News from the BPA

Rebuttal: New Report from NGO is Not Credible and Lacks Critical Context

The British Ports Association is disappointed by a new report from NGO Transport & Environment (T&E) due to a lack of any serious academic rigour. The report and this press release are both embargoed until Friday 17 May.

The report ranks the UK’s most polluted ports by modelling air pollutant emissions from ships, using a flawed methodology. It does not include any dispersion modelling or account for other factors, like atmospheric conditions, which all have a significant impact on how emissions affect local populations and are fundamental to any rigorous research into air quality.

The bizarre comparison of shipping emissions to emissions from cars is comparing apples with oranges and adds nothing to ongoing policy debates.  It also ignores the critical point that emissions from road transport tend to be much closer to human populations. Previous analysis done by environmental consulting firm Ricardo found that SO2 emissions from ships at berth account for just 3.6% of the UK’s transport sector emissions (and 0.68% of CO2 emissions and 2.6% of NOx emissions).

Most major ports (and many smaller ports) already monitor and/or model emissions in their harbours and industry research shows that emissions from ports is a fraction of wider background emissions in most cities. The report also largely ignores the measures taken by ship owners and operators to address emissions and the proactive role taken by UK ports to decarbonise their own operations and encourage the use of greener fuels and technologies by tenants and customers. The BPA has addressed some of the specific inaccuracies in the report in a table below

Ports are already acting to monitor, model and reduce emissions from their own operations, and increasingly from shipping. Most of the industry has ambitious net zero targets in place, which will also have a positive impact on air quality. These industry targets are backed by robust actions plans and most of them are a decade or more ahead of the UK government’s 2050 deadline.

Air pollutant emissions have a very localised impact and comparing emissions from ships, which deliver 450 million tonnes of goods a year including half our of food and energy, to local car journeys is absurd. Air pollutant emissions from ships are limited whilst at-berth when the main engines are turned off. To exclude any dispersion analysis or other factors that affect how pollutants actually impact human populations is irresponsible and discredits the findings.

The ports industry is working hard on ambitious plans to reduce their own emissions as well as those from shipping and others. The BPA will also continue to work constructively with government and will support sensible policy that will further help the abatement of shipping emissions.

Mark Simmonds, Director of Policy & External Affairs at the British Ports Association

BPA Analysis: T&E Claims vs Reality

In the top 10 Sox polluted ports, 3,700 ships produced 30 times more Sox emissions than all ~1 million cars in the same area.The comparison of car emissions and vessel emissions is meaningless scaremongering and has little application to policy development.

Air pollutant emissions have a very localised impact. The impact of nitrogen and sulphur oxides is significantly impacted by the proximity between the source and the receptor. To compare the ships and cars emissions impact on people, when cars are much closer to receptors, is not credible.
All residents of port towns are forced to breathe poisoned air because vessels burn fossil fuel whilst at berth.There is no correlation between the presence of a port in a town or city and its ambient air quality. The analysis makes no attempt to account for dispersion or any of the factors, such as atmospheric conditions, that affect how emissions impact people.

This report makes no attempt to acknowledge other sources of air pollution in and around ports, such as surface transport and other industrial activity. Studies undertaken by individual ports and at an industry level show that ports are responsible for a fraction of the air pollutants found in towns and cities.
Other vessels were assumed to run on heavy fuel oil (HFO), very low sulphur fuel oil (VLSFO) or marine gas oil (MGO).Vessels at-berth will be using auxiliary engines rather than their main propulsion engines. These generators will burn diesel instead of heavy fuel oil. Shore power – one of the main policy solutions proposed by the report – can only abate emissions at-berth when ships are moored (a small percentage of overall emissions from a ship). It will not impact emissions from ships moving in and out of a port.
Ships also routinely discharge pollutant-laden wash water from exhaust gas clean systems (“scrubbers”) straight into the sea and only a small number of UK ports prohibit this.BPA research shows that most ports manage the discharge of open-loop scrubber wash water into their harbours. This is usually done where there are unresolved concerns about the impact of the wash water on marine sediments. A growing body of international literature shows little impact, due to dispersion, in open waters.
In 2021, UK shipping used 7 million tonnes of fossil fuel and produced nearly 20% of total UK transport GHG emissions… …Propulsion is not the only source of shipping emissions. Vessels continue to run engines when moored to meet on-board electricity and heat requirements. Indeed, the vessels included in this study burned almost half a million tonnes of fossil marine fuel in the UK’s ports in 2022. This is a significant proportion of UK shipping’s total fuel use and associated emissions.A 2018 report by marine consultants Ricardo for electrical supplier (and shore power supplier) Schneider Electric found that emissions at berth from ships in UK ports amounted to:
0.68% of transport’s total CO2 emissions
2.6% of the transport sector’s NOx emissions
3.6% of the transport sector’s SO2 emissions
Ricardo acknowledged, whereas this report does not, that there is very limited data available on actual vessel auxiliary engine power. Emission from auxiliary engines at-berth are a small proportion of most vessels’ overall emissions although in reality this varies so much by type of ship it is not a useful statistic for shipping overall.
Solutions exist, and with the right policies from the Government they could be developed rapidly. Shore side electricity allows vessels to plug in at berth rather than running engines for power. Alternative fuels like hydrogen from renewable electricity can also greatly reduce air pollutant emissions.Shore power is an established technology, but BPA research in 2020 found that only 1500 ships out of the global merchant fleet of 96,000 vessels(1.5%) are able to plug in to shore power.

The BPA set out the major barriers to the provision of shoreside power in 2020. Several ports are working on installing shore power for ships, including Portsmouth for new hybrid ferries arriving in 2025. The reality is that shore power is a means to tackle emissions and not an end in itself to aim for. It will not be the solution everywhere and a mandate is unworkable, especially as it can take many years to secure the required power. Government policy on abating emissions at berth must be technology neutral and industry is well advanced in exploring these options.
Designating all UK waters and ports as an emission control area (ECA), where limits and even charges are placed on ship pollution, would lower emissions and could help fund cleaner forms of energy.It is government policy to extend the ECA and the ports industry is not opposed to this.
But with shipping still relying almost entirely of fuels of the dirtiest kind, the sector is a major source of pollution.The UK is an island served by global shipping. Shipping is, by far, the most carbon-efficient way to move freight, given the huge scale involved.
Present UK air quality and shipping pollution policies and regulations fall far short of what is needed to meet WHO guidelines, and are failing to address the problem of port pollution. Without reform, this will not change.The maritime industry is working closely with Government to tackle emissions.

Even without government policy, UK ports are already acting and have ambitious net zero plans in place, most are a decade ahead of the Government’s 2050 target. Port decarbonisation will have an impact on air pollutant emissions.

Background levels of air pollutants, as measured by many individual ports and at an industry level in 2018, show that port contributions to poor air quality are tiny and that background levels alone would surpass WHO guidelines (which only 7 countries in the world currently meet). Reducing emissions in ports to zero would therefore not have the impact this report says it would.