015 - as it will be for SECA areas. It was also expecte d that the sulphur directive would be reviewed

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### AEA 74 before 2010, and some ship-owners seem to have anti cipated, until relatively recently, that HFO with 0.1% sulphur would be made available.

10.3 Types of ships where the risks may be relevant

Boilers are used on ships either for propulsion or as auxiliary boilers. Boilers for propulsion are used in combination with steam turbines and, althou gh once abundant, they are today relatively uncommon because diesel engines have a higher therm al efficiency and are more fuel efficient.

An application where boilers are used for propulsio n is for ships that transport LNG, the reason being that some of the cargo boils off during trans port and using it as fuel for the ship recovers a part of the cargo that would otherwise be lost. Fo r reasons of thermal efficiency, these boilers operate at high pressure ~60 bar. Some newer ships instead use reliquefaction plants to collect the boil-off gas. Boil-off gas (BOG) is sometimes used in combination with a liquid fuel and, depending on power demand and operational mode, the final fuel mix can be either 100% BOG

or a combination of oil and BOG. The reasons for t he dual fuel arrangements lie in safety and the need for reliability for propulsion. For example, when manoeuvring - or for other purposes that demand a rapid response in boiler power, the gaseou s fuel alone may not be sufficient. In such situations, dual fuel mode is used where oil and BO G is burnt simultaneously. A change in power can then be taken up more slowly by using gas. Fur ther, in cases when the gas supply to the boilers is unintentionally reduced or interrupted, the system can use a fuel-oil boost up to ensure continuity in power. There is also a limited turn d own ratio for gas burners and so oil is used at low loads too. The boiler powered LNG ships used t oday are designed for a combination of BOG and HFO. Typically, a ship that would use 150 tonne s HFO per day if operated on HFO alone

uses around 10 tonnes of HFO in dual fuel mode. The boilers use small amounts of MGO during flashing from cold when furnace temperatures are lo w (normally after refit) but cannot use MGO during normal operation without modifications (see below).

Auxiliary boilers may be divided into:

1) small boilers used on ships to produce steam that can be used to heat residual oil, to produce hot water and for the purpose of heating ; and 2) larger boilers used on tankers for heating cargo and to drive steam turbine pumps

.

Auxiliary boilers are used on practically all ocean going ships. These boilers can be designed to

be used with either HFO or distillate fuel. Some bo ilers can use both HFO and MGO. Typically, boilers are used with HFO on ships that use this fu el for propulsion. The type of fuel used in auxiliary boilers has not been investigated in deta il since the fuel consumption is normally assumed to be a minor part compared to main and aux iliary engines; it is difficult, therefore, to

establish the exact distribution of boilers that us e only MGO, only HFO or a combination. The vast majority of boilers, however, use HFO and this is certainly true for the larger auxiliary boilers

on tankers.

10.4 Relevant number of ships

The need for an assessment of the potential modific ations to existing boilers to manage the switch from HFO to MGO applies, in principle, to al l ships by 2010. It is today not clear how many of these will need modifications. Work by the lead ing manufacturer of boilers, Aalborg industries (Aalborg 2009) and a study by the California Air Re source board (CARB 2008) indicates that most boilers can at least temporarily use MGO witho ut problems. However, both studies, as well as a report by DNV (DNV 2005), state that MGO shoul d not be used in a boiler designed for HFO before it has been inspected. Further, a large numb er of boilers will need modifications before they can be used safely with MGO. Although a number of ship-owners have assessed and— when necessary—modified their boilers, it seems unl ikely that all boilers will be able to run on MGO by the 1st of January 2010.

According to OCIMF at least 2 368 of 3 476 chemical and oil tankers that enter EU ports use steam for cargo pumps or cargo heating. Other ship s may use diesel engines or electrical motors

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### AEA 75 to drive the pumps, and some use electrical heating . These boilers are more likely to need modifications since they use relatively large amoun ts of fuel, which affects valves and fuel pumps. A number of tank owners will have difficulty making these modifications before the end of the year, although the exact number is difficult to say . Modifications on all ships will, in all likelihoo d, not be complete until late 2010.

The boilers on tankers are often used during the di scharge of the cargo. Intertanko estimated that in 2006 there were 8 000 - 10 000 port calls o f tankers in the EU. With a fuel use per discharge of 50 - 90 tonnes, this amounts in the EU to a total fuel use of around 400 - 500 ktonnes per year.

There are 262 LNG ships with steam turbine propulsion, of which most service EU ports. Thirty two ships use diesel propulsion while 19 are dual fuel diesel electric. A number of LNG ships are several decades old but the production of LNG tankers has increased a lot recently. About 43% of the LNG ships were delivered between 2 005 and 2008. The trend for new ships seems to be that diesel engines in combination with reliquefaction plants are preferred to steam propulsion. There is also a development towards dua l fuel diesel engines that can burn fuel oil (distillate or HFO) and gas. LNG tankers are refitt ed about every 2.5 years - or every 5 years for newer ships. If modifications needed to comply with the sulphur directive are carried out during refit it will be approximately 2014 before all ship s are modified. The ships could also be taken out of service for the modifications, which could be co mplete within approximately one - two years. The latter alternative then implies extra costs whe n the ships are out of service for modifications.

There are approximately 690 deliveries by LNG tanke rs per year to the EU. At each port visit, around 50 tonnes of HFO is used adding up to about 35 ktonnes per year.

By 2020 all ships will have had the time needed to make the necessary adjustments on their

boilers.

10.5 The nature of the risks

There have been reports of boiler explosions due to defects or improper operations. This can occur if, for some reason, the flame goes out, a hi gh pressure of fuel gas builds up in the burner, and the control system is malfunctioning or disconn ected. In such a case, the furnace must be purged before ignition. Failure to do this may caus e an explosion, as for example reported by the British Department of Transport (1983). There are f lame monitoring and control systems that will automatically purge the furnace so that during norm al operation the risks for explosions are small.

There are concerns that these risks may be higher w hen switching over from residual oil to distillate fuel. This is noted by the IMO subcommit tee on bulk liquids (2007), which states: "The routine switching between marine distillate and Hea vy Fuel Oil (HFO) has safety implications for existing boilers. The boiler combustion systems may require to be modified to prevent the risk of boiler furnace explosions in distillate operation". The risks are also noted in a recent US Coast Guard maritime safety alert (2009) in relation to r egulations for California which apply from 1 July 2009. These regulations stipulate that Marine Gas O il (MGO) or Marine Distillate Oil (MDO) must be used in all engines including boilers (with the exception of boilers for propulsion). The notice points out that "proper procedures, training, and m aintenance are essential for vessels to safely switch between heavy/intermediate fuel oils and mar ine distillates". The notice is about all engines and auxiliary boilers and suggests that eac h system should be assessed for modifications and that training and routines should be established.

The reason for the special concerns regarding a fue l switch from HFO to distillates is that the pipes and other parts are heated when using residua l oil. When the distillate enters the furnace there are concerns that it will fail to ignite, cau sing a build-up of gases that in turn is an explosi on risk. When distillate fuel is present in hot piping vapour locks may cause irregular fuel flows to the burners (this may also be an issue for diesel engin es). This irregular fuel and vapour flows/bursts towards burners can cause flame extinction; the lig hter the fuel, the easier the evaporation and

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### AEA 76 the larger the risk for an air/fuel mix which is po tentially unsafe. There are concerns that the crew on many ships may not be familiar with managing the se situations safely.

The boilers normally run on MGO during start up; ho wever, at this point the system has not yet been heated. After the boiler pressure is up, the p ipes can be emptied of MGO and then heated

and used for HFO. MGO is thus not introduced to th e boiler through heated pipes at this stage.

In normal ship installations, "heat tracing" of pip es (by steam or electric heating) can be turned on or off. In this kind of installation, proper opera tion may be sufficient to avoid the risk of an explosion. In many cases, fuel switching is automa tically managed by the ships’ hardware and software (and there is no difference between fuel f lows to engines and boilers in this respect) - this may be the situation in modern ships that have been delivered during the recent years. When fuel switching cannot be done automatically, h owever, the ship’s officers must follow very precise operational instructions.

Besides concerns about explosions inside the boiler s, there are other issues that need to be addressed before a boiler designed for HFO can be u sed with MGO. These, reported by DNV (DNV 2005) and Aalborg industries (Aalborg 2009), i nclude:

• Fuel pumps and valves may need to be replaced due to the different viscosity of the fuels. There is an increased risk of wear and pump breakdown if the oil has a higher viscosity and lower lubricity than what the pump is designed for.

• There may be increased smoke emissions because the amount of fuel injected in the burner is set for HFO – which has a higher density and lower calorific value than MGO.

• On certain types of burners (rotary cup) coke depo sits may build up when using distillate fuel. In steam atomising burners the MGO may be he ated - causing vaporisation.

Other concerns raised, by the shipping industry, ab out the regulations from 1 January 2010

related to:

1) problems with the supply of fuel with 0.1% sulph ur for ships at berth; 2) issues with ships not having enough fuel tanks t o store the different kinds of fuels that they will need; and 3) concerns that there is not enough time to modify existing boilers and train crews.

The objective of the present study is not to invest igate possible problems with the supply of MGO. However, according to a study by Entec (2002) c. 3 000 ktonnes of fuel was used for manoeuvring and in port in the EU in the year 2000. The main portion of this fuel will likely have to be MGO from 2010 and, considering the increase i n shipping, a rough estimate is that around

4 000 ktonnes of MGO is needed.

For the LNG ships with steam propulsion, the issues are essentially similar to those described

above - with some additional concerns. Since the bo ilers are used for propulsion, it is essential that the fuel supply is not interrupted. As describ ed above, there must be a reliable supply of fuel oil in addition to the BOG. The fuel oil systems in these ships are designed for HFO. They should

not be used with distillate fuel for a number of re asons:

1) There would be an increased risk of failure in f uel pumps and valves. 2) The distillate fuel could be unintentionally hea ted in pumps or in the burner leading to the mentioned problems with evaporation. 3) Most of the burners used have fuel injectors of the concentric type where the atomising steam is in between the tubes for fuel oi l where distillate fuel may be heated. Other burners have parallel tubes for steam and fuel oil. Here the heating of the distillate fuel is less of a concern but temper ature gradients when cold fuel oil is used could cause distortion of the tubings used for oil supply.

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### AEA 77 4) The burner management system and flame supervisi on/monitoring systems are designed for HFO.

10.6 Technical solutions and costs

For the safety and operational reasons discussed ab ove, all boilers designed for the use of HFO should be inspected before they are used with disti llate fuels. Many boilers may be used temporarily with gas oil without modifications, but for others modifications may be needed on fuel pumps, burners or pipes, as well as flame supervisi on and adjustments in air/fuel ratio, fuel flow and post-purging sequence. These modifications are further described in Aalborg (2009) and DNV (2005). Modifications will have to be approved by a Classification Society. The solutions for LNG tankers with boiler propulsion are discussed se parately at the end of this section.

The risk of a boiler explosion, as discussed above, is associated with the vaporis ation of

distillate fuel in combination with flame failure a nd improper purging. To avoid the heating of MGO in the piping system, heaters should be by-passed o r the tracing of fuel pipes turned off. The fuel system should have time to cool to around 60°C befo re MGO is introduced. The pipe system may have to be converted to contain two parallel feeds to the burners. The fuel may also be unintentionally heated in fuel pumps that then have to be adjusted or replaced. There are potential problems with gassing in steam atomising burners, which may have to be modified. Protective heat shields should be present on rotary cup burners to avoid deposit build-up and unintended ignition after flame failure. The flame supervision system may have to be modified to

include another flame scanner - due to the differe nt properties of HFO and MGO flames. The control system may have to be modified to implement automatic post-purging sequence. This will ascertain whether a potentially explosive gas mixtu re in the furnace has been purged in a safe

way.

Fuel pumps may have to be modified or replaced to b e able to tolerate MGO, with lower viscosity and lubricating properties than HFO, for a longer p eriod. In some cases, it may be sufficient to modify the control system.

Fuel pressure may have to be adjusted and/or burner nozzles replaced To avoid smoking, the air/fuel ratio may also have to be adjusted.

The costs associated with these measures will vary depending on the modifications needed. The exact distribution of costs for the existing boiler s is not known. Boiler suppliers estimate costs in the range of 5 000 to 25 000 € per boiler when modifications are needed. For tank ers with large boilers, costs around 150 000 € per ship have been quoted. There will also be cost s for approval

and certification.

For LNG ships with steam turbine propulsion, the boil-off from t he cargo is used in combination with HFO. For the reasons described above, these sh ips should be modified before they are used

with MGO.

The boiler management system (BMS) settings will ha ve to be adjusted, new flame scanners may have to be installed, and a separate fuel supply sy stem for MGO will be needed. The majority of burners will have to be modified to avoid vaporisat ion. Further, fuel change-over procedures have to be investigated. Some ships may also need l arger tanks for MGO in order to accommodate enough fuel for one port stay.

These modifications and actions would make it possi ble to use MGO rather than HFO at berth and thus comply with the directive. There are still some concerns that there may be an increased

number of flame failures and that the main boiler m anufacturers lack experience in burning MGO during normal operation. After the modifications, however, these incidents would be handled in a safe way by the BMS, although there may be interrup tions and operational problems. The costs for these measures have been estimated by SIGTTO. T he costs are difficult to estimate and figures ranging from 70 000 to 1 400 000 € per ship have been cited with a median of around 6 00

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### AEA 78 000 € . To this should be added costs for taking the ship s out of service if the modifications are done outside a regular refit.

An alternative solution would be to use 100% BOG wh ile at berth. There are, however, concerns about the stability of the boiler power at low load s. It is unclear if this can be implemented on all ships and modifications to the control system and B MS would be needed. Further, there are situations where 100% BOG cannot be used. This appl ies for relighting after a flame failure and in cases where there is no LNG cargo, as when ships en ter/leave refit/dry dock. Therefore, this alternative does not comply in full with the EU dir ective. No cost estimates are available for this

alternative because the extent of modifications nee ded has not yet been investigated. This alternative may require substantial modifications a nd may be more expensive than the previous alternative. The problems with stability and non-co mpliance make this alternative less attractive for the industry. Also, some ship-owners do not se e this as a solution to comply with the SECA rules coming in 2015 because 100% BOG will be unsui table during some operational modes.

A third possibility which seems more attractive to ship-owners is to minimise the use of HFO and use as much BOG as possible. The dual fuel combinat ion of low sulphur HFO and BOG would then be used in such a way that the emissions of SO 2 

### are lower than what they would have been

if 0.1% fuel oil were used at berth. If the scheme were set up in such a way that BOG together with minimum amounts of low sulphur HFO is used for the complete port stay (including manoeuvring) the resulting SO 2 

### emissions could be lowered further. This option wo uld allow for

fuel boost with HFO in the case of flame failure. T his option requires fewer modifications on most ships and thus lower modification costs. It may not be suitable for older ships. Whether or not this solution is in compliance with the EU regulations d epends on whether the equivalence principle outlined is regarded to be in line with paragraph 4 c. In addtion, the ships would still need to use HFO after refit. This option would be likely to req uire a monitoring system with either control of fuel use and sulphur levels in the fuel or the inst allation of flue gas monitoring systems to monitor

the SO 2 

### emissions. The cost of the latter is in the order of 70 000 € per ship.

An option of using exhaust gas scrubbing would not available by the end of the year because the technology has not yet been tested for this applica tion.

10.7 Conclusions

There are genuine safety risks associated with swit ching from HFO to MGO in existing boilers that are supported by evidence gained through conta cts with the industry and authorities. There are, however, technical and operational ways to cir cumvent these risks.

Although many boilers can be used with MGO, all boi lers should be inspected. The exact number

of boilers that need to be modified is uncertain at this point. There are 262 LNG ships with steam propulsion that need to be modified. There are arou nd 2500 tankers that use boilers for steam driven pumps and/or cargo heating - and most are li kely to need to be modified.

