Cost Benefit Analysis to Support the Impact Assessment 

accompanying the revision of Directive 1999/32/EC on the 

Sulphur Content of certain Liquid Fuels 

Final Report 

 

 

 

Report to European Commission

ED45756 

Issue 3 

 23rd December 2009 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

ii 

Title Cost Benefit Analysis to support the impact assessment accompanying the 

revision of Directive 1999/32/EC on the sulphur content 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 Service Request ENV 

C5/GK/em/Ares (08) 36661 Under framework contract No – 

ENV.C.5/FRA/2006/0071 between the Commission and AEA Technology. 

File reference AEA/ED45756/Issue 3 

 

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 AEA Technology plc is certificated to ISO9001 and ISO14001 

Authors Name Peter Bosch, Peter Coenen (TNO), Erik Fridell, Stefan 

Åström (IVL), Tom Palmer (AEA Technology), Mike 

Holland (EMRC) 

Approved by Name Mike Woodfield (AEA) 

 Signature 

 Date 23rd December 2009 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

iii 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 of 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 assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 SO2 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 assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

vi 

17 Appendix 5 - Health Benefit Diagrams 153

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

accompanying the revision of Directive 1999/32/EC on 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 Content of certain Liquid Fuels. 

Maritime activities constitute a significant fraction of anthropogenic emissions of air pollutants in Europe. 

International shipping in the EU is expected to increase in the coming decade and there is a risk that

this will offset the effects of the current emission reduction legislation for maritime activities and the 

future emissions will surpass the target levels established by the European Commission in its Thematic

Strategy on Air Pollution for land based sources. 

A number of ongoing developments will lead to reductions in emissions of sulphur oxides (SOx) and 

nitrogen oxides (NOx). In this report the effect of these developments is determined in order to inform the 

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

fuels. 

This study has examined the effects of emission reduction measures (for the years 2015 and 2020) in 

maritime activities by: 

1. Analysing the benefits of: the new IMO marine fuel and engine standards (SO2 and NOx

reduction respectively), and the potential extensions of emission control areas. The benefits of 

different scenarios have been evaluated against a revised 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 respect to a baseline scenario for emissions, 

air quality (concentrations) as well as their impact on human health. 

2. Calculating the costs of emission reductions that result from the new IMO marine fuel and 

engine standards and the potential extension of emission control areas. 

3. Assessing the effects, costs, risks and technical requirements that are associated with the use 

of emission abatement equipment and steam boilers by 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 English Channel SECAs (20151 and 20202 3) 

• Inclusion of Mediterranean as a SECA (2015) 

• Inclusion of the Black Sea as a SECA (2015 and 2020) 

• Reduction of land based sources4 by reduction of the S-content in gasoil to 0.05 % (2015 and 

2020) 

• Reduction of land based sources by reduction of the S-content in gasoil to 0.001 % (2015 and 

2020) 

For each scenario the emissions of relevant air pollutants 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 emission reduction using the methods developed in the 

CAFE and EC4MACS studies for EC DG-ENV. 

Cost analysis 

The cost calculations for NOX and SO2 abatement from shipping in this report contain two parts. The 

first consists of calculating unit costs (per PJ) for each abatement option under consideration, the 

second the calculation of scenario specific costs based on the penetration of the low-NOX and low-SO2

 

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

2 In all 2020 marine scenario’s Tier I - III for NOx reduction is assumed simulating the designation of the Baltic Sea , 

North Sea , the English Channel and the Mediterranean as NECA 

3 For 2020 also scenario’s are elaborated with a reduced S content (0,5 %) in marine fuels used outside the SECA 

4 Only for heating in households and agriculture 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 2 

technology options. The calculations allow for scenario comparison and comparison of alternative 

technologies to reach the required standards. 

For each scenario, costs are calculated, specifying high and low costs for NOX and SO2 abatement. For 

SO2 abatement, separate cost calculations are presented 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 following 

tables - taking the results directly from the analysis. The low bound for costs is the lower estimate for 

fitting a scrubber to reduce SO2 emissions together with the costs of NOx control. The upper bound for 

costs is for the high estimate for using low sulphur fuels to reduce SO2 emissions and the costs of NOx 

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, giving the upper bound) to value mortality. 

In all cases there is no overlap between the estimates for costs and benefits as shown above, indicating 

that for all scenarios benefits would exceed costs.. 

Further analysis was undertaken to assess the effect of further uncertainties on the balance of costs 

and benefits. This found that the probability of benefit exceeding cost can be described as very likely / 

virtually certain, using terminology developed by the Intergovernmental Panel on Climate Change 

(IPCC). With one slight exception (the last 2020 scenario: All European seas Included in the SECA and 

reduced S-content outside the SECA ) the probability of benefits exceeding costs can be described as 

likely, very likely or virtually certain even for worst case assumptions on cost. 

It is to be remembered that the probabilities calculated here are quantified only against benefits for

improved health. The inclusion of impacts to materials (including cultural heritage) and ecosystems, in 

particular, would add to the benefits and further increase the already high probabilities. Taking these 

issues together it is concluded that more detailed assessment of the limitations of the analysis finds that 

the initial conclusion, that benefits of the proposed 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 36
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 3 

Comparison of the benefits of the land based scenarios against the maritime scenario (Baltic Sea , 

North Sea and the English Channel as SECAs) shows that 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 emissions of sulphur dioxide from ships is an 

alternative to reduced S content in marine fuels. The only technology available at present is scrubbing. 

Scrubber units can be of two kinds, seawater scrubbers and closed scrubbers, or a combination of two. 

The use of scrubbers to clean the exhaust from marine engines using residual oil could in principle lead 

to high concentrations of a number of harmful compounds in the marine environment around the ships. 

The present situation is somewhat incongruous in the sense that washwater limits for scrubbers are set

by IMO while there still are no limits for the gaseous exhaust (except for SO2 and NOX). It is 

recommended that criteria are developed that promote the abatement of PM. At least the levels of PM 

reduction should be established to allow for voluntary 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 for PAH, pH, turbidity and nitrates. Of these all except 

the nitrate criterion are intended for continuous monitoring onboard the ship. A major factor when 

formulating the criteria is that they should be possible to monitor online. However, it would also be 

possible to add more criteria that are to be tested during certification. This could give further assurance 

that the units are environmentally safe and would not be constrained by the possibility to measure 

online in a simple way. 

With the present criteria for pH it seems as if dilution and buffering in the sea will rapidly give acceptable 

levels. Even in confined areas it is likely that the effect is limited. However, it is recommended that 

further studies are undertaken for brackish and river water and that the criteria then are reviewed. It is 

suggested that the IMO guidelines are adopted for the 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 emissions 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 appropriate to monitor PM reduction because there is no 

relation between particle concentration and turbidity. 

It is recommended that the concentrations of particulate matter, metals, and PAH are regulated and 

tested during commission, and, further, that the correlation to turbidity is investigated in order to have 

continuous measurement available onboard. 

The present criteria for nitrates could in principle lead to large additional contributions of nitrates to 

sensitive areas. The best way to deal with this issue is to use abatement technology for NOX 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 regarding monitoring, i.e., allowing for the possibility of 

not using continuous monitoring of the SO2 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 marine scrubbers for SO2. It is important to follow the 

trials taking place and make sure that thorough environmental impact assessments are conducted in 

order to evaluate and develop the washwater criteria. 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 necessary to use distillate fuel while at berth. There are 

concerns that there are risks associated with switching from residual oil to distillate fuel in boilers. 

One can state that there are real safety concerns with switching from HFO to MGO in existing boilers. 

The main safety concern is that a distillate fuel may vaporise in hot boilers with heated pipes. If the 

boiler system has not been modified, there is—in the case of flame failure and improper handling— an 

explosion risk. Although many boilers can be used with 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 used for space heating is use of the latent heat of the 

water vapour in the exhaust gases. This increases the fuel efficiency and therefore decreases the CO2

emission by 6% compared to conventional boilers. Because the flue gases are cooled down below the 

dew point, condensation will occur on the heat exchanger in the boiler and using heating oil will cause 

an acidic (and thus corrosive) condensate. It is suggested that this phenomena sets limits for the 

maximum sulphur content of heating oil to be used in 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 conventional boilers. Using low sulphur oil will prevent this. 

Furthermore are there no technical obstacles which prevent the use of low sulphur heating oil in 

condensation boilers designed for “standard” heating oil. 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 5 

2 Introduction 

Maritime activities constitute a significant fraction of anthropogenic emissions of air pollutants in Europe. 

In 2000, SO2 and NOx emissions from international maritime shipping in Europe amounted to 

approximately 30 percent of the land based emissions 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 these measures and will lead to further growth in ship 

emissions. Under business-as-usual assumptions, by 2020, emissions from maritime activities would 

come close to the projected baseline emission levels from land based sources and surpass the target 

levels established by the European Commission in its Thematic Strategy on Air Pollution for land based

sources. 

This anticipated increase in ship emissions will counteract the envisaged benefits of the costly efforts to 

control the remaining emissions from land based sources in Europe. While at present emissions from 

ships are responsible for 10 to 20 percent of sulphur deposition in coastal areas, their contribution is 

expected, by 2020, to have increased to more than 30 percent in large areas in Europe, and up to 50 

percent in coastal areas. 

Analysis by IIASA in 2007 demonstrated that limiting air pollution from shipping reduces the necessity to 

further control emissions from land based sources and provides important cost savings in achieving air

quality targets in Europe. 

A number of ongoing developments will lead to reductions in emissions of sulphur oxides (SOx) and 

nitrogen oxides (NOx), these include: 

• Annex VI of MARPOL and the Technical Code on Control 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 formally 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 (MARPOL) 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 Channel. Article 7 of Directive 1999/32/EC 

requires the Commission to give consideration to proposals for the addition of SECAs. 

• The possibility that European institutions will designate 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 the 

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

fuels. 

This study has examined the effects of emission reduction 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 benefits of different scenarios have been 

evaluated against a revised NECD 2008 baseline scenario. All existing and foreseeable 

Community and national measures were taken into account, 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 major Member State economies in the second 

half of 2009) and that the economy will subsequently evolve as was expected before the crisis. 

The benefits were quantified with respect to the baseline scenario for emissions, air quality 

(concentrations) as well as the impact on human health. 

• Calculating the costs of emission reductions that result from the new IMO marine fuel and 

engine standards and the potential extension of emission control areas. 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 by ships as well as the use of 

condensation boilers for heating purposes. 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 7 

3 Methodology 

3.1 Overview of methods 

 In general terms the cost benefits analysis consists of the different steps illustrated in figure 3.1. 

Figure 3.1 Flow scheme for the cost benefit analysis 

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 developed. All other policy scenarios will be compared to this 

baseline. The emissions of SO2, NOx, PM, CO and NMVOC for these scenarios are calculated and fed 

into the dispersion model. The scenario descriptions and emission estimates are given in section 4. The 

most relevant parameters for the dispersion modelling are given in section 5. The assessment of the 

benefits is elaborated in section 6 and section 7 describes the cost calculations for the emission 

reduction. In section 8 a comparison is made between costs and benefits based on the results of the 

two previous sections. 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 for 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 decision 

phase of European Institutions. It includes: 'Current legislation' in all sectors plus: revision of the IPPC 

Directive for large stationary combustion sources in 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 and 19 (Amman et al, 2008). 

As the NEC6 scenarios do not fully cover international shipping (they contain national maritime fuel 

consumption but not international bunkering) a separate baseline has been developed for international 

shipping. The starting point for the fuel consumption of international shipping is the 2000 fuel 

consumption - from Cofala et al. 2007 (page 11). The fuel consumption is given by fuel type (MD/HF), 

vessel type (cargo/ferry) and regional sea. It is based on the 2000 inventory of emissions produced by

ENTEC, which is in itself based on a detailed analysis 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 model 

(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 from 

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 year, while use of MD decreases with 0.5% per year 

We have also used the outcomes of the Ex-tremis baseline 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 (Chiffi et al., 2007). Assuming, however, that the 

developments in transport and developments in the fleet in EU and outside EU will run in parallel, it is 

possible to apply the distribution of ship types (bulk carrier, tanker, containership, general cargo, etc.), 

and engine class (gas turbine, high speed diesel, medium speed diesel, slow speed diesel, steam 

turbine) in each of the years to the regional fuel consumption for international shipping in 2010, 2015 

and 2020. 

Emission factors have been added by detailed ship-classification and by regional sea. The baseline is 

a reference scenario and does not include any policies - it is based on fixed emissions factors and, for 

instance, does not include the 1997 IMO protocol, introducing Tier I for ships built after 2000 and which 

took effect in 2005. Neither does it include the Tier 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 larger 

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 baseline outside SECAs is 2.70% (according to TFEIP, 

2009), which is the current worldwide average. Inside SECAs it is 1.45% representing the present 

regulation of 1.5%. This is used to be able to illustrate 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 been adapted from Cooper and Gustafson (2004) and 

have been chosen according to the sulphur content of 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 scrubbers, we have not introduced a detailed calculation 

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 calculation of the sulphur emissions the way emissions 

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

accompanying the revision of Directive 1999/32/EC on 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 Section 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 given in Table 4.1a. 

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

2000 2020 

Sea area SO2 NOx

NMV

OC PMtotal SO2 NOx

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 was used to distribute the emissions per sea 

area to generate the gridded data needed for the dispersion 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 or less comparable to those in Cofala et al. (2007).

Differences, however, are caused by the split in ship types we have introduced by using Ex-tremis, 

which brings about a split in HF and MD that differs from the split used by Cofala et al. (2007). Further 

differences are brought about by the larger differentiation in emission factors for NOx, 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 shipping according to Cofala et al, 2007, 2000 and 

2020 

2000 2020 

Sea area SO2 NOx

NMV

OC PM2,5 SO2 NOx

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 assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 critical comparison of the effects of policy measures 

that restrict emissions by: 

• The (already decided) designation of the Baltic and 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 fuels outside designated SECA areas to 

0.5% 

• Application of the IMO Tier I and Tier II standards 

• Designating the Baltic, the North Sea/English Channel and the Mediterranean as NOx emission 

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

Additionally, two scenarios for decreasing the emissions 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 Table 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) 

NOx 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 with reduced emissions for land based emissions 

Land 

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

Land 

based 

B 

2015 0.001 % S in MD and Gasoil for use by Consumers and Agriculture 

(Bbase and BSEA1) 
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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) 

NOx Tier 

Standards SECA regions 

Baseline 2020 2.7 % 1.45% Baseline scenario (Task A1) 

SEA1 2020 2.94% 0.10% Tier I & II,& III1) 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 emissions for land based emissions 

Land 

based A 2020 0.05 % S in MD and Gasoil for use in Consumers and Agriculture (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, North Sea/English Channel and the Mediterranean Sea (Tier 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. For 

example, the comparison of SEA1 with SEA2 illustrates the impact of designating the Mediterranean 

Sea as SECA, the comparison of SEA1 with SEA3 illustrates the impact of designating the 

Mediterranean Sea and the Black Sea as SECA, the comparison of SEA2 with SEA3 illustrates the 

additional impact of designating the Black Sea as SECA, etc. 

4.2.2 SEA1 

The SEA 1 scenario uses the baseline for the land based 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 the 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 sulphur 

fuels for use in the SECAs will lead to a shift towards high sulphur fuel outside SECAs; a rough 

estimate, based on the worldwide fuel consumption in 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 revised5 IMO standards have been used for the NOx 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 the 

world merchant fleet by type of vessel as of 1st January 2005 (Source: Chiffi et al 2007, Technical 

 

5

 Revised Annex VI of MARPOL and the revised NOx Technical Code adopted in October 2008, these will enter into force 1 July 2010. 
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AEA 12 

Annex, Maritime Transport Inventory, Table 2.5). In the absence of better data it has been assumed that 

the age distribution will not change over the period up to 2020. 

Ships constructed on or after 1 January 1990 but prior to 1 January 2000 (and with a displacement ≥ 90 

litres per cylinder and rated output ≥ 5000 kW) will be required to comply with the NOx emission limits in 

force today, subject to the availability of approved 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 ships 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 designation 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 comparison to SEA2. In the scenario run for 2020 

it is additionally assumed that the Baltic Sea, the North Sea/English Channel and the Mediterranean will 

be designated as NOx Emission Control Areas, in which Tier III standards apply. 

4.2.5 SEA4 

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

outside SECAs has been reduced to 0.5%. For the rest SEA4 is comparable to the 2020 run of SEA1, 

with only the Baltic and the North Sea/English Channel designated as SECAs and the Baltic, the North 

Sea/English Channel and the Mediterranean Sea designated as NOx Emission Control Areas. 

4.2.6 SEA5 

The SEA5 scenario is the most advanced scenario: The 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 maximum sulphur content of 0.1% only. The Baltic 

Sea, the North Sea/English Channel and the Mediterranean Sea have been designated as NOx

Emission Control Areas, implying IMO Tier III standards. 

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 fuels, also covers medium distillates and gasoil used in 

small scale combustion on land. Combustion in industry falls under the large combustion plants directive 

(Directive 94/66/EC). The current limit for gasoil in the fuel quality directive is a sulphur content of 0,10 

% (since 1 January 2008). Scenario Land based A assumes 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 necessary to mention that this reduction only has been 

applied for the EU27 countries only. 

The LandA scenario has been combined with the baseline sea emissions (ABASE) and the SEA1 

scenario (ASEA1). 

4.2.8 Land based B 

The Land based B scenario takes the reductions a step 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 most stringent sea scenario SEA4 (BSEA4). 

 

6 This results in a conservative estimate of the NOx emissions
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4.2.9 SO2 emissions in the different scenarios 

The emission figures for SO2 in the different areas and scenarios as calculated in this study are 

summarised in the Tables 4.4.and 4.5. Appendix 2 gives the detailed emission figures for all scenarios 

all areas and all pollutants. 

