Fuel Storage & Handling Systems and The Costs of Operating in ECAs, 2010

Fuel Storage & Handling Systems and
the Costs of Operating in ECAs
Authors:
Eugene van Rynbach (M), Herbert Engineering Corp.
Karl Briers (M), Herbert Engineering Corp.
April 29, 2010
Fuel Storage & Handling Costs and the Costs of Operating in ECAs
1. Introduction
With the approval of the North American ECA at MEPC 60 last month and the one already in
effect in the Baltic Sea and most of the North Sea, ECAs have become a reality for ship owners
and operators and the impacts on ship design and operation will need to be considered going
forward. The North American ECA, illustrated above, will be along the coasts of Canada and the
USA, out to 200 NM. This ECA will go into effect on 1 August 2011, but fuel requirements will
not be enforced until 1 August 2012.
Since operation on heavy fuel oil (HFO) offered a significant cost savings most ships in the world
in the last few decades became unifuel ships that operated all the principal machinery full time on
a single heavy fuel with marine diesel oil (MDO) used only in special circumstances. While the
fuel processing and heating equipment necessary to operate full time on HFO was complex and
expensive, the savings were clear. That era will now be over as ECAs become adopted more
widely around the world. Ships in the future will need to become dual fuel ships, able to operate
equally on high viscosity, high density HFO outside the ECA, and low viscosity, low sulfur MGO
in the ECA. The change to dual fuel operation will affect all ships that operate on heavy fuel and
enter an ECA, both existing and new ships. Further impacts will likely occur when the allowed
sulfur limit for all fuels reduces to 0.50% sulfur in 2020, as currently required by Annex VI of
MARPOL.
Because of the need to change to lower sulfur fuel in the ECA, its implementation will have an
immediate effect on fuel costs and vessel routing, particularly in later years when distillate fuel
Operating Ships within Emission Control Areas (ECAs)
SNAME Symposium, 29 April 2010
pg 2
Herbert Engineering Corp.
may be the only option to meet the 0.1% sulfur limit in ECAs. The first part of this paper
discusses the impacts of the ECA on vessel fuel costs. Besides the direct cost of burning higher
priced fuels, operation in an ECA also impacts the design of ships. The two main impacts are the
effect on fuel storage capacity and the effect on the design of the fuel transfer, purifying and
service systems and the equipment contained in those systems. This paper will discuss the design
impacts of both. Most ships today lack adequate storage capacity for a second fuel and guidance
will be provided on how much capacity is needed and on how to keep the two fuels properly
segregated. Besides having the proper fuels onboard, the fuel transfer, purifying and service
systems must have the proper fittings and equipment to operate safely and effectively with two
fuels onboard, particularly when the second fuel is a low viscosity, low sulfur fuel. Discussed
will be the required changes in fuel settling and service tanks, fuel transfer piping, fuel purifiers,
fuel service piping, fuel changeover valves and what equipment can be installed to reduce the
impact of low viscosity fuel. Other papers at this symposium cover the effects of the required low
viscosity, low sulfur fuels on the fuel switching process and its impact on operation and
maintenance of machinery. It should be noted that ships trading in California waters are already
required to burn distillate fuel within 24 miles of Californias coast. This has a similar affect on
the fuel service system equipment, but a relatively minor affect on the fuel storage issues.
2. ECA Implementation Schedule

Regulation 14 of Annex VI of MARPOL contains the allowable limits for sulfur oxides (SOx)
and particulate matter while operating in an ECA. The limits will be implemented in three
phases, the first of which ends in July 2010. The limits on sulfur content in fuel, applicable to all
ships, and enforcement dates are as follows:
Existing ECA (North Sea & Baltic Sea)
1.50% Sulfur prior to 1 July 2010
1.00% Sulfur on and after 1 July 2010
0.10% Sulfur on and after 1 January 2015
For the North American ECA, while the ECA will go into effect in August 2011, the enforcement
date for the ECA requirements is August 2012 according to the US EPA. This is in accordance
with the 12 month exemption from enforcement given in Regulation 14.7 of Annex VI of
MARPOL for newly adopted ECAs. On that basis, for ships operating in the new ECA the
applicable dates are as follows:

pg 3
North American ECA
4.50% Sulfur prior to 1 January 2012 per Annex VI (prior to ECA)
3.50% Sulfur on and after 1 January 2012 per Annex VI (prior to ECA)
1.00% Sulfur on and after 1 August 2012 (enforcement date for ECA)
0.10% Sulfur on and after 1 January 2015
As can be seen, starting this year in the existing ECA and in mid 2012 when the North American
ECA becomes effective, Low Sulfur HFO (LSHFO) with sulfur content up to 1% can still be
used. This fuel may be hard to find in many ports and will cost more than conventional HFO,
however, operation using LSHFO will not have much of an impact on machinery and fuel system
operation. Regulation 14 contains requirements that low sulfur fuels be segregated from normal
fuels and that documentation be retained onboard indicating the sulfur content of the fuel and
records kept of the fuel quantities onboard at entering and leaving the ECA, time of fuel
switching, and written procedures on how to carry out switching. Therefore, starting with the first
effective dates of an ECA, a ship will have to start operating as a dual fuel ship, even though both
fuels are heavy fuel oil. Initially, this will impact fuel storage, segregation and capacity and fuel
transfer piping, but will not greatly affect machinery operation since viscosity and characteristics
of both fuels are similar.
Starting in January 2015 when the 0.1% sulfur limit comes into effect, besides the dual fuel
storage, segregation and capacity issues, there will also be a need to address the many issues
relating to operation of machinery on very low sulfur and low viscosity fuel.
3. Distances within the North American ECA

The distance a ship will transit within an ECA is very route sensitive and depends on both the
origination and destination ports, plus any intermediate ports that may be served. This section
discusses the North American ECA as there is more variability in possible routes to reduce
distances in the ECA. For the North Sea and Baltic Sea ECA the possibilities to reduce time in
the ECA by varying the route are very limited since there is one main entrance point for most
ships, except those going to Norway, via the narrow entrance to the English Channel. Rerouting
north around the British Isles will not generally reduce mileage within the ECA. Distance
traveled within the North American ECA can vary from full time for ships engaged in only
coastwise trade to over a thousand miles for a voyage south along the US East and across the Gulf
of Mexico to Texas to the minimum of about 200 NM for a ship approaching the ECA on a route
perpendicular to the coast. The distance to leave the ECA also has to be considered.
Transatlantic
The following figures illustrate the mileages in the ECA for some sample transatlantic voyages
for both the normal great circle route and a revised route that minimizes mileage within the ECA.
In the tables following the figures are listed the total distance and distance within the ECA for the
pg 4
great circle route and for the minimized ECA route, plus the difference in mileage between the
two routes. It should be noted the mileages given are single passage mileage and for a round trip
voyage the distance within the ECA will be double the indicated distance. As can be seen,
substantial reductions in mileage within the ECA are possible for US East Coast routes by revised
routing without a substantial penalty in increased distance. For US Gulf ports there is no easy
alternative routing to shorten the distance in the ECA because Cuba blocks entering the ECA
from the south. There are two ways a ship could reduce distance n the ECA on passage to the US
Gulf ports. It could potentially pass through the Bahamas and travel along the coast of Cuba
south of the ECA boundary to reduce distance in the ECA, but this may not be safe navigation
and will probably not be adopted. Secondly, to the west of Florida it could head south of the ECA
line, travel parallel to the boundary and then re-enter the ECA due south of its destination to cross
the ECA in the shortest manner. It is also considered unlikely this strategy will be adopted
because it means the ship will be switching fuel four times in a short period of time as it enters the
ECA to pass Florida, leaves the ECA in the Gulf and re-enters to arrive at its destination port.
Furthermore, the deviation distance will be significant, reducing the benefit of this deviation.
Figures 1 and 2 show routes that originate in the English Channel and go to the indicated US East
Coast ports. These routes cover most voyages from Northern Europe since most would pass
through the English Channel. The data for these routes are presented in Table 1. Table 2 has data
for routes originating from Gibraltar, which would cover most routes from Southern Europe. The
Gibraltar routes are not illustrated because they are similar to the English Channel routes.
Figure 1 English Channel to US East Coast Great Circle Routes

pg 5
Figure 2 English Channel to US East Coast Minimized ECA Routes

Table 1 ECA Mileages for English Channel to US East Coast
Origination
English Channel
Great Circle Route
Minimized ECA Route
Distances
Distance
Distance Differences
Increase
Reduction
Total
Inside ECA
Total
Inside ECA
Total Dist.
ECA Dist.
[NM]
[NM]
[NM]
[NM]
[NM]
[NM]
New York, NY
2937
1212
3007
375
70
-837
Norfolk, VA
3101
1378
3151
225
50
-1153
Charleston, SC
3368
1672
3443
300
75
-1372
Houston, TX
4604
1309
4604
1309
Destination
Table 2 ECA Mileages for Gibraltar to US East Coast