The main safety concern is that a distillate fuel m ay vaporise in hot boilers with heated pipes. If the boiler system has not been modified, there is—i n the case of flame failure and improper handling—a risk of an explosion. There are technica l solutions to solve these issues where fuel piping systems, burners, and flame inspection syste ms are modified. The control system may have to be modified and new handling routines estab lished. For LNG ships, modifications are required. The costs range from 5 000 to 25 000 for small auxiliary boilers, around 150 000 € per ship for tankers and 70 000 to 1 400 000 € for LNG tankers.

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### AEA 79 

# 11 Requirements with regard to maximum sulphur content of heating oil for

condensation boilers

11.1 Objective

The purpose of this section of the report is to mak e an inventory of the requirements with regard to the maximum sulphur content of heating oil in co ndensation boilers for heating purposes. Where relevant, the requirements for different cate gories of condensation boilers are given.

11.2 Introduction to oil fired condensation boilers

Until recent years there were only household heatin g boilers based on constant temperature and low temperature systems. All boilers used the same standard heating oil. With the introduction of condensing boilers a distinction was introduced bet ween boilers that can use only low sulphur heating oils and other boilers that can use the dif ferent heating oil available on the market. Condensation technology is an efficient way to use the heating value of burned natural gas and oil. In low temperature boilers condensation of fl ue gas water vapour on the heat exchange

surfaces must be avoided because of corrosion. Cond ensation technology recovers the latent heat of the water vapour in the flue gases by conde nsation. Condensation of water vapour occurs when flue gases are cooled down to temperatures bel ow dew point of the gases. The dew point temperature of flue gases from oil fired boilers is about 47 °C. The flue gas temperature from

condensation boilers is lower than of conventional boilers resulting in a better use of sensible heat in the flue gases as well. In this way heat ef ficiency of condensation boilers is about 6 % higher (and CO2 emissions about 6 % less) than for conventional oil fired boilers at nominal capacity. Another advantage of condensation boiler technology is that the water temperature in the heating system can be regulated according to ou tside temperature - whereas conventional boilers provide a constant water temperature. Espec ially in spring and autumn when heating demand is much lower than nominal capacity, the eff iciency of condensing boilers is much higher than 6% compared to conventional boilers because th e firing is modulated [1].

11.3 Heating oil quality and availability

According to Directive 1999/32/EC the content of su lphur in heating oils to be used in EU Members States from 1st of January 2008 should not exceed 0.1% by mass (=1000 mg/kg). Since July 2000 the permitted sulphur content is, at maximum, 0.2%. The sulphur content of the

diesel oil used for vehicle fuel has been reduced from 50 mg/kg to >10 mg/kg from 1st of January 2009. In this chapter sulphur content is given in mg/kg oil, in the literature sulphur content is sometimes given in ppm (parts per million) while mg /kg is meant. In Germany the availability of low sulphur oil (< 50 mg/kg), originally meant for vehicles, has facilitated the introduction and use

of condensation boilers. There is also an intermed iate quality oil - sulphur reduced heating oil (50-500 mg/kg) - available on the market which can be used in the EU countries to reduce emissions of sulphur dioxide to the environment:

The use of gas oil for heating has been in general decline for many years, inland consumption fell by about 22% over the period 1995 to 2007, most of this was in the residential commercial sector and is the result of switching to natural gas. Ove rall a continuing decrease in heating oil use is expected as the result of further natural gas subst itution and improved equipment efficiency (i.e. replacement of old heating systems) but may be sust ained in some markets i.e. housing developments outside cities (beyond the gas distrib ution system) [6]

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### AEA 80 According to a Concawe study [7] the weighted avera ge sulphur content in the gas oil (automotive diesel fuel, heating oil, industrial ga s oil and marine diesel fuel) used in the EU has fallen from 1100 mg/kg in 1998 to 900 mg/kg in 2002 . Average weighted sulphur content of gas oil varies with European region; in 2002 average co ntent was highest (1150 mg/kg) in the Mediterranean region and lowest (470 mg/kg) in the former EFTA countries (Norway, Sweden, Finland, Austria and Switzerland) compared to North west Europe and the Atlantic.

11.4 Construction of condensation boilers

In most conventional low temperature boilers hot fl ue gases flow horizontally through the heat changer and condensation must be avoided. In conden sation boilers hot flue gases flow downwards through the heat exchanger, water is allo wed to condense, this also drains downwards providing a self cleaning effect that pre vents the accumulation of salts on the heat exchange surfaces. Depending on the amount of sulp hur in the oil burned, and the acids produced as a result, the water can be acidic, with a pH between 1.5 and 3.5 [3]; standard heating oil produces a condensate that can be very corrosive unless suitable construction materials have been used. Extensive experience has shown that heat exchangers made of stainless steel are most suitable but specific alum inium alloys can be an acceptable alternative. A variety of stainless steel alloys are available ( with e.g. chromium, nickel, molybdenum, titanium) that are durable and which do not require additiona l surface treatment.

11.5 Condensation boilers and sulphur content of he ating oil

Traditional heating oil (EL quality) contains up to 2000 mg/kg sulphur, its flue gas condensate contains significant amounts of sulphurous and sul phuric acids and, if produced in large amounts, should be neutralized before discharge to the sewer system; neutralisation is not required if low sulphur oil is used. Neither can s tandard heating oil be used in all condensation boilers on the market - some producers only allow t he use of low sulphur heating oil. Condensation boilers for standard heating oil are s pecifically constructed for this duty and tend to have lower heat efficiencies [4].

Originally producers of condensation boilers in Ger many were reluctant to specify the use of low sulphur oil but concerns were allayed following ext ensive tests [5]. A distinction should be made, irrespective of whether or not heating oil of diffe ring sulphur content can be used, between three categories of condensation boilers:

- air-to-water condensation boilers

o boilers in which flue gas cooling and condensation both take place on the heat exchange surface integrated in the boiler;

o boilers that cool flue gases to the dew point usi ng an internal heat exchanger and where condensation then occurs on separate heat exchanger.

- air-to-air condensation boilers

o boilers in which the condensation of the flue gas system is used to preheat incoming combustion air.

Air-to-water condensation boilers in which flue gas cooling and condensation takes place on a heat exchange surface which is integrated in the bo iler This category of condensation boilers has been on t he market for a long time. The heat exchangers are exposed to the high temperatures of the flame and are susceptible to deposition of the substances resulting from burning of high su lphur oils. Heat exchangers in this category

have to be made of corrosion resistant material lik e stainless steel. According to [3] also some specific formulated alloys of aluminium can be used . To prevent deposition and maintain high heat efficiency, if cleaned only once a year, these condensation boilers ideally need low sulphur heating oil (< 50 mg/kg) [1] but can tolerate sulph ur reduced heating oil (< 500 mg/kg) [2]. The use of high sulphur heating oil (1000 mg/kg) in thi s type of condensation boilers results in faster deposition and decrease of heat efficiency but this can be avoided by cleaning the heat exchanger surface at least twice a year.

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### AEA 81 Air-to-water condensation boilers that cool flue ga ses to the dew point using an internal heat exchanger and where condensation occurs on separate heat exchanger. High sulphur heating oil (1000-2000 mg/kg sulphur) can be used in this categ ory of condensation boilers because condensation does not take place in the first (inte rnal) heat exchanger [1; 2]. Combustion residues (containing reaction products of sulphur) deposit on the heat exchanger in the

combustion chamber but because there is no condensa tion at this point there is no corrosion of the surfaces. Hence the heat exchanger can be made of standard steel. In the second (add-on) heat exchanger, where the condensation occurs, is m ade of stainless steel and there is little deposition. Because high or medium sulphur heating oil may be used for this category of condensation boilers the condensate can be aggressi ve and neutralisation of the condensate may be required before discharge - depending on hea ting capacity of the boiler and wastewater quality regulations.

Air-to-air condensation boilers in which condensati on takes place in the flue gas system to preheat incoming combustion air. In these systems the internal heat exchanger and wa ter flow are designed in such a way that condensation does not take place. Flue gases reach the second heat exchanger at temperatures far above dew point (about 100°C). Condensation in this second heat exchanger is then governed by control of flue gas and combustion air flow. Hea ting efficiency of this category of

‘condensation’ boilers is lower than for the air-to -water condensation boilers.

As a summary the suitability of different types of heating oil in different categories of condensation boilers is given in the table below.

Table 11.1 Suitability of heating oils in different categories of condensation boilers 

### Boiler integrated heat exchanger Add-on heat exchanger

High sulphur heating oil (1000 mg/kg) Problematic, high deposits on heat exchange surface Allowed, moderate deposits

Sulphur reduced heating oil (50 – 500 mg/kg) Allowed, moderate deposits Allowed, minor deposits

Low sulphur heating oil (< 50 mg/kg) Allowed, minor deposits Allowed, no deposits

11.6 Conclusions

Heating oils with sulphur content up to the maximum allowed concentration of 1000 mg/kg can be used in condensation boilers. Deposits on heat exc hanger surfaces caused by use of high sulphur heating oils are more problematic in conden sation boilers with integrated heat exchanger

than in boilers with an add-on condensation heat ex changer. To maintain high efficiency integrated heat exchangers have to be cleaned more frequently than add-on heat exchangers and more frequently than once a year as is usual. E fficiency will be kept at a high level for both configurations if low sulphur oil is used.

There are no technical obstacles which prevent the use of low sulphur heating oil in condensation boilers designed for “standard” heating oil.

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### AEA 82 

# 12 References:

Section 4

Amman et al, 2008. National Emission Ceilings for 2 020 based on the 2008 Climate and Energy Package. NEC Scenario Analysis report, nr 6. IIASA.

Chiffi, Fiorello, Schrooten, De Vlieger, 2007. EX-T REMIS - Exploring non road Transport Emissions in Europe --Annex to Final Report. IPTS - Institute for Prospective Technological Studies, DG-JRC, Seville, Spain (www.ex-tremis.eu).

Cofala et al., 2007. Analysis of Policy Measures to Reduce Ship Emissions in the Context of the Revision of the National Emission Ceilings Directiv e. IIASA/MET.NO/ENTEC UK Ltd.

Roemer M. and others (2003). Ozone trends according to ten dispersion models. Eurotrac-2 ISS,

GSF-National Research Centre for Environment and He alth, Munich, Germany.

Roemer M., T. van Harmelen and P. Builtjes (2006). Establishment of optimal control areas for acidification, eutrophication and ground level ozon e. TNO report 2006-A-R0251/B, TNO, Utrecht,

The Netherlands.

Schaap M., M. Roemer, F. Sauter, G. Boesen, R. Timm ermans and P. Builtjes (2005). LOTOSEUROS: documentation. TNO report B&O-A R2005/297, T NO, Utrecht, The Netherlands.

Van Harmelen T., M. Roemer, J. Pesik and G. Boersen (2007). Analysis of the potential costs savings and environmental and health implications o f emission trading for sulphur dioxide and nitrogen dioxide. TNO report 2007-A-R1256/B, TNO, U trecht, The Netherlands.

Van Loon M.,M. Roemer and P. Builtjes (2004). Model intercomparison in the framework of the review of the Unified EMEP model. TNO report R2004/ 282, TNO, Utrecht, The Netherlands.

Section 7

Purvin&Gertz, 2009, Avis M.J., Birch C.H.,

IMPACTS ON THE EU REFINING INDUSTRY & MARKETS OF IM O SPECIFICATION

CHANGES & OTHER MEASURES TO REDUCE THE SULPHUR CONT ENT OF CERTAIN

FUELS

Entec, 2005, Service contract on ship emissions: As signment, Abatement and Market-based

instruments

UK-Maritime and Coastgard Agency, 2009, Impact asse ssment of merchant Shipping (prevention of Air pollution from ships (Amendment)) Regulation s 2009

US-EPA, 2009, Proposal to Designate an Emission Con trol Area for Nitrogen Oxides, Sulfur Oxides and Particulate Matter - Technical Support D ocument - Chapter 5 Costs, Assessment and Standards Division Office of Transportation and Air Quality U.S. Environmental Protection Agency

Krystallion, Sea Water Scrubbing – Does it Contribu te to increased Global CO2 Emissions

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### AEA 83 www.purchasingdata.com

Wärtsilä, 2009, General description of Wärtsilä scr ubber system

Marine and Energy Consulting limited, 2009, present ation at 2nd Bunker Fuel Management, 16th & 17th September, London, UK

Delft 2006. Greenhouse Gas Emissions for Shipping a nd Implementation Guidance for the Marine Fuel Sulphur Directive

Chiffi, Fiorello, Schrooten, De Vlieger, 2007. EX-T REMIS - Exploring non road Transport Emissions in Europe --Annex to Final Report. IPTS - Institute for Prospective Technological Studies, DG-JRC, Seville, Spain.

Section 9

Winnes, H and Fridell, E, Particle Emissions from S hips: Dependence on Fuel Type, J. Air & Waste Manage. Assoc. 59:1391 (2009).

V. Eyring, H. W. Köhler, J. van Aardenne and A. Lau er, Emissions from international shipping: 1. The last 50 years. J. Geophys. Res. 110, D17305 (20 05).

Skema 2009: Impact Study of the future requirements of Annex VI of the MARPOL Convention on Short Sea Shipping, Skema 2009.

MEPC 59/WP.10, 16 July 2009

US EPA, 1976. Quality criteria for water. United St ates Environmental Protection Agency, Washington D.C. 20460, The Red book, July 1976.

Polycyclic aromatic hydrocarbons (PAH), KEMI Swedis h Chemicals Agency, www.kemi.se Phenanthrene CAS Number 85-01-8, United States Envi ronmental Protection Agency www.epa.gov/waste/hazard/wastemin/minimize/factshts /phenanth.pdf

Billiard, S. M., Meyer, J. N., Wassenberg, D. M., H odson, P. V., Di Giulio, R. T. 2008. Nonadditive effects of PAHs on early vertebrate development: Me chanisms and implications for risk

assessment. Toxicol. Sci. 105: 5-23.

Behrends, B., & Liebezeit, G., 2003, Reducing SO X 

### and NO X



### Emissions from Ships by a Seawater Scrubber. Research Centre Terramare, Wilhe lmshaven, Germany.

Hufnagel, M., Liebezeit, G., & Behrends, B., 2005. Effects of Sea Water Scrubbing, Final report.

Buhaug, Ø., Fløgstad, H., Bakke T., 2006. MARULS W P3: Wash-water Criteria for seawater exhaust gas-SO X



### scrubbers. MARINTEK report, for Norwegian Marine T echnology.

Karle, I-M. and Turner, D., 2007. Seawater Scrubbin g - reduction of SO X 

### emissions from ship exhausts. Department of Chemistry, Göteborg Univers ity, ISBN: 978-91-976534-1-1.

MEPC 59/4/19. Marine Environment Protection Committ ee, 59 th session Agenda item 4. Prevention of air pollution from ships. Advice by G ESAMP on the interim criteria for discharge of wash-water from Exhaust Gas Cleaning Systems for re moval of sulphur-oxides.

Whall et al., Quantification of emissions from ship s associated with ship movements between ports in the European Community, Entec 2002.

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 84 Cooper, D. A., Peterson, K., and Simpson, D., 1996, Hydrocarbon, PAH and PCB emissions from ferries: a case study in the Skagerak-Kattegatt-Öre sund region, Athmospheric Environment 30,

2463.

MEPC 56/INF.5, ANNEX 1, Page 22

Directive 2008/105/EC of the European Parliament an d of the Council of 16 December 2008 on environmental quality standards in the field of wat er policy, amending and subsequently repealing Council Directives 82/176/EEC, 83/513/EEC, 84/156/E EC, 84/491/EEC, 86/280/EEC and amending Directive 2000/60/EC of the European Parli ament and of the Council.