Table 4.4 Sulphur dioxide emissions, 2000-2020, all 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 is 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 sources, 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 maritime fuel consumption (e.g. fisheries), which are included in the GAINS-totals 

Source: GAINS Europe, NEC6, C&E package current policy 
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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 emissions, and their effect on the European distribution of 

sulphur- and nitrogen deposition, and on ground-level 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 (~30x30 km). In vertical direction it extends to 2-3 km above 

the surface resolved in four layers: a planetary boundary layer with a fixed surface layer of 25 metre

height, and two reservoir layers on top of the planetary 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 diffusion 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 NOx and SO2; in addition 1997 was put forward by TNO 

(and supported by a.o. EMEP) as a year which represents an average atmosphere over Europe. 

Dry deposition is described via a multiple serial and parallel resistance approach (surface-to-air, laminar 

and turbulent resistance) and wet deposition is described 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, acidification, eutrophication and aerosols. 

Anthropogenic emissions of 7 species (NOx, SO2, NMVOC, CH4, PM10, PM2.5 and NH3) are based on 

Gains Europe (NEC report Nr. 6). Emissions of the remaining component CO come from TNO’s own 

emission database. Furthermore, the model accounts for natural emissions from trees (isoprene, 

terpene), and from soil (NOx). 

The standard output (on an hourly basis)7 is generated as a longitude-latitude grid which was 

subsequently converted into the EMEP grid. Ecosystem burden is expressed in terms of the sulphur and 

nitrogen deposition and the average accumulated exceedence (AAE) for acidification and 

eutrophication. The model also delivers: concentrations of primary PM10 and PM2.5 and secondary 

species as sulphate, nitrate and ammonium; concentrations of ground-level ozone are expressed in the 

four ozone metrics - AOT40c, AOT40f, SOMO35 and annual mean. 

The results of this modelling exercise will be discussed in the next paragraphs. Emphasis is laid on the 

comparison between the baseline results and the specific scenarios and the difference between the 

scenarios and changes between 2025 and 2020. 

The most relevant results in terms of geographic distribution over Europe for the exceedence of critical 

loads for eutrophication and acidification, the distribution of ozone and PM10 are presented in maps in 

 

7 The model has been used in several model inter-comparison studies and it shows a good performance (Roemer et al., 

2003; van Loon et al., 2004). It was used in earlier studies on SO2 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 compared 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 PM10 concentrations in LOTOS-EUROS are about a factor of two lower than the measured values. Underestimation 

of PM10 values is a common problem for nearly all large scale models. The problem occurs with the primary PM10 

concentrations (the part of PM10 that is emitted directly). Quite a good comparison with measurements is seen for 

secondary PM10 (sulphate, nitrate). 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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AEA 15 

appendix 3. Appendix 4 includes tables of the dispersion calculations aggregated to the different EU 

member states. 

5.2 SEA1 

The main feature of this scenario is the lowering of the sulphur content in the Baltic and the North 

Sea/English Channel SECAs, and the implementation of 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 vulnerable 

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 to 100%) whereas the reduction for inland areas 

is10-20%. In 2020, compared with 2015, acid deposition has further decreased, due to lower NOx

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 NOx emissions decrease in all European seas, 

resulting in a similar decrease of eutrophication all over Europe (0-10%). Larger fractional reductions 

are apparent in those coastal zones of the Mediterranean where shipping is a major source of NOx 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 Mediterranean. 

Both in 2015 and 2020, the concentrations of PM10 are reduced by 20-30% (in the coastal areas around

the North Sea, English Channel and Baltic Sea). 

PM10 concentrations in the northern part of Europe decrease by up to 10 % but in the Mediterranean 

region PM concentrations rise as a result of increasing, uncontrolled, sulphur emissions. The increase in 

sulphur emissions (as sulphate) outweighs the simultaneous decrease in NOx (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 NOx emissions due to the introduction of IMO Tier I and II in a NOx rich 

environment. Similar trends in modelled ozone response to a limited decrease of NOx emissions are 

seen in urban environments and other NOx rich conditions over land. In the Mediterranean, where NOx

concentrations are much lower, the reduction in NOx 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 but less so in the North Sea because of the higher 

ambient NOx concentration. 
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AEA 16 

5.3 SEA2 (applies only to 2015) 

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

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

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

because maritime NOx emissions here are a larger determining factor of ambient concentrations of NOx. 

The reduction of PM10 concentrations in the Mediterranean area is also considerable; on shipping routes 

in the southern part of the Mediterranean Sea reductions up to 70% are seen whereas the 

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

20 %. 

As a result of the significant reduction of SO2 emissions, compared to SEA 1, the ozone concentrations 

in the whole Mediterranean area (land and sea) increase slightly (see difference between the following

maps) as the result of heterogeneous chemistry in which sulphur reduction causes a slight increase of 

nitrogen oxides through the formation of additional N2O5. 
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5.4 SEA3 

2015 

SEA3, by comparison with SEA2, assumes that the Black Sea is also designated as a SECA. Although 

this results in a relatively minor additional emission reduction in Europe as a whole, and a negligible 

effect in Western Europe states, the reductions in exceedance of critical loads for acidification and 

eutrophication in areas close to the Black Sea (Romania and Bulgaria) is significant (up to 30% in some 

grid cells). 

Reduction of PM10 is only significant over the sea and apart from a small reduction in PM10

concentrations in Bulgaria it has a very small effect over the land. The ozone effect is also small and 

resembles that of SEA2 on the Mediterranean area; the Black Sea, however, is much smaller and the 

rise in ozone concentration more limited. 

2020 

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

Mediterranean Sea and the Black Sea. The effects are quite comparable to the effects of the two 

separate reductions combined as discussed under SEA2 and SEA3 (2015). 

5.5 SEA4 (2020 only) 

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

content of fuels used outside SECAs to 0.5%. In SEA4 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 sulphur 

emissions in these areas as compared to SEA1 scenario. 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 Sea has little effect in reducing the exceedance of 

acidification due to the location and distance of sensitive ecosystems. 

For eutrophication the benefits of SEA4 (as compared to SEA1) are relatively small since NOx

emissions stay the same. 

PM10 concentrations are lowered as a result of the PM10 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 there is a slight increase in the ozone (NOTE: this 

phenomenon was described under SEA2). 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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5.6 SEA5 (2020 only) 

In SEA5, apart from the lower sulphur content outside SECAs, the Baltic, the North Sea/English 

Channel, the Mediterranean and the Black Sea have been assumed to be SECAs, resulting in a further 

reduction of sulphur and PM emissions. 

Of all the sea-based scenarios SEA5 yields the least exceedance of acidification and eutrophication and 

the lowest PM10 concentrations. The ozone related parameters are slightly 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 this 

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 eutrophication is really very small, less than 0.5%; the PM10

concentrations drop about 1% (as a result of less sulphate formation and less direct PM emissions), and 

the effects are negligible for ozone related parameters.

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 Scenario 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%; PM10 concentrations drop 

by about 2% (less sulphate and less direct PM emissions), 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 scenarios compared to the SEA1 and SEA4 scenarios 

(without additional land based measures) are as small as the effects of the A and B scenarios in relation 

to the baseline (as discussed in the previous section). 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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6 Benefits assessment 

The objective of this stage of the study is to quantify the health benefits of the scenarios described

above in terms of reduced impact, and then to monetise 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 would 

be appropriate to expand the analysis to bring in other effects such as those on building materials and 

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 the 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 Pollution. The input data for the ALPHA2 programme 

are the outcomes of the dispersion modelling reported in Chapter 5. 

6.2 Methodology 

The CAFE CBA methodology was described in three volumes (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 continually since. Further to this, the methodology used 

here was the subject of intense consultation in 2003 and 2004 with stakeholders from the European 

Union Member States, academic institutes, environment agencies, industry and non-governmental 

organisations. It was also subject to formal peer review by senior experts in the USA and Europe (the 

peer review report is available at the above website). Further work to refine the model is being carried 

out under the LIFE+ Programme’s EC4MACS Project9 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 valuation. 

 

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

9

 http://www.ec4macs.eu/home/reports/Interim%20Methodology%20Reports/4_BenefitsAssessment_task_8.pdf 
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Figure 6.1. Impact Pathway Approach, illustrated with the example of the effects of emissions of NOx and 

VOCs on ozone concentrations and crop yield 

Impacts are generally calculated as: 

Impact = Pollution x Stock at risk x Response function 

Pollution may be expressed in terms of concentration or deposition. The term ‘stock at risk’ relates to 

the amount of sensitive material (people, ecosystems, materials, etc.) present in the modelled domain.

For the health impact assessment account is taken of the distribution of population and of effects on 

demographics within the population, such as children, the elderly, or those of working age. Incidence 

rates considered representative of the rate of occurrence 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 and 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 applying only the ‘core’ set of functions, reserving the 

‘sensitivity’ set for the situation in which it could be found that ‘core’ benefits do not exceed costs. 

Valuation is performed as follows: 

Economic damage = Impact x Unit value of impact

Unit values seek to describe the full economic effect of the impacts that they are linked with. For health 

impacts, for example, which dominate the analysis, this will include elements associated with the costs 

of health care, lost productivity amongst workers and aversion to premature death or ill health. 

A more complete account of the methods used for health impact quantification is provided in Volume 2 

of the CAFE methodology (Hurley et al, 2005), though the valuation data used here have been revised 

for the current study drawing on information from the 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 of 

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 linked to pollution exposure using the value of 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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AEA 21 

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

both VOLY and VSL estimates to demonstrate sensitivity on this issue. 

There are two main differences between the values shown and those used in the CAFE-CBA work. 

First, values have been increased in line with prices for the period 2000 to 2005, reflecting the different 

price years used in this work compared to CAFE. Second, the value of a life year (VOLY) has been 

reduced from €52,000 to €40,000 reflecting the results of the recent NEEDS study for EC DG Research. 

The result of the NEEDS work may be preferred for several 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 states (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 individual estimates of willingness to pay) and so could be

adopted as the best estimate of VOLY. In the earlier NewExt study (the basis of the previous estimate of 

€52,000 per VOLY), in contrast, the mean was not stable, and so two estimates of the VOLY, 

representing the mean and the median of the study population, were adopted. Use of a single estimate 

clearly simplifies the analysis. A problem in basing the VOLY purely on the results of the NEEDS project 

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, though it is currently likely that it will seek to 

account for both the NewExt and NEEDS results. Basing the present analysis only on the NEEDS result 

leads to a lower estimate of benefits, making it less 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 of 

costs and benefits in Chapter 7: a prolonged discussion here of whether or not a higher value should be 

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 wider 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 unit values applied in this analysis.

Impact / population group Pollutant Unit value (€)

Acute Mortality (All ages) O3 40,000

Respiratory Hospital Admissions (65yr +) O3 2,364

Minor Restricted Activity Days (MRADs 15-64yr) O3 42

Respiratory medication use (adults 20yr +) O3 1

Chronic Mortality (30yr +) - as life years lost PM2.5 40,000

Chronic Mortality (30yr +) as premature deaths PM2.5 1,130,000

Infant Mortality (0-1yr) PM2.5 1,695,000

Chronic Bronchitis (27yr +) PM2.5 208,000

Respiratory Hospital Admissions (All ages) PM2.5 2,364

Cardiac Hospital Admissions (All ages) PM2.5 2,364

Restricted Activity Days (RADs 15-64yr) PM2.5 97

Respiratory medication use (children 5-14yr) PM2.5 1

Respiratory medication use (adults 20yr +) PM2.5 1

Lower Respiratory Symptom days (children 5-14yr) PM2.5 42

Lower Respiratory Symptom among adults (15yr +) with chronic symptoms PM2.5 42

Uncertainties are of course present in all inputs to the analysis. Particularly important are those relating 

to the response functions used and the valuation data. These are accounted for later in the analysis 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 information in preceding chapters. Impacts in terms of 

the change in incidence of ill health, loss of longevity, etc. are shown Table 6.3 for 2015 and in Table 

6.4 for 2020. 

Estimates of monetised morbidity and mortality impacts 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 dominated by PM mortality, although PM related 

morbidity is also significant. The most important effects (in monetised terms) for PM related morbidity 

are restricted activity days and cases of chronic bronchitis. 

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 2020 
Cost benefit analysis to support the impact assessment AEA/

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

AEA 

Table 6.3. Estimated annual health impacts in 2015 due to air pollution in the EU27 

End point Population at risk Impact Pollutant base_2015 Sea1_2015 Sea2_2015 Sea3_2015 abase1_2015 as1_2Acute Mortality (All ages) All Premature deaths O3 22,368 22,047 22,153 22,153 22,366 2Respiratory Hospital Admissions (65yr +) Elderly Cases O3 19,078 18,801 18,891 18,891 19,075 Minor Restricted Activity Days (MRADs 15-64yr) Adults Days O3 48,756,183 48,054,241 48,283,256 48,283,081 48,749,473 48,06Respiratory medication use (adults 20yr +) Adults Days O3 8,920,808 8,791,789 8,834,138 8,834,103 8,919,611 8,79Chronic Mortality (All ages) All Life years lost PM2.5 2,153,682 2,032,021 1,979,544 1,977,795 2,147,341 2,02Chronic Mortality (30yr +) Infants Premature deaths PM2.5 221,810 209,851 204,017 203,810 221,164 20Infant Mortality (0-1yr) Adults Premature deaths PM2.5 362 344 337 336 361 Chronic Bronchitis (27yr +) All Cases PM2.5 105,552 99,769 97,096 97,007 105,244 9Respiratory Hospital Admissions (All ages) All Cases PM2.5 35,800 33,777 32,905 32,876 35,694 3Cardiac Hospital Admissions (All ages) Adults Cases PM2.5 22,079 20,832 20,294 20,276 22,014 2Restricted Activity Days (RADs 15-64yr) Children Days PM2.5 195,942,769 184,937,515 180,227,493 180,058,414 195,373,880 184,34Respiratory medication use (children 5-14yr) Adults Days PM2.5 1,813,697 1,702,016 1,660,289 1,659,437 1,808,029 1,69Respiratory medication use (adults 20yr +) Children Days PM2.5 17,371,218 16,406,775 15,976,148 15,961,648 17,320,399 16,35LRS symptom days (children 5-14yr) Adults Days PM2.5 81,377,920 76,544,732 74,661,618 74,603,414 81,132,661 76,29LRS among adults (15yr +) with chronic symptoms All Days PM2.5 173,956,597 164,208,588 159,928,445 159,785,506 173,446,398 163,67

Note: Results are rounded to the nearest 100. 
Cost benefit analysis to support the impact assessment AEA/

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

AEA 

Table 6.4. Estimated annual health impacts in 2020 due to air pollution in the EU27 

End point Population at risk Impact Pollutant base_2020 Sea1_2020 Sea3_2020 Sea4_2020 Sea5_2020 as1_2020 as4Acute Mortality (All ages) All Premature deaths O3 22,244 21,417 21,539 21,567 21,598 21,418 Respiratory Hospital Admissions (65yr +) Elderly Cases O3 21,059 20,272 20,387 20,413 20,442 20,273 Minor Restricted Activity Days (MRADs 15- 64yr) Adults Days O3 45,487,097 43,798,565 44,045,892 44,109,754 44,173,452 43,800,727 44Respiratory medication use (adults 20yr +) Adults Days O3 8,722,895 8,398,086 8,445,792 8,457,617 8,469,909 8,398,511 8Chronic Mortality (All ages) All Life years lost PM2.5 2,006,114 1,844,775 1,784,037 1,766,272 1,756,678 1,839,089 1Chronic Mortality (30yr +) Infants Premature deaths PM2.5 213,937 197,499 190,441 188,774 187,660 196,898 Infant Mortality (0-1yr) Adults Premature deaths PM2.5 316 293 285 282 281 292 Chronic Bronchitis (27yr +) All Cases PM2.5 101,238 93,329 90,158 89,302 88,801 93,046 Respiratory Hospital Admissions (All ages) All Cases PM2.5 33,347 30,665 29,655 29,360 29,200 30,570 Cardiac Hospital Admissions (All ages) Adults Cases PM2.5 20,566 18,912 18,289 18,107 18,009 18,854 Restricted Activity Days (RADs 15-64yr) Children Days PM2.5 176,608,196 162,476,303 157,154,649 155,558,842 154,718,078 161,982,356 155Respiratory medication use (children 5- 14yr) Adults Days PM2.5 1,558,598 1,422,846 1,379,585 1,362,086 1,355,244 1,418,167 1Respiratory medication use (adults 20yr +) Children Days PM2.5 16,466,061 15,161,445 14,654,192 14,512,750 14,432,597 15,115,158 14LRS symptom days (children 5-14yr) Adults Days PM2.5 70,418,108 64,527,840 62,543,893 61,835,829 61,523,051 64,323,547 61LRS among adults (15yr +) with chronic symptoms All Days PM2.5 163,596,876 150,535,695 145,515,226 144,094,510 143,301,342 150,073,885 143

Note: Results are rounded to the nearest 100. 
Cost benefit analysis to support the impact assessment AEA/

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

AEA 

Table 6.5. Monetised annual health impacts under each scenario in 2015 in the EU27 (€billion) 