Origination
Great Circle Route
Gibraltar
Total
Destination
Minimized ECA Route
Distance
Inside ECA
Total
Distance
Inside ECA
Increase
Total Dist.
Reduction
ECA Dist.
[NM]
[NM]
[NM]
[NM]
[NM]
[NM]
New York, NY
3180
1090
3200
375
20
-715
Norfolk, VA
3335
417
3385
300
50
-117
Charleston, SC
3594
400
3735
290
141
-110
Houston, TX
4754
1261
4754
1261

pg 6
Transpacific
Similar to transatlantic routes, for transpacific routes to the US West Coast distance traveled
within the ECA can be reduced by a course deviation. Figures 3 and 4 below show the routes
from Shanghai to US West Coast ports, both the nominal great circle route and a revised route
with minimized ECA distance. The data for these routes are presented in Table 3 and similar data
for the route from Yokohama to US West Coast ports are given in Table 4. As can be seen, there
is much smaller reduction in ECA mileage to be gained by deviation to minimize ECA distance
for West Coast ports than for East Coast ports because ships approach the coast in a more
perpendicular direction. The reason for this is the configuration of the coast and the larger Pacific
Ocean changes the great circle route. Therefore, the deviation is a substantial percentage of the
reduced miles and this will affect whether it pays to travel the extra miles as will be discussed in
the fuel consumption and cost analysis.
Figure 3 Shanghai to US West Coast Great Circle Routes

pg 7
Figure 4 Shanghai to US West Coast Minimized ECA Routes

Table 3 ECA Mileages for Shanghai to US West Coast
Origination
Great Circle Route
Minimized ECA Route
Distance
Distance
Shanghai
Increase
Reduction
Total
Inside ECA
Total
Inside ECA
Total Dist.
ECA Dist.
[NM]
[NM]
[NM]
[NM]
[NM]
[NM]
Seattle, WA
5131
620
5156
400
25
-220
San Francisco, CA
5396
343
5446
250
50
-93
Los Angeles, CA
5699
491
5749
325
50
-166
Destination
Table 4 ECA Mileages for Yokohama to US West Coast

Origination
Great Circle Route
Minimized ECA Route
Yokohama
Distance
Distance
Increase
Reduction
Total
Inside ECA
Total
Inside ECA
Total Dist.
ECA Dist.
[NM]
[NM]
[NM]
[NM]
[NM]
[NM]
Seattle, WA
4276
666
4301
400
25
-266
San Francisco, CA
4536
353
4561
275
25
-78
Los Angeles, CA
4839
527
4864
350
25
-177
Destination

pg 8
Hawaii & Alaska

Besides the routes across the oceans, of interest to US operators would be the impact of the ECA
on vessels traveling between Hawaii or southern Alaska and the US West Coast since the ECA is
encountered at both ends of these voyages, doubling its impact. Although Hawaii is isolated in
the middle of the Pacific Ocean, without much ship traffic, it was included in the ECA. Vessels
traveling between Hawaii and the US West Coast operating with dual fuels will have to switch
fuels four times as they enter and exit the ECA twice, which can create significant operational
concerns. Because ships can cross the ECA in mostly a perpendicular fashion when traveling
between Hawaii and the US West Coast, distance in the ECA will be on the order of 250 NM at
each end of a passage.
For voyages between southern Alaska (the ECA only covers the south and southeast coasts of
Alaska) and the US West Coast there is significant distance traveled in the ECA diagonally along
the West Coast so the distance traveled within the ECA is a substantial portion of the voyage. As
with Hawaii, ships that operate on dual fuel will need to switch fuel four times on a round trip
voyage between the south coast of Alaska (ports such as Anchorage and Valdez) and the US West
Coast. For voyages to southeast Alaska ports (such as Ketchikan) from US Pacific Northwest and
British Columbia ports the route is completely within the ECA. Estimates for the mileages within
the ECA for voyages between the US West Coast and Hawaii or the south coast of Alaska are
given in Table 13 in the section on analysis of fuel cost impacts.
4. Fuel Consumption and Cost Impacts of the North American ECA

There are several impacts on vessel fuel consumption and fuel cost as a result of the adoption of
the North American ECA. One impact is that the fuel type used in the ECA will be changed from
HFO to most likely MGO starting in 2015, since MGO currently is the only type of fuel that
meets the low sulfur requirement. One advantage of operation on MGO (as well as MDO) is that
it will reduce specific fuel consumption by about 5% because of the higher heating value of MGO
compared to HFO. (MGO/MDO: 42,700 kJ/kg, HFO: 40,600 kJ/kg). It should be noted that
engine makers published specific fuel consumption is normally based on MDO operation. The
makers have advised that engines when using MGO can have about 1% higher consumption than
with MDO because of the density difference between the fuels. However, this may only apply at
MCR power levels and it is uncertain of the effect for lower power levels. The difference, either
way, is not considered significant for this analysis. While there is an incentive to make a
deviation to minimize the distance traveled in the ECA to reduce consumption of high priced
ECA fuel, there is a penalty in extra distance and time, as presented in the below tables.
However, in most cases the cost savings will outweigh the extra time, even considering the hourly
operating costs of the ship over the extra time period. The decision on whether to make a
deviation to reduce distance in the ECA is very route specific. The below tables are based on
vessel operation at constant speed (vessel was already traveling at full speed so it cannot speed up
to restore arrival time due to the deviation). This assumes the vessel schedule can be adjusted to
pg 9
accept the later arrival. Later in the section there is discussion of how much of a speed up, if it
were possible, is needed to keep the same arrival time and the impact of the speed up on fuel cost.
It will be seen that speed up can also have a significant cost penalty. This analysis is based on the
cost impacts of using MGO in the ECA and will cover operation starting on 1 Jan. 2015. Up until
then operation on LSHFO is possible in the ECA, if available at 1.00% sulfur level, except in
coastal California. The cost difference between regular HFO and LSHFO is much smaller than
between regular HFO and MGO, so the below cost estimates would not apply. The cost impacts
of using scrubbers to allow continued operation on HFO, even after the implementation of the
ECA, are outside the scope of this analysis.
Transatlantic - Fuel Cost Impacts of the ECA