Jalkanen, J. -P., Brink A., Kalli, J., Pettersson, H., Kukkonen, J. and Stipa, T., 2009, A modelling system for the exhaust, emissions of marine traffic and its application in the Baltic Sea area, Atmos. Chem. Phys. Discuss., 9, 15339–15373.

Benedictow et al., 2009. Transboundary Acidificatio n,Eutrophication and Ground Level Ozone in Europe in 2007, EMEP Status Report.

Johnsen et al., (2006) Part C of Delft report Green house Gas Emissions for Shipping and Implementation Guidance for the Marine Fuel Sulphur Directive, DNV.

Mellqvist, J, Berg, N. and Ohlsson, D., 2008. Remot e surveillance Remote surveillance of the

sulfur content and NO

x 

### emissions of ships, Presentation at Haqcc

Section 10

Aalborg 2009. Aalborg Industries. Aalborg Solutions No 12 January 2009. http://www.aalborgindustries.com/marine_solutions/documents/12Fuelcha ngetoMDOMGO-09JAN09.pdf.

British Department of Transport 1983. Explosion in boiler furnaces, Merchant Shipping Notice No. M. 1083, August 1983.

CARB 2008. California Environmental Protection Agen cy Air Resource Board, Fuel sulfur and other operational requirements for ocean-going vess els within California waters and 24 nautical miles of the California baseline, June 2008. http://www.arb.ca.gov/regact/2008/fuelogv08/isorfue logv08.pdf.

DNV 2005. DNV, Regulations for the prevention of ai r pollution from ships, technical and operational implications. February 2005. http://www .dnv.com/binaries/Marpol_Annex_VI_tcm4- 125462.pdf.

Entec 2002. C Whall et al., Quantification of emiss ions from ships associated with ship movements between ports in the European Community, Entec, European Commission, 2002.

IMO subcommittee on bulk liquids, 2007. Review of M ARPOL VI and the NO

x 

### technical code December, 2007.

US coast guard Maritime Safety Alert, 2009. Avoidin g propulsion loss from fuel switching:

American Petroleum Institute Technical Consideratio ns. May 2009.

Section 11

Condensation technology – Condensation technology f or energy saving and a clean environment.Documentation Viessmann (www.viessmann. com) [1]

### Cost benefit analysis to support the impact assessm ent AEA/ED05315018/Issue 3

accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels



### AEA 85 Rogatty, W.: Modern oil-heating technology. IKZ-Hau stechnik, Volume 8/2004, page 60 [2]

. Brennwerttechnik. : http://www.energiesparmobil.de/downloads_infomateri al/pdf/haustechnik/brennwerttechnik.pdf 

### [3]

Frequently asked questions and answers in relation to the common declaration of the National Government and the Mineral oil business on January 15th 2007. Bundesministerium für Umwelt,

Naturschutz und Reaktorsicherheit. (http://www.bmu.de/energieeffizienz/gebaeude/doc/38 680.php) 

### [4]

Geräteeignung und Verfügbarkeit. Institut für wirts chaftliche Oelheizung e.V.

http://www.iwo.de/sites/iwo_website/standard.jsp?no deId=159355&open=x&pagename=TECH_HELSA_0 

### [5]

Impacts on the EU refining industry & markets of IM O specification changes & other measures to reduce the sulphur content of certain fuels. Purvin & Gertz Inc., 30 June 2009 [6]

Post, L.: Sulphur dioxide emissions from oil refine ries and combustion of oil products in Western Europe and Hungary (2000). CONCAWE report no. 2/07, March 2007 [7]

Appendix 1

Cooper and Gustafsson, 2004 D. Cooper and T. Gustaf sson, Methodology for Calculating Emissions from Ships. 1. Update of Emission Factors Report Series for SMED and SMED&SLU, SMHI, Norrköping, Sweden (2004) www.smed.se ISSN: 1 652-4179.

IPCC 1995, Greenhouse gas inventory Reference manua l. Intergovernmental Panel on Climate Change.

Lloyds’’s Register, 1995. Marine Exhaust Emissions Research Programme. Lloyds’’s Register Engineering Services, London.

TFEIP, 2009. EMEP/EEA Emission Inventory Guidebook, 2008 version, Task Force for Emission Inventories and Projections (TFEIP). Available via http://www.eea.europa.eu/publications/emepeea-emission-inventory-guidebook-2009

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### AEA 86 

# 13 Appendix 1 - Emission factors used

Table 1: Unabated emission factors used in the base line scenario

kg/ton kg/GJ source notes
heavy fuel

oil

SO 2 -SECA 29 0.72 TFEIP 2009 1.45% S, after 2006 in North Sea and Baltic Sea

in baseline

SO 2 54 1.34 TFEIP 2009 2,70% S, pre-2006

NO
x 43 1.07 Ex-tremis

NMVOC 4.9 0.12 Ex-tremis

CO 5.5 0.14 IVL and Lloyds

PM 3.4 0.08 Ex-tremis

diesel oil

SO 2 4 0.09 TFEIP 2009 0.2% S

NO
x 43 0.99 Ex-tremis

NMVOC 4.9 0.11 Ex-tremis

CO 5.5 0.14 IVL and Lloyds

PM 2.6 0.06 Ex-tremis

Note: Since 1-1-2008, for seagoing ships on route b etween member states, the sulphur content of diesel fuel has

been lowered to 0.1%. Data were insufficient to mak e this distinction in the emission calculation



### .

Table 2: Unabated emission factors by fuel and moto r speed

Fuel consumption NO
x NMVOC CO

g fuel/kWh kg/ton kg/GJ kg/ton kg/GJ kg/ton kg/GJ

GT-MG/DO 290 19.6 0.45 0.3 0.01 0.3 0.01

GT-RO 305 20.0 0.50 0.3 0.01 0.3 0.01

HSDMG/DO 203 59.1 1.36 0.9 0.02 5.5 0.13

HSD-RO 213 59.6 1.48 0.9 0.02 5.5 0.14

MSDMG/DO 203 61.2 1.41 2.5 0.06 5.5 0.13

MSD-RO 213 65.7 1.63 2.3 0.06 5.5 0.14

SSDMG/DO 185 92.2 2.13 3.2 0.07 7.1 0.16

SSD-RO 195 92.8 2.31 3.1 0.08 7.1 0.18

ST-MG/DO 290 6.9 0.16 0.3 0.01 0.7 0.02

ST-RO 305 6.9 0.17 0.3 0.01 0.7 0.02
Note: ] GT-MG/DO: gas turbine - marine diesel oil/marine g asoil GT-RO: gas turbine – bunker fuel oil HSD-MG/DO: high speed diesel - marine diesel oil/m arine gasoil HSD-RO: high speed diesel – bunker fuel oil MSD-MG/DO: medium speed diesel - marine diesel oil/ marine gasoil MSD-RO: medium speed diesel – bunker fuel oil SSD-MG/DO: slow speed diesel - marine diesel oil/m arine gasoil SSD-RO: slow speed diesel – bunker fuel oil

ST-MG/DO: steam turbines - marine diesel oil/marin e gasoil

ST-RO: steam turbines – bunker fuel oil

Source: TFEIP 2009 1.A.3.d Table 3-5, and (for CO) IVL and Lloyds (for Diesel engines) and Cooper and Gustafsson, 2004 for GT and ST.

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### AEA 87 Table 3: Unabated PM emission factors by fuel and motor speed and sulphur

content of the fuel

Note: see table 2 for abbreviations;



### Table 4: SO 2 

### emission factors in the scenarios

Outside SECAs Within SECAs Baltic Black

Sea Mediterranean North

Sea Remaining

NE-atl

Scenar

io S content

(mass%) EF

(kg/GJ) S content

(mass%) EF

(kg/GJ) IN

SECA? IN

SECA? IN

SECA? IN

SECA? IN SECA?

1 2.94% 1.46 0.10% 0.05 Y N N Y N

2 2.94% 1.46 0.10% 0.05 Y N Y Y N

3 2.94% 1.46 0.10% 0.05 Y Y Y Y N

4 0.50% 0.25 0.10% 0.05 Y N N Y N

5 0.50% 0.25 0.10% 0.05 Y Y Y Y N

BASE

LINE 2.70% 1.34 1.45% 0.72 Y N N Y N Sulphur

content 0.10% 0.20% 0.50% 1.50% 2.70%

kg/ton kg/GJ kg/ton kg/GJ kg/ton kg/GJ kg/ton kg/G J kg/ton kg/GJ

GT-MG/DO 0.017 0.000 0.023 0.001 0.039 

### 0.001

GT-RO 0.059 0.001 0.064 0.002 0.078 

### 0.002 0.126 0.003 0.183 0.005

HSDMG/DO 0.488 0.011 0.651 0.015 1.139 

### 0.026

HSD-RO 0.843 0.021 0.910 0.023 1.112 

### 0.028 1.787 0.044 2.596 0.065

MSDMG/DO 0.488 0.011 0.651 0.015 1.139 

### 0.026

MSD-RO 0.843 0.021 0.910 0.023 1.112 

### 0.028 1.787 0.044 2.596 0.065

SSDMG/DO 0.541 0.012 0.721 0.017 1.261 

### 0.029

SSD-RO 2.416 0.060 2.609 0.065 3.189 

### 0.079 5.121 0.127 7.440 0.185

ST-MG/DO 0.500 0.012 0.667 0.015 1.167 

### 0.027

ST-RO 0.950 0.024 1.026 0.026 1.254 

### 0.031 2.015 0.050 2.927 0.073

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### AEA 88 Table 5: NO

x 

### emission factors in scenarios

Tier I Tier II Tier III

kg/GJ ships constructed

between 1-1-2000

and 1-1-2010 ships constructed

after 1-1-2011 for 2020 only:

ships constructed

after 1-1-2016

GT-MG/DO 0.45234 0.45234 0.45234

GT-RO 0.45234 0.45234 0.45234

HSD-MG/DO 1.06184 1.06184 0.21670

HSD-RO 1.06184 1.06184 0.21670

MSD-MG/DO 1.33494 1.07477 0.26699

MSD-RO 1.33494 1.07477 0.26699

SSD-MG/DO 1.84196 1.56025 0.36839

SSD-RO 1.84196 1.56025 0.36839

ST-MG/DO 0.15924 0.15924 0.15924

ST-RO 0.15924 0.15924 0.15924

Note: see table 2 for abbreviations



### Table 6: Applicability of the Tiers in the various scenarios

Scenario

1 Tier I&II, for 2020 Tier III

2 Tier I& II

3 Tier I&II, for 2020 Tier III

4 Tier I,II & III (2020 only)

5 Tier I,II & III (2020 only)



### Background on NO

x 

### limits to marine diesel engines and Emission Contr ol Areas (ECAs)

NO X 

### emissions are regulated under the International Ma ritime Organization (IMO), in the

International Convention for the Prevention of Poll ution From Ships, 1973 as modified by the Protocol of 1978 (in short MARPOL 73/78). NOx limit s for marine diesel engines are set in Annex

VI of MARPOL and the revised NOx Technical Code. In October 2008, the IMO’s Marine Environmental Pro tection Committee (MEPC) adopted both

the revised Annex VI of MARPOL and the revised NOx Technical Code. The annex and the code will enter into force 1 July 2010.

The new revision substantially tightens the NOx and Sulphur limits compared to the existing annex, and also includes requirements governing NOx emissions from ships constructed from 1 January 1990 to 1 January 2000.

New NO

x 

### limits The revised NOx regulations contain a three-Tier ap proach as follows: Tier I (identical to today’s limits) For diesel engines installed on ships constructed f rom 1 January 2000 to 1 January 2011, the

allowable NOx emissions are:

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### AEA 89 • 17.0 g/kWh when n is less than 130 rpm

• 45.0*n(-0.2) g/kWh when n is 130 rpm or more but less than 2,000 rpm

• 9.8 g/kWh when n is 2,000 rpm or more

Tier II For diesel engines installed on ships constructed o n or after 1 January 2011, the allowable NOx

emissions are:

• 14.4 g/kWh when n is less than 130 rpm

• 44.0*n(-0.23) g/kWh when n is 130 rpm or more but less than 2,000 rpm

• 7.7 g/kWh when n is 2,000 rpm or more

Tier III Ships constructed on or after 1 January 2016 will h ave additional limitations when operating in an Emission Control Area (ECA). No ECAs have yet been designated for NO

x 

### emissions, but it is expected that both the Baltic Sea and North Sea wil l be designated as NO

x 

### ECAs well ahead of 1 January 2016. The allowable NOx emissions are:

• 3.4 g/kWh when n is less than 130 rpm

• 9.0*n(-0.2) g/kWh when n is 130 rpm or more but l ess than 2,000 rpm

• 1.96 g/kWh when n is 2,000 rpm or more

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### AEA 90 

# 14 Appendix 2 - Emission Figures by

Scenario and Area Baseline

Emission Figures by Scenario and Area Baseline

Baltic Sea Black Sea Remaining NE Atl antic

ocean
x 1000

tonnes 2000 2015 2020 2000 2015 2020 2000 2015 2020

SO 2 

### 177 149 169 53 82 93 472 730 829

NMVOC 10 15 17 3 5 5 26 40 46

CO 22 34 39 7 10 12 58 90 103

PM 9 15 17 6 10 11 56 88 100

NO

x 

### 283 439 498 83 130 147 742 1153 1310

Mediterranean Sea North Sea

X 1000

tonnes 2000 2015 2020 2000 2015 2020

SO 2 

### 1024 1582 1795 417 351 399

NMVOC 56 86 98 23 36 41

CO 125 194 220 52 81 92

PM 118 185 210 22 34 39

NO

x 

### 1593 2469 2805 664 1031 1171

SEA1

Baltic Sea Black Sea Remaining

NE Atlantic

ocean Mediterranean

Sea North Sea

x 1000

tonnes 2015 2020 2015 2020 2015 2020 2015 2020 2015 2020

SO 2 

### 10 12 90 102 795 903 1722 1955 24 28

NMVOC 15 17 5 5 40 46 86 98 36 41

CO 34 39 10 12 90 103 194 220 81 92

PM 11 13 10 12 88 100 185 210 26 30

NO

x 

### 364 325 108 115 957 1,018 2,055 1,841 856 765

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### AEA 91 SEA2

Baltic Sea Black Sea Remaining

NE Atlantic

ocean Mediterranean

Sea North Sea

x 1000

tonnes 2015 2020 2015 2020 2015 2020 2015 2020 2015 2020

SO 2 

### 10 12 90 102 795 903 59 67 24 28

NMVOC 15 17 5 5 40 46 86 98 36 41

CO 34 39 10 11 90 103 194 220. 81 92

PM 11 13 10 11 88 100 62 71 26 30

NO

x 

### 364 388 108 115 957 1,018 2,055 2,187 856 911

SEA3

Baltic Sea Black Sea Remaining

NE Atlantic

ocean Mediterranean

Sea North Sea

x 1000

tonnes 2015 2020 2015 2020 2015 2020 2015 2020 2015 2020

SO 2 

### 10 12 3 3 795 903 59 67 24 28

NMVOC 15 17 5 5 40 46 86 98 36 41

CO 34 39 10 12 90 103 194 220 81 92

PM 11 13 3 4 88 100 62 71 26 30

NO

x 

### 364 325 108 115 957 1,018 2,055 1,841 856 765

SEA4

Baltic Sea Black Sea Remaining

NE Atlantic

ocean Mediterranean

Sea North Sea

x 1000

tonnes 2015 2020 2015 2020 2015 2020 2015 2020 2015 2020

SO 2 

### 10 12 15 17 135 154 293 333 24 28

NMVOC 15 17 5 5 40 46 86 98 36 41

CO 34 39 10 12 90 103 194 220 81 92

PM 11 14 4 5 39 44 81 92 26 30

NO

x 

### 364 325 108 115 957 1,018 2,055 1,841 856 765

SEA5

Baltic Sea Black Sea Remaining

NE Atlantic

ocean Mediterranean

Sea North Sea

x 1000

tonnes 2015 2020 2015 2020 2015 2020 2015 2020 2015 2020

SO 2 

### 10 12 3 3 135 154 59 67 24 28

NMVOC 15 17 5 5 40 46 86 98 36 41

CO 34 39 10 12 90 103 194 220 81 92

PM 11 13 3 4 39 44 62 71 26 30

NO

x 

### 364 325 108 115 957 1,018 2,055 1,841 856 765

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### AEA 92 Emissions land based sources, baseline and scenario s Baseline

2000 2010 2015 2020

x 1000 tonnes

SO 2 

### 16,726 10,324 9,897 9,734

NMVOC 16,236 13,033 12,374 11,931

PM10 4,726 4,013 3,988 3,988

PM2.5 3,231 2,768 2,716 2,678

NO

x 

### 16,582 13,839 12,691 11,312

Note: exclusive of emissions related to national ma ritime fuel consumption (e.g. fisheries), which are included in the

GAINS-totals Source: GAINS Europe, NEC6, C&E package current pol icy



### Land based A

2015 2020

x 1000 tonnes

SO 2 

### 9,851 9694

NMVOC 12,374 11931

PM10 3,988 3,988

PM2.5 2,716 2,678

NO

x 

### 12,691 11,312

Land based B

2015 2020

x 1000 tonnes

SO 2 

### 9,806 9,665

NMVOC 12,374 11,931

PM10 3,988 3,988

PM2.5 2,716 2,678

NO

x 

### 12,691 11,312

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### AEA 93 

# 15 Appendix 3 - Relevant geographical representations of the dispersion

calculations

In this appendix the most relevant results of the d ispersion calculations are presented. First some background information is given on the r elevant background concentrations used in the dispersion calculations and the effect of inter -annual changes due to the meteorology. As states earlier we used the meteorology of 1997 give n the fact that this is considered a representative year for the European meteorology. The absolute values of the calculated pollutant con centration are certainly relevant but in this cost benefit analysis the emphasis is on the differences between the results for the different scenarios.