End Point Poll BASE_2015 SEA1_2015 SEA2_2015 SEA 3_2015 AS1_2015 BAcute Mortality (All ages) O3 0.89 0.88 0.89 0.89 0.88 Respiratory Hospital Admissions (65yr +) O3 0.05 0.04 0.04 0.04 0.04 Minor Restricted Activity Days (MRADs 15-64yr) O3 2.05 2.02 2.03 2.03 2.02 Respiratory medication use (adults 20yr +) O3 0.01 0.01 0.01 0.01 0.01 Total O3 Mortality 3.00 2.95 2.97 2.97 2.95 Chronic Mortality (30 yr+) VOLY valuation PM2.5 86.15 81.28 79.18 79.11 81.02 Chronic Mortality (30yr +) VSL valuation PM2.5 250.65 237.13 230.54 230.31 236.37 Infant Mortality (0-1yr) PM2.5 0.61 0.58 0.57 0.57 0.58 Chronic Bronchitis (27yr +) PM2.5 21.95 20.75 20.2 20.18 20.69 Respiratory Hospital Admissions (All ages) PM2.5 0.08 0.08 0.08 0.08 0.08 Cardiac Hospital Admissions (All ages) PM2.5 0.05 0.05 0.05 0.05 0.05 Restricted Activity Days (RADs 15-64yr) PM2.5 19.01 17.94 17.48 17.47 17.88 Respiratory medication use (children 5-14yr) PM2.5 0.002 0.002 0.002 0.002 0.002 Respiratory medication use (adults 20yr +) PM2.5 0.02 0.02 0.02 0.02 0.02 LRS symptom days (children 5-14yr) PM2.5 3.42 3.21 3.14 3.13 3.2 LRS among adults (15yr +) with chronic symptoms PM2.5 7.31 6.9 6.72 6.71 6.87 Total PM damage (low, VOLY valuation) 139 131 127 127 130 Total PM damage high, VSL valuation) 303 287 279 279 286 Total PM+O3 damage high, VSL valuation) 142 134 130 130 133 Total PM+O3 damage (low, VOLY valuation) 306 290 282 281 289 
Cost benefit analysis to support the impact assessment AEA/

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

AEA 

Table 6. 6. Monetised annual health impacts under each scenario in 2020 in the EU27 (€billion) 

End Point Poll base_2020 SEA1_2020 SEA 3_2020 SEA 4_2020 SEA 5_2020 AS1_2020 AS4_202Acute Mortality (All ages) O3 0.89 0.86 0.86 0.86 0.86 0.86 0.8Respiratory Hospital Admissions (65yr +) O3 0.05 0.05 0.05 0.05 0.05 0.05 0.0Minor Restricted Activity Days (MRADs 15-64yr) O3 1.91 1.84 1.85 1.85 1.86 1.84 1.8Respiratory medication use (adults 20yr +) O3 0.01 0.01 0.01 0.01 0.01 0.01 0.0Total O3 Mortality 2.86 2.75 2.77 2.77 2.78 2.75 2.7Chronic Mortality (30 yr+) VOLY valuation PM2.5 80.24 73.79 71.36 70.65 70.27 73.56 70.4Chronic Mortality (30yr +) VSL valuation PM2.5 241.75 223.17 215.20 213.31 212.06 222.50 212.6Infant Mortality (0-1yr) PM2.5 0.54 0.50 0.48 0.48 0.48 0.50 0.4Chronic Bronchitis (27yr +) PM2.5 21.06 19.41 18.75 18.57 18.47 19.35 18.5Respiratory Hospital Admissions (All ages) PM2.5 0.08 0.07 0.07 0.07 0.07 0.07 0.0Cardiac Hospital Admissions (All ages) PM2.5 0.05 0.04 0.04 0.04 0.04 0.04 0.0Restricted Activity Days (RADs 15-64yr) PM2.5 17.13 15.76 15.24 15.09 15.01 15.71 15.0Respiratory medication use (children 5-14yr) PM2.5 0.002 0.001 0.001 0.001 0.001 0.001 0.00Respiratory medication use (adults 20yr +) PM2.5 0.02 0.02 0.01 0.01 0.01 0.02 0.0LRS symptom days (children 5-14yr) PM2.5 2.96 2.71 2.63 2.60 2.58 2.70 2.5LRS among adults (15yr +) with chronic symptoms PM2.5 6.87 6.32 6.11 6.05 6.02 6.30 6.0Total PM damage (low, VOLY valuation) 129 119 115 114 113 118 11Total PM damage high, VSL valuation) 290 268 259 256 255 267 25Total PM+O3 damage high, VSL valuation) 132 121 117 116 116 121 11Total PM+O3 damage (low, VOLY valuation) 293 271 261 259 258 270 25
Cost benefit analysis to support the impact assessment AEA/

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

AEA 

Table 6.7. Monetised annual health benefits compared to the relevant baseline under each scenario in 2015 in the EU27 (€billion) 

End point Pollutant SEA1_2015 SEA2_2015 SEA3_2015 AS1_2015 BS1_20Acute Mortality (All ages) O3 0.01 0.01 0.01 0.01 0Respiratory Hospital Admissions (65yr +) O3 0.00 0.00 0.00 0.00 0Minor Restricted Activity Days (MRADs 15-64yr) O3 0.03 0.02 0.02 0.03 0Respiratory medication use (adults 20yr +) O3 0.00 0.00 0.00 0.00 0Total ozone benefit 0.04 0.03 0.03 0.04 0Chronic Mortality (30 yr+) VOLY valuation* PM2.5 4.87 6.97 7.04 0.25 5Chronic Mortality (30yr +) VSL valuation* PM2.5 13.51 20.11 20.34 0.73 14Infant Mortality (0-1yr) PM2.5 0.03 0.04 0.04 0.00 0Chronic Bronchitis (27yr +) PM2.5 1.20 1.76 1.78 0.06 1Respiratory Hospital Admissions (All ages) PM2.5 0.00 0.01 0.01 0.00 0Cardiac Hospital Admissions (All ages) PM2.5 0.00 0.00 0.00 0.00 0Restricted Activity Days (RADs 15-64yr) PM2.5 1.07 1.52 1.54 0.06 1Respiratory medication use (children 5-14yr) PM2.5 0.00 0.00 0.00 0.00 0Respiratory medication use (adults 20yr +) PM2.5 0.00 0.00 0.00 0.00 0LRS symptom days (children 5-14yr) PM2.5 0.20 0.28 0.28 0.01 0LRS among adults (15yr +) with chronic symptoms PM2.5 0.41 0.59 0.60 0.02 0Total PM benefit (low, VOLY valuation) 7.79 11.18 11.29 8.21 8Total PM benefit (high, VSL valuation) 16.44 24.32 24.59 17.36 18Total PM+O3 benefit (low, VOLY valuation) 7.83 11.20 11.32 8.25 8Total PM+O3 benefit (high, VSL valuation) 16.48 24.35 24.62 17.40 18
Cost benefit analysis to support the impact assessment AEA/

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

AEA 

Table 6.8. Monetised annual health benefits compared to the relevant baseline under each scenario in 2020 in the EU27 (€billion) 

End point Pollutant Sea1_2020 Sea3_2020 Sea4_2020 Sea5_2020 as1_2020 as4_2020 Acute Mortality (All ages) O3 0.03 0.03 0.03 0.03 0.03 0.0Respiratory Hospital Admissions (65yr +) O3 0.00 0.00 0.00 0.00 0.00 0.0Minor Restricted Activity Days (MRADs 15-64yr) O3 0.07 0.06 0.06 0.06 0.07 0.0Respiratory medication use (adults 20yr +) O3 0.00 0.00 0.00 0.00 0.00 0.0Total ozone benefit 0.11 0.09 0.09 0.08 0.11 0.0Chronic Mortality (30 yr+) VOLY valuation* PM2.5 6.45 8.88 9.59 9.98 6.68 9.8Chronic Mortality (30yr +) VSL valuation* PM2.5 18.58 26.55 28.43 29.69 19.25 29.1Infant Mortality (0-1yr) PM2.5 0.04 0.05 0.06 0.06 0.04 0.0Chronic Bronchitis (27yr +) PM2.5 1.65 2.30 2.48 2.59 1.70 2.5Respiratory Hospital Admissions (All ages) PM2.5 0.01 0.01 0.01 0.01 0.01 0.0Cardiac Hospital Admissions (All ages) PM2.5 0.00 0.01 0.01 0.01 0.00 0.0Restricted Activity Days (RADs 15-64yr) PM2.5 1.37 1.89 2.04 2.12 1.42 2.0Respiratory medication use (children 5-14yr) PM2.5 0.00 0.00 0.00 0.00 0.00 0.0Respiratory medication use (adults 20yr +) PM2.5 0.00 0.00 0.00 0.00 0.00 0.0LRS symptom days (children 5-14yr) PM2.5 0.25 0.33 0.36 0.37 0.26 0.3LRS among adults (15yr +) with chronic symptoms PM2.5 0.55 0.76 0.82 0.85 0.57 0.8Total PM benefit (low, VOLY valuation) 10.32 14.23 15.37 15.99 10.68 15.7Total PM benefit (high, VSL valuation) 22.44 31.90 34.21 35.71 23.25 35.0Total PM+O3 benefit (low, VOLY valuation) 10.42 14.32 15.46 16.07 10.79 15.8Total PM+O3 benefit (high, VSL valuation) 22.54 31.99 34.30 35.79 23.36 35.1

* Alternative estimates, not to be combined
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 29

In addition to the impacts by scenario, a key consideration is the location of the benefits that arise

from each scenario. 

The following tables demonstrate the health benefits 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 that benefits are distributed across Member 

States. An overview of the impact by scenario is provided 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 impacts being experienced in the United Kingdom, 

Germany, France and Netherlands. This is in part driven by the SECA and the high population 

densities of the Member States. There are also significant 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 being seen in Italy, Greece and Spain. France 

also experiences higher health benefits from the new 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 scenario only. This 

results in slightly higher health benefits in Germany, France, Italy, Netherlands, Belgium, Poland 

and the United Kingdom. 

The BS1 scenario includes SEA 1 and the more restrictive 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 scenario 

only. This results in slightly higher health benefits in Germany, France, Italy, Netherlands, 

Belgium, Poland and the United Kingdom. 

The BS4 scenario includes SEA 4 and the more restrictive land based scenario (0.001% S). The 

overall impact is almost is an increase of approximately €300m against the AS4 scenario. The 

impact occurs primarily in the same countries as identified under AS4 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 Member State in Appendix 2.
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 32

Benefits outside of the EU27 

In addition to the EU27 Member States the ALPHA model also includes the following 4 additional 

countries: 

• Croatia 

• Norway 

• Switzerland 

• Turkey 

The impact of the additional countries differs by scenario. 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% benefit (low, VOLY valuation). The reason for 

the additional health benefits under SEA3 in particular is the result of the additional SECA 

regions; Mediterranean and Black Seas. This is combined with the high population densities that 

exist in Turkey that result in a net benefit of approximately €1.27bn under this scenario. 

The health impacts in Croatia, Norway and Switzerland 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 Table 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 assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 33

Summary 

A summary of the net health benefits, against the baselines 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 relative 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 assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 impact of the new IMO marine fuel and engine 

standards and potential extension of the Sulphur Emission Control Areas. Furthermore, the costs for 

stricter control of NOx emissions from shipping are explored. 

 

The scenarios developed are aimed at illustrating the impact of varying the stringency of emission 

controls in the sea regions under consideration. In the cost analysis, the scenarios represent 

altering either: the SO2 content of fuels (thereby changing the fuel costs) or introducing SO2

abatement technology (scrubbers), as well as the introduction of NOX control technologies 

classified into Tier I, II and III emission standards. 

7.1 Cost calculation method description 

The cost calculations for NOX and SO2 abatement from shipping in this report have two parts. The 

first part consists of calculating unit costs for the abatement option under consideration. In the 

second part scenario specific costs are calculated - based on the penetration of low-NOX and lowSO2 technology options. The cost calculations are presented in low and high cost settings. In the 

calculations, technologies that may, but are not certain to, reach the emission reduction levels 

stipulated by the Tier standards are considered. The calculations also allow for scenario 

comparison between closed loop scrubbers, open scrubbers and low sulphur fuels. 

The unit costs are calculated per petajoule (PJ), corresponding to the heat of combustion of the 

fuel used, for each fuel and engine category. The unit costs are based on the costs for 

installation, maintenance, operation and fuel penalties for using the equipment. These costs take 

into consideration the relevant technology-specific cost parameters. Furthermore, the 

technologies and associated costs are split into the NOX 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 costs for SO2 emission abatement are calculated as 

the difference in costs between the high and low fuel qualities. The costs are subject to scenariospecific estimates on hours of use for the technologies. In this report scenario-specific operating 

hours are of specific relevance for sulphur scrubbing options - because the regions considered as 

SECA varies between scenarios. For NOX, the Tier III technologies are for all relevant scenarios 

implemented in the Baltic, Mediterranean, and North Seas. 

For each scenario, costs are calculated, specifying high and low costs estimates for NOX and SO2

abatement. For SO2 abatement, separate cost calculations are presented for scrubber costs and 

low S-fuel costs. 

All costs are given in €2005. Adjustments of literature values and expert estimate values to 

inflation and currency exchange rates have been made when necessary. In the central analysis, a 

4 % investment interest rate has been used. 

In obtaining the costs the following economic assumptions have been made: 

The dynamics of supply / demand on price have not been considered. 

The actual price of fuels or emission abatement equipment 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 prices. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 fairly small production volumes of abatement 

equipment. Given that emission standards become more strict by 2016 and 2020, the market 

volume for abatement technologies will increase, this 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 transport 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 introducing emission abatement. 

7.2 Abatement Technology Description 

This section briefly describes the technical options for implementing regulations for SO2

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 NOX emissions are described. The costs for the different 

abatement options are discussed below. 

Sulphur oxide abatement 

Low sulphur fuel 

The emission of sulphur dioxide is directly proportional to the sulphur content in the fuel, the 

sulphur is oxidised in the combustion chamber and the mass of emitted SO2 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 sulphur 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 typically 

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 scenarios in which the quality of the 0.5% S 

fuel varies; the lowest priced fuel in that study had a high content of heavy oils. 

Scrubbers 

An alternative low sulphur fuel is to use an abatement technology which reduces the SO2

emissions by an equivalent amount. While several technologies might be discussed well 

established data is only available for wet scrubbing – 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 SO2 is trapped and converted to 

sulphate ions. 

Scrubbers for marine applications can be divided into open (seawater) scrubbers and closed 

(freshwater) scrubbers. The former utilises the natural alkalinity of sea water for the scrubbing 

and neutralisation process, the residual SO2 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 efficiency of SO2 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 systems 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 fuel used. The closed scrubbers use 

freshwater with an added neutralising agent (normally 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 assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 36

Nitrogen oxides 

Marine engine manufacturers will be able to meet the 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 Tier 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 already been demonstrated to reach Tier III 

emission levels on many ships while the EGR alternatives are still in the development phase. 

 

SCR 

In SCR a reducing agent, normally urea, is mixed with the exhaust gases in the presence of a 

catalyst. For marine applications the catalyst is usually composed of vanadium and titanium 

oxides. Under these conditions the urea is decomposed to ammonia which then selectivity reacts 

with nitrogen oxides to produce nitrogen gas. The SCR systems require a minimum exhaust gas 

temperature to operate effectively, this is normally around 300 °C but the temperature depends 

on the sulphur content of the fuel. Consequently SCR 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 catalysts 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 may be tuned for low fuel consumption with 

increased engine NOX emissions thus saving some fuel. The SCR system must, 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 Tier 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 required. The main track seems to be to use exhaust 

gas recirculation (EGR) in combination with other techniques. EGR means that some of the 

exhaust is re-circulated into the engine leading to lower cylinder temperatures and reduce 

formation/emission of NOX. The potential for NOX reduction is likely to be around 50%. The recirculated gas must not contain excessively high concentration of SO2 or soot. Therefore a low 

sulphur fuel (around 0.1%) would be needed or alternatively exhaust cleaning integrated with the 

circulation system - this could be either a scrubber or a particulate filter (if low sulphur fuel is 

used); EGR may also impose a fuel consumption penalty. 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 require 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 (similar costs are expected with water emulsion 

instead of DWI). Tier II is assumed to be reached by engine modifications. Retrofit costs for Tier0 

engines produced between 1990 and 2000 to reach Tier I standards have also been estimated. 

Compatibility 

As mentioned above there are problems with using high sulphur fuel in combination with NOX

abatement technologies. EGR requires very low sulphur content in the fuel or an internal 

scrubber. SCR performance can fall away due to catalyst poisoning with high sulphur fuel and the 

techniques using water injection or emulsion may also impose limits on the fuel sulphur content. 

Consequently there are unresolved design issues with combining NOX reduction techniques with 

scrubbers: if scrubbers are combined with SCR the exhaust 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 assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 37

7.3 Unit abatement costs 

The abatement costs are presented as costs per petajoule of the heat value for the fuel used 

(PJ); the costs are also presented as costs per tonne emission reduced - to facilitate comparison 

with other cost estimates. The costs for the different control standards are dependent on which 

technology can reach these standards. Abatement costs have been calculated for NOX and SO2

abatement using previous literature values (Entec 2005, UK Maritime and Coastguard Agency 

2009, US-EPA 2009) and information resulting from direct communications with main engine and 

equipment manufacturers,. 

Sulphur oxides 

In order to calculate costs for reducing sulphur emissions the following options have been 

considered: 

Table 7.1: SO2 abatement options 

SO2 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 costs for scrubbers from costs of low sulphur 

fuels. The following text presents the costs for fuel shifts and scrubbers respectively. 

Fuels 

The costs of fuel shifts depend mainly on the projected future fuel prices for different sulphur 

categories. The main parameters influencing the costs of fuel relate to sulphur content of crude 

oils as well as the necessary investments in refinery 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 price projections in Purvin & Gertz (2009). The fuel 

shift costs, specified as a cost per PJ of heat value in the fuel is given in the table below: 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 38

Table 7-2: Fuel costs in 2020, adapted from Purvin & Gertz, 2009 and corresponding SO2 associated 

abatement cost. 