The fuel cost impacts on a per passage basis are calculated for three sizes of ships. One is a small
to medium size ship of 14 knots average passage speed with daily fuel consumption of 35 tons per
day with HFO and 33.3 tons/day with MGO. All tons in this paper are metric tons. This could be
typical for a midsize bulker (Handymax or Panamax) or product tanker. The mid-size ship has an
assumed speed of 18 knots and daily fuel consumption of 75 tons/day with HFO and 71.3
tons/day with MGO. This could be a PCTC or midsize containership. The high consumption
ship has an assumed speed of 22 knots and daily consumption of 125 tons/day with HFO and 119
tons/day with MGO. This could be a Panamax or larger containership. Actual vessel speeds and
consumptions will vary depending on the size and type of ship, but these are considered
representative speeds and consumptions to demonstrate the impacts of the ECA. The extra
generator fuel consumption resulting from the additional time at sea due to the deviation to
minimize ECA distance is not included in the calculation as the impact on the results is small.
Ships which travel also to the North Sea and Baltic Sea ECA will have additional cost impact
because of the need to operate on ECA compliant fuel at the other end of the voyage. For ships in
coastwise trade, basically they will always be in the ECA, and will have much higher fuel cost
impact as all fuel consumed will be high priced ECA compliant fuel.
Tables 5 to 7 present the fuel and cost impact data for the three ship sizes for passages originating
from the English Channel and traveling to the indicated US East Coast ports. Passages from
Gibraltar to the same ports will have similar results. The results are for a single passage. A
roundtrip will have double the impact. Table 5 presents the full data and shows how the
conclusions were determined. Tables 6 and 7 present summaries of the data for the larger 18 kt
and 22 kt ships, using the same methodology as given in Table 5. Fuel cost is estimated based on
current prices of $500 per ton for heavy fuel and $725 per ton for MGO. As fuel prices change
the estimated costs will change accordingly.

pg 10
Table 5 Small Ship - Impact of ECA on Fuel Consumption & Cost - English Channel
Vessel Speed
14 kts
Vessel Daily
Consumption
35.0 t/d
33.3 t/d
HFO
MGO
Impacts of ECA on Vessel Fuel Consumption and Cost from English Channel
Destination
New York, NY
Distance
Time
Consumption
Cost for Fuel
(NM)
(hrs)
(tons)
($)
GC ECA Mileage
1212
86.6
120
$86,955
MGO
Min ECA Mileage
375
26.8
37
$26,904
MGO
Mileage Shifted to
outside ECA
837
59.8
87
$43,594
HFO
Deviation for Min ECA
70
5.0
$3,646
HFO
Comparison - Min ECA

Route to GC ECA Route
70
12
-$12,811
MGO
1212
86.6
126
$63,125
HFO
70
5.0
$11,019
MGO
GC ECA Mileage
1672
119.4
165
$119,957
MGO
Min ECA Mileage
300
21.4
30
$21,523
MGO
Mileage Shifted to
outside ECA
1372
98.0
143
$71,458
HFO
75
5.4
$3,906
HFO

75
5.4
15
-$23,069
MGO
1672
119.4
174
$87,083
HFO
75
5.4
$9,805
MGO
GC ECA Mileage
1309
93.5
130
$93,914
MGO
Min ECA Mileage
1309
93.5
130
$93,914
MGO
Mileage Shifted to
outside ECA
0.0
$0
HFO
0.0
$0
HFO

$0
MGO
1309
93.5
136
$68,177
HFO
0.0
-7
$25,737
MGO
Item
If No ECA
Comparison- Min ECA
Route to no ECA
Charleston, SC
If No ECA
Comparison- Min ECA
Route to no ECA
Houston, TX
If No ECA
Comparison- Min ECA
Route to no ECA
Notes:
1.
2.
3.
4.
5.
Fuel Type
GC = Great Circle Route

MGO has 5% higher heating value than HFO so 5% lower consumption when using MGO.
Based on ship operating at constant speed.
Impacts are for single passage. For round trip will be double.
Assumed cost of fuel is $500 per ton for HFO and $725 per ton for MGO.