Sensitivity of results to inter-annual variability in meteorology and background ozone

concentrations.

Background ozone

and changes therein are important to metrics such as AOT40, SOMO35 etc. The increase of hemispheric ozone is under scientif ic debate and it is not easy to answer how much more of ozone we can expect in 2020. Because t he effect of IMO regulations on NO

x 

### emissions in the remaining North Atlantic beyond 10 W is not quantified we do not know how this will affect background ozone concentrations. In gen eral terms one can state; with each 1ug/m 3



### increase of the background one can expect at the fr inge of Europe, as a rough maximum estimate, an increase of 2500 ug/m 3 

### .h in AOT40f, simply being the number of associated hours in

the AOT40f definition that will be increased with 1 ug/m 3 

### , plus a few hours that in addition will exceed the threshold. At the interior of Europe thi s will be less, since part (say 70%) of the extra ozone will be consumed by dry deposition, leaving a n increase as a rule of thumb of 800 ug/m 3 

### .h. Suppose the hemispheric increase of ozone between 2 010 and 2020 will be 4 ug/m3, then the AOT40f in continental Europe will increase by about 3200 ug/m3.h which is an increase of 10% compared to 2010 levels.

Based on Laurila et al., 2004 we find, following th eir lowest SRES scenario, an increase of AOT40f due to hemispheric changes of 2000 ug/m3.h f rom 2010 to 2020 on top of an AOT40f in 2010 of about 14000 ug/m3.h.

Uncertainty estimates in changes in hemispheric ozo ne are hard to give since the cause of the changes is poorly understood; given this lack of kn owledge we estimate an uncertainty of 100%.

The inter-annual variability in AOT40f can be as la rge as 8000 ug/m3.h fluctuation from one year to another, but on average the fluctuation is typic al in the other of 3000 ug/m3.h. For continental

sites as in Switzerland and Austria the aforementio ned fluctuations are 30% and 12% of the long term average of AOT40f in these countries. In the U K of the Netherlands (with much lower longterm baseline AOT40f values) the fluctuations in re lative terms are much larger, typically in the order of 100-50%. More important are the inter-annu al fluctuations of the scenarios. In absolute terms (change in ug/m3.h) the fluctuations will be considerable, but once expressed in terms of fractional changes with respect to the baseline AOT 40f the inter-annual fluctuations are much smaller, and more robust against the choice of mete orological year. For other ozone metrics that are derived from large r portions of the ozone distribution, such as SOMO35 (annual sum of daily max eight hour running mean of ozone exceeding 35 ppb) and annual mean the fluctuations from year to year are smaller than for AOT40.

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### AEA 94 The atmosphere is never in equilibrium. The lifetim e of NO

x 

### is short but due its effect on ozone (which has a longer lifetime) still in the order of weeks to months. However, I do not see any transient effects in the range of years due to NO

x 

### emission changes.

The interannual variation in PM concentrations is typically in the order of 10%. Again, scenario changes expressed with respect to the baseline are less sensitive to interannual variability.

Based on the EMEP status report 2005/1 in which the exceedances of critical loads for either

a cidification or eutrophication in 2002 and 2003 were compared (with 2003 being an extreme year) the relative differences amount to about 20% from one year to another

Does the calculation grid size have an effect on th e calculated benefits? A smaller grid means a smaller grid for the dispers ion calculations and for the ecosystems/population data bases. Assuming that the concentration (deposition) in a 50x50 km grid cell differs only slightly from the averaged c oncentration (deposition) of all associated 10x10 grid cells, then we can expect differences in the c hoice of grid cell only if the set 10x10 km

concentration data within 50x50 km bears some corre lation with the set of 10x10 km ecosystem (population) data. This will be specified for the t hemes separately.

Acidification. / Eutrophication

We have no information on the distribution of sensi tive ecosystems (with regard to acidification or eutrophication) at scales smaller than 50x50 km. Th erefore, the question cannot be addressed.

SOMO35 (annual sum of daily max eighth hour running mean of ozone exceeding 35 ppb. ) In this study the SOMO35 values are multiplied with population numbers.

In rural areas with low NO

x 

### concentrations grid cells within a 50x50 km grid c ell will not differ much from the value in a 50x50 km cell. This part w on’t be affected by working on smaller scales. In urban areas, characterised by high levels of NO

x 

### ozone concentrations (SOMO35) vary in general from relatively low values in the city cent res (high NO

x 

### levels, densely populated) to relatively high values in residential suburban area s (lower NO

x 

### , less populated). The effect is to put more weight on the low values, and consequently , a 10x10 km grid in an urban area results in

somewhat lower SOMO35*inhabitant’s values than a co rresponding 50x50 km would.

PM10 For PM10 similar considerations apply as for SOMO35 , although with a different sign. In rural areas, there is no effect expected from reducing th e grid size. In urban areas the primary PM10 emission (assuming it is proportional to population numbers) correlates with populations and, as a result, so does the PM10 concentration (although th e effect is smaller due to the damping effect of the smoother sulphate and nitrate fields). The e ffect is that in urban areas the PM10*inhabitants’ values are larger for a smaller g rid than for a larger grid.

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### AEA 95

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### AEA 96Figure A1: Average Accumulated Exceedence for acidification (eq./ha/yr) for 2015.a) BaselineIn all areas, not colored green, there is an exceedence of the critical loadb) Fractional change (%) of SEA1 compared to base lineThe map shows clearly the reduction of the exceedence of the critical load all round the North Sea andthe Baltic due thedesignation of these waters as SECA.c) Fractional change (%) of SEA 2 compared to SEA 1Thus the effect of inclusion of the Mediterranean sea and Black sea in the SECA does add only to a small extend to theimprovement gained in scenario SEA1 compared to thebaseline.d) Fractional change (%) of SEA 3 compared to SEA 3Reduction of the S content outside the SECAs does lower the exceedence of the critical load in the UKand IR.See also table 7 in appendix 4

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### AEA 97

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### AEA 98Figure A2 Average Accumulated Exceedence for acidification (eq./ha/yr) for 2015..a) BaselineIn all areas, not colored green, there is an exceedence of the critical loadb) Fractional change (%) of Bbase compared to BaselineThe map shows the positive effect on the exceedenceof the critical load for acidification when lowering the S content of fuel on land to0.001%. This map indicates the maximum effect of lowering the S content in land based fuel.c) Fractional change (%) of BSEA1 compared to SEA 1The map shows the same picture as map b), the minordifferences are caused by the fact that in these scenario’s the North Sea/British channel and the Baltic are already designated as SECA and thus exceedences were already reduced.The general conclusion of these maps is that the effect on the exceedence of the critical load for acidification when lowering the Scontent of fuel on land is marginal approximately 1.3 to 2.8 % reduction. Because acidification is theparameter effected the most bysulfur emissions this analysis is not performed forthe other parametersSee also table 7 and 9 in appendix 4

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### AEA 99

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### AEA 100Figure A3: Average Accumulated Exceedence for eutrophication (eq./ha/yr) for 2015..a) BaselineIn all areas, not colored green, there is an exceedence of the critical loadb) Fractional change (%) of SEA1 compared to baselineThe map shows the reduction of the exceedence of the critical load as a result of the NOxTier I & II standards in allEuropean seas. The designation of the North Sea andthe Baltic des not have an significant impact on theexceedence. Which can be seen in the next mapc) Fractional change (%) of SEA2 compared to SEA1Thus the effect of inclusion of the Mediterranean sea and Black sea in the does not add significant totheimprovement gained in scenario SEA1 compared to thebaseline.d) Fractional change (%) of SEA3 compared to SEA2Extension of the SECA with the Black Sea does lowerthe exceedence of the critical load only to a verysmallextend.See also table 10 en 12 in appendix 4

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### AEA 101

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### AEA 102Figure A4 AOT40f (ppm.h) for 2015.a) Baselineb) Difference (ppm.h) of SEA1 compared to baselineThe map shows clearly the reduction of the ozone concentration as an result of the reduced NOxemissions inall seas as a result of the Tier standards. The effect in the Mediterranean is enhanced by the longerperiods ofsunshine.The maps c and d show a similar picture but there are small differences. These are elaborated in table22in appendix 4.c) Difference (ppm.h) of SEA2 compared to baseline.d) Difference (ppm.h) of SEA3 compared to baseline.See also table 22 and 24 in appendix 4

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### AEA 103

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### AEA 104

.Figure A5 SOMO35 (ppm.h) for 2015..a) Baselineb) Difference (ppm.h) of SEA1 compared to baselineThe map shows clearly the reduction of the ozone concentration as an result of the reduced NOxemissions in allseas as a result of the Tier standards. The effectin the Mediterranean is enhanced by the longer periods ofsunshine.The maps c and d show a similar picture but there are small differences. These are elaborated in table16 inappendix 4.c) Difference (ppm.h) of SEA2 compared to baseline.d) Difference (ppm.h) of SEA3 compared to baseline.See also table 16 and 18 in appendix 4

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### AEA 105

### Cost benefit analysis to support the impact assessm ent AEA/ED 

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### AEA 106Figure A6 PM10 (ug/m3) for 2015.a) Baselineb) SEA 1The map shows the positive effect on PM concentration when designating the North Sea / English Channeland The Baltic asSECA. The reduction of sulfur in fuels is associated with an reduction in PM emissions. In the coastalzones all round the SECAshow reduced concentrations of PMc) SEA 2The map shows the positive effect when designatingthe Baltic Sea, North Sea / English Channel, the Mediterranean Sea and theBlack Sea as SECA. Although not clearly indicated in the map the differences with the former map is that the concentrations in theMediterranean coastal zones are reduced.See also table 13 and 15 in appendix 4d) SEA 3Extension of the SECA with the Black Sea does lowerthe concentration in this area..

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### AEA 107

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### AEA 108Figure A7 PM10 (ug/m3) for 2015.a) Baselineb) Fractional change (%) of SEA1 compared to baselineThe next map shows the positive effect on PM concentration when designating the North Sea / English Channel and The Baltic asSECA. The reduction of sulfur in fuels is associated with an reduction in PM emissions.c) Fractional change (%) of SEA2 compared to baselineThe map shows the positive effect (% reduction in concentration) when designating the Mediterranean sea and the Black Sea asSECA.d) Fractional change (%) of SEA3 compared to baselineExtension of the SECA with the Black Sea reduces the PM concentration in this area.See also table 13 and 15 in appendix 4

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### AEA 109

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### AEA 110Figure A8: Average Accumulated Exceedence for acidification (eq./ha/yr) for 2020..a) BaselineIn all areas, not colored green, there is an exceedence of the critical loadb) Fractional change (%) of SEA1 compared to baselineThe map shows clearly the reduction of the exceedence of the critical load all round the North Sea andthe Baltic due thedesignation of these waters as SECA.c) Fractional change (%) of SEA 3 compared to SEA 1Thus the effect of inclusion of the Mediterranean sea and Black sea in the SECA does add only to a small extend to theimprovement gained in scenario SEA1 compared to thebaseline.d) Fractional change (%) of SEA 4 compared to SEA 3Reduction of the S content outside the SECAs does lower the exceedence of the critical load in the UKand IR.See also table 8 in appendix 4

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### AEA 111

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### AEA 112Figure A9 Average Accumulated Exceedence for acidification (eq./ha/yr) for 2020..a) Fractional change (%) of ASEA 1 compared to SEA1The map shows the small positive effect on the exceedence of the critical load for acidification whenlowering the Scontent of fuel on land to 0.05%.b) Fractional change (%) of BSEA 1 compared to SEA1The map shows the positive effect on the exceedenceof the critical load for acidification when lowering the S content offuel on land to 0.001%. There are only small difference to map a especially in those grid cells with high populationdensities.c) Fractional change (%) of ASEA 4 compared to SEA4The map shows the same picture as map a), the onlydifference is that in these scenario’s the sulphurcontent outsidethe SECA is reduced to 0.5 %.d) Fractional change (%) of BSEA 4 compared to SEA4The map shows the same picture as map b), the onlydifference is that in these scenario’s the sulphurcontent outsidethe SECA is reduced to 0.5 ).The general conclusion of these maps is that the effect on the exceedence of the critical load for acidification whenlowering the S content of fuel on land is marginalapproximately 1.2 to 2.1 % reduction. Because acidification is theparameter effected the most by sulfur emissions this analysis is not performed for the other parametersSee also table 9 in appendix 4

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### AEA 113

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### AEA 114Figure A10: Average Accumulated Exceedence for eutrophication (eq./ha/yr) for 2020..a) BaselineIn all areas, not colored green, there is an exceedence of the critical loadb) fractional change (%) of SEA1 compared to baselineThe map shows clearly the reduction of the exceedence of the critical load all round the North Sea andthe Baltic duethe designation of these waters as SECA. Also the exceedence in the Mediterranean countries improves as a result ofthe NOXTier standards.c) fractional change (%) of SEA 3 compared to SEA 1Thus the effect of inclusion of the Mediterranean sea and Black sea in the SECA and designation thesewaters asNECA does add to the improvement gained in scenarioSEA1 compared to the baseline.d) fractional change (%) of SEA 4 compared to SEA 3Reduction of the S content outside the SECAs does lower the exceedence of the critical load only to asmall extend.The remainder reduction in SEA4 stems from the NECAin the Mediterranean and the Black SeaSee also table 11 in appendix 4

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### AEA 115

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### AEA 116Figure A11 PM10 (ug/m3) for 2020..a) Baselineb) SEA 1The map shows the positive effect on PM concentration when designating the designating the North Sea /English Channel and The Baltic as SECA. The reduction of sulfur in fuels is associated with an reduction in PMemissions. In the coastal zones all round the SECAshow reduced concentrations of PMc) SEA 3The map shows the positive effect when designatingthe Baltic Sea, North Sea / English Channel, theMediterranean Sea and the Black Sea as SECA. Although not clearly indicated in the map the differenceswiththe former map is that the concentrations in the Mediterranean coastal zones are reduced.See also table 14 in appendix 4d) SEA 5The map shows that reducing the S content outside the SECA has a positive effect on PM10 particularlyin theUK and IR (compare to map b).For more details see also table 14 in appendix 4