Option 

(%S in fuel) 

Low 

cost 

[$ / 

tonne] 

High cost 

[$ / 

tonne] 

Low cost 

[k€2005 / PJ] 

High 

cost 

[k€2005 / 

PJ] 

Low SO2

abatement 

cost [€ / 

ton SO2] 

Low SO2

abatement 

cost [€ / 

ton SO2] 

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 content is projected to be $ 420 / tonne in Purvin 

& Gertz 2009. The fuel costs per tonne are converted to costs per PJ by considering the specific 

heat value of the fuel and the conversion rate between euro and dollar. 

Scrubbers 

The most important parameters deciding the costs for scrubbers are whether the technology 

would be installed in a new vessel or retrofitted to 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 calculations. In closed loop systems, costs for 

maintenance, purchase of NaOH and fresh water are also taken into consideration. For open 

systems, only maintenance is considered relevant for the cost calculations in addition to the fuel 

penalty. The cost for disposal of sludge is included 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 scrubber 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 is high but engine 

manufacturers estimate NaOH prices will range between 0.1 - 2 € / litre, so the price is on the 

lower boundary of other estimates. In 2007 the price for different grades of NaOH was 0.2 - 0.25 

€ / litre. 

The price for urea is also subject to variation, but the engine manufacturer experts are closer in 

their estimates on urea prices with a price range of 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 report 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 assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 39

Costs for different scrubber solutions are presented 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 calculations, 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 combination 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 with manufacturer estimates (Wärtsilä 2009, Marine 

and Energy Consulting 2009). The costs for scrubber operation vary with the required SO2

content in the exhaust gases - and the different amounts 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 SO2 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 equipment 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 standard tariff used at the port of Rotterdam. 

ENTEC (2005) indicated that the amount of sludge produced would be within the current 

allocations/ tariffs of a port like Rotterdam. Meech (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, using the Gothenburg harbour port tariffs as a 

reference, based on the Gross Tonnage (GT) of the vessel of maximum 0.4 € / GT, and assuming 

that vessels spend 500 hours between sludge discharge in ports, we have calculated that a 

maximum cost of sludge disposal could be ~10 000 euro for a small vessel. 

Table 7.4 Sludge disposal costs for Port of Göteborg 

Scrubber sulphur sludge disposal cost estimates - based 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 allocate all sludge disposal costs to the scrubber 

sludge, which would constitute only one part of total 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 (which 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 during 30 operating hours. This corresponds to 

an hourly cost of 2.9 €. A medium vessel (15 MW) would produce some 0.4 tonne over 40 

operating hours, corresponding to a cost of ~1€ / hour. No estimates are given for small vessels. 

Wärtsilä (2009) specifies that some scrubbers produce 1.3 litres sludge per MWh. By using these 

numbers, the following sludge disposal costs are calculated for scrubbers, 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 medium 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 

SO2 [€] 

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 and 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. This large variation is a consequence of the 

relatively expensive NaOH costs used in these cost estimates. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 41

NOX

The cost for reduction of NOX emissions in the scenarios studied is only applicable as a 

replacement of Tier II technologies with Tier III technologies. There is currently much research 

ongoing by engine manufacturers to reach Tier III standards 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 assumed for urea is important. Its price, like that of 

fuel, is heavily dependent on future supply and demand; 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 modified for optimal fuel performance - the NOX

emissions increase but remain within the capacity of 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 several 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 fuel efficiency while turbo charging may 

improve it. The net effect of EGR combinations in our study is assumed to imply a 2% fuel 

penalty. 

The Tier I and Tier II costs are based on the estimates 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 NOX abatement. 

Table 7.7: NOX control standards considered in this study

NOx % Removal Comment

Tier I retrofit 5 % NOX

For ships constructed before 

the year 2010 

Tier II new 20 % NOX Built after 2011 

Tier III new 80 % NOX

Built after 2016 for NOXECAs 

For a typical vessel with a medium sized SSD-RO engine using residual oil with a 2.94 % sulphur 

content, using the main and auxiliary engines at some 4500 hours per year (4000 hours at sea), 

the following unit costs are obtained in the cost calculations. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 

NOX [€] 

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 - because 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 not completely established as of yet. However, 

in the scenario calculations performed here, SCR will only be used in combination with either 

scrubbers or low sulphur fuels. The additional costs 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 exhaust 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-circulated. The costs for this internal scrubber is 

dependent on the amount of NaOH used which is in turn dependent on the sulphur content of the 

fuel. This impact on costs is illustrated in the table above by the four different price estimates for

EGR + WIF. 

The costs for Tier III equipment and consumables are within the range of the cost estimates in 

ENTEC (2005) and by the USEPA (2009). The USEPA study presents significantly higher costs 

per ton NOX abated with Tier III technology. The reason for this difference lies in the fact that the 

USEPA study allocates the total cost of the abatement equipment to the relatively small amounts 

of NOX that will actually be abated in the US coastal zone that is suggested for NOX-ECA. 

In the scenario cost calculations used in this study are based on the cost per PJ. Having the cost 

per PJ for each fuel/vessel/tech combination, scenario 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-specific fuel use and abatement technology 

penetration is used to calculate the total costs for NOX and SO2 abatement associated with the 

scenarios. 

The specifics of the scenarios analysed are as follows: 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 43

For SO2: 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 maximum 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 NOX: Marine diesel engines with a power output that exceeds 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 January 2000 and 1 January 2011; 

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

• Tier III standards for ships constructed on or after 1 January 2016 and sailing in the Baltic 

Sea, North Sea/English Channel and/or the Mediterranean 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 scenarios, it is assumed that scrubbers are not 

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

for scrubbers will be associated with fuel cost savings 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, 2020 

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 within a SECA or 

NOX 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 NOX removal is assumed. The costs for fuel represent the total fuel 

costs for all sea regions considered in the report. 

Readers should note that Table 7.10 is the only cost 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 the 

total costs of each scenario, the costs of the baseline should be added to the costs presented in 

the tables below. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 NOX control in the Baltic, Mediterranean and the North sea, 

the annual costs for NOX 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 the 1.5 % S fuel used in the baseline. 

Therefore, the costs for high S fuel given in the table are negative. If reaching the SO2 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

SO2

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.

 

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

Note: n.c. – not calculated 

In SEA2, only covering the year 2015, the Mediterranean Sea is considered as a SECA. The fuel 

costs increase significantly following the large fuel 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 than 0.5% S (as in the base case) which implies 

extra costs. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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

SO2

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

 

NOX Tier I - III 76 76 393 645

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

the Mediterranean is considered as a NOX ECA. The low cost estimate on Tier III (EGR+WIF) is 

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

SO2

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

 

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

Note: n.c. – not calculated 

In SEA 4, the permitted sulphur content in the areas outside SECA is reduced to 0.5 %. The 

Mediterranean and the Black Sea are again outside SECA. The Mediterranean Sea is together 

with the Baltic and North Sea considered as a NOX Emission Control Area. The low cost 

estimates for Tier III is lower than in SEA1 but higher than SEA3, following the allowed sulphur 

content of 0.5 % (0.1% in SEA3). 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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

SO2

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

 

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

Note: n.c. – not calculated 

In SEA5, all sea regions but the North East Atlantic are considered as SECAs (as in SEA3), and 

the North East Atlantic has a maximum sulphur content of 0.5 %. This results in the highest 

sulphur removal costs of all scenarios. The low cost estimates on Tier III are again following the 

sulphur content of the low sulphur fuel scenario for the Mediterranean. The inclusion of the 

Mediterranean and the Black Sea is not visible in the 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 SO2 emissions corresponding to either 0.1% or 0.5%. 

Disaggregated into regions, the costs for the different scenarios are as follows: 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 SO2

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

 NOX Tier I - III 6 6 41 70

Black SO2

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

 NOX Tier I - III 2 2 2 2

Med SO2

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

 NOX Tier I - III 36 36 291 389

NE Atl SO2

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

 NOX Tier I - III 17 17 21 21

North SO2

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

 NOX Tier I - III 15 15 97 163

ALL REGIONS SO2

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

 NOX Tier I - III 76 76 452 645
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 SO2

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.

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

Black SO2

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.

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

Med SO2

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.

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

NE Atl SO2

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.

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

North SO2

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.

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

ALL REGIONS SO2

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.

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

Note: n.c. – not calculated 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 SO2

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

NOX Tier I - III 6 6 41 70

Black SO2

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

NOX Tier I - III 2 2 2 2

Med SO2

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

NOX Tier I - III 36 36 231 389

NE Atl SO2

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

NOX Tier I - III 17 17 21 21

North SO2

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

NOX Tier I - III 15 15 97 163

ALL REGIONS SO2

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

 NOX Tier I - III 76 76 393 645
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 SO2

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

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

Black SO2

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

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

Med SO2

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

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

NE Atl SO2

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

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

North SO2

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

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

ALL REGIONS SO2

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

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

Note: n.c. – not calculated 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 SO2

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

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

Black SO2

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

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

Med SO2

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

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

NE Atl SO2

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

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

North SO2

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

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

ALL REGIONS SO2

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

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

Note: n.c. – not calculated 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 comparison 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 SO2 emissions together with the costs of NOx

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

SO2 emissions and the costs of NOx control. The range for benefits is based on use of either the 

VOLY (lower bound) or VSL (upper bound) to value mortality. 

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 estimates shown above: in other words that benefits 

exceed costs for all of the cases shown. However, the ranges shown to this point are simply 

indicative – they do not account for all of the uncertainties 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 unclear how robust the conclusion that benefits 

exceed costs actually is (even though the results appear conclusive). To illustrate the problem, 

the surplus of benefit over cost would grow were other benefits, to ecosystems, crops and the 

built environment to be added in. However, if certain key aspects of the analysis are 

overestimated, in particular elements relating to the quantification of benefits of reduced mortality 

using the lower bound (VOLY) approach, benefits would in turn be overestimated. It is therefore 

clearly appropriate to consider the uncertainties in 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 costs and benefits. Table 8.3 summarises the 

uncertainties accounted for and not accounted for in 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 assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 applied 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 the more detailed comparison of costs and 

benefits. The analysis in the preceding section already suggests that it is very likely that costs will 

be less than benefits. The uncertainty analysis therefore needs to consider how robust this 

conclusion is and whether there could be any grounds 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 estimates 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 information 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 values 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 may therefore be one possible outcome, but 

it may also be extremely unlikely to happen. On this basis the use of extremes to generate ranges 

is not helpful for informing policy development unless it demonstrates unequivocally that the 

range for two parameters of interest (e.g. total cost and total benefit) do not overlap. 

It has been observed that the ranges given in Tables 8.1 and 8.2 do not overlap. However, for the 

benefits in particular the ranges shown account only partially for the uncertainties that are 

present, as they show the effect of using a best estimate of the VOLY or a best estimates of the 

VSL to value mortality. They do not account for uncertainty in these best estimates or in the other 

parameters used in the quantification of impacts and monetary benefits. 

This section factors in the uncertainties in the estimation of benefits relating to the population at 

risk, the incidence of ill health, concentration-response functions and unit values for each of the 

health impacts that have been quantified. This generates not only a range around the final 

estimate of benefit, but also the probability distribution within that range. Extreme values may 

arise, but they can be shown to be of very low probability compared to values closer to the centre 

of the distribution. 

The ranges described for costs in the previous chapter account for all available data accessed 

during the project. These ranges are adopted for comparison with the newly-computed ranges for 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 results of the present study). Other distributions are 

possible, but are broadly similar to those shown. In cases where there is a reasonable amount of 

information it may be appropriate to assume a detailed distribution like the lognormal or normal 

case. In the present situation, however, we have only 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

-2

02468

10

0.0

0.1

0.2

0.3

0.4-4

-2

02468

10

0.0

0.1

0.2

0.3

0.4-4

-2

02468

10

0.0

0.1

0.2

0.3

0.4-4

-2

02468

10

Probability

Value

Lognormal Normal Triangular Uniform

Figure 8.1 Examples of possible distributions for variables 

Once distributions have been determined for the input variables the Monte Carlo analysis is 

runover 10,000 iterations. At each iteration a value is selected at random from within each of the 

defined probability distributions that have been input to the model. The resulting distributions can 

be used to assess the extent of overlap in the distribution 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 year 2020 rather than 2015 to account for more 

complete implementation of the policies under investigation. 

Describing the uncertainties in cost estimates 

Three options have been considered for sulphur controls, the use of open or closed loop 

scrubbers and the use of low sulphur fuels. For each 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 benefits above. It should be pointed out that the 

low range scrubber costs are for sea water scrubbers. It is still unclear under what regulations 

these will operate (see Section 9). A likely scenario is that scrubbers operate with seawater at 

open sea and as closed scrubbers or with low-sulphur 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 scrubbers could be in the middle or higher part 

of the range given here for scrubbers. Various techniques were investigated for NOx control, as 

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

are apparent: 

• Costs are dominated by controls on sulphur, the costs of controls on nitrogen being an 

order of magnitude less (with the partial exception of SEA1) 

• The extent of variation in the NOx estimates is small compared to variation in the SO2

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 assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 55

Table 8.4 Summary of annual abatement costs given in 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 SO2 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 sum of NOx control costs with 

the low range for SO2 control costs (using scrubbers). 

• Average Case: Triangular or uniform distributions across the full ranges shown, which 

would assume that ship owners opt for a mixed approach 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 sum of NOx control costs 

with the high range for SO2 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 benefit there is no need to be concerned 

about other parts of the cost range as they would simply further increase the probability. 

For the first case we apply a triangular distribution 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 assumption 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 attaining a net benefit (remembering that it is intended 

as a worst case) given the observed relationship between costs and benefits from Tables 8.1 and 

8.2. Resulting distributions can be compared for scenario SEA5 in Figure 8.2. The two worst 

cases are shown to be significantly more pessimistic than the average case. 

Triang(2.416, 4.99, 7.564)

0.00

0.15

0.30

0.45

0.60

0369

1215

Uniform(11.513, 13.953)

0.00

0.15

0.30

0.45

0.60

0369

1215

Uniform(11.513, 13.953)

0.00

0.15

0.30

0.45

0.60

0369

1215

Triang(2.4, 8.2, 14)

0.00

0.15

0.30

0.45

0.60

0369

1215 Value

1.0 1.0 1.0

0.45

0.30

0.15

0

1.0

Triangular (2.42, 4.99. 7.56) Triangular (2.42, 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 15

Probability density

Figure 8.2 Probability distributions used for the sensitivity cases on costs (examples are 

all for scenario SEA5). 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 56

Uncertainties in benefit estimates 

As noted above, account is taken here of uncertainties in the population at risk, the incidence of ill

health, concentration-response functions and unit values 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 together 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 and 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 cost 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=16.5

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

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 uncertainties 

Results from the Monte Carlo analysis showing the probability 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 of deriving a net benefit is more than 98% 

for all SEA scenarios, even for Worst case 1 (the extreme 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 assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 57

• For the best case assumptions (lower range for S control 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 scenario there is a probability greater 

than 94% of gaining a net benefit for all SEA scenarios. 

The precise probability estimates reported in the table are themselves a function of assumptions 

made in the uncertainty analysis. What is important therefore is not the precise figures shown, 

but the overall perspective that when further uncertainties 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 under 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 Best

Probability of benefit>cost

VOLY estimates

SEA1

SEA3

SEA4

SEA5

VSL estimates

SEA1

SEA3

SEA4

SEA5

Figure 8.1 Probability of deriving a net benefit under various sensitivity cases. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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 the 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 cases) the probability of benefit exceeding cost 

can therefore be described as very likely / virtually certain, irrespective of the approach taken to 

mortality valuation. With one slight exception (SEA5 with mortality valued using the VOLY) the 

probability of benefits exceeding costs can be described as likely, very likely or virtually certain 

even for the worst case assumptions on cost. 

It is to be remembered that the probabilities calculated here are quantified only against benefits 

for improved health. The inclusion of impacts to materials (including cultural heritage) and 

ecosystems, in particular, would add to the benefits and further increase the already high 

probabilities. Economies of scale, as the use of abatement techniques becomes more 

widespread have also been excluded from the analysis. These would tend to reduce costs from 

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

It is more difficult to make a qualitative appraisal of the effect of other uncertainties that have 

been excluded from the current analysis, for example price effects on demand for transport and 

the potential for modal shift in response for legislation, 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, however, not beyond possibility that there 

could be even more significant variation in cost than that considered here in the future, and that 

this would lead to a net cost being incurred. However, from observations made here on the 

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

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

abatement costs 

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

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

The following should also be considered: 

• Alternative methods for reaching the same goals have been identified. If the costs of one 

option were to increase significantly it may therefore be appropriate to switch to a 

different option 

• A conservative best estimate was adopted for the VOLY. 

The challenge of accounting for all possible uncertainties in this analysis, given the number of 

inputs and factors that need to be accounted for, is 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 the 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. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 59

9 Emission abatement equipment 

9.1 Summary 

This section of the report discusses technical criteria for exhaust abatement equipment for the 

reduction of emissions of sulphur dioxide from ships. The only technology available at present is 

scrubbing. Scrubber units can be of two kinds, seawater (open) scrubbers and freshwater 

(closed) scrubbers, or a combination of these. Criteria for the SO2 to CO2 ratio for emissions to air 

have been presented by the IMO. Also criteria for the 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 oxides); this is unfortunate from an 

environmental point of view and better optimised abatement units could be developed if the 

regulations covered both the emissions to air and to 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 amount 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 "phenanthrene 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 phenanthrene, this seems to be a high limit and 

widespread use of scrubbers emitting wash-water with 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 with 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' contribution 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. In one the SO2-emission to air is measured 

continuously and in the other the scrubber’s operational parameters are monitored to check its 

efficiency of operation; it is suggested that the latter is applied because there will be scrubbers, 

notably closed scrubbers, where the operation can be monitored without continuously measuring 

the SO2 concentration in the exhaust gas. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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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 emissions have historically been the most important 

source for the acidification of lakes and soils leading to deterioration of soils, collapsing 

ecosystems and loss of forest production. Sulphur emissions also lead to the formation of 

particulate matter. High levels of particulate matter 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, cleaning of exhaust gases, sulphur limits on diesel 

and gasoline for road transportation, etc. 