pg 11
Table 6 Mid-Size Ship - Impact of ECA on Fuel Consumption & Cost - English Channel
Vessel Speed
18 kts
Vessel Daily
Consumption
75.0 t/d
HFO
71.3 t/d
MGO
Destination
New York, NY
Charleston, SC
Houston, TX
Item
Comparison- Min ECA
Route to no ECA
Comparison- Min ECA
Route to no ECA
Comparison- Min ECA
Route to no ECA
Distance
Time
Consumption
Cost for Fuel
Fuel Type
(NM)
(hrs)
(tons)
($)
70
3.9
19
-$21,351
MGO
70
3.9
$18,365
MGO
75
4.2
25
-$38,449
MGO
75
4.2
10
$16,341
MGO
MGO
0.0
-11
$42,895
MGO
Notes: Same as Table 5.
Table 7 Large Ship - Impact of ECA on Fuel Consumption & Cost - English Channel
Vessel Speed
22 kts
Vessel Daily
Consumption
125.0 t/d
HFO
118.8 t/d
MGO
Destination
New York, NY
Charleston, SC
Houston, TX
Item
Comparison- Min ECA
Route to no ECA
Comparison- Min ECA
Route to no ECA
Comparison- Min ECA
Route to no ECA
Distance
Time
Consumption
Cost for Fuel
Fuel Type
(NM)
(hrs)
(tons)
($)
70
3.2
26
-$29,115
MGO
70
3.2
12
$25,043
MGO
75
3.4
34
-$52,430
MGO
75
3.4
14
$22,283
MGO
MGO
0.0
-15
$58,493
MGO
Notes: Same as Table 5.

pg 12
Table 8 Transatlantic Voyages Annual Impact of ECA Fuel Costs & Time for Deviation
Vessel Speed
14 kts
Vessel Daily
Consumption
35.0 t/d
HFO
33.3 t/d
MGO
Annualized Cost Impact of ECA - Transatlantic Routes

Fuel Cost Impact
per Passage
Voyages
per year
Annual Fuel
Cost Impact
Extra time
per passage
Extra Time
per year
New York, NY
$11,019
$176,302
5.0
80.0 hrs
Charleston, SC
$9,805
$156,875
5.4
85.7 hrs
Houston, TX
$25,737
$411,790
0.0
0.0 hrs
Vessel Speed
18 kts
Vessel Daily
Consumption
75.0 t/d
HFO
71.3 t/d
MGO
Destination

Fuel Cost Impact
per Passage
Voyages
per year
Annual Fuel
Cost Impact
Extra time
per passage
Extra Time
per year
New York, NY
$18,365
$293,837
3.9
62.2 hrs
Charleston, SC
$16,341
$261,458
4.2
66.7 hrs
Houston, TX
$42,895
$686,316
0.0
0.0 hrs
Vessel Speed
22 kts
Vessel Daily
Consumption
125.0 t/d
HFO
118.8 t/d
MGO
Destination

Fuel Cost Impact
per Passage
Voyages
per year
Annual Fuel
Cost Impact
Extra time
per passage
Extra Time
per year
New York, NY
$25,043
$400,687
3.2
50.9 hrs
Charleston, SC
$22,283
$356,534
3.4
54.5 hrs
Houston, TX
$58,493
$935,885
0.0
0.0 hrs
Destination
Notes:
1. Based on fuel cost of $500 per ton for HFO and $725 per ton for MGO.
2. A round trip voyage has two passages in the ECA, one arriving in the USA and one departing from the USA.
An order of magnitude estimate can be made of the annual fuel impact costs of an ECA and the
annual extra passage time incurred because of the need to make a deviation to reduce the distance
traveled in the ECA. This information is shown in Table 8. The cost and time impacts for
passages originating from the English Channel are the basis for the annual cost calculations, but
the mileages in the ECA are similar for most transatlantic voyages so these numbers can be
generalized as order of magnitude estimates for most transatlantic voyages to a single port in the
US East Coast. Voyages to multiple ports within the ECA will have higher costs. The number of
transatlantic voyages a ship will make is very trade dependent, but for purposes of this analysis a
pg 13
6 week round trip voyage is assumed or 8 voyages per year. Note that there are two ECA
passages in each round trip voyage (arriving in the USA and departing from the USA) so the
number of passages is 16 per year. This type of operation on a regular schedule is typical of
containerships, but can apply to other types of ships that may not go to the same ports but do have
regular voyages to and from the USA. The extra voyage time caused by a deviation to reduce
distance in the ECA has a cost as well, but since the daily costs of ships varies so much it is hard
to make an estimate that is applicable to most ships. Depending on the route, ship type and flag,
it can be on the order of no impact (where there is no extra time such as Houston) to about 50% of
the fuel cost for ships with high daily cost.
Transpacific - Fuel Cost Impacts of ECA