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### AEA 117

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### AEA 118Figure A12 PM10 (ug/m3) for 2020..a) Baselineb) fractional change (%) of SEA 1 compared to baselineThe next map shows the positive effect on PM concentration when designating the designating the NorthSea /English Channel and The Baltic as SECA. The reduction of sulfur in fuels is associated with an reduction in PMemissions..c) fractional change (%) of SEA 3 compared to baselineThe map shows the positive effect (% reduction in concentration) when designating the Mediterranean sea andthe Black Sea as SECA and the Baltic Sea, North Sea/ English Channel and the Mediterranean Sea as NECA.d) fractional change (%) of SEA 4 compared to baselineThe map shows that reducing the S content outside the SECA (Mediterranean Sea and Black Sea are in thisscenario not SECA) also has a positive effect on PM10 particularly in the UK and IR (compare to map b).See also table 14 in appendix 4

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### AEA 119

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### AEA 120Figure A13 AOT40F (ppm.h) for 2020..a) Difference (ppm.h) of ASEA 1 compared to SEA 1 ;b) difference (ppm.h) of BSEA 1 compared to SEA 1The map shows clearly the reduction of the ozone concentration as an result of the reduced NOxemissions in all seas as a result ofthe Tier standards.c) difference (ppm.h) of ASEA 4 compared to SEA 4Thus the effect of inclusion of the Mediterranean Sea and Black sea in the SECA does not add to the improvement gained inscenario SEA1 compared to the baseline.d) difference (ppm.h) of BSEA 4 compared to SEA 4Reduction of the S content outside the SECAs does not add to a reduction of ozone compared to SEA1. SEA1 is comparable toSEA4.Al the maps show little differences as one could expect because the differences shown in the maps arethe result of lowering the Scontent in fuel used on land. Because the differences are that small please see also 24 and 27 in appendix 4

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### AEA 121

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### AEA 122Figure A14 AOT40F (ppm.h) for 2020..a) Baselineb) Difference (ppm.h) of SEA1 compared to baselineThe map shows clearly the reduction of the ozone concentration as an result of the reduced NOxemissions in all seasas a result of the Tier standards.c) Difference (ppm.h) of SEA3 compared to baselineThus the effect of inclusion of the Mediterranean Sea and Black sea in the SECA does not add to the improvementgained in scenario SEA1 compared to the baseline.d) Difference (ppm.h) of SEA4 compared to baselineReduction of the S content outside the SECAs does not add to a reduction of ozone compared to SEA1. SEA1 iscomparable to SEA4.See also table 23 in appendix 4

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### AEA 123

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### AEA 124Figure A15 SOMO35 (ppm.h) for 2020..a) Baselineb) Difference (ppm.h) of SEA 1 compared to baselineThe map shows clearly the reduction of the ozone concentration as an result of the reduced NOxemissions in all seas asa result of the Tier standards.c) Difference (ppm.h) of SEA 3 compared to baselineThus the effect of inclusion of the Mediterranean sea and Black sea in the SECA does not add to the improvement gainedin scenario SEA1 compared to the baseline.d) Difference (ppm.h) of SEA 4 compared to baselineReduction of the S content outside the SECAs does not add to a reduction of ozone compared to SEA1. SEA1 iscomparable to SEA4.See also table 17 in appendix 4

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### AEA 125 

# 16 Appendix 4 - Results per EU member

states

In this appendix the results of the dispersion mode lling are aggregated to the level of the

individual countries. In order to make the results more comparable the rough results were multiplied by either the area of the country or the number of inhabitants.

For each parameter first the result for 2015 qnd 20 20 are presented. A third table shows the absolute and percentage difference between differen t scenarios and the trend between 2015 and

2020 on the level of total EU 27+2.

Table 1: Sulphur deposition in 2015 (Meq/year)

area (km2) base SEA1 SEA2 SEA3 ASEA1 BSEA1 A B

AT Austria 83756 913 877 820 819 869 851 904 887

BE Belgium 30520 1028 913 908 908 880 851 995 966
BG Bulgaria 110857 2061 2062 1944 1912 2056 2050 20 55 2049

CH Switzerland 41084 434 422 392 392 418 414 430 42 6
CY Cyprus 5120 48 48 39 39 48 48 47 47

CZ Czech republic 78600 1216 1167 1151 1150 1159 11 49 1207 1198
DE Germany 355693 5826 5161 5100 5100 5054 4933 571 9 5598

DK Denmark 44270 728 334 331 331 331 326 725 720

EE Estonia 45263 445 313 310 310 311 310 444 442

ES Spain 497559 6749 6878 6085 6085 6853 6831 6724 6702

FI Finland 334395 1617 1258 1251 1251 1255 1244 161 3 1603

FR France 547219 5928 5433 4914 4914 5316 5215 5810 5709

GR Greece 132022 2178 2236 1459 1452 2210 2188 2152 2130

HU Hungary 92857 1189 1173 1120 1119 1169 1163 1185 1180

IE Ireland 68128 781 745 743 743 732 721 768 757

IT Italy 301129 4358 4465 2897 2896 4430 4399 4323 4293

LT Lithuania 64612 866 785 778 777 783 780 863 860

LU Luxembourg 2589 45 43 42 42 41 39 43 41

LV Latvia 64207 658 543 536 535 540 537 656 653

MT Malta 319 6 6 1 1 6 6 6 6

NL Netherlands 35076 869 650 647 647 637 624 855 84 3
NO Norway 295987 1845 1386 1377 1377 1381 1375 1839 1832

PO Poland 310641 6797 6448 6395 6393 6407 6366 6756 6715

PT Portugal 88648 1329 1366 1320 1320 1360 1356 132 4 1319

RO Romania 237394 3821 3791 3656 3615 3778 3764 380 7 3794

SE Sweden 446266 2893 1858 1845 1845 1848 1832 2880 2865

SK Slovakia 48857 805 789 771 770 786 782 802 798

SL Slovenia 20672 377 378 320 320 374 371 373 370

UK United kingdom 243251 3886 3185 3172 3172 3167 3145 3867 3845

EU27+2 4626991 59697 54714 50323 50237 54197 53670 59174 58646

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### AEA 126 Table 2: Sulphur deposition in 2020 (Meq/year)

Area (km2) base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4

AT Austria 83756 897 857 791 790 780 849 838 782 77 1

BE Belgium 30520 1002 872 866 852 852 843 824 824 8 05
BG Bulgaria 110857 2033 2033 1864 1885 1861 2028 20 23 1879 1875

CH Switzerland 41084 427 414 381 376 371 410 408 37 2 370
CY Cyprus 5120 40 41 31 32 31 41 41 32 32

CZ Czech republic 78600 1178 1122 1104 1098 1095 1115 1110 1090 1085

DE Germany 355693 5914 5160 5090 5030 5020 5068 500 7 4939 4877

DK Denmark 44270 782 335 332 323 323 333 329 321 31 8

EE Estonia 45263 456 306 303 300 299 305 304 299 29 7
ES Spain 497559 5569 5716 4817 3912 3784 5697 5684 3893 3880

FI Finland 334395 1641 1234 1227 1209 1208 1232 122 5 1206 1199

FR France 547219 5729 5169 4582 4262 4179 5072 5007 4165 4100

GR Greece 132022 2177 2243 1356 1479 1352 2219 2202 1455 1438

HU Hungary 92857 1145 1126 1065 1069 1060 1122 1119 1065 1062

IE Ireland 68128 772 731 729 629 629 719 711 618 60 9

IT Italy 301129 4446 4568 2792 3011 2756 4534 4511 2977 2954

LT Lithuania 64612 883 792 783 779 778 790 788 777 775

LU Luxembourg 2589 44 41 40 40 39 39 38 38 36

LV Latvia 64207 683 552 543 539 538 549 548 536 535

MT Malta 319 7 7 1 2 1 7 7 2 2

NL Netherlands 35076 889 641 638 627 627 630 622 61 6 608
NO Norway 295987 1904 1386 1375 1277 1275 1381 1377 1272 1268

PO Poland 310641 6718 6324 6261 6243 6234 6287 6261 6206 6180

PT Portugal 88648 1177 1218 1166 775 767 1213 1210 770 766

RO Romania 237394 3880 3846 3647 3667 3640 3833 382 4 3655 3645

SE Sweden 446266 3040 1870 1854 1805 1803 1861 1851 1796 1786

SK Slovakia 48857 800 782 761 761 758 780 777 758 7 55

SL Slovenia 20672 380 381 315 322 313 377 375 319 3 16

UK United kingdom 243251 3783 2991 2976 2542 2540 2975 2961 2526 2512

EU27+2 4626991 58396 52759 47691 45635 44912 52310 51981 45186 44858

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### AEA 127 Table 3: Differences between scenarios and years fo r sulphur depositions (EU27+2 total)

2015 2020

abs (Meq/yr) % abs (Meq/yr ) %

SEA1-base -4983 -8.3% -5638 -10%

SEA2-base -9374 -16% n.c n.c

SEA3-base -9460 -16% -10706 -18%

SEA4-base n.c n.c -12761 -22%

SEA5-base n.c n.c -13484 -23%

BSEA1-

ASEA1 -527 -1.0% -329 -0.6%

ASEA1-SEA1 -517 -0.9% -449 -0.9%

BSEA1-SEA1 -1044 -1.9% -778 -1.5%

A-SEA4-

ASEA1 n.c n.c -7123 -14%

BSEA4-

BSEA1 n.c n.c -7123 -14%

A-base -522 -0.9% n.c n.c

B-base -1050 -1.8% n.c n.c

B-A -528 -0.9% n.c n.c

SEA2-SEA1 -4391 -8.0% n.c n.c

SEA3-SEA2 -86 -0.2% n.c n.c

SEA3-SEA1 n.c n.c -5068 -11%

SEA4-SEA1 n.c n.c -7124 -14%

SEA5-SEA3 n.c n.c -2779 -5.8%

SEA5-SEA4 n.c n.c -723 -1.6%

ASEA1-base -5500 -9.2% n.c n.c

BSEA1-base -6027 -10% n.c n.c

n.c - not calculated

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### AEA 128 Table 4: Nitrogen deposition in 2015 (Meq/year)

area (km2) base SEA1 SEA2 SEA3 ASEA1 BSEA1 A B

AT Austria 83756 4160 4127 4115 4115 4127 4123 4159 4156

BE Belgium 30520 3076 3040 3039 3039 3036 3032 3073 3071
BG Bulgaria 110857 4128 4097 4071 4065 4097 4096 41 27 4127

CH Switzerland 41084 2021 2008 2000 2000 2008 2007 2021 2021
CY Cyprus 5120 132 131 131 131 131 131 132 132

CZ Czech republic 78600 4256 4230 4224 4224 4229 4228 4255 4254

DE Germany 355693 23806 23592 23573 23573 23576 235 57 23789 23769

DK Denmark 44270 2099 2059 2058 2058 2059 2059 2099 2099

EE Estonia 45263 818 791 789 789 790 790 817 817
ES Spain 497559 18212 17864 17698 17698 17860 17857 18208 18205

FI Finland 334395 3180 3068 3063 3063 3066 3065 317 9 3177

FR France 547219 28449 28101 28009 28009 28075 2805 2 28418 28393

GR Greece 132022 3740 3605 3511 3510 3603 3602 3738 3736

HU Hungary 92857 4053 4030 4018 4018 4029 4028 4052 4051

IE Ireland 68128 3624 3603 3602 3602 3602 3601 3623 3621

IT Italy 301129 16276 16006 15681 15681 15994 15984 16263 16253

LT Lithuania 64612 2163 2143 2139 2139 2143 2142 21 63 2163

LU Luxembourg 2589 198 196 196 196 195 195 197 196

LV Latvia 64207 1468 1431 1426 1426 1430 1430 1467 1467

MT Malta 319 6 6 5 5 6 6 6 6

NL Netherlands 35076 3819 3772 3770 3770 3769 3766 3817 3814
NO Norway 295987 4183 4025 4018 4018 4023 4021 4181 4180

PO Poland 310641 15721 15602 15580 15580 15599 1559 6 15718 15714

PT Portugal 88648 3305 3229 3213 3213 3228 3228 330 4 3304

RO Romania 237394 9751 9697 9663 9658 9695 9693 974 9 9747

SE Sweden 446266 5821 5546 5537 5537 5544 5541 5818 5816

SK Slovakia 48857 2124 2108 2100 2100 2107 2106 212 3 2123

SL Slovenia 20672 1248 1236 1225 1225 1235 1235 124 8 1248

UK United kingdom 243251 11978 11759 11747 11747 11756 11753 11976 11 973

EU27+2 4626991 183814 181100 180202 180188 181012 1 80921 183722 183633

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### 129 Table 5: Nitrogen deposition in 2020 (Meq/year)

area (km2) base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4

AT Austria 83756 3974 3918 3909 3904 3902 3918 3917 3904 3902

BE Belgium 30520 2949 2895 2894 2890 2889 2891 2888 2886 2883

BG Bulgaria 110857 4080 4010 3977 3981 3974 4010 4010 3980 3980

CH Switzerland 41084 1913 1890 1884 1882 1880 1890 1890 1882 1882

CY Cyprus 5120 132 129 128 128 128 129 129 128 128

CZ Czech republic 78600 4070 4030 4025 4021 4020 4030 4029 4020 4019

DE Germany 355693 23205 22886 22869 22848 22844 22874 22865 22 835 22826

DK Denmark 44270 2022 1937 1936 1934 1934 1937 1938 1934 1935

EE Estonia 45263 811 761 759 757 757 761 761 757 757

ES Spain 497559 17062 16409 16244 16141 16104 16406 16404 16 137 16135

FI Finland 334395 3084 2899 2894 2886 2885 2898 2897 2884 2883

FR France 547219 27267 26678 26598 26578 26560 26658 26646 26 559 26546

GR Greece 132022 3695 3382 3288 3304 3284 3381 3380 3302 3300

HU Hungary 92857 3991 3950 3938 3936 3934 3949 3949 3936 3935

IE Ireland 68128 3562 3527 3526 3523 3522 3526 3525 3521 3521

IT Italy 301129 15634 15019 14702 14748 14680 15009 15001 14 734 14725

LT Lithuania 64612 2156 2118 2114 2112 2111 2118 2118 2112 2112

LU Luxembourg 2589 186 184 183 183 183 183 182 183 182

LV Latvia 64207 1439 1375 1370 1367 1366 1374 1374 1366 1366

MT Malta 319 6 5 5 5 5 5 5 5 5

NL Netherlands 35076 3832 3758 3757 3755 3755 3756 3754 3753 3752

NO Norway 295987 4081 3816 3809 3789 3788 3815 3814 3787 3786

PO Poland 310641 15292 15098 15075 15063 15059 15095 15094 15 060 15059

PT Portugal 88648 3235 3112 3099 3055 3052 3112 3111 3055 3054

RO Romania 237394 9695 9592 9553 9554 9546 9591 9590 9552 9551

SE Sweden 446266 5695 5222 5213 5190 5188 5221 5219 5188 5186

SK Slovakia 48857 2034 2008 2001 1999 1998 2008 2007 1999 1998

SL Slovenia 20672 1192 1165 1156 1156 1154 1165 1165 1156 1156

UK United kingdom 243251 11379 11027 11015 10998 10996 11025 11023 10 996 10995

EU27+2 4626991 177674 172803 171922 171688 171499 1 72734 172685 171611 171559Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