One sector that, until recently, has been unaffected 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 sulphur in the fuel ends up as emission of sulphur 

oxides (SOX) after combustion in the engine. Some of this SO2 is then oxidized further and may 

then form particles. There is a clear connection between the sulphur content in the fuel and 

particle emissions (Winnes 2009). Eyring et al. (2005) estimate that the worldwide annual SO2

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 2007 also the North Sea and the English 

Channel) have a limit of 1.5% sulphur. In view of the environmental and health impacts of sulphur 

emission IMO have decided on future reduction in the 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 regional limits for sulphur in marine fuels. Within 

the European Union ships at berth and ships using inland 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 been 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 years. 

There are two principle approaches to reducing SO2 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 oil together with an SO2 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 an established technique that has been used 

for many years for land-based power plants etc. Scrubbers 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 continuous addition of alkali, or alternatively, sea 

water - where the natural alkalinity of sea water is utilised for the capture of SO2. The removal 

efficiency is normally high but depends on the alkalinity of the water. The latter also decides the 

acidity of the effluent water together with factors like the scrubber water flow in relation to exhaust 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 61

flow. The scrubber will also remove a significant part of the particles and a minor part of the 

nitrogen oxides (NOx) from the exhaust. The seawater is by various means 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 article 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 SO2 in 

combination with HFO should be such that the environmental and health impacts are less than 

what they would have been had low-sulphur fuel (according to Table 9.1) been used. 

9.3 Abatement of sulphur oxides 

Scrubber systems have been used since the 1930s in order to remove SO2 from flue gases. The 

basic principle is that SO2 reacts with substances in a spray of water, which essentially keeps 

pollutants in the exhaust from being emitted to air by capturing them in the liquid. In many land 

based systems, SO2 is treated with limestone to form gypsum but some facilities utilise the 

natural alkalinity of sea water for sulphur scrubbing. On land, installations of SOX-scrubbers are 

relatively common because land based industries do not have the same constraints of space and 

complexity as ship based equipment. Alternatively freshwater, in combination with caustic soda, 

can be used as the scrubbing agent. The solid particles that end up in the water are allowed to 

settle in a sludge tank and the wash-water is treated before being disposed into the sea. If this 

treatment is not carried out, particulates and other pollutants will reach the sea water. 

The most important chemical reactions that take place during the desulphurisation process are 

the following. 

SO2 (gas) + H2O + 1⁄2O2 ==> SO4

2- + 2H+

 

HCO3

-

 + H+ ==> CO2 + H2O 

SO2 absorbed in seawater reacts with oxygen to form sulphate ions and hydrogen ions. Increased 

concentration of hydrogen ions means increased acidity and decreased pH. Bicarbonate ions 

(HCO3

-

) from the seawater react with hydrogen ions and thereby neutralise the acidity and raise 

the pH. SO2 consumes oxygen to form sulphate and SO2 concentration therefore corresponds to 

a certain Chemical Oxygen Demand (COD). 

In addition to the capture of SO2 some NOx and CO2 may be removed from the exhaust gas in the 

scrubber. For NOx it is mainly the NO2 fraction that is captured and it will be emitted with the 

wash-water as nitrates. While some CO2 may be captured and emitted with the wash-water this 

gives no net capture of CO2 because the balance between CO2 in sea and air will be reestablished by CO2 emission from the sea. 

The alkalinity of the water is thus a key factor for the acidity of the effluent water. Furthermore, 

the efficiency of the scrubber process increases with higher alkalinity. There are two principle 

designs of marine scrubbers: seawater or open scrubbers and fresh water or closed loop 

scrubbers. In a marine seawater scrubber the flue gas either passes through a spray of seawater 

or is bubbled through seawater. The alkalinity of seawater is used to capture the sulphur and 

neutralise the wash-water. The sulphur is discharged into the sea with the treated wash-water 

which is acidic. In a freshwater scrubber the alkalinity 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 that, for example, closed loop operation can be 

used in waters with low alkalinity and seawater operation at open sea. A number of trials have 

been undertaken with seawater and freshwater scrubbers onboard ships (see Skema 2009). 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 62

Three principle functions can be identified. 1. scrubbing of the flue gas where SO2, particles and 

other constitutes are trapped in the seawater. 2. Filtering the seawater and dilution before 

disposal overboard. This leaves a sludge that is kept onboard for disposal at shore. 3. Demisting 

and heating of the exhaust gas after the scrubber unit in order to prevent a mist with low pH. 

9.4 A comparison between reducing SO2 emissions with low sulphur fuel or scrubbers 

The intention of the equivalent clause described above is to allow for abatement technologies to 

be used in combination with heavy fuel oil which may 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 are also other factors to consider. It can be 

useful to consider impacts which may be expected from the use of scrubbers in combination with 

high-sulphur heavy fuel oil and compare to the impact from use of low sulphur fuel oil. 

The abatement of SO2 emissions required to be equivalent to certain sulphur content in fuel has 

been calculated by IMO and is expressed as a ratio between SO2 and CO2 concentrations in the 

exhaust gas. Thus, the SO2 emissions for a ship using scrubbers, when fulfilling these criteria, will 

be lower or equal to what it would be with the stipulated fuel sulphur content. However, in many 

cases scrubber equipment would be able to reduce the SO2 emissions significantly further, for 

example when the ship is used outside SECA areas. Since 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 reduction in SO2 emissions that may be accessed 

through policy initiatives. 

In the production of low-sulphur fuel the sulphur from the refineries can be used for other 

products. There is a fuel (and thus CO2) penalty in producing low sulphur fuel the magnitude of 

which depends on a number of factors in the refinery 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 present. However, the acidity of the effluent may 

be an issue – see above, its neutralisation is achieved either using the natural alkalinity of the 

sea water (open scrubbers) or by an alkaline chemical (closed scrubbers). In both cases there 

will be a net CO2 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 particulate matter produced. If at the same time there 

is a switch from residual oil to distillate fuel then 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 SO2, 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 the 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 high 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 safe 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; this is because a scrubber system that has not 

been designed, specifically to abate exhaust gas particulate can more easily comply with the 

wash-water criteria - less PM will be present in the wash-water and less treatment is needed. A 

potential solution would be to combine wash-water criteria and PM exhaust emission criteria in 

order to require that the scrubber units abate PM from the exhaust gas and treat the wash-water 

effectively. The two main alternatives to comply with the sulphur emission regulations in a SECA 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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. The 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 fuel oil with around 3.5% sulphur. The reduction 

of PM emissions for the scrubbers that have been tested for marine applications has varied 

between 0 and 85%. The scrubbers were designed for SO2 abatement and while a high PM 

abatement efficiency may be possible it is not a trivial matter to measure the PM trapping 

efficiency -when the temperature and humidity varies 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 effective treatment sludge will be produced and 

disposed at land. At present there are no real incentives to make scrubbers an effective 

abatement technology for PM. 

 

Regarding nitrogen oxides, scrubbers are likely to capture the NO2-fraction in the exhaust and 

may be designed to capture NO as well. Doing so may cause an emission of nitrates into the sea 

with the scrubber water – which is unwanted in areas at risk of eutrophication. NOx emitted with 

the exhaust gas is distributed over sea and over land so a scrubber that captures NOx 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 methods of reducing SO2 emissions - scrubbers 

and low sulphur fuel - is that ships would carry different 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 more severe in the case of HFO. Furthermore, a 

greater and more efficient use of scrubbers will produce sludge, for ports to handle, that is 

potentially toxic.

9.5 Emission criteria for EGC 

The emissions to air of SO2 can be monitored as the SO2 to CO2 ratio from which corresponding 

fuel-sulphur content can be obtained. Since there may be capture of CO2 in the scrubber, or 

release of CO2 from the chemical reactions involved in the buffering, the CO2 concentration 

should be measured before the scrubber unit. All sulphur compounds emitted to air should be 

measured and aggregated – care should be taken to ensure that the more highly oxidised sulphur 

compounds are accounted for. The SO2 to CO2 ratios corresponding to certain fuel-sulphur levels 

have been calculated by IMO (see Table 9.2). No other emissions to air are regulated in the IMO 

guidelines for sulphur abatement technologies. 

Table 9.2. SO2/CO2 ratio corresponding to certain fuel-sulphur levels 

Fuel-sulphur content (wt %) SO2(ppm)/CO2(%) 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 section 10 of Annex 5 to MARPOL 73/78. We refer 

here to the preliminary guidelines dated July 16, 2009. The values that are to be monitored 

should include pH, PAH, turbidity and temperature. There are also limits on the nitrate content in 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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 versions the criteria were only applied to harbours, 

estuaries and ports. It is uncertain, at present, if separate limits will be developed for operation at 

open sea. 

pH 

pH is a measure of the acidic or basic (alkaline) nature of a solution. The concentration of the 

hydrogen ion [H+] in a solution determines the pH. Ocean water usually has an excellent buffering 

system, with interaction of carbon dioxide and water, and pH generally varies between 7.5 and 

8.5. Neutral water has a pH of 7 while acidic substances are less than 7 (down to 1, which is 

highly acidic) and alkaline substances are more than 7 (up to 14, which is highly alkaline). 

Anything either highly acid or alkaline would severely 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 of 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 stated that the wash-water should comply with 

one of the following: 

· The discharge wash-water should have a pH of no less 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 installation, the discharged wash-water plume 

should be measured externally from the ship (at rest in harbour) and the discharge pH at 

the ship’s overboard pH monitoring point will be recorded 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 pH discharge limit recorded. 

PAH 

Polycyclic aromatic hydrocarbons (PAH) are the largest known group of carcinogenic substances 

and include many individual chemical substances containing two or more condensed aromatic 

rings. The biological effect of PAH is linked to the planar structure of the molecule and its ability to 

affect DNA in the cell nucleus. PAH are formed when coal, oil, or other hydrocarbons are heated 

under anoxic conditions, i.e. with insufficient oxygen, and are the products of incomplete 

combustion. PAH are not usually present as individual compounds but occur in mixtures. PAH 

are fat soluble and might be bio-accumulative (in fatty tissues). In the aquatic environments, PAH 

are usually bound to particles which transport to sediment. Many PAH compounds accumulate 

in invertebrate organisms. Fish eggs and fry exposed to PAH have been found to suffer 

mutation, bleeding, heart conditions, reduced growth and increased mortality. A group of 16 

PAHs are usually measured and analysed, but in the IMO wash-water criteria, PAHphe or 

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

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

hydrocarbons. 

The IMO wash-water criteria regarding PAH: 

· The maximum PAH concentration in the wash-water should not be greater than 50 μg/l 

PAHphe above the inlet water PAH concentration. The PAH concentration should be 

measured downstream of the water treatment equipment. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 65

· The 50 μg/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 PAHphe. 

· 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 in the water, or rather the cloudiness caused by 

suspended solids. Turbidity in open water can be caused by several different reasons, e.g. 

phytoplankton or high levels of sediment in the water. In lakes and shallow areas the turbidity can 

decrease the amount of light reaching the lower depths and thereby affect submerged plants and 

in the end also species that are dependent on the amount of plants. Turbidity is measured in FTU 

(Formazin Turbidity Unit) or FNU (Formazin Nephelometric Units). 

The IMO wash-water criteria regarding turbidity: 

· The maximum continuous turbidity in wash-water should not be greater than 25 FNU 

or 25 NTU above the inlet water turbidity. 

Nitrates 

Nitrogen oxides, i.e. the sum of NO and NO2, are produced during combustion at high 

temperatures. The oxides can contribute to acid rain and other environmental effects. Nitrate 

(NO3

-

) 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 decreases during springtime and all processes in 

the nitrogen cycle are seasonally dependent. When oxygen is present, ammonia can be oxidised 

to nitrate (via nitrite) in a process called nitrification. 

The IMO Wash water criteria regarding nitrates: 

· Nitrates should be monitored. The wash-water treatment system should prevent the 

discharge of nitrates beyond that associated with a 12% removal of NOx from the 

exhaust, or beyond 60 mg/l normalized for wash-water discharge rate of 45 

tonnes/MWh whichever is greater. 

9.7 Environmental assessments 

Behrends and Liebezeit (2003) presented an environmental impact analysis of sea water 

scrubbers. Laboratory tests with mixtures of seawater 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. (2005) sampling was carried out of scrubber water and 

water from ports where a trial with a seawater scrubber onboard the Pride of Kent was 

undertaken. A decrease in pH of maximum 2 in the effluent was observed together with 

increased nitrate content. No impacts on seawater or 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 water under the assumption that 45 kg 

water/kWh is used in the scrubber. They also suggest that the PNEC value for total hydrocarbons 

(THC) is set to 40 μg/l. Values recalculated to mass per engine output are given in Table 9.3. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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Buhaug et al. use the concept of near field, outside which no effect concentration should be 

reached. This is set to 50 m from the stern for a moving 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 water needed for scrubbing of SO2 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 SO2 is significantly 

higher in river water than at open sea and with brackish water in between. They also showed that 

the wash-water with a pH of 6.5 will quickly be neutralised to reach a delta pH of 0.2 and that both 

the capture of SO2 and the buffering (i.e. the dilution needed) are temperature 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 recommended that a generalised marine 

environmental risk assessment should be developed in 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 SOx and its potential for acute effects on biota. 

PAH represents any oily discharge, NOx reflects any tendency towards eutrophication and 

turbidity is intended to safeguard against particulate matter (heavy metals and ash). GESAMP 

stated that an environmental benefit in reducing SOx emissions to the atmosphere only can be 

achieved if the discharge do not create further risks to the aquatic environment. One remark by 

GESAMP was that IMO should consider the potential contribution to ocean acidification of the 

large scale application of SO2 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 emissions 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 level (in ports or at sea) although the amount of 

dilution needed can be obtained from Karle and Turner. 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 are high and close to the PNEC; it is not clear 

from these reports how a PAHphe concentration is related to the emission of THC. Hufnagl et al. 

report that phenanthrene is the dominating PAH in the wash water and thus the best candidate 

for analysis. Turbidity is not discussed except that GESAMP regards it as a way to monitor 

particulate matter. Elevated nitrate levels were observed by Hufnagl et al. and they actually note 

that up to 20% of the NOx may be captured and released as nitrates. In addition 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 water criteria 

The potential impact of aqueous discharges to the marine 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 the sensitivity of the marine environment in the 

region of concern. This should, furthermore, be related to the discharge conditions and the 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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resulting rate of dilution and spatial extent of the plume formed by the discharge after disposal to 

the sea. There is a risk for locally high concentrations of a number of harmful substances if there 

are no adequate wash-water criteria in force. 

pH 

Hufnagel et al. have analyzed the environmental impact of a seawater scrubber for two harbours, 

Calais and Dover. They took samples from the seawater scrubber system and the samples 

partially showed values lower than pH 3. The buffering system increased the pH. Experiments 

showed that a mixture containing 40 % of seawater acidified to a pH of 4 (comparable to what 

happens in a seawater scrubber) only changed pH about 0.2 units. The lowest pH measured in 

the overboard discharge was 6.2. The US EPA, as mentioned earlier, has passed a guideline 

concerning the introduction of acids which states that outside the initial mixing zone the pH 

change is not allowed to be more than 0.2 units. Under the circumstances stated, the pH would 

not reach a value that is harmful to the marine environment. This is dependent on the dilution, 

volume of water and the specific area of concern. Buhaug et al. (2006) stated that discharges 

from a single ship are rapidly diluted when the ship is moving, but expected to be much slower 

when the ship is not moving. 

Karle and Turner calculated the amount of water needed for scrubbing SO2 and dilution to first 

obtain pH of 6.5 and then a delta pH of 0.2. In addition they looked at further dilution to reach a 

maximum of 1% reduction in oxygen concentration. They 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 SO2 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 compared 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 scrubbing to a SO2 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 more water for dilution is needed when 

scrubbing takes place in fresh water, compared to open sea. 

As an example we can look at the port of Hamburg. In 2000 115.5 ktonne of CO2 and 1.9 ktonne 

of SO2 were emitted corresponding to a fuel consumption of about 36.3 ktonne with a sulphur 

content of 2.6% (Whall et al. 2002). If all of these 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 effluent 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 equivalents" is not well established and needs to be 

explained or replaced. Assuming that it simply means that the phenanthrene concentration is 

measured, the criteria correspond to about 2.2 mg/kWh of PAHphe. Cooper et al. (1996) analysed 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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PAH in the exhaust from two ships and found phenanthrene levels in the gas to be 71 and 250 

μg/kWh respectively. The lower value refers to an engine 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 in addition unknown amounts of other PAHs. 

According to Buhaug et al. (2006) OSPAR have developed Ecotoxicological Assessment Criteria 

(EAC) for a large range of chemicals, including PAHs. This was done to make the evaluation of 

monitoring data on toxic substances in the marine environment 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 μg/l PAHphe (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 concentration should also be considered, which may 

lead to further limits on the emissions. In Directive 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 the PAH criteria used will ensure that the levels of 

total hydrocarbon compound (THC) emissions are at safe levels. The criteria for THC developed 

by Buhaug et al. are 4500, 450 and 45 μg/l for the three "Safety Margins" that they use. This is 

under the assumption of a wash-water flow of 44 tonne/MWh. These levels would correspond to 

200, 20 and 2 mg/kWh. Thus the IMO criteria which applies only to phenanthrene is set to about 

the same as the THC value by Buhaug et al. for safety margin 3. 

If we look at the port of Hamburg again, the amount of PAHphe 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 suspended solids in the water – and because it a 

simple method for on-line analysis. Turbidity can be a useful indicator of the status of the 

scrubber, i.e. that suspended particles are not being 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 etc in the wash water before this criteria can be 

considered an indication of particulate levels in the wash-water. These uncertainties make it 

hard to make an environmental assessment of the turbidity criteria. 