The same calculations of the impact of the ECA can be made for transpacific routes, such as
between Shanghai and US West Coast ports. Similar impacts would apply for other ports in East
Asia. Summary Tables are listed below as the calculation method is the same as shown in Table 5
for transatlantic voyages. See Tables 9, 10, and 11 for the impacts for the same three ships sizes
as for the transatlantic analysis above. Table 12 estimates the impacts on an annual basis,
assuming 6 voyages per year for the longer transpacific distances. For the reasons discussed in
the analysis of transpacific ECA mileages, the fuel impacts are less for the transpacific voyages
than for the transatlantic voyages because the distances in the ECA are shorter, and while a
deviation can shorten the distance in the ECA by a little, the extra fuel cost caused by the
deviation nearly counterbalances the savings in the ECA. In the case of the route between
Shanghai and San Francisco, the extra fuel cost resulting from the deviation is more than the
savings from the small distance saved in the ECA, which is why a positive fuel cost is indicated
for the impact of deviation to minimize ECA distance. In the below tables, for San Francisco, the
comparison of the minimum ECA route to the no ECA route is based on the direct route as the
minimum ECA route, which is why there is no distance or time penalty for ECA operation.

pg 14
Table 9 Small Ship - Impact of ECA on Fuel Consumption & Cost Shanghai
Vessel Speed
14 kts
Vessel Daily
Consumption
35.0 t/d
HFO
33.3 t/d
MGO
Impacts of ECA on Vessel Fuel Consumption and Cost from Shanghai

Distance
Time
Consumption
Cost for Fuel
(NM)
(hrs)
(tons)
($)
25
1.8
-$3,023
MGO
25
1.8
$9,167
MGO

50
3.6
$776
MGO
Comparison- Min ECA

Route to no ECA
-2
$6,744
MGO

50
3.6
-$660
MGO
Comparison- Min ECA

Route to no ECA
50
3.6
$8,994
MGO
Destination
Item
Seattle, WA

Comparison- Min ECA
Route to no ECA
San Francisco,
CA
Los Angeles,
CA
Fuel Type
Notes:
1. For San Francisco, lowest cost is direct route, not deviation to minimize ECA, so no mileage or time impact of ECA
2. Other notes same as Table 5.
Table 10 Mid-Size Ship - Impact of ECA on Fuel Consumption & Cost Shanghai
Vessel Speed
18 kts
Vessel Daily
Consumptio
n
75.0 t/d
HFO
71.3 t/d
MGO

Destination
Seattle, WA
San Francisco,
CA
Los Angeles,
CA
Distance
Time
Consumption
Cost for Fuel
(NM)
(hrs)
(tons)
($)

25
1.4
-$5,039
MGO
Comparison- Min ECA

Route to no ECA
25
1.4
$15,278
MGO

50
2.8
$1,293
MGO
Comparison- Min ECA

Route to no ECA
-3
$11,240
MGO

50
2.8
10
-$1,099
MGO
Comparison- Min ECA

Route to no ECA
50
2.8
$14,990
MGO
Item
Fuel Type
Notes:
1. For San Francisco, lowest cost is direct route, not deviation to minimize ECA, so no mileage or time impact of ECA

pg 15
Table 11 Large Ship - Impact of ECA on Fuel Consumption & Cost - Shanghai- Summary
125.0 t/d
HFO
Vessel Daily
Consumption
118.8 t/d
MGO
Vessel Speed
Destination
Seattle, WA
San Francisco,
CA
Los Angeles,
CA
22 kts
Item
Comparison- Min ECA
Route to no ECA
Comparison- Min ECA
Route to no ECA
Comparison- Min ECA
Route to no ECA
Distance
Time
Consumption
Cost for Fuel
Fuel Type
(NM)
(hrs)
(tons)
($)
25
1.1
-$6,871
MGO
25
1.1
$20,833
MGO
50
2.3
13
$1,763
MGO
-4
$15,327
MGO
50
2.3
14
-$1,499
MGO
50
2.3
$20,441
MGO
Notes:
1. For San Francisco, lowest cost is direct route, not deviation to minimize ECA so no mileage or time impact of ECA
Table 12 Transpacific Voyage Annual Impact of ECA Fuel Costs &Time for Deviation
Vessel Speed
14 kts
Vessel Daily
Consumption
35.0 t/d
33.3 t/d
HFO
MGO
Annualized Cost Impact of ECA - Transpacific Routes

Destination
Fuel Cost Impact

per Passage
Voyages
per year
Annual Fuel
Cost Impact
Extra time
per passage
Extra Time
per year
Seattle, WA
$9,167
$110,000
1.8
21.4 hrs
San Francisco, CA
$6,744
$80,927
Los Angeles, CA
$8,994
$107,930
3.6
42.9 hrs
Vessel Speed
18 kts
Vessel Daily
Consumption
75.0 t/d
HFO
71.3 t/d
MGO