130 Table 6: Differences between scenarios and years fo r nitrogen depositions (EU27+2 total)

2015 2020

abs (Meq/yr) % abs

(Meq/yr) %

SEA1-base -2714 -1.5% -4871 -2.7%

SEA2-base -3613 -2.0% n.c n.c

SEA3-base -3626 -2.0% -5752 -3.2%

SEA4-base n.c n.c -5986 -3.4%

SEA5-base n.c n.c -6175 -3.5%

BSEA1-

ASEA1 -90 0.0% -49 0.0%

ASEA1-SEA1 -88 0.0% -69 0.0%

BSEA1-SEA1 -179 -0.1% -118 -0.1%

A-SEA4-

ASEA1 n.c n.c -1123 -0.7%

BSEA4-

BSEA1 n.c n.c -1126 -0.7%

A-base -92 -0.1% n.c n.c

B-base -182 -0.1% n.c n.c

B-A -90 0.0% n.c n.c

SEA2-SEA1 -899 -0.5% n.c n.c

SEA3-SEA2 -14 0.0% n.c n.c

SEA3-SEA1 n.c n.c -881 -0.5%

SEA4-SEA1 n.c n.c -1115 -0.6%

SEA5-SEA3 n.c n.c -423 -0.2%

SEA5-SEA4 n.c n.c -189 -0.1%

ASEA1-base -2803 -1.5% n.c n.c

BSEA1-base -2893 -1.6% n.c n.c

n.c - not calculatedCost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

131 Table 7: Acidification (AAE) in 2015 (Meq/year)

area (km2) base SEA1 SEA2 SEA3 ASEA1 BSEA1 A B

AT Austria 83756 1 1 1 1 1 1 1 1

BE Belgium 30520 28 21 20 20 20 19 26 25
BG Bulgaria 110857 0 0 0 0 0 0 0 0

CH Switzerland 41084 3 3 2 2 3 3 3 3
CY Cyprus 5120 0 0 0 0 0 0 0 0

CZ Czech republic 78600 5 4 4 4 4 4 5 5

DE Germany 355693 558 474 471 471 464 452 547 534

DK Denmark 44270 3 1 1 1 1 1 3 3

EE Estonia 45263 0 0 0 0 0 0 0 0
ES Spain 497559 0 0 0 0 0 0 0 0

FI Finland 334395 12 6 6 6 6 6 12 11

FR France num 61 55 55 55 53 51 59 56

GR Greece 132022 0 0 0 0 0 0 0 0
HU Hungary 92857 0 0 0 0 0 0 0 0

IE Ireland 68128 6 6 5 5 5 5 6 6

IT Italy 301129 0 0 0 0 0 0 0 0

LT Lithuania 64612 0 0 0 0 0 0 0 0
LU Luxembourg 2589 0 0 0 0 0 0 0 0

LV Latvia 64207 0 0 0 0 0 0 0 0

MT Malta 319 0 0 0 0 0 0 0 0

NL Netherlands 35076 214 184 183 183 182 180 212 210

NO Norway 295987 422 270 267 267 268 267 421 419

PO Poland 310641 5 5 5 5 5 5 5 5

PT Portugal 88648 6 6 6 6 6 6 6 6

RO Romania 237394 0 0 0 0 0 0 0 0

SE Sweden 446266 220 113 112 112 112 111 219 217

SK Slovakia 48857 2 2 2 2 2 2 2 2

SL Slovenia 20672 0 0 0 0 0 0 0 0

UK United kingdom 243251 187 158 157 157 157 156 186 185

EU27+2 4626991 1734 1305 1296 1296 1287 1266 1712 1686Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

132 Table 8: Acidification (AAE) in 2020 (Meq/year)

area (km2) base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4

AT Austria 83756 1 0 0 0 0 0 0 0 0

BE Belgium 30520 24 17 17 16 16 16 15 15 15
BG Bulgaria 110857 0 0 0 0 0 0 0 0 0

CH Switzerland 41084 2 2 2 2 2 2 2 2 2
CY Cyprus 5120 0 0 0 0 0 0 0 0 0

CZ Czech republic 78600 2 2 1 1 1 2 2 1 1

DE Germany 355693 551 448 446 442 442 441 436 434 429

DK Denmark 44270 4 0 0 0 0 0 0 0 0

EE Estonia 45263 0 0 0 0 0 0 0 0 0
ES Spain 497559 0 0 0 0 0 0 0 0 0

FI Finland 334395 12 5 5 5 5 5 5 5 5

FR France 547219 45 41 40 39 39 39 38 38 37

GR Greece 132022 0 0 0 0 0 0 0 0 0
HU Hungary 92857 0 0 0 0 0 0 0 0 0

IE Ireland 68128 5 5 5 4 4 5 5 4 4

IT Italy 301129 0 0 0 0 0 0 0 0 0

LT Lithuania 64612 0 0 0 0 0 0 0 0 0
LU Luxembourg 2589 0 0 0 0 0 0 0 0 0

LV Latvia 64207 0 0 0 0 0 0 0 0 0

MT Malta 319 0 0 0 0 0 0 0 0 0

NL Netherlands 35076 223 183 182 181 181 181 180 179 178

NO Norway 295987 423 239 235 223 223 238 237 222 221

PO Poland 310641 4 3 3 3 3 3 3 3 3

PT Portugal 88648 3 3 3 0 0 3 3 0 0

RO Romania 237394 0 0 0 0 0 0 0 0 0

SE Sweden 446266 235 107 106 103 103 106 105 102 101

SK Slovakia 48857 1 1 1 1 1 1 1 1 1

SL Slovenia 20672 0 0 0 0 0 0 0 0 0

UK United kingdom 243251 137 108 107 90 90 107 107 90 89

EU27+2 4626991 1673 1165 1155 1112 1111 1151 1140 1098 1087Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

133 Table 9: Differences between scenarios and years fo r acidification (AAE) (EU27+2 total)

2015 2020

abs (Meq/yr) % abs

(Meq/yr) %

SEA1-base -429 -25% -508 -30%

SEA2-base -438 -25% n.c n.c

SEA3-base -438 -25% -518 -31%

SEA4-base n.c n.c -561 -34%

SEA5-base n.c n.c -562 -34%

BSEA1-

ASEA1 -21 -1.7% -11 -0.9%

ASEA1-SEA1 -19 -1.4% -14 -1.2%

BSEA1-SEA1 -40 -3.1% -25 -2.1%

A-SEA4-

ASEA1 n.c n.c -53 -4.6%

BSEA4-

BSEA1 n.c n.c -53 -4.6%

A-base -22 -1.3% n.c n.c

B-base -48 -2.8% n.c n.c

B-A -26 -1.5% n.c n.c

SEA2-SEA1 -9 -0.7% n.c n.c

SEA3-SEA2 0 0.0% n.c n.c

SEA3-SEA1 n.c n.c -10 -0.8%

SEA4-SEA1 n.c n.c -53 -4.5%

SEA5-SEA3 n.c n.c -45 -3.9%

SEA5-SEA4 n.c n.c -1 -0.1%

ASEA1-base -447 -26% n.c n.c

BSEA1-base -468 -27% n.c n.c

n.c - not calculatedCost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

134 Table 10: Eutrophication (AAE) in 2015 (Meq/year)

area (km2) base SEA1 SEA2 SEA3 ASEA1 BSEA1 A B

AT Austria 83756 1240 1218 1212 1212 1218 1215 1239 1236

BE Belgium 30520 461 442 441 441 440 437 459 458
BG Bulgaria 110857 21 20 19 17 20 20 21 21

CH Switzerland 41084 29 29 28 28 29 29 29 29

CY Cyprus 5120 31 31 31 31 31 31 31 31

CZ Czech republic 78600 345 334 332 332 334 333 344 344

DE Germany 355693 9042 8869 8855 8855 8856 8840 902 8 9011

DK Denmark 44270 21 20 20 20 20 20 21 21

EE Estonia 45263 2 2 2 2 2 2 2 2

ES Spain 497559 2037 1921 1853 1853 1919 1918 2035 2034

FI Finland 334395 43 31 31 31 31 31 43 43

FR France 547219 5330 5108 5069 5069 5088 5073 5306 5288

GR Greece 132022 57 47 39 39 47 47 57 57

HU Hungary 92857 139 136 134 134 136 135 139 138

IE Ireland 68128 0 0 0 0 0 0 0 0

IT Italy 301129 1495 1443 1357 1357 1437 1432 1489 1484

LT Lithuania 64612 57 56 56 56 56 56 57 57

LU Luxembourg 2589 43 42 42 42 42 41 43 42

LV Latvia 64207 5 5 5 5 5 5 5 5

MT Malta 319 0 0 0 0 0 0 0 0

NL Netherlands 35076 873 852 851 851 850 848 872 87 0

NO Norway 295987 0 0 0 0 0 0 0 0

PO Poland 310641 1958 1900 1889 1889 1899 1897 1956 1955

PT Portugal 88648 145 131 128 128 130 130 145 145

RO Romania 237394 140 135 132 131 135 135 140 139

SE Sweden 446266 35 27 27 27 27 27 35 35

SK Slovakia 48857 158 154 153 152 154 154 158 157

SL Slovenia 20672 190 184 180 180 184 184 190 190

UK United kingdom 243251 58 50 50 50 50 50 58 58

EU27+2 4626991 23955 23188 22935 22932 23139 23088 23903 23850Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

135 Table 11: Eutrophication (AAE) in 2020 (Meq/year)

area (km2) base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4

AT Austria 83756 1121 1087 1082 1078 1077 1086 1085 1078 1076

BE Belgium 30520 410 384 384 383 383 382 381 381 379
BG Bulgaria 110857 19 17 14 15 14 17 17 15 15

CH Switzerland 41084 22 21 21 21 21 21 21 21 21
CY Cyprus 5120 31 29 29 29 29 29 29 29 29

CZ Czech republic 78600 267 254 252 251 250 254 253 250 250

DE Germany 355693 8582 8332 8319 8304 8302 8322 8315 8294 8286

DK Denmark 44270 18 16 16 16 16 16 16 16 16

EE Estonia 45263 2 1 1 1 1 1 1 1 1
ES Spain 497559 1539 1345 1276 1253 1240 1343 1343 1251 1250

FI Finland 334395 36 20 20 20 20 20 20 20 20

FR France 547219 4633 4301 4271 4266 4259 4288 4279 4253 4244

GR Greece 132022 47 29 23 24 23 29 29 24 24
HU Hungary 92857 129 124 123 123 123 124 124 123 123

IE Ireland 68128 0 0 0 0 0 0 0 0 0

IT Italy 301129 1283 1183 1119 1128 1116 1177 1173 1122 1117

LT Lithuania 64612 58 57 57 57 57 57 57 57 57
LU Luxembourg 2589 35 34 34 34 34 34 33 34 33

LV Latvia 64207 5 5 5 5 5 5 5 5 5

MT Malta 319 0 0 0 0 0 0 0 0 0

NL Netherlands 35076 884 853 853 852 852 852 851 851 850

NO Norway 295987 0 0 0 0 0 0 0 0 0

PO Poland 310641 1693 1607 1596 1590 1588 1606 1606 1589 1588

PT Portugal 88648 132 111 110 99 98 111 111 99 98

RO Romania 237394 131 122 118 119 118 122 122 118 118

SE Sweden 446266 33 21 21 20 20 21 21 20 20

SK Slovakia 48857 134 128 127 127 126 128 128 126 126

SL Slovenia 20672 164 154 151 151 150 154 154 151 150

UK United kingdom 243251 26 21 21 20 20 21 21 20 20

EU27+2 4626991 21436 20259 20043 19984 19941 20222 20195 19946 19918Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

136 Table12: Differences between scenarios and years fo r eutrophication (AAE) (EU27+2 total)

2015 2020

abs (Meq/yr) % abs

(Meq/yr) %

SEA1-base -768 -3.2% -1178 -5.5%

SEA2-base -1020 -4.3% NC NC

SEA3-base -1023 -4.3% -1393 -6.5%

SEA4-base n.c n.c -1453 -6.8%

SEA5-base n.c n.c -1495 -7.0%

BSEA1-ASEA1 -50 -0.2% -27 -0.1%

ASEA1-SEA1 -49 -0.2% -37 -0.2%

BSEA1-SEA1 -99 -0.4% -64 -0.3%

A-SEA4-ASEA1 NC NC -276 -1.4%

BSEA4-BSEA1 NC NC -277 -1.4%

A-base -53 -0.2% n.c n.c

B-base -106 -0.4% n.c n.c

B-A -53 -0.2% n.c n.c

SEA2-SEA1 -252 -1.1% n.c n.c

SEA3-SEA2 -3 0.0% n.c n.c

SEA3-SEA1 n.c n.c -215 -1.1%

SEA4-SEA1 n.c n.c -275 -1.4%

SEA5-SEA3 n.c n.c -102 -0.5%

SEA5-SEA4 n.c n.c -43 -0.2%

ASEA1-base -817 -3.4% n.c n.c

BSEA1-base -867 -3.6% n.c n.c

n.c - not calculatedCost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

137 Table 13: Particulate matter inhabitant weighted in 2015 (μg PM10/m3*Minh.)

inhabitants base SEA1 SEA2 SEA3 ASEA1 BSEA1 A B

AT Austria 7994855 36 34 34 34 34 34 36 35

BE Belgium 10065306 100 91 91 91 90 90 100 99
BG Bulgaria 8392665 37 36 35 35 36 36 37 36

CH Switzerland 6994898 30 29 29 29 29 29 30 29
CY Cyprus 437692 1 1 1 1 1 1 1 1

CZ Czech republic 10362569 61 59 58 58 59 59 61 61

DE Germany 81558728 490 459 458 458 457 455 488 486

DK Denmark 4714330 23 17 17 17 17 17 23 23

EE Estonia 1460788 4 3 3 3 3 3 4 4
ES Spain 36886896 193 192 179 179 192 192 193 193

FI Finland 4900677 5 5 5 5 5 5 5 5

FR France 56954432 371 354 349 349 353 351 369 368

GR Greece 9640492 33 33 27 27 33 33 33 33

HU Hungary 10213844 52 51 50 50 50 50 52 52

IE Ireland 3472169 13 12 12 12 12 12 13 12

IT Italy 56077436 363 359 331 331 358 357 362 361

LT Lithuania 3684786 15 14 14 14 14 14 15 15

LU Luxembourg 404906 3 3 3 3 3 3 3 3

LV Latvia 2553183 8 7 7 7 7 7 8 8

MT Malta 326771 1 1 0 0 1 1 1 1

NL Netherlands 15059911 140 122 121 121 121 121 140 139

NO Norway 3874886 6 6 6 6 6 6 6 6

PO Poland 38535612 295 284 283 283 284 283 294 294

PT Portugal 9137149 41 41 40 40 41 41 41 41

RO Romania 22628702 122 121 120 118 121 120 122 122

SE Sweden 8315852 18 14 14 14 14 14 18 18

SK Slovakia 5318256 26 25 25 25 25 25 26 26

SL Slovenia 2023350 8 8 8 8 8 8 8 8

UK United kingdom 56343596 385 352 351 351 351 350 384 383

EU27+2 478334737 2878 2732 2670 2668 2724 2716 2870 2863Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

138 Table 14: Particulate matter inhabitant weighted in 2020 (μg PM10/m3*Minh.)

inhabitants base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4

AT Austria 7994855 32 31 30 30 30 31 31 30 30

BE Belgium 10065306 96 84 84 83 83 83 83 83 82
BG Bulgaria 8392665 36 36 34 34 34 36 36 34 34

CH Switzerland 6994898 27 26 26 25 25 26 26 25 25
CY Cyprus 437692 1 1 1 1 1 1 1 1 1

CZ Czech republic 10362569 55 52 52 52 52 52 52 52 51

DE Germany 81558728 464 423 422 419 419 422 420 417 416

DK Denmark 4714330 23 16 16 16 16 16 16 16 16

EE Estonia 1460788 4 3 3 3 3 3 3 3 3
ES Spain 36886896 173 171 155 151 149 171 171 151 151