Nitrates 

The criteria for nitrates are motivated by the increased contribution to eutrophication that will be 

the result of increased emissions of nitrates with the effluent water. Since scrubbers are likely to

capture the NO2 in the exhaust the 12% maximum capture requirement of NOx will normally be 

met. Hufnagl et al. (2005), however, report a capture 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 eutrophication and large efforts are made to decrease the 

flow of nutrients into the Baltic. The total emission of NOx from shipping in the Baltic according to 

a recent Helcom study (Jalkanen 2009) is around 400 ktonne per year at present. EMEP 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

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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 NOx 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. Consequently ~ 107 ktonne per year is deposited in the 

Baltic Sea from shipping in the Baltic Sea calculated as nitrates. If all of these ships were to use 

scrubbers and all of these scrubbers captured 12% of the NOx 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 land 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 deposition and the rest via rivers and direct 

waterborne discharges. Thus the hypothetical maximum 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 the theoretical oxygen consumption of a 

water sample, i.e. the amount of oxygen needed to break down the organic matter in it. 

According to Buhaug et al. there are no environmental standards for COD. Tolerance to reduced 

dissolved oxygen varies between organisms, life stages and environmental conditions. While 

Buhaug et al. concluded that COD was not a matter of 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 that ships using abatement technology to achieve 

low SO2 emissions must be fitted with continuous monitoring equipment for SO2 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 certification with parameter and emission 

checks) and Scheme B (continuous monitoring with parameter checks). 

In Scheme A the unit should be certified to meet the limit values for SO2/CO2 concentration in the 

exhaust. The fuel that may be used, including sulphur 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 neutralisation agents. A SOX emission compliance 

certification must be obtained from the administration. There must also be a certification 

procedure established for use during surveys. The system must automatically record that the 

abatement equipment is in use by monitoring wash water pressure and flow rate at a frequency of 

at least 0.0035 Hz. Further, daily spot checks of the SO2/CO2 ratio are "recommended". If the 

manufacturer is unable to provide assurance that the unit will meet the certified value this way, 

Scheme B is recommended. 

In Scheme B compliance is demonstrated by continuous monitoring. Thus SO2 and CO2

concentrations are to be measured after the abatement equipment with a frequency of at least 

0.0035 Hz. In this scheme parameters such as exhaust gas flow rate and water flow rate are to 

be checked daily. There should be a technical manual where it is stated, for example, the 

minimum and maximum water flow rate and minimum inlet 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 recording is described and the same for both 

schemes. The recording equipment must be tamper proof. For both schemes the ship must have 

a SOX emission compliance plan showing how the equipment should be used to comply and how 

this is demonstrated. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 70

In addition, both schemes will require continuous monitoring of the wash-water criteria discussed 

above, i.e., pH, PAH concentration, turbidity and temperature. 

Thus, in Scheme A the function of the abatement equipment is certified by continuously recording 

operational parameters such as water flow and pressure as well as wash-water parameters. In 

Scheme B the compliance is verified through direct measurements of the SO2 emission together 

with the wash-water parameters. Only Scheme B complies with the wording in Directive 

2005/33/EC. 

The advantage with continuous monitoring of the SO2/CO2 ratio is that compliance with 

regulations is directly monitored at all times. There 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 Johnsen et al, the measurement systems may 

also be affected by the high temperatures and the high 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 systems may then require much maintenance 

and calibration in order to function properly. 

Continuous monitoring can be of great value especially if the conditions that may influence the 

performance of the abatement equipment are likely to change. For sea water scrubbers this may 

be when moving in areas with seawater of varying alkalinity. In waters with low alkalinity more 

seawater is required to meet the required SO2 emissions and further, more dilution will be 

required to meet the wash water limit for pH. 

For closed loop scrubbers the function is not dependent on the characteristics of the surrounding 

seawater since the operation of the equipment involves fresh water and an added neutralising 

agent. 

The requirements in the MEPC guidelines make it possible to use Scheme A for closed 

scrubbers, it may also be suitable for some sea water scrubbers. During certification the 

feasibility of using Scheme A should also be investigated, i.e., by showing that the monitoring of 

the system parameters gives evidence that the SO2 emission and wash-water requirements are 

met. There may well be cases where a scrubber is not certified, for example, for use in rivers or 

brackish water systems and then the functionality can be expected to be more stable. If a system, 

during certification, is found to have too low a capacity under certain conditions, such as 

alkalinity, sea water temperature etc, it is possible to certify the unit using Scheme B. Since it is

possible that there will be a number of systems that can be monitored satisfactorily using Scheme 

A it is recommended that the IMO regulations regarding monitoring are incorporated also in the 

EU regulations. 

With the use of either scheme it is of great importance that the SO2 emissions and wash-water 

criteria are controlled. This might be achieved via regular certification measurements required by 

administrative provisions. Further surveillance of the SO2 emissions can be made by authorities 

using remote sensing of the SO2/CO2 ratio in the exhaust plume – from the land or from

airplanes, there is an ongoing program for the development of such systems at the JRC. 

Mellqvist et al. (2008) have demonstrated such a method 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. One problem may be that scrubbers can capture 

some CO2 and thus the SO2/CO2 in the exhaust may show values that over-represent the actual 

SO2 emissions. This problem could be circumvented by listing the scrubber units' CO2 capture 

capacity during certification. 

9.10 Conclusions and suggestions 

The use of scrubbers to clean the exhaust from marine engines using residual oil could in 

principle lead to high concentrations of a number of harmful compounds in the marine 

environment around the ships. The use of scrubbers in combination with high sulphur residual oil 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 71

may be an economically attractive option in SECA areas 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 the marine environment is protected. There 

should be mechanisms to prevent the use of scrubbers in certain areas if there is a risk to marine 

ecosystems. The technology allows for the use of closed systems - making it possible to limit the 

wash-water discharged in areas with limited water circulation or especially sensitive 

environmental conditions. Scrubbing systems can be used to abate particulate emissions. The 

present situation is somewhat incongruous in the sense that wash-water limits for scrubbers have 

been set up while there are only limits for the gaseous emissions of SO2 and NOx – a situation 

that does not reflect current concerns related to the health impacts of PM. It is recommended 

that criteria are developed that promote the abatement of PM with, as a minimum, limits set to 

allow either voluntary or market based reductions of PM emissions; it is suggested, furthermore, 

that where/when possible, EU regulations are kept in 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 monitoring onboard the ship. So, a major factor to be 

considered when formulating the criteria is that they should be suitable for online monitoring. 

However, it would also be possible to add additional criteria that are to be tested during 

certification. This could give further assurance that the units are environmentally safe and would 

not have to be constrained by the need to measure online. The wash-water criteria apply 

everywhere but it is possible that additional, separate, criteria can be developed for open sea. 

With the present criteria for pH it would appear that the dilution in the sea and natural buffering 

will rapidly give acceptable levels - even in confined areas. It is recommended, however, that 

further studies are undertaken for brackish and river water and that the criteria are then reviewed 

accordingly. It is suggested that the IMO guidelines are adopted for the pH criteria while, at the 

same time, allowing for revision as more data becomes available. If the criteria for open sea were 

relaxed then more acidic scrubber water may be emitted 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 expressed as phenanthrene equivalents. This is not a 

well established concept and should be further defined 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 was 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, nevertheless, to ensure a low discharge of a range of 

PAHs – so how the measured value relate to the PAH 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 criteria that are used are in line with Directive 

2008/105/EC. The criteria for THC suggested by Buhaug et al. could be used for commissioning. 

It is yet to be established that PAHphe is an adequate measure of the concentration of oil or THC 

in the wash-water. 

The criteria for turbidity may be suitable for establishing that unwanted solid material is not 

formed in the scrubber unit but it is unlikely to be appropriate as a measure of the proportion of 

particulate matter from the exhaust gas that captured and discharged with the effluent water. 

There is no simple relation between particle concentration and turbidity and the turbidity measure 

is strongly dependent on particle size. It is suggested that: the concentrations of particulate 

matter, metals, and PAH are regulated and tested during commissioning, and that the correlation 

to turbidity is investigated in order to allow continuous measurement onboard. Pending the 

delivery of data from on-going trials it is suggested that the turbidity criteria from IMO are used, 

alternatively the criteria suggested by Buhaug et al. could be applied. 

The criteria for nitrates could in principle lead to large additional discharges of nitrates to sensitive 

areas. The best way to deal with this issue would be to use exhaust gas NOx abatement 

technology. Taking the Baltic example described above, an engine with an emission factor of 17 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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g NOx /kWh should reduce its emission to about 9.4 g/kWh (if 12% of the NOx is emitted as 

nitrates with the scrubber water) in order not to increase the nitrate load when using a scrubber. It 

is recommended that provisions are made when setting criteria for nitrate emissions so that 

increased loads can be prevented in sensitive areas. 

Since there is limited data on the performance of marine scrubbers for SO2, it is important to 

follow on-going trials in order to ensure that thorough 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; these are frequently used though smaller than 

exhaust gas scrubbers made to comply with sulphur emission regulations. It is also important to 

obtain more data on the properties and amounts of the sludge produced. This will be needed in 

order to develop facilities for handling of the sludge by ports. 

It seems appropriate to adopt the IMO guidelines regarding monitoring, i.e., allowing for the 

possibility of using alternatives to continuous monitoring of the SO2 emissions on the basis that 

there will be units that can be adequately monitored by other means. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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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 exception 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 and as late as possible before departure. This 

regulation applies to all engines and to all boilers, including auxiliary boilers. 

These regulations will most likely make it necessary to use distillate fuel while at berth. There are 

concerns that there are risks associated with switching from residual oil to distillate fuel in boilers. 

This report has been drafted under the project “Service contract for a Cost Benefit Analysis to 

support the Impact Assessment accompanying the revision of Directive 1999/32/EC on the sulphur 

content of certain liquid fuels”, which was undertaken for the Commission by a team including 

TNO, IVL and AEA under an AEA-led framework contract. 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 be 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 searches 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, representatives 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 Fuel Oil (HFO) cannot, in general, be used with 

Marine Gas Oil (MGO) without modifications. A switch from HFO to MGO in a boiler that is 

designed for HFO use could lead to operational problems with potential flame failure and an 

increased risk of a boiler explosion. To avoid these 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 modifications, 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 modifications 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 seems to have been started during 2008 and, in 

most cases, activity intensified in 2009. The reason 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 expected that the sulphur directive would be reviewed 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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before 2010, and some ship-owners seem to have anticipated, 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, although once abundant, they are today relatively 

uncommon because diesel engines have a higher thermal efficiency and are more fuel efficient. 

An application where boilers are used for propulsion is for ships that transport LNG, the reason 

being that some of the cargo boils off during transport and using it as fuel for the ship recovers a 

part of the cargo that would otherwise be lost. For 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 the 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 gaseous fuel alone may not be sufficient. In such 

situations, dual fuel mode is used where oil and BOG is burnt simultaneously. A change in power 

can then be taken up more slowly by using gas. Further, 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 down ratio for gas burners and so oil is used at 

low loads too. The boiler powered LNG ships used today are designed for a combination of BOG 

and HFO. Typically, a ship that would use 150 tonnes 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 low (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 boilers can use both HFO and MGO. Typically, 

boilers are used with HFO on ships that use this fuel for propulsion. The type of fuel used in 

auxiliary boilers has not been investigated in detail since the fuel consumption is normally 

assumed to be a minor part compared to main and auxiliary engines; it is difficult, therefore, to 

establish the exact distribution of boilers that use 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 modifications to existing boilers to manage the 

switch from HFO to MGO applies, in principle, to all ships by 2010. It is today not clear how many 

of these will need modifications. Work by the leading manufacturer of boilers, Aalborg industries 

(Aalborg 2009) and a study by the California Air Resource board (CARB 2008) indicates that 

most boilers can at least temporarily use MGO without problems. However, both studies, as well 

as a report by DNV (DNV 2005), state that MGO should not be used in a boiler designed for HFO 

before it has been inspected. Further, a large number 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 unlikely 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 ships may use diesel engines or electrical motors 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 75

to drive the pumps, and some use electrical heating. These boilers are more likely to need 

modifications since they use relatively large amounts 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 likelihood, 

not be complete until late 2010. 

The boilers on tankers are often used during the discharge of the cargo. Intertanko estimated 

that in 2006 there were 8 000 - 10 000 port calls of 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 2005 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 dual fuel diesel engines that can burn fuel oil 

(distillate or HFO) and gas. LNG tankers are refitted 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 ships are modified. The ships could also be taken out 

of service for the modifications, which could be complete within approximately one - two years. 

The latter alternative then implies extra costs when the ships are out of service for modifications.

There are approximately 690 deliveries by LNG tankers 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 high pressure of fuel gas builds up in the burner, 

and the control system is malfunctioning or disconnected. In such a case, the furnace must be 

purged before ignition. Failure to do this may cause an explosion, as for example reported by the 

British Department of Transport (1983). There are flame monitoring and control systems that will 

automatically purge the furnace so that during normal operation the risks for explosions are small. 

There are concerns that these risks may be higher when switching over from residual oil to 

distillate fuel. This is noted by the IMO subcommittee on bulk liquids (2007), which states: "The 

routine switching between marine distillate and Heavy 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 regulations for California which apply from 1 July 

2009. These regulations stipulate that Marine Gas Oil (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 maintenance are essential for vessels to safely 

switch between heavy/intermediate fuel oils and marine distillates". The notice is about all 

engines and auxiliary boilers and suggests that each system should be assessed for 

modifications and that training and routines should be established. 

The reason for the special concerns regarding a fuel switch from HFO to distillates is that the 

pipes and other parts are heated when using residual oil. When the distillate enters the furnace 

there are concerns that it will fail to ignite, causing a build-up of gases that in turn is an explosion 

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 engines). This irregular fuel and vapour flows/bursts 

towards burners can cause flame extinction; the lighter the fuel, the easier the evaporation and 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 76

the larger the risk for an air/fuel mix which is potentially unsafe. There are concerns that the crew 

on many ships may not be familiar with managing these situations safely. 

The boilers normally run on MGO during start up; however, at this point the system has not yet 

been heated. After the boiler pressure is up, the pipes can be emptied of MGO and then heated 

and used for HFO. MGO is thus not introduced to the boiler through heated pipes at this stage. 

In normal ship installations, "heat tracing" of pipes (by steam or electric heating) can be turned on 

or off. In this kind of installation, proper operation may be sufficient to avoid the risk of an 

explosion. In many cases, fuel switching is automatically managed by the ships’ hardware and 

software (and there is no difference between fuel flows 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, however, the ship’s officers must follow very 

precise operational instructions. 

Besides concerns about explosions inside the boilers, there are other issues that need to be 

addressed before a boiler designed for HFO can be used with MGO. These, reported by DNV 

(DNV 2005) and Aalborg industries (Aalborg 2009), include: 

• 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 deposits may build up when using distillate 

fuel. In steam atomising burners the MGO may be heated - causing vaporisation. 

Other concerns raised, by the shipping industry, about the regulations from 1 January 2010 

related to: 

1) problems with the supply of fuel with 0.1% sulphur for ships at berth; 

2) issues with ships not having enough fuel tanks to 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 investigate 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 in 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 boilers are used for propulsion, it is essential 

that the fuel supply is not interrupted. As described 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 reasons: 

1) There would be an increased risk of failure in fuel pumps and valves. 

2) The distillate fuel could be unintentionally heated 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 oil 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 temperature gradients when cold fuel oil is 

used could cause distortion of the tubings used for oil supply. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 77

4) The burner management system and flame supervision/monitoring systems are 

designed for HFO. 

10.6 Technical solutions and costs 

For the safety and operational reasons discussed above, all boilers designed for the use of HFO 

should be inspected before they are used with distillate 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 supervision 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 separately at the end of this section. 

The risk of a boiler explosion, as discussed above, is associated with the vaporisation of 

distillate fuel in combination with flame failure and improper purging. To avoid the heating of MGO 

in the piping system, heaters should be by-passed or the tracing of fuel pipes turned off. The fuel 

system should have time to cool to around 60°C before 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 different 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 mixture in the furnace has been purged in a safe 

way. 

Fuel pumps may have to be modified or replaced to be able to tolerate MGO, with lower viscosity 

and lubricating properties than HFO, for a longer period. 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 boilers is not known. Boiler suppliers estimate costs in 

the range of 5 000 to 25 000 € per boiler when modifications are needed. For tankers with large 

boilers, costs around 150 000 € per ship have been quoted. There will also be costs for approval 

and certification. 

For LNG ships with steam turbine propulsion, the boil-off from the cargo is used in combination 

with HFO. For the reasons described above, these ships should be modified before they are used 

with MGO. 

The boiler management system (BMS) settings will have to be adjusted, new flame scanners may 

have to be installed, and a separate fuel supply system for MGO will be needed. The majority of 

burners will have to be modified to avoid vaporisation. Further, fuel change-over procedures 

have to be investigated. Some ships may also need larger tanks for MGO in order to 

accommodate enough fuel for one port stay. 

These modifications and actions would make it possible 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 manufacturers 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 interruptions and operational problems. The costs 

for these measures have been estimated by SIGTTO. The 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 600 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 78

000 €. To this should be added costs for taking the ships out of service if the modifications are 

done outside a regular refit. 