Destination
Fuel Cost Impact

per Passage
Voyages
per year
Annual Fuel
Cost Impact
Extra time
per passage
Extra Time
per year
Seattle, WA
$15,278
$183,333
1.4
16.7 hrs
San Francisco, CA
$11,240
$134,878
Los Angeles, CA
$14,990
$179,883
2.8
33.3 hrs

pg 16
Vessel Speed
22 kts
Vessel Daily
Consumption
125.0 t/d
HFO
118.8 t/d
MGO

Destination
Fuel Cost Impact

per Passage
Voyages
per year
Annual Fuel
Cost Impact
Extra time
per passage
Extra Time
per year
Seattle, WA
$20,833
$250,000
1.1
13.6 hrs
San Francisco, CA
$15,327
$183,924
Los Angeles, CA
$20,441
$245,295
2.3
27.3 hrs
Notes:
1. Based on fuel cost of $500 per ton for HFO and $725 per ton for MGO.
2. A round trip voyage has two passages in the ECA, one arriving in the USA and one departing from the USA
Hawaii & Alaska - Fuel Cost Impacts of ECA

A special situation exists between the US West Coast and the south coast of Alaska (e.g.
Anchorage and Valdez) and Hawaii in that a normal route between these ports would start in the
ECA, exit the ECA, and then re-enter the ECA when coming into port. This could potentially
double the mileage in the ECA. For voyages from the US West Coast, particularly California, to
ports along the south coast of Alaska ships will probably deviate to go outside the ECA boundary
to allow use of HFO for part of the voyage. Table 13 provides estimates of the fuel cost impacts
of the Hawaiian and Alaskan trades. Since routes between these areas are so service specific no
specific route mileages are listed, only estimated mileages that cover a range of routes. The lower
mileage is based on a short direct route across the ECA at both ends of the passage, such as San
Francisco to Hawaii, and estimated as 525 miles total in the ECA per passage. The higher
mileage is based on some diagonal routing across the ECA and estimated as 700 miles total in the
ECA per passage. The results are presented only for the small ship and the large ship as this will
bound the estimates and most ships will fall somewhere in between. Round trip voyages between
the US West Coast and Alaska and Hawaii can typically take 2 or 3 weeks. For purposes of the
analysis 2 week voyages was used and, therefore, 25 round trip voyages per year are indicated in
Table 13 The fuel cost and extra time resulting from the deviation to get outside the ECA were
not considered in this analysis. These are only order of magnitude estimates and a specific
calculation should be made for any particular vessel and route.

pg 17
Table 13 US West Coast to South Alaska & Hawaii - Impact of ECA on Fuel Costs
Vessel
Speed
Route
14 kts
Vessel Daily
Consumption
35.0 t/d
HFO
33.3 t/d
MGO
25
Impacts of ECA on Vessel Fuel Consumption and Cost US West Coast to South Alaska & Hawaii
Cost for
Annual
Distance
Time
Consumption
Fuel
Fuel Cost
Item
US West
Coast to
Hawaii &
South Alaska
(hrs)
(tons)
($)
($)
Short ECA
Route, no ECA
525
37.5
54.7
$27,344
$683,594
HFO
Short ECA
Route, with ECA
525
37.5
52.0
$37,666
$941,650
MGO
$10,322
$258,057
Cost Increase
for ECA
Medium ECA
Route, no ECA
700
50.0
72.9
$36,458
$911,458
HFO
700
50.0
69.3
$50,221
$1,255,534
MGO
$13,763
$344,076
Cost Increase
for ECA
Vessel
Speed
22 kts
Vessel Daily
Consumption
125.0 t/d
HFO
118.8 t/d
MGO
Voyages
per year
25
Impacts of ECA on Vessel Fuel Consumption and Cost US West Coast to South Alaska & Hawaii
Cost for
Annual
Distance
Time
Consumption
Fuel
Fuel
Cost
Item
US West
Coast to
Hawaii &
South Alaska
Fuel
Type
(NM)
Medium ECA
Route, with ECA
Route
Voyages
per year
Fuel
Type
(NM)
(hrs)
(tons)
($)
($)
Short ECA
Route, no ECA
525
23.9
124.3
$62,145
$1,553,622
HFO
Short ECA
Route, with ECA
525
23.9
118.1
$85,605
$2,140,115
MGO
$23,460
$586,492
Cost Increase
for ECA
Medium ECA
Route, no ECA
Medium ECA
Route, with ECA
700
31.8
165.7
$82,860
$2,071,496
HFO
700
31.8
157.4
$114,139
$2,853,486
MGO
$31,280
$781,990
Cost Increase
for ECA
Impact of Speeding Up the Vessel to Maintain Schedule