FI Finland 4900677 5 4 4 4 4 4 4 4 4

FR France 56954432 339 317 312 309 308 316 315 308 307

GR Greece 9640492 33 33 26 27 25 33 33 26 26

HU Hungary 10213844 48 46 46 46 45 46 46 45 45

IE Ireland 3472169 12 11 11 10 10 11 11 10 10

IT Italy 56077436 337 328 298 302 297 328 327 301 300

LT Lithuania 3684786 15 14 13 13 13 14 14 13 13

LU Luxembourg 404906 2 2 2 2 2 2 2 2 2

LV Latvia 2553183 8 7 7 7 7 7 7 7 7

MT Malta 326771 1 1 0 1 0 1 1 1 1

NL Netherlands 15059911 135 112 112 111 111 112 112 110 110

NO Norway 3874886 6 5 5 5 5 5 5 5 5

PO Poland 38535612 275 262 260 260 259 261 261 259 259

PT Portugal 9137149 39 39 38 34 34 39 39 34 34

RO Romania 22628702 123 122 119 119 119 121 121 119 119

SE Sweden 8315852 18 13 13 13 13 13 13 13 13

SK Slovakia 5318256 24 23 23 23 23 23 23 23 23

SL Slovenia 2023350 8 7 7 7 7 7 7 7 7

UK United kingdom 56343596 361 318 318 307 307 317 317 307 306

EU27+2 478334737 2701 2509 2437 2414 2403 2502 2497 2407 2402Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

139 Table 15: Differences between scenarios and years f or particulate matter ( inhabitant weighted, EU27+2 total)

2015 2020

abs (μg PM10/m3*Minh.) % abs (μg PM10/m3*Minh.) %

SEA1-base -146 -5.1% -192 -7.1%

SEA2-base -208 -7.2% NC NC

SEA3-base -210 -7.3% -264 -10%

SEA4-base n.c n.c -287 -11%

SEA5-base n.c n.c -298 -11%

BSEA1-ASEA1 -8 -0.3% -5 -0.2%

ASEA1-SEA1 -8 -0.3% -7 -0.3%

BSEA1-SEA1 -16 -0.6% -12 -0.5%

A-SEA4-ASEA1 n.c n.c -95 -3.8%

BSEA4-BSEA1 n.c n.c -96 -3.8%

A-base -7 -0.3% n.c n.c

B-base -15 -0.5% n.c n.c

B-A -7 -0.3% n.c n.c

SEA2-SEA1 -62 -2.3% n.c n.c

SEA3-SEA2 -2 -0.1% n.c n.c

SEA3-SEA1 n.c n.c -72 -3.0%

SEA4-SEA1 n.c n.c -95 -3.8%

SEA5-SEA3 n.c n.c -34 -1.4%

SEA5-SEA4 n.c n.c -11 -0.5%

ASEA1-base -154 -5.3% n.c n.c

BSEA1-base -162 -5.6% n.c n.c

n.c - not calculatedCost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

140 Table 16: SOMO35 in 2015 (ppm.d.*Minh.)

inhabitants base SEA1 SEA2 SEA3 ASEA1 BSEA1 A B

AT Austria 7994855 14 14 14 14 14 14 14 14

BE Belgium 10065306 13 13 13 13 13 13 13 13
BG Bulgaria 8392665 14 14 14 14 14 14 14 14

CH Switzerland 6994898 15 14 14 14 14 14 15 15
CY Cyprus 437692 1 1 1 1 1 1 1 1

CZ Czech republic 10362569 15 14 15 15 14 14 15 15

DE Germany 81558728 126 124 125 125 124 124 126 126

DK Denmark 4714330 7 7 7 7 7 7 7 7

EE Estonia 1460788 1 1 1 1 1 1 1 1
ES Spain 36886896 101 98 99 99 98 98 100 100

FI Finland 4900677 5 5 5 5 5 5 5 5

FR France 56954432 95 94 94 94 94 94 95 95

GR Greece 9640492 28 27 28 28 27 27 28 28

HU Hungary 10213844 19 19 19 19 19 19 19 19

IE Ireland 3472169 3 3 3 3 3 3 3 3

IT Italy 56077436 183 180 181 181 180 180 183 184

LT Lithuania 3684786 3 3 3 3 3 3 3 3

LU Luxembourg 404906 1 1 1 1 1 1 1 1

LV Latvia 2553183 3 3 3 3 3 3 3 3

MT Malta 326771 1 1 1 1 1 1 1 1

NL Netherlands 15059911 20 20 20 20 20 20 20 20

NO Norway 3874886 5 4 4 4 4 4 5 5

PO Poland 38535612 49 48 48 48 48 48 49 49

PT Portugal 9137149 28 27 27 27 27 27 28 28

RO Romania 22628702 31 31 31 31 31 31 31 31

SE Sweden 8315852 12 12 12 12 12 12 12 12

SK Slovakia 5318256 9 9 9 9 9 9 9 9

SL Slovenia 2023350 5 5 5 5 5 5 5 5

UK United kingdom 56343596 65 64 64 64 64 64 65 65

EU27+2 478334737 873 860 864 864 860 860 873 873Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

141 Table 17: SOMO35 in 2020 (ppm.d.*Minh.)

inhabitants base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4

AT Austria 7994855 13 13 13 13 13 13 13 13 13

BE Belgium 10065306 14 14 14 14 14 14 14 14 14
BG Bulgaria 8392665 13 13 13 13 13 13 13 13 13

CH Switzerland 6994898 13 13 13 13 13 13 13 13 13
CY Cyprus 437692 1 1 1 1 1 1 1 1 1

CZ Czech republic 10362569 14 13 13 13 13 13 13 13 13

DE Germany 81558728 124 121 121 121 121 121 121 121 121

DK Denmark 4714330 7 7 7 7 7 7 7 7 7

EE Estonia 1460788 1 1 1 1 1 1 1 1 1
ES Spain 36886896 99 94 95 96 96 94 94 96 96

FI Finland 4900677 5 4 4 4 4 4 4 4 4

FR France 56954432 89 86 86 86 86 86 86 86 86

GR Greece 9640492 27 26 26 26 26 26 26 26 26

HU Hungary 10213844 17 17 17 17 17 17 17 17 17

IE Ireland 3472169 3 3 3 3 3 3 3 3 3

IT Italy 56077436 173 165 166 166 166 165 165 166 166

LT Lithuania 3684786 3 3 3 3 3 3 3 3 3

LU Luxembourg 404906 1 1 1 1 1 1 1 1 1

LV Latvia 2553183 3 2 2 2 2 2 2 2 2

MT Malta 326771 1 1 1 1 1 1 1 1 1

NL Netherlands 15059911 21 21 21 21 21 21 21 21 21

NO Norway 3874886 4 4 4 4 4 4 4 4 4

PO Poland 38535612 46 44 45 45 45 44 44 45 45

PT Portugal 9137149 26 25 26 26 26 25 25 26 26

RO Romania 22628702 30 29 29 29 29 29 29 29 29

SE Sweden 8315852 12 11 11 11 11 11 11 11 11

SK Slovakia 5318256 9 9 9 9 9 9 9 9 9

SL Slovenia 2023350 5 5 5 5 5 5 5 5 5

UK United kingdom 56343596 68 65 65 65 65 65 65 65 65

EU27+2 478334737 843 811 815 816 817 811 811 816 816Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

142 Table 18: Differences between scenarios and years f or SOMO35 (EU27+2 total)

2015 2020

abs (ppm.d.*Minh.) % abs (ppm.d.*Minh.) %

SEA1-base -13 -1.5% -33 -3.9%

SEA2-base -9 -1.0% n.c n.c

SEA3-base -9 -1.1% -28 -3.3%

SEA4-base n.c n.c -27 -3.2%

SEA5-base n.c n.c -26 -3.1%

BSEA1-ASEA1 0 0.0% 0 0.0%

ASEA1-SEA1 0 0.0% 0 0.0%

BSEA1-SEA1 0 0.0% 0 0.0%

A-SEA4-ASEA1 n.c n.c 6 0.7%

BSEA4-BSEA1 n.c n.c 6 0.7%

A-base 0 0.0% n.c n.c

B-base 0 0.0% n.c n.c

B-A 0 0.0% n.c n.c

SEA2-SEA1 4 0.5% n.c n.c

SEA3-SEA2 0 0.0% n.c n.c

SEA3-SEA1 NC NC 5 0.6%

SEA4-SEA1 NC NC 6 0.7%

SEA5-SEA3 NC NC 2 0.3%

SEA5-SEA4 NC NC 1 0.1%

ASEA1-base -13 -1.5% n.c n.c

BSEA1-base -13 -1.5% n.c n.c

n.c - not calculatedCost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

143 Table 19: AOT40c in 2015 (ppm.d.*Minh.)

inhabitants base SEA1 SEA2 SEA3 ASEA1 BSEA1 A B

AT Austria 7994855 43 41 42 42 41 41 43 43

BE Belgium 10065306 31 31 31 31 31 31 31 31

BG Bulgaria 8392665 28 28 28 28 28 28 28 28

CH Switzerland 6994898 33 33 33 33 33 33 33 33

CY Cyprus 437692 3 2 2 2 2 2 3 3

CZ Czech republic 10362569 40 39 40 40 39 39 40 40

DE Germany 81558728 296 288 291 291 288 288 296 296

DK Denmark 4714330 23 22 22 22 22 22 23 23

EE Estonia 1460788 5 5 5 5 5 5 5 5

ES Spain 36886896 241 231 237 237 231 231 241 241

FI Finland 4900677 14 14 14 14 14 14 14 14

FR France 56954432 186 183 183 183 183 183 187 187

GR Greece 9640492 83 79 81 81 79 80 83 83

HU Hungary 10213844 53 52 53 53 52 52 53 53

IE Ireland 3472169 15 15 15 15 15 15 15 15

IT Italy 56077436 592 574 583 583 575 575 592 593

LT Lithuania 3684786 7 6 6 6 6 6 7 7

LU Luxembourg 404906 1 1 1 1 1 1 1 1

LV Latvia 2553183 7 7 7 7 7 7 7 7

MT Malta 326771 5 5 5 5 5 5 5 5

NL Netherlands 15059911 43 43 43 43 43 43 43 43

NO Norway 3874886 11 10 11 11 10 10 11 11

PO Poland 38535612 162 160 161 161 160 160 162 162

PT Portugal 9137149 77 74 75 75 74 74 77 77

RO Romania 22628702 74 74 74 74 74 74 74 74

SE Sweden 8315852 42 40 40 40 40 40 42 42

SK Slovakia 5318256 30 30 30 30 30 30 30 30

SL Slovenia 2023350 21 21 21 21 21 21 21 21

UK United kingdom 56343596 162 157 157 157 157 157 162 162

EU27+2 478334737 2328 2263 2290 2290 2263 2264 2329 2329Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

144 Table 20: AOT40c in 2020 (ppm.d.*Minh.)

Inhabitants base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4

AT Austria 7994855 37 33 34 34 35 34 34 34 34

BE Belgium 10065306 30 30 30 30 30 30 30 30 30
BG Bulgaria 8392665 23 22 23 23 23 23 23 23 23

CH Switzerland 6994898 28 27 27 28 28 27 27 28 28
CY Cyprus 437692 2 2 2 2 2 2 2 2 2

CZ Czech republic 10362569 34 30 32 31 32 30 30 31 31

DE Germany 81558728 276 256 259 259 259 256 256 259 259

DK Denmark 4714330 22 20 20 20 20 20 20 20 20

EE Estonia 1460788 4 4 4 4 4 4 4 4 4
ES Spain 36886896 230 207 215 217 219 207 207 217 217

FI Finland 4900677 13 11 11 11 11 11 11 11 11

FR France 56954432 169 159 160 160 160 159 159 160 160

GR Greece 9640492 79 71 73 72 73 71 71 72 72

HU Hungary 10213844 45 42 43 43 43 42 42 43 43

IE Ireland 3472169 14 13 13 13 13 13 13 13 13

IT Italy 56077436 534 490 499 498 501 490 490 499 499

LT Lithuania 3684786 6 6 6 6 6 6 6 6 6

LU Luxembourg 404906 1 1 1 1 1 1 1 1 1

LV Latvia 2553183 6 6 6 6 6 6 6 6 6

MT M alta 326771 5 4 4 4 4 4 4 4 4

NL Netherlands 15059911 43 42 42 42 42 42 42 42 42

NO Norway 3874886 10 9 9 9 9 9 9 9 9

PO Poland 38535612 142 135 137 137 137 135 135 137 137

PT Portugal 9137149 73 68 69 71 71 68 68 71 71

RO Romania 22628702 65 63 64 64 64 63 64 64 64

SE Sweden 8315852 40 35 35 35 35 35 35 35 35

SK Slovakia 5318256 26 25 25 25 25 25 25 25 25

SL Slovenia 2023350 18 17 17 17 18 17 17 17 17

UK United kingdom 56343596 163 146 146 147 147 146 146 147 147

EU27+2 478334737 2138 1975 2006 2008 2016 1976 1977 2009 2010Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

145 Table 21: Differences between scenarios and years f or AOT40c (EU27+2 total)

2015 2020

abs (ppm.d.*Minh.) % abs (ppm.d.*Minh.) %

SEA1-base -66 -2.8% -163 -7.6%

SEA2-base -39 -1.7% n.c n.c

SEA3-base -38 -1.6% -133 -6.2%

SEA4-base n.c n.c -130 -6.1%

SEA5-base n.c n.c -122 -5.7%

BSEA1-ASEA1 1 0.0% 0 0.0%

ASEA1-SEA1 1 0.0% 1 0.0%

BSEA1-SEA1 1 0.0% 1 0.1%

A-SEA4-ASEA1 n.c n.c 33 1.7%

BSEA4-BSEA1 n.c n.c 33 1.7%

A-base 0 0.0% n.c n.c

B-base 1 0.0% n.c n.c

B-A 1 0.0% n.c n.c

SEA2-SEA1 27 1.2% n.c n.c

SEA3-SEA2 0 0.0% n.c n.c

SEA3-SEA1 NC NC 30 1.5%

SEA4-SEA1 NC NC 33 1.7%

SEA5-SEA3 NC NC 11 0.5%

SEA5-SEA4 NC NC 8 0.4%

ASEA1-base -65 -2.8% n.c n.c

BSEA1-base -65 -2.8% n.c n.c

n.c. - not calculatedCost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

146 Table 22: AOT40f in 2015 (ppm.d.*Minh.)

inhab. base SEA1 SEA2 SEA3 ASEA1 BSEA1 A B

AT Austria 7994855 60 59 60 60 59 59 60 60

BE Belgium 10065306 54 54 54 54 54 54 54 54
BG Bulgaria 8392665 50 49 49 49 49 49 50 50

CH Switzerland 6994898 59 59 59 59 59 59 59 59
CY Cyprus 437692 4 3 4 4 3 3 4 4

CZ Czech republic 10362569 49 48 49 49 48 48 49 49

DE Germany 81558728 463 453 455 455 453 453 463 463

DK Denmark 4714330 32 31 31 31 31 31 32 32

EE Estonia 1460788 5 5 5 5 5 5 5 5
ES Spain 36886896 448 431 442 442 431 431 448 448