An alternative solution would be to use 100% BOG while at berth. There are, however, concerns 

about the stability of the boiler power at low loads. It is unclear if this can be implemented on all 

ships and modifications to the control system and BMS would be needed. Further, there are 

situations where 100% BOG cannot be used. This applies for relighting after a flame failure and in 

cases where there is no LNG cargo, as when ships enter/leave refit/dry dock. Therefore, this 

alternative does not comply in full with the EU directive. No cost estimates are available for this 

alternative because the extent of modifications needed has not yet been investigated. This 

alternative may require substantial modifications and may be more expensive than the previous 

alternative. The problems with stability and non-compliance make this alternative less attractive 

for the industry. Also, some ship-owners do not see this as a solution to comply with the SECA 

rules coming in 2015 because 100% BOG will be unsuitable 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 combination of low sulphur HFO and BOG would 

then be used in such a way that the emissions of SO2 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 SO2 emissions could be lowered further. This option would allow for 

fuel boost with HFO in the case of flame failure. This 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 depends on whether the equivalence principle 

outlined is regarded to be in line with paragraph 4c. In addtion, the ships would still need to use 

HFO after refit. This option would be likely to require a monitoring system with either control of 

fuel use and sulphur levels in the fuel or the installation of flue gas monitoring systems to monitor 

the SO2 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 application. 

10.7 Conclusions 

There are genuine safety risks associated with switching from HFO to MGO in existing boilers 

that are supported by evidence gained through contacts with the industry and authorities. There 

are, however, technical and operational ways to circumvent these risks. 

Although many boilers can be used with MGO, all boilers 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 around 2500 tankers that use boilers for steam 

driven pumps and/or cargo heating - and most are likely to need to be modified. 

The main safety concern is that a distillate fuel may vaporise in hot boilers with heated pipes. If 

the boiler system has not been modified, there is—in the case of flame failure and improper 

handling—a risk of an explosion. 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. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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 make an inventory of the requirements with regard 

to the maximum sulphur content of heating oil in condensation boilers for heating purposes. 

Where relevant, the requirements for different categories of condensation boilers are given. 

11.2 Introduction to oil fired condensation boilers

Until recent years there were only household heating 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 between boilers that can use only low sulphur 

heating oils and other boilers that can use the different 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 flue gas water vapour on the heat exchange 

surfaces must be avoided because of corrosion. Condensation technology recovers the latent 

heat of the water vapour in the flue gases by condensation. Condensation of water vapour occurs 

when flue gases are cooled down to temperatures below 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 efficiency 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 outside temperature - whereas conventional 

boilers provide a constant water temperature. Especially in spring and autumn when heating 

demand is much lower than nominal capacity, the efficiency of condensing boilers is much higher 

than 6% compared to conventional boilers because the firing is modulated [1]. 

11.3 Heating oil quality and availability 

According to Directive 1999/32/EC the content of sulphur 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 intermediate 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. Overall a continuing decrease in heating oil use is 

expected as the result of further natural gas substitution and improved equipment efficiency (i.e. 

replacement of old heating systems) but may be sustained in some markets i.e. housing 

developments outside cities (beyond the gas distribution system) [6] 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 80

According to a Concawe study [7] the weighted average sulphur content in the gas oil 

(automotive diesel fuel, heating oil, industrial gas 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 content 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 Northwest Europe and the Atlantic. 

11.4 Construction of condensation boilers 

In most conventional low temperature boilers hot flue gases flow horizontally through the heat 

changer and condensation must be avoided. In condensation boilers hot flue gases flow 

downwards through the heat exchanger, water is allowed to condense, this also drains 

downwards providing a self cleaning effect that prevents the accumulation of salts on the heat 

exchange surfaces. Depending on the amount of sulphur 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 aluminium 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 additional surface treatment. 

11.5 Condensation boilers and sulphur content of heating oil 

Traditional heating oil (EL quality) contains up to 2000 mg/kg sulphur, its flue gas condensate 

contains significant amounts of sulphurous and sulphuric 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 standard heating oil be used in all condensation 

boilers on the market - some producers only allow the use of low sulphur heating oil. 

Condensation boilers for standard heating oil are specifically constructed for this duty and tend to 

have lower heat efficiencies [4]. 

Originally producers of condensation boilers in Germany were reluctant to specify the use of low 

sulphur oil but concerns were allayed following extensive tests [5]. A distinction should be made, 

irrespective of whether or not heating oil of differing 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 using 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 boiler 

This category of condensation boilers has been on the 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 sulphur oils. Heat exchangers in this category 

have to be made of corrosion resistant material like 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 sulphur reduced heating oil (< 500 mg/kg) [2]. The 

use of high sulphur heating oil (1000 mg/kg) in this 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. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 81

Air-to-water condensation boilers that cool flue gases 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 category of condensation boilers because 

condensation does not take place in the first (internal) 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 condensation 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 made 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 aggressive and neutralisation of the condensate 

may be required before discharge - depending on heating capacity of the boiler and wastewater 

quality regulations. 

Air-to-air condensation boilers in which condensation takes place in the flue gas system to 

preheat incoming combustion air. 

In these systems the internal heat exchanger and water 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. Heating 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 exchanger surfaces caused by use of high 

sulphur heating oils are more problematic in condensation boilers with integrated heat exchanger 

than in boilers with an add-on condensation heat exchanger. 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. Efficiency 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. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 82

12 References: 

Section 4

Amman et al, 2008. National Emission Ceilings for 2020 based on the 2008 Climate and Energy 

Package. NEC Scenario Analysis report, nr 6. IIASA.

Chiffi, Fiorello, Schrooten, De Vlieger, 2007. EX-TREMIS - 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 Directive. 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 Health, Munich, Germany. 

Roemer M., T. van Harmelen and P. Builtjes (2006). Establishment of optimal control areas for 

acidification, eutrophication and ground level ozone. TNO report 2006-A-R0251/B, TNO, Utrecht, 

The Netherlands. 

Schaap M., M. Roemer, F. Sauter, G. Boesen, R. Timmermans and P. Builtjes (2005). LOTOSEUROS: documentation. TNO report B&O-A R2005/297, TNO, 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 of emission trading for sulphur dioxide and 

nitrogen dioxide. TNO report 2007-A-R1256/B, TNO, Utrecht, 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 IMO SPECIFICATION 

CHANGES & OTHER MEASURES TO REDUCE THE SULPHUR CONTENT OF CERTAIN 

FUELS 

Entec, 2005, Service contract on ship emissions: Assignment, Abatement and Market-based 

instruments 

UK-Maritime and Coastgard Agency, 2009, Impact assessment of merchant Shipping (prevention 

of Air pollution from ships (Amendment)) Regulations 2009 

US-EPA, 2009, Proposal to Designate an Emission Control Area for Nitrogen Oxides, Sulfur 

Oxides and Particulate Matter - Technical Support Document - Chapter 5 Costs, Assessment and 

Standards Division Office of Transportation and Air Quality U.S. Environmental Protection Agency 

Krystallion, Sea Water Scrubbing – Does it Contribute to increased Global CO2 Emissions 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 83

www.purchasingdata.com 

Wärtsilä, 2009, General description of Wärtsilä scrubber system 

Marine and Energy Consulting limited, 2009, presentation at 2nd Bunker Fuel Management, 16th 

& 17th September, London, UK 

Delft 2006. Greenhouse Gas Emissions for Shipping and Implementation 

Guidance for the Marine Fuel Sulphur Directive 

Chiffi, Fiorello, Schrooten, De Vlieger, 2007. EX-TREMIS - 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 Ships: Dependence on Fuel Type, J. Air & 

Waste Manage. Assoc. 59:1391 (2009). 

V. Eyring, H. W. Köhler, J. van Aardenne and A. Lauer, Emissions from international shipping: 1. 

The last 50 years. J. Geophys. Res. 110, D17305 (2005). 

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 States Environmental Protection Agency, 

Washington D.C. 20460, The Red book, July 1976. 

Polycyclic aromatic hydrocarbons (PAH), KEMI Swedish Chemicals Agency, www.kemi.se 

Phenanthrene CAS Number 85-01-8, United States Environmental Protection Agency 

www.epa.gov/waste/hazard/wastemin/minimize/factshts/phenanth.pdf

Billiard, S. M., Meyer, J. N., Wassenberg, D. M., Hodson, P. V., Di Giulio, R. T. 2008. Nonadditive 

effects of PAHs on early vertebrate development: Mechanisms and implications for risk 

assessment. Toxicol. Sci. 105: 5-23. 

Behrends, B., & Liebezeit, G., 2003, Reducing SOX and NOX Emissions from Ships by a 

Seawater Scrubber. Research Centre Terramare, Wilhelmshaven, Germany. 

Hufnagel, M., Liebezeit, G., & Behrends, B., 2005. Effects of Sea Water Scrubbing, Final report. 

Buhaug, Ø., Fløgstad, H., Bakke T., 2006. MARULS WP3: Wash-water Criteria for seawater 

exhaust gas-SOX scrubbers. MARINTEK report, for Norwegian Marine Technology. 

Karle, I-M. and Turner, D., 2007. Seawater Scrubbing - reduction of SOX emissions from ship 

exhausts. Department of Chemistry, Göteborg University, ISBN: 978-91-976534-1-1. 

MEPC 59/4/19. Marine Environment Protection Committee, 59 th session Agenda item 4. 

Prevention of air pollution from ships. Advice by GESAMP on the interim criteria for discharge of 

wash-water from Exhaust Gas Cleaning Systems for removal of sulphur-oxides. 

Whall et al., Quantification of emissions from ships associated with ship movements between 

ports in the European Community, Entec 2002. 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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-Öresund region, Athmospheric Environment 30, 

2463. 

MEPC 56/INF.5, ANNEX 1, Page 22 

Directive 2008/105/EC of the European Parliament and of the Council of 16 December 2008 on 

environmental quality standards in the field of water policy, amending and subsequently repealing 

Council Directives 82/176/EEC, 83/513/EEC, 84/156/EEC, 84/491/EEC, 86/280/EEC and 

amending Directive 2000/60/EC of the European Parliament 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 Acidification,Eutrophication and Ground Level Ozone 

in Europe in 2007, EMEP Status Report. 

Johnsen et al., (2006) Part C of Delft report Greenhouse Gas Emissions for Shipping and 

Implementation Guidance for the Marine Fuel Sulphur Directive, DNV. 

Mellqvist, J, Berg, N. and Ohlsson, D., 2008. Remote surveillance Remote surveillance of the 

sulfur content and NOx 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/12FuelchangetoMDOMGO-09JAN09.pdf. 

British Department of Transport 1983. Explosion in boiler furnaces, Merchant Shipping Notice No. 

M. 1083, August 1983. 

CARB 2008. California Environmental Protection Agency Air Resource Board, Fuel sulfur and 

other operational requirements for ocean-going vessels within California waters and 24 nautical 

miles of the California baseline, June 2008. 

http://www.arb.ca.gov/regact/2008/fuelogv08/isorfuelogv08.pdf. 

DNV 2005. DNV, Regulations for the prevention of air 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 emissions from ships associated with ship 

movements between ports in the European Community, Entec, European Commission, 2002. 

IMO subcommittee on bulk liquids, 2007. Review of MARPOL VI and the NOx technical code 

December, 2007. 

US coast guard Maritime Safety Alert, 2009. Avoiding propulsion loss from fuel switching: 

American Petroleum Institute Technical Considerations. May 2009. 

Section 11 

Condensation technology – Condensation technology for energy saving and a clean 

environment.Documentation Viessmann (www.viessmann.com) [1] 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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Rogatty, W.: Modern oil-heating technology. IKZ-Haustechnik, Volume 8/2004, page 60 [2]

 . 

Brennwerttechnik. : http://www.energiesparmobil.de/downloads_infomaterial/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/38680.php) [4] 

Geräteeignung und Verfügbarkeit. Institut für wirtschaftliche Oelheizung e.V. 

http://www.iwo.de/sites/iwo_website/standard.jsp?nodeId=159355&open=x&pagename=TECH_HELSA_0 [5] 

Impacts on the EU refining industry & markets of IMO 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 refineries 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. Gustafsson, 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: 1652-4179. 

IPCC 1995, Greenhouse gas inventory Reference manual. 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 
Cost benefit analysis to support the impact assessment AEA/ED05315018/Issue 3 

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13 Appendix 1 - Emission factors used 

Table 1: Unabated emission factors used in the baseline scenario 

kg/ton kg/GJ source notes 

heavy fuel 

oil 

SO2-SECA 29 0.72 TFEIP 2009 1.45% S, after 2006 in North Sea and Baltic Sea 

in baseline 

SO2 54 1.34 TFEIP 2009 2,70% S, pre-2006 

NOx 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 

SO2 4 0.09 TFEIP 2009 0.2% S 

NOx 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 between member states, the sulphur content of diesel fuel has 

been lowered to 0.1%. Data were insufficient to make this distinction in the emission calculation. 

Table 2: Unabated emission factors by fuel and motor speed 

Fuel consumption NOx 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 gasoil 

GT-RO: gas turbine – bunker fuel oil 

HSD-MG/DO: high speed diesel - marine diesel oil/marine 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/marine gasoil 

SSD-RO: slow speed diesel – bunker fuel oil 

ST-MG/DO: steam turbines - marine diesel oil/marine 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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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: SO2 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/GJ 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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Table 5: NOx 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 NOx limits to marine diesel engines and Emission Control Areas (ECAs) 

NOX emissions are regulated under the International Maritime Organization (IMO), in the 

International Convention for the Prevention of Pollution From Ships, 1973 as modified by the 

Protocol of 1978 (in short MARPOL 73/78). NOx limits 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 Protection 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 NOx limits 

The revised NOx regulations contain a three-Tier approach as follows: 

Tier I (identical to today’s limits) 

For diesel engines installed on ships constructed from 1 January 2000 to 1 January 2011, the 

allowable NOx emissions are: 
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• 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 on 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 have additional limitations when operating in an 

Emission Control Area (ECA). No ECAs have yet been designated for NOx emissions, but it is 

expected that both the Baltic Sea and North Sea will be designated as NOx 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 less than 2,000 rpm 

• 1.96 g/kWh when n is 2,000 rpm or more 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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14 Appendix 2 - Emission Figures by 

Scenario and Area Baseline 

Emission Figures by Scenario and Area Baseline 

Baltic Sea Black Sea Remaining NE Atlantic 

ocean 

x 1000 

tonnes 2000 2015 2020 2000 2015 2020 2000 2015 2020 

SO2 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

NOx 283 439 498 83 130 147 742 1153 1310

Mediterranean Sea North Sea 

X 1000 

tonnes 2000 2015 2020 2000 2015 2020 

SO2 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

NOx 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 

SO2 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

NOx 364 325 108 115 957 1,018 2,055 1,841 856 765
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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 

SO2 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

NOx 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 

SO2 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

NOx 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 

SO2 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

NOx 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 

SO2 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

NOx 364 325 108 115 957 1,018 2,055 1,841 856 765
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Emissions land based sources, baseline and scenarios Baseline 

2000 2010 2015 2020 

x 1000 tonnes 

SO2 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

NOx 16,582 13,839 12,691 11,312

Note: exclusive of emissions related to national maritime fuel consumption (e.g. fisheries), which are included in the 

GAINS-totals 

Source: GAINS Europe, NEC6, C&E package current policy 

Land based A 

2015 2020 

x 1000 tonnes 

SO2 9,851 9694

NMVOC 12,374 11931

PM10 3,988 3,988

PM2.5 2,716 2,678

NOx 12,691 11,312

Land based B 

2015 2020 

x 1000 tonnes 

SO2 9,806 9,665

NMVOC 12,374 11,931

PM10 3,988 3,988

PM2.5 2,716 2,678

NOx 12,691 11,312
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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15 Appendix 3 - Relevant geographical 

representations of the dispersion 

calculations 

In this appendix the most relevant results of the dispersion calculations are presented. 

First some background information is given on the relevant 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 given the fact that this is considered a 

representative year for the European meteorology. 

The absolute values of the calculated pollutant concentration 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 scientific debate and it is not easy to answer how 

much more of ozone we can expect in 2020. Because the effect of IMO regulations on NOx

emissions in the remaining North Atlantic beyond 10 W is not quantified we do not know how this 

will affect background ozone concentrations. In general terms one can state; with each 1ug/m3

increase of the background one can expect at the fringe of Europe, as a rough maximum 

estimate, an increase of 2500 ug/m3.h in AOT40f, simply being the number of associated hours in 

the AOT40f definition that will be increased with 1 ug/m3, plus a few hours that in addition will 

exceed the threshold. At the interior of Europe this will be less, since part (say 70%) of the extra 

ozone will be consumed by dry deposition, leaving an increase as a rule of thumb of 800 ug/m3.h. 

Suppose the hemispheric increase of ozone between 2010 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 their lowest SRES scenario, an increase of 

AOT40f due to hemispheric changes of 2000 ug/m3.h from 2010 to 2020 on top of an AOT40f in 

2010 of about 14000 ug/m3.h. 

 

Uncertainty estimates in changes in hemispheric ozone are hard to give since the cause of the 

changes is poorly understood; given this lack of knowledge we estimate an uncertainty of 100%. 

The inter-annual variability in AOT40f can be as large as 8000 ug/m3.h fluctuation from one year 

to another, but on average the fluctuation is typical in the other of 3000 ug/m3.h. For continental 

sites as in Switzerland and Austria the aforementioned fluctuations are 30% and 12% of the long 

term average of AOT40f in these countries. In the UK of the Netherlands (with much lower longterm baseline AOT40f values) the fluctuations in relative terms are much larger, typically in the 

order of 100-50%. More important are the inter-annual 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 AOT40f the inter-annual fluctuations are much 

smaller, and more robust against the choice of meteorological year. 

For other ozone metrics that are derived from larger 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. 

 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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The atmosphere is never in equilibrium. The lifetime of NOx 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 NOx 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 

acidification 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 the calculated benefits? 

A smaller grid means a smaller grid for the dispersion 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 concentration (deposition) of all associated 10x10 

grid cells, then we can expect differences in the choice of grid cell only if the set 10x10 km 

concentration data within 50x50 km bears some correlation with the set of 10x10 km ecosystem 

(population) data. This will be specified for the themes separately. 

