Port emission strategies up in the air
What, how, who and when? English ports need clarity on the government's requirements for air quality strategies. Felicity Landon reports
English ports know they must submit air quality strategies soon, but which ports are affected, what they must do and even the deadlines for compliance are unclear.
An original deadline of December for submitting strategies was based on a promise of guidelines to be available in the spring. In January, the Department for Transport (DfT) confirmed the guidelines would be published in May.
After hosting a recent workshop with the DfT and Department for Food, Environment and Rural Affairs (Defra) to discuss the government's progress, the British Ports Association (BPA) asked shipping minister Nusrat Ghani to consider putting back the deadline and placing more focus on improving air quality rather than just tackling emissions at source, and it also asked for more clarity on which ports are required to produce a plan.
Since then, the minister's office has acknowledged the “challenging timetable” and that the deadline could be “detrimental to producing high-quality plans”. Instead, it is apparently looking at a two-step approach, with interim plans due in by December and final plans one year after the guidelines are issued.
But even with this extension the timeline is extremely tight, says Mark Simmonds, head of policy and external affairs at the BPA.
“My main concern is that we don't know which ports are covered. The DfT is not clear whether it is talking about harbour authorities or terminals – it hasn't defined what a port is.”
There was an initial list of 23 ports being looked at but then the DfT said it had “narrowed down” that list – to 25. The policy, which only covers England, is said to apply to ports handling 1m tonnes or more since 2016, but clearly that is open to interpretation, given one port could include several separately run terminals, for example.
“There are cases where smaller terminals are handling under 1m but have been taken together, and others where that hasn't happened,” says Mr Simmonds.
Then there is responsibility – for what? The air quality strategies are to cover the port estate, including the landside and ships alongside, but not ships manoeuvring or at anchor. If there happens to be a power station or manufacturing operation within a port's boundaries, the port cannot control emissions generated there. How this works has yet to be explained.
The ports will be required to prepare inventories calculated back to 2016 and work out the associated emissions. “There are some concerns that the DfT will bring together inventories and publish them in January and it won't give a realistic picture, will be devoid of context and could involve commercial sensitivities,” says Mr Simmonds.
Preparing the inventory and developing an air quality strategy is not an easy exercise and many ports won't have budgeted for this, he says. “Ports will need to engage consultants and undertake research. They haven't planned for this level of work. For an exercise like this, you need to plan it well and set budgets.”
Both the BPA and the UK Major Ports Group have emphasised that many ports are already taking action on air quality, monitoring the sources or producing action plans.
“Air quality has been a topic of interest and action for major ports for years,” says UKMPG chief executive Tim Morris. “There are real, practical examples of what has been achieved.”
The Port of Felixstowe is one example. In 2009, the local council imposed an Air Quality Management Area (AQMA) on areas near the port after levels of NOx breached statutory limits. This was revoked by the council in 2016 after both parties worked together to reduce emissions from activities at the port and from vehicles coming to and from the port. When the AQMA was lifted, the port highlighted “smarter working, smarter kit and smarter technology”, including electrification of kit and the introduction of stop-start vehicles.
Ports have been stepping up their activity on air quality since the government announced its policy, says Mr Morris. In September, the UKMPG hired Arup to analyse and report on emissions and mitigation measures at three illustrative ports. Arup concluded that port machinery made up only 0.2-0.3% of total NOx in a city with a very large port, while port-related factors (including shipping) together make up 6% at worst.
“The issue affects different ports differently,” says Mr Morris. “For example, urban port or relatively rural; containers or general cargo. As with many things, there is a tendency to rush to the fashionable rather than what is necessarily effective. A lot of the more immediate gains probably come from good operational practices extended slightly. Are you installing start-stop motors on your port machinery? Are you working with local hauliers with a VBS and local traffic management systems? Are you maximising the opportunity for non-road transport, effectively rail or water?”
He questions the value of setting “relatively arbitrary thresholds” as opposed to targeting areas where there is a problem.
“You may be a port with more than 1m tonnes, in a rural area, not co-located with other sources of emissions. Or you may be a small port near a motorway junction with a number of other operations all adding up to air quality issues. It isn't all about the port but the port quite rightly has to play its part to drive forward better air quality for local people.”
The final guidelines from the DfT are expected to largely mirror what has been done by the Port of London Authority (PLA), which published the first ever draft air quality strategy for a UK port, in 2017. The PLA's environment manager, Tanya Ferry, has been seconded to the DfT on a part-time basis to support the DfT in drawing up the guidelines. The PLA was also the first port in the UK to offer a discount for vessels with lower emissions. This was increased from 5% to 10% discount at the start of 2019.
The San Pedro Bay Ports Clean Air Action Plan (CAAP), introduced by the Ports of Los Angeles and Long Beach in 2006, was not without opposition. While there was tremendous pressure on the ports to tackle the issue of air quality, there were also pushbacks such as a court battle over its Clean Trucks programme.
“Container throughput – at what were predominantly fishing ports until the 1980s – had gone up from 1m teu to 17m teu. And we are surrounded by mountains and by very large communities,” says Tim DeMoss, air quality supervisor at the Port of Los Angeles. “The primary goal of the CAAP was to reduce the health risk to surrounding communities.”
The focus was, therefore, on diesel particulate matter. A five-year goal to reduce emissions by 50% was achieved in year four. “We had some really successful measures,” says Mr DeMoss.
These included ships approaching the ports slowing to 12 nautical miles (nm) per hour from a distance 40 nm out, ships switching to low-sulphur fuel from 200 nm out and ships being required to plug into shore power.
The Clean Truck programme implemented a $35 per teu levy on non-EPI 2007 compliant trucks and the success of this seems to demonstrate that ports can indeed influence matters beyond their control.
“In 2008 we had 16-20,000 dirty trucks serving our ports. By 2012 we had seen the entire fleet turned over as trucking companies decided to buy new trucks – and emissions from trucks were reduced by 95%.”
The CAAP has been updated twice and the latest version envisages further truck fleet transition, first to 'near zero' and then to no-emission trucks. Also, there is a new focus on NOx and greenhouse gases, on top of diesel particulate matter.
The Port of Los Angeles is a landlord, and doesn't own any of the trucks, equipment or harbour craft used by terminal operators and others. However, Mr DeMoss says incentives can be used to persuade companies to switch to cleaner equipment. Another way is through leases. “When leases are due for renewal, we insist on cleaner operations. Also, whenever a new project is being planned, the terminal operators are required to have mitigation measures – for example, if you extend, you must electrify your equipment or plug in more ships.”
He adds: “You can also achieve change through port tariffs. However, you do walk a fine line when you do this type of thing. We get pressure from all our stakeholders, whether the business community, trucking companies, environmental groups, regulatory agencies or the community at large. They all want something and often they conflict.
“We are very transparent and have regular meetings so that everyone knows what we are trying to do. I wouldn't say the business community is always happy with what we are doing but they are now more willing to work with us because they can see the first action plan was successful – and they can't deny that.”
Finally, he points out, the effort never stops – the ports are looking to grow their volumes but must at the same time remain within their air quality goals.
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