FI Finland 4900677 18 17 17 17 17 17 18 18

FR France 56954432 387 378 379 379 378 378 387 387

GR Greece 9640492 133 128 130 130 128 128 133 133

HU Hungary 10213844 78 77 78 78 77 77 78 78

IE Ireland 3472169 16 15 15 15 15 15 16 16

IT Italy 56077436 1022 994 1004 1004 994 995 1022 1022

LT Lithuania 3684786 10 10 10 10 10 10 10 10

LU Luxembourg 404906 2 2 2 2 2 2 2 2

LV Latvia 2553183 10 10 10 10 10 10 10 10

MT Malta 326771 8 8 8 8 8 8 8 8

NL Netherlands 15059911 71 70 70 70 70 70 71 71

NO Norway 3874886 18 17 17 17 17 17 18 18

PO Poland 38535612 202 199 200 200 199 199 202 202

PT Portugal 9137149 130 125 127 127 125 125 130 130

RO Romania 22628702 104 104 105 105 104 104 104 104

SE Sweden 8315852 58 56 56 56 56 56 58 58

SK Slovakia 5318256 42 41 42 42 41 41 42 42

SL Slovenia 2023350 30 30 30 30 30 30 30 30

UK United kingdom 56343596 293 284 284 284 284 284 293 293

EU27+2 478334737 3856 3756 3791 3792 3757 3757 3856 3856Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

147 Table 23: AOT40f in 2020 (ppm.d.*Minh.)

inhabitants base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4

AT Austria 7994855 53 49 50 50 50 49 49 50 50

BE Belgium 10065306 55 55 55 55 55 55 55 55 55
BG Bulgaria 8392665 44 41 41 41 41 41 41 41 41

CH Switzerland 6994898 52 50 50 50 50 50 50 50 50
CY Cyprus 437692 4 3 3 3 3 3 3 3 3

CZ Czech republic 10362569 43 39 40 40 40 39 39 40 40

DE Germany 81558728 442 415 418 418 418 415 415 418 418

DK Denmark 4714330 31 28 28 28 28 28 28 28 28

EE Estonia 1460788 5 4 4 4 4 4 4 4 4
ES Spain 36886896 433 395 408 410 414 395 395 410 410

FI Finland 4900677 16 14 14 14 14 14 14 14 14

FR France 56954432 345 323 324 326 326 323 323 326 326

GR Greece 9640492 127 115 117 116 117 115 115 116 117

HU Hungary 10213844 66 62 64 64 64 63 63 64 64

IE Ireland 3472169 14 13 13 13 13 13 13 13 13

IT Italy 56077436 929 859 870 869 872 859 859 870 870

LT Lithuania 3684786 9 9 9 9 9 9 9 9 9

LU Luxembourg 404906 2 2 2 2 2 2 2 2 2

LV Latvia 2553183 10 9 9 9 9 9 9 9 9

MT Malta 326771 9 7 8 7 8 7 7 7 7

NL Netherlands 15059911 72 71 71 71 71 71 71 71 71

NO Norway 3874886 16 14 14 14 14 14 14 14 14

PO Poland 38535612 178 170 171 171 172 170 170 171 171

PT Portugal 9137149 122 114 116 119 119 114 114 119 119

RO Romania 22628702 93 91 92 92 92 91 91 92 92

SE Sweden 8315852 55 49 49 49 49 49 49 49 49

SK Slovakia 5318256 37 35 35 35 35 35 35 35 35

SL Slovenia 2023350 26 25 25 25 25 25 25 25 25

UK United kingdom 56343596 296 271 271 272 272 271 271 272 272

EU27+2 478334737 3579 3331 3371 3378 3388 3332 3333 3379 3380Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

148 Table 24: Differences between scenarios and years f or AOT40f (EU27+2 total)

2015 2020

abs (ppm.d.*Minh.) % abs (ppm.d.*Minh.) %

SEA1-base -100 -2.6% -248 -6.9%

SEA2-base -64 -1.7% n.c n.c

SEA3-base -64 -1.7% -208 -5.8%

SEA4-base n.c n.c -201 -5.6%

SEA5-base n.c n.c -191 -5.3%

BSEA1-ASEA1 1 0.0% 0 0.0%

ASEA1-SEA1 1 0.0% 1 0.0%

BSEA1-SEA1 1 0.0% 1 0.0%

A-SEA4-ASEA1 NC NC 47 1.4%

BSEA4-BSEA1 NC NC 47 1.4%

A-base 0 0.0% n.c n.c

B-base 1 0.0% n.c n.c

B-A 1 0.0% n.c n.c

SEA2-SEA1 35 0.9% n.c n.c

SEA3-SEA2 0 0.0% n.c n.c

SEA3-SEA1 n.c n.c 40 1.2%

SEA4-SEA1 n.c n.c 46 1.4%

SEA5-SEA3 n.c n.c 17 0.5%

SEA5-SEA4 n.c n.c 10 0.3%

ASEA1-base -99 -2.6% n.c n.c

BSEA1-base -99 -2.6% n.c n.c

n.c - not calculatedCost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

149 Table 25: O3avg in 2015 (ppm.d.*Minh.)

inhabitants base SEA1 SEA2 SEA3 ASEA1 BSEA1 A B

AT Austria 7994855 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

BE Belgium 10065306 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2
BG Bulgaria 8392665 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

CH Switzerland 6994898 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2
CY Cyprus 437692 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

CZ Czech republic 10362569 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

DE Germany 81558728 2.0 2.0 2.0 2.0 2.0 2.0 2.0 2.0

DK Denmark 4714330 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

EE Estonia 1460788 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
ES Spain 36886896 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

FI Finland 4900677 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

FR France 56954432 1.5 1.5 1.5 1.5 1.5 1.5 1.5 1.5

GR Greece 9640492 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

HU Hungary 10213844 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

IE Ireland 3472169 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

IT Italy 56077436 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7

LT Lithuania 3684786 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

LU Luxembourg 404906 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

LV Latvia 2553183 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

MT Malta 326771 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

NL Netherlands 15059911 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

NO Norway 3874886 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

PO Poland 38535612 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

PT Portugal 9137149 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

RO Romania 22628702 0.7 0.7 0.7 0.7 0.7 0.7 0.7 0.7

SE Sweden 8315852 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

SK Slovakia 5318256 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

SL Slovenia 2023350 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

UK United kingdom 56343596 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1

EU27+2 478334737 12 12 12 12 12 12 12 12Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

150 Table 26: O3avg in 2020 (ppm.d.*Minh.)

Inhabitants base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4

AT Austria 7994855 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

BE Belgium 10065306 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2
BG Bulgaria 8392665 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

CH Switzerland 6994898 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2
CY Cyprus 437692 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

CZ Czech republic 10362569 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

DE Germany 81558728 2.1 2.1 2.1 2.1 2.1 2.1 2.1 2.1 2.1

DK Denmark 4714330 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

EE Estonia 1460788 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0
ES Spain 36886896 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

FI Finland 4900677 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

FR France 56954432 1.5 1.5 1.5 1.5 1.5 1.5 1.5 1.5 1.5

GR Greece 9640492 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

HU Hungary 10213844 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

IE Ireland 3472169 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

IT Italy 56077436 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7 1.7

LT Lithuania 3684786 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

LU Luxembourg 404906 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

LV Latvia 2553183 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

MT Malta 326771 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

NL Netherlands 15059911 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

NO Norway 3874886 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

PO Poland 38535612 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

PT Portugal 9137149 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3 0.3

RO Romania 22628702 0.7 0.7 0.7 0.7 0.7 0.7 0.7 0.7 0.7

SE Sweden 8315852 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

SK Slovakia 5318256 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2 0.2

SL Slovenia 2023350 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

UK United kingdom 56343596 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2

EU27+2 478334737 13 13 13 13 13 13 13 13 13Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

151 Table 27: Differences between scenarios and years f or O3avg (EU27+2 total)

2015 2020

abs (ppm.d.*Minh.) % abs (ppm.d.*Minh.) %

SEA1-base 0.008 0.06% 0.006 0.05%

SEA2-base 0.018 0.14% n.c n.c

SEA3-base 0.019 0.15% 0.023 0.18%

SEA4-base n.c n.c 0.027 0.21%

SEA5-base n.c n.c 0.023 0.18%

BSEA1-ASEA1 0.005 0.04% 0.008 0.06%

ASEA1-SEA1 -0.006 -0.05% -0.001 -0.01%

BSEA1-SEA1 -0.001 -0.01% 0.007 0.06%

A-SEA4-ASEA1 n.c n.c 0.014 0.11%

BSEA4-BSEA1 n.c n.c 0.010 0.08%

A-base -0.002 -0.02% n.c n.c

B-base 0.001 0.01% n.c n.c

B-A 0.003 0.02% n.c n.c

SEA2-SEA1 0.010 0.08% n.c n.c

SEA3-SEA2 0.001 0.01% n.c n.c

SEA3-SEA1 n.c n.c 0.017 0.13%

SEA4-SEA1 n.c n.c 0.021 0.17%

SEA5-SEA3 n.c n.c 0.000 0.00%

SEA5-SEA4 n.c n.c -0.004 -0.03%

ASEA1-base 0.002 0.02% n.c n.c

BSEA1-base 0.007 0.06% n.c n.c

n.c - not calculatedCost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

152 Table 28: Difference between 2015 and 2020 per effe cted area

SECA NS, B NS, B NS, B, MED,

BS NS, B NS, B

Baseline SEA1 SEA3 ASEA1 BSEA1

S-deposition abs -1300 -1955 -2546 -1887 -1689

% -2% -4% -5% -3% -3%

N-deposition abs -6140 -8297 -8266 -8278 -8237

% -3% -5% -5% -5% -5%

Acidification abs -61 -141 -141 -136 -126

% -4% -11% -11% -11% -10%

Eutrophication abs -2519 -2929 -2948 -2917 -2894

% -11% -13% -13% -13% -13%

PM10 abs -177 -223 -231 -222 -219

% -6% -8% -9% -8% -8%

AOT40f abs -277 -425 -420 -424 -424

% -7% -11% -11% -11% -11%Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

153 

# 17 Appendix 5 - Health Benefit Diagrams

SEA1 Scenario - 2015

SEA2 Scenario - 2015Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

154 SEA3 Scenario - 2015

AS1 Scenario - 2015Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

155 BS1 Scenario - 2015

SEA1 Scenario - 2020Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

156 SEA3 Scenario - 2020

SEA4 Scenario - 2020Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

157 SEA5 Scenario - 2020

ASEA1 Scenario - 2020Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

158 BSEA1 Scenario - 2020

ASEA4 Scenario - 2020Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

159 BSEA4 Scenario – 2020Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

160 

# 18 Appendix 6 - Methodology for cost

calculations

Scenario description The following parameters are specified in each scen ario: 1. Fuel use [PJ] 2. Implementation of Tier I, II, III NO X control technologies [% of fuel] 3. Sulphur control: * The sulphur content of fuel used, [mass % in fuel ] or * Implementation rate of new or retrofit scrubbers [% of vessels]

4. Costs for NO X and SO 2 control

Scenario background data specification

Scenarios : Baseline, SEA1, SEA2, SEA3, SEA4, SEA5 (see chapt er 6 for more info)

Years : 2015 and 2020 Sea regions : Baltic Sea

Black Sea

Mediterranean

North East Atlantic North Sea & English Channel

Vessel types : Ferry

Bulk carrier

Chemical tanker
Container ship General Cargo

LG tanker

Oil tanker
RoRo cargo

Engine types :
Abbreviation Description
SSD-MG/DO Slow Speed engines using Marine Diesel or Gas Oil
MSD-MG/DO Medium Speed engines using Marine Diesel or Gas Oil
HSD-MG/DO High Speed engines using Marine Diesel or Gas Oil
GT-MG/DO Gas turbines using Marine Diesel or Gas Oi l
ST-MG/DO Steam turbines using Marine Diesel or Gas Oil
SSD-RO Slow Speed engines using Residual Oil
MSD-RO Medium Speed engines using Residual Oil
HSD-RO High Speed engines using Residual Oil
GT-RO Gas turbines using Residual Oil
ST-RO Steam turbines using Residual OilCost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

161 Engine size classification : Main engine
Small Medium Large

range [kW] 0 - 6 000 6 000 - 15 000 15 000 -

Average ME size [kW] 3 000 10 000 25 000
SSD 2 share [%] 48 58 55
Auxiliary engine size
Small Medium Large
range [kW] 0 - 1 000 1 000 - 2 000 2 000 -
Average AE size [kW] 560 1 480 3 800

The engine size classification follows the engine s ize classification as specified in the ENTEC 2005
reports.

The distribution of the engine sizes relative to th e total fuel use is derived from ENTEC 2005 and is expressed as % of total fuel use.

Share of fuel used in respective engine size catego ry:
Small Medium Large

25% 41% 34%

Scenario specific parameters Fuels considered and sulphur content The following fuels are available for use in the sc enarios. The use of each fuel is scenario-specific and depends on whether the sea region is considered as a Sulphur Emission Control Area (SECA) in

the scenario. When scrubbers are used instead of lo w-sulphur fuel oils, a sulphur content of maximum 2.94 % is used for the region.

Fuel type Sulphur content Marine Diesel (MD) 0.5 %

MD 0.1 % Heavy Fuel Oils (HF) / Residual Oils (RO) 2.94 %

HF 1.5 %

HF 0.5 %

HF 0.1 %

Implementation of Tier I, II, III NO

x control technologies The implementation of Tier control technologies cor respond to the vessel vintages specified in

Extremis. In the cost estimates it is assumed that the age distribution will remain the same for the years 2005, 2015 and 2020.

For 2015 and all sea regions, the following impleme ntation rates of Tier technologies are obtained:

2015 Tier III Tier II Tier I 30 % Tier I No NO

x control

Ferry 0% 16% 28% 17% 39%

Bulk carrier 0% 20% 37% 13% 30%

Chemical tanker 0% 29% 44% 8% 19%
Container ship 0% 32% 46% 7% 16%
General Cargo 0% 7% 26% 20% 47%

LG tanker 0% 29% 44% 8% 19%

Oil tanker 0% 29% 44% 8% 19%
RoRo cargo 0% 16% 28% 17% 39%Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

162 For 2020 in sea regions considered as NO X -ECAs, the following Tier technology implementation rates

are obtained:

2020 NO X -ECA Tier III Tier II Tier I 30% Tier I No NO X control
Ferry 16% 16% 20% 15% 34%

Bulk carrier 20% 22% 27% 9% 22%

Chemical tanker 29% 23% 33% 5% 11%
Container ship 32% 29% 25% 4% 10%
General Cargo 7% 15% 22% 17% 39%

LG tanker 29% 23% 33% 5% 11%

Oil tanker 29% 23% 33% 5% 11%
RoRo cargo 16% 16% 20% 15% 34%

For 2020, in sea regions considered as outside NO X -ECA, the following Tier technology implementation rates are obtained:

2020 outside

NO X -ECA Tier III Tier II Tier I 30% Tier I No NO X control
Ferry 0% 32% 20% 15% 34%

Bulk carrier 0% 42% 27% 9% 22%

Chemical tanker 0% 52% 33% 5% 11%
Container ship 0% 61% 25% 4% 10%
General Cargo 0% 22% 22% 17% 39%

LG tanker 0% 52% 33% 5% 11%

Oil tanker 0% 52% 33% 5% 11%
RoRo cargo 0% 32% 20% 15% 34%

Sulphur control - scrubbers

In the calculations where SO 2 scrubbers are used instead of low-sulphur fuels, t he following implementation rates are obtained from considering the age distribution in Extremis The scrubber implementation rates takes into consideration wheth er retrofit is needed or if new installations are sufficient. The 'Retrofit' categories include the v essels constructed before 2011, while the 'New' category includes the vessels constructed after 201 1.

Scrubbers -new

and retrofits 2015 2015 2020 2020

Retrofit New Retrofit New
Ferry 84% 16% 68% 32%

Bulk carrier 80% 20% 58% 42%

Chemical tanker 71% 29% 48% 52%
Container ship 68% 32% 39% 61%
General Cargo 93% 7% 78% 22%

LG tanker 71% 29% 48% 52%

Oil tanker 71% 29% 48% 52%
RoRo cargo 84% 16% 68% 32%Cost benefit analysis to support the impact assessm ent AEA/ED 45756 /Issue 3 accompanying the revision of Directive 1999/32/EC o n the sulphur content of certain liquid fuels

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