Acidification. / Eutrophication 

We have no information on the distribution of sensitive ecosystems (with regard to acidification or 

eutrophication) at scales smaller than 50x50 km. Therefore, 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 NOx concentrations grid cells within a 50x50 km grid cell will not differ 

much from the value in a 50x50 km cell. This part won’t be affected by working on smaller scales. 

In urban areas, characterised by high levels of NOx ozone concentrations (SOMO35) vary in 

general from relatively low values in the city centres (high NOx levels, densely populated) to 

relatively high values in residential suburban areas (lower NOx, 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 corresponding 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 the 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 the effect is smaller due to the damping effect 

of the smoother sulphate and nitrate fields). The effect is that in urban areas the 

PM10*inhabitants’ values are larger for a smaller grid than for a larger grid. 

 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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sulphur content of certain liquid fuels 

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Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 96 Figure A1: Average Accumulated Exceedence for acidification (eq./ha/yr) for 2015 . a) Baseline In all areas, not colored green, there is an exceedence of the critical load b) Fractional change (%) of SEA1 compared to base line The map shows clearly the reduction of the exceedence of the critical load all round the North Sea and the Baltic due the designation of these waters as SECA. c) Fractional change (%) of SEA 2 compared to SEA 1 Thus the effect of inclusion of the Mediterranean sea and Black sea in the SECA does add only to a small extend to the improvement gained in scenario SEA1 compared to the baseline. d) Fractional change (%) of SEA 3 compared to SEA 3 Reduction of the S content outside the SECAs does lower the exceedence of the critical load in the UK and IR. See also table 7 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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sulphur content of certain liquid fuels 

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Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 98 Figure A2 Average Accumulated Exceedence for acidification (eq./ha/yr) for 2015. . a) Baseline In all areas, not colored green, there is an exceedence of the critical load b) Fractional change (%) of Bbase compared to Baseline The map shows the positive effect on the exceedence of the critical load for acidification when lowering the S content of fuel on land to 0.001%. This map indicates the maximum effect of lowering the S content in land based fuel. c) Fractional change (%) of BSEA1 compared to SEA 1 The map shows the same picture as map b), the minor differences 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 S content of fuel on land is marginal approximately 1.3 to 2.8 % reduction. Because acidification is the parameter effected the most by sulfur emissions this analysis is not performed for the other parameters See also table 7 and 9 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 99
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 100 Figure A3: Average Accumulated Exceedence for eutrophication (eq./ha/yr) for 2015. . a) Baseline In all areas, not colored green, there is an exceedence of the critical load b) Fractional change (%) of SEA1 compared to baseline The map shows the reduction of the exceedence of the critical load as a result of the NOx Tier I & II standards in all European seas. The designation of the North Sea and the Baltic des not have an significant impact on the exceedence. Which can be seen in the next map c) Fractional change (%) of SEA2 compared to SEA1 Thus the effect of inclusion of the Mediterranean sea and Black sea in the does not add significant to the improvement gained in scenario SEA1 compared to the baseline. d) Fractional change (%) of SEA3 compared to SEA2 Extension of the SECA with the Black Sea does lower the exceedence of the critical load only to a very small extend. See also table 10 en 12 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 101
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 102 Figure A4 AOT40f (ppm.h) for 2015. a) Baseline b) Difference (ppm.h) of SEA1 compared to baseline The map shows clearly the reduction of the ozone concentration as an result of the reduced NOx emissions in all seas as a result of the Tier standards. The effect in the Mediterranean is enhanced by the longer periods of sunshine. The maps c and d show a similar picture but there are small differences. These are elaborated in table 22 in 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
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 103
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 104

. 

Figure A5 SOMO35 (ppm.h) for 2015. 

. 

a) Baseline b) Difference (ppm.h) of SEA1 compared to baseline 

The map shows clearly the reduction of the ozone concentration as an result of the reduced NOx emissions in all 

seas as a result of the Tier standards. The effect in the Mediterranean is enhanced by the longer periods of 

sunshine. 

The maps c and d show a similar picture but there are small differences. These are elaborated in table 16 in 

appendix 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 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 105
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 106 Figure A6 PM10 (ug/m

3) for 2015 

. 

a) Baseline b) SEA 1 

The map shows the positive effect on PM concentration when designating the North Sea / English Channel and The Baltic as SECA. The reduction of sulfur in fuels is associated with an reduction in PM emissions. In the coastal zones all round the SECA 

show reduced concentrations of PM 

c) SEA 2 

The map shows the positive effect when designating the Baltic Sea, North Sea / English Channel, the Mediterranean Sea and the Black Sea as SECA. Although not clearly indicated in the map the differences with the former map is that the concentrations in the 

Mediterranean coastal zones are reduced. See also table 13 and 15 in appendix 4 

d) SEA 3 

Extension of the SECA with the Black Sea does lower the concentration in this area..
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 107
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 108 Figure A7 PM10 (ug/m

3) for 2015 

. 

a) Baseline b) Fractional change (%) of SEA1 compared to baseline 

The next map shows the positive effect on PM concentration when designating the North Sea / English Channel and The Baltic as 

SECA. The reduction of sulfur in fuels is associated with an reduction in PM emissions. 

c) Fractional change (%) of SEA2 compared to baseline 

The map shows the positive effect (% reduction in concentration) when designating the Mediterranean sea and the Black Sea as 

SECA. 

d) Fractional change (%) of SEA3 compared to baseline 

Extension of the SECA with the Black Sea reduces the PM concentration in this area. 

See also table 13 and 15 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 109
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 110 Figure A8: Average Accumulated Exceedence for acidification (eq./ha/yr) for 2020. . a) Baseline In all areas, not colored green, there is an exceedence of the critical load b) Fractional change (%) of SEA1 compared to baseline The map shows clearly the reduction of the exceedence of the critical load all round the North Sea and the Baltic due the designation of these waters as SECA. c) Fractional change (%) of SEA 3 compared to SEA 1 Thus the effect of inclusion of the Mediterranean sea and Black sea in the SECA does add only to a small extend to the improvement gained in scenario SEA1 compared to the baseline. d) Fractional change (%) of SEA 4 compared to SEA 3 Reduction of the S content outside the SECAs does lower the exceedence of the critical load in the UK and IR. See also table 8 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 111
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 112 Figure A9 Average Accumulated Exceedence for acidification (eq./ha/yr) for 2020. . a) Fractional change (%) of ASEA 1 compared to SEA 1 The map shows the small positive effect on the exceedence of the critical load for acidification when lowering the S content of fuel on land to 0.05%. b) Fractional change (%) of BSEA 1 compared to SEA 1 The map shows the positive effect on the exceedence of the critical load for acidification when lowering the S content of fuel on land to 0.001%. There are only small difference to map a especially in those grid cells with high population densities. c) Fractional change (%) of ASEA 4 compared to SEA 4 The map shows the same picture as map a), the only difference is that in these scenario’s the sulphur content outside the SECA is reduced to 0.5 %. d) Fractional change (%) of BSEA 4 compared to SEA 4 The map shows the same picture as map b), the only difference is that in these scenario’s the sulphur content outside the 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 when lowering the S content of fuel on land is marginal approximately 1.2 to 2.1 % reduction. Because acidification is the parameter effected the most by sulfur emissions this analysis is not performed for the other parameters See also table 9 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 113
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 114 Figure A10: Average Accumulated Exceedence for eutrophication (eq./ha/yr) for 2020. . a) Baseline In all areas, not colored green, there is an exceedence of the critical load b) fractional change (%) of SEA1 compared to baseline The map shows clearly the reduction of the exceedence of the critical load all round the North Sea and the Baltic due the designation of these waters as SECA. Also the exceedence in the Mediterranean countries improves as a result of the NOX Tier standards. c) fractional change (%) of SEA 3 compared to SEA 1 Thus the effect of inclusion of the Mediterranean sea and Black sea in the SECA and designation these waters as NECA does add to the improvement gained in scenario SEA1 compared to the baseline. d) fractional change (%) of SEA 4 compared to SEA 3 Reduction of the S content outside the SECAs does lower the exceedence of the critical load only to a small extend. The remainder reduction in SEA4 stems from the NECA in the Mediterranean and the Black Sea See also table 11 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 115
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 116 Figure A11 PM10 (ug/m

3) for 2020. 

. 

a) Baseline b) SEA 1 

The 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 PM emissions. In the coastal zones all round the SECA show reduced concentrations of PM 

c) SEA 3 

The map shows the positive effect when designating the Baltic Sea, North Sea / English Channel, the Mediterranean Sea and the Black Sea as SECA. Although not clearly indicated in the map the differences with the former map is that the concentrations in the Mediterranean coastal zones are reduced. See also table 14 in appendix 4 

d) SEA 5 

The map shows that reducing the S content outside the SECA has a positive effect on PM10 particularly in the UK and IR (compare to map b). 

For more details see also table 14 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 117
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 118 Figure A12 PM10 (ug/m

3) for 2020. 

. 

a) Baseline b) fractional change (%) of SEA 1 compared to baseline 

The next 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 PM emissions.. 

c) fractional change (%) of SEA 3 compared to baseline 

The map shows the positive effect (% reduction in concentration) when designating the Mediterranean sea and 

the 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 baseline 

The map shows that reducing the S content outside the SECA (Mediterranean Sea and Black Sea are in this 

scenario 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 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 119
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 120 Figure 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 1 The map shows clearly the reduction of the ozone concentration as an result of the reduced NOx emissions in all seas as a result of the Tier standards. c) difference (ppm.h) of ASEA 4 compared to SEA 4 Thus the effect of inclusion of the Mediterranean Sea and Black sea in the SECA does not add to the improvement gained in scenario SEA1 compared to the baseline. d) difference (ppm.h) of BSEA 4 compared to SEA 4 Reduction of the S content outside the SECAs does not add to a reduction of ozone compared to SEA1. SEA1 is comparable to SEA4. Al the maps show little differences as one could expect because the differences shown in the maps are the result of lowering the S content in fuel used on land. Because the differences are that small please see also 24 and 27 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 121
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 122

 

Figure A14 AOT40F (ppm.h) for 2020. 

. 

a) Baseline b) Difference (ppm.h) of SEA1 compared to baseline 

The map shows clearly the reduction of the ozone concentration as an result of the reduced NOx emissions in all seas 

as a result of the Tier standards. 

c) Difference (ppm.h) of SEA3 compared to baseline 

Thus the effect of inclusion of the Mediterranean Sea and Black sea in the SECA does not add to the improvement gained in scenario SEA1 compared to the baseline. 

d) Difference (ppm.h) of SEA4 compared to baseline 

Reduction of the S content outside the SECAs does not add to a reduction of ozone compared to SEA1. SEA1 is 

comparable to SEA4. See also table 23 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 123
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 124 Figure A15 SOMO35 (ppm.h) for 2020. . a) Baseline b) Difference (ppm.h) of SEA 1 compared to baseline The map shows clearly the reduction of the ozone concentration as an result of the reduced NOx emissions in all seas as a result of the Tier standards. c) Difference (ppm.h) of SEA 3 compared to baseline Thus the effect of inclusion of the Mediterranean sea and Black sea in the SECA does not add to the improvement gained in scenario SEA1 compared to the baseline. d) Difference (ppm.h) of SEA 4 compared to baseline Reduction of the S content outside the SECAs does not add to a reduction of ozone compared to SEA1. SEA1 is comparable to SEA4. See also table 17 in appendix 4 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 125

16 Appendix 4 - Results per EU member 

states 

In this appendix the results of the dispersion modelling 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 2020 are presented. A third table shows the 

absolute and percentage difference between different 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 2055 2049 

CH Switzerland 41084 434 422 392 392 418 414 430 426 

CY Cyprus 5120 48 48 39 39 48 48 47 47 

CZ Czech republic 78600 1216 1167 1151 1150 1159 1149 1207 1198 

DE Germany 355693 5826 5161 5100 5100 5054 4933 5719 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 1613 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 869 650 647 647 637 624 855 843 

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 1324 1319 

RO Romania 237394 3821 3791 3656 3615 3778 3764 3807 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 

 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 126

Table 2: Sulphur deposition in 2020 (Meq/year) 

Area 

(km2) base SEA1 SEA3 SEA4 SEA5 ASEA1 BSEA1 ASEA4 BSEA4 

AT Austria 83756 897 857 791 790 780 849 838 782 771 

BE Belgium 30520 1002 872 866 852 852 843 824 824 805 

BG Bulgaria 110857 2033 2033 1864 1885 1861 2028 2023 1879 1875 

CH Switzerland 41084 427 414 381 376 371 410 408 372 370 

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 5007 4939 4877 

DK Denmark 44270 782 335 332 323 323 333 329 321 318 

EE Estonia 45263 456 306 303 300 299 305 304 299 297 

ES Spain 497559 5569 5716 4817 3912 3784 5697 5684 3893 3880 

FI Finland 334395 1641 1234 1227 1209 1208 1232 1225 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 772 731 729 629 629 719 711 618 609 

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 889 641 638 627 627 630 622 616 608 

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 3824 3655 3645 

SE Sweden 446266 3040 1870 1854 1805 1803 1861 1851 1796 1786 

SK Slovakia 48857 800 782 761 761 758 780 777 758 755 

SL Slovenia 20672 380 381 315 322 313 377 375 319 316 

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 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

AEA 127

Table 3: Differences between scenarios and years for 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 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels 

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 4127 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 23557 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 3179 3177 

FR France 547219 28449 28101 28009 28009 28075 28052 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 2163 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 15596 15718 15714 

PT Portugal 88648 3305 3229 3213 3213 3228 3228 3304 3304 

RO Romania 237394 9751 9697 9663 9658 9695 9693 9749 9747 

SE Sweden 446266 5821 5546 5537 5537 5544 5541 5818 5816 

SK Slovakia 48857 2124 2108 2100 2100 2107 2106 2123 2123 

SL Slovenia 20672 1248 1236 1225 1225 1235 1235 1248 1248 

UK United 

kingdom 243251 11978 11759 11747 11747 11756 11753 11976 11973 

EU27+2 4626991 183814 181100 180202 180188 181012 180921 183722 183633 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 2 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

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 22835 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 16137 16135 

FI Finland 334395 3084 2899 2894 2886 2885 2898 2897 2884 2883

FR France 547219 27267 26678 26598 26578 26560 26658 26646 26559 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 14734 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 15060 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 10996 10995 

 

EU27+2 4626991 177674 172803 171922 171688 171499 172734 172685 171611 171559 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

130 

Table 6: Differences between scenarios and years for 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 calculated 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 1686
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 1087 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

133 

Table 9: Differences between scenarios and years for 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 calculated 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 9028 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 873 852 851 851 850 848 872 870 

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 23850 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 19918 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

136 

Table12: Differences between scenarios and years for 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 calculated 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 2863 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 2402 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

139 

Table 15: Differences between scenarios and years for 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 calculated 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 873 860 864 864 860 860 873 873 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 843 811 815 816 817 811 811 816 816
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

142 

Table 18: Differences between scenarios and years for 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 calculated 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 2329 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 Malta 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 2010
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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Table 21: Differences between scenarios and years for 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 calculated 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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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 3856 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

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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 3380 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

148 

Table 24: Differences between scenarios and years for 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 calculated 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 12 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on 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 13
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

151 

Table 27: Differences between scenarios and years for 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 calculated 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

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Table 28: Difference between 2015 and 2020 per effected 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 assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

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17 Appendix 5 - Health Benefit Diagrams 

SEA1 Scenario - 2015

SEA2 Scenario - 2015
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

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SEA3 Scenario - 2015 

AS1 Scenario - 2015
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

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BS1 Scenario - 2015

SEA1 Scenario - 2020
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

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SEA3 Scenario - 2020

SEA4 Scenario - 2020
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

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SEA5 Scenario - 2020

ASEA1 Scenario - 2020
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accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

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BSEA1 Scenario - 2020

ASEA4 Scenario - 2020
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accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

159 

BSEA4 Scenario – 2020 
Cost benefit analysis to support the impact assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

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18 Appendix 6 - Methodology for cost 

calculations 

Scenario description 

The following parameters are specified in each scenario: 

1. Fuel use [PJ] 

2. Implementation of Tier I, II, III NOX 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 NOX and SO2 control 

Scenario background data specification 

Scenarios: Baseline, SEA1, SEA2, SEA3, SEA4, SEA5 (see chapter 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 Oil 

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 Oil 
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sulphur content of certain liquid fuels

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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 size classification as specified in the ENTEC 2005 

reports. 

The distribution of the engine sizes relative to the total fuel use is derived from ENTEC 2005 and is 

expressed as % of total fuel use. 

Share of fuel used in respective engine size category: 

Small Medium Large 

25% 41% 34%

Scenario specific parameters 

Fuels considered and sulphur content 

The following fuels are available for use in the scenarios. 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 low-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 NOx control technologies 

The implementation of Tier control technologies correspond 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 implementation rates of Tier technologies are obtained: 

2015 Tier III Tier II Tier I 30 % Tier I No NOxcontrol 

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 assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

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162 

For 2020 in sea regions considered as NOX-ECAs, the following Tier technology implementation rates 

are obtained: 

2020 NOX-ECA Tier III Tier II Tier I 30% Tier I No NOXcontrol 

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 NOX-ECA, the following Tier technology 

implementation rates are obtained: 

2020 outside 

NOX-ECA Tier III Tier II Tier I 30% Tier I No NOXcontrol 

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 SO2 scrubbers are used instead of low-sulphur fuels, the following 

implementation rates are obtained from considering the age distribution in Extremis The scrubber 

implementation rates takes into consideration whether retrofit is needed or if new installations are 

sufficient. The 'Retrofit' categories include the vessels constructed before 2011, while the 'New' 

category includes the vessels constructed after 2011. 

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 assessment AEA/ED45756/Issue 3 

accompanying the revision of Directive 1999/32/EC on the 

sulphur content of certain liquid fuels

163 

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