While wanting to take advantage of the considerable fuel cost savings by minimizing distance
traveled in the ECA, but needing to maintain the same schedule, some operators may want to
speed up the ship to compensate for the extra time caused by the deviation to reduce ECA
mileage. This applies more to the transatlantic voyages to the US East Coast than to transpacific
voyages to the US West Coast, which had minimal or no savings from deviation. Other issues
pg 18
such as a need for timely arrival versus the ship will wait for the berth could outweigh the fuel
cost differences between the direct route and the minimal distance in ECA route. Typical ship
operators for whom schedule is of great importance are containership operators, who operate on
fixed schedules and may not be able to add hours to their passage times and maintain the same
overall voyage schedule. If possible, they may opt to speed up ships to make up the difference,
but many ships may already be operating at near full power and this would not be possible. There
is also the cost of the delay in terms of ship overall daily cost, such that there may be an overall
savings in vessel operating costs if it is sped up to maintain schedule because the extra cost of fuel
is less than the cost for the extra hours of ship time. The additional fuel costs to speed up a ship
to maintain schedule can be estimated and are presented for transatlantic voyages in Table 14. It
covers representative passages for the three sample ships for voyages between the English
Channel and New York, considered representative of transatlantic voyages. The additional power
required by speeding up the ship is calculated assuming a cubic speed power relationship. For
transpacific service there is little need to speed up the ship since the deviations are small.
Table 14 Transatlantic - Fuel Cost Impact when Speeding Up Vessel to Maintain Schedule
Route
English
Channel to
New York
Daily FO
Cons
FO Cons
Fuel Cost
(t/day)
(tons)
($)
209.8
35.0
306
$152,969
HFO
14.3
183.6
37.6
287
$143,696
HFO
14.3
26.2
35.7
39
$28,202
MGO
326
$171,898
Mileage
Speed
(NM)
(kts)
Without ECA
2937
14.0
Outside ECA with

Deviation to
Minimize ECA
2632
Inside ECA
375
Item
Hours
209.8
ECA Totals
Extra Cost of Fuel same arrival
English
Channel to
New York
$18,929
Without ECA
2937
18.0
163.2
75.0
510
$254,948
HFO
Outside ECA with

Deviation to
Minimize ECA
2632
18.4
142.8
80.5
479
$239,493
HFO
Inside ECA
375
18.4
20.3
76.5
65
$47,003
MGO
544
$286,496
163.2
ECA Totals
English
Channel to
New York
Fuel
Type
$31,548
Without ECA
2937
22.0
133.5
125.0
695
$347,656
HFO
Outside ECA with

Deviation to
Minimize ECA
2632
22.5
116.9
134.2
653
$326,581
HFO
Inside ECA
375
22.5
16.6
127.4
88
$64,096
MGO
742
$390,677
ECA Totals
133.5

$43,020
pg 19
A comparison is made in Table 15 between the extra costs of fuel for the three operating schemes
considered in this analysis. The first is taking a direct route through the ECA, the second is
deviating to minimize distance in the ECA while keeping constant speed and the third is deviating
the ship to minimize ECA distance, but speeding up to maintain schedule. The outcome of the
analysis is different for transatlantic and transpacific voyages. For transatlantic voyages, the
lowest cost option is clearly to make the deviation and accept the somewhat later arrival. If delay
is not acceptable, then the best option for keeping arrival time is to speed up the ship. For
transpacific voyages, the gain from deviation to minimize ECA distance is small, and if same time
arrival is needed, it is best to take the direct route through the ECA, rather than deviating and
speeding up to compensate. There may be intermediate solutions consisting of partial deviation to
save some on ECA fuel, while delaying the vessel less, that may be optimum for a particular
voyage. Since what is the best course of action is so dependent on circumstances, it is expected
there will soon be computer programs available where you can input much of the data considered
in this analysis, plus whatever ship hourly costs apply and the impacts of schedule changes on
port costs, to calculate the optimum solution for how to route the ship through the ECA and at
what speed.
Table 15Fuel Cost Impact Comparison of Speeding Up Vessel versus Constant Speed
Route
English
Channel to
New York
Shanghai to
Los Angeles
Nominal Speed
Deviation at
Constant
Speed - Hrs
14.0
Extra Fuel Cost with ECA

Min ECA w/
Constant Speed
- Later Arrival
GC Route Same Arrival
Min ECA w/
Speed Up Same Arrival
5.0
$11,019
$23,830
$18,929
18.0
3.9
$18,365
$39,716
$31,548
22.0
3.2
$25,043
$54,158
$43,020
14.0
3.6
$8,994
$9,654
$14,384
18.0
2.8
$14,990
$16,090
$23,973
22.0
2.3
$20,441
$21,940
$32,691
5. Fuel Storage Requirements for the North American ECA

As soon as the North American ECA becomes enforced in August 2012 vessels will need to have
separate, segregated fuel that complies with the ECA requirements. This applies currently for the
North Sea / Baltic Sea ECA, and to California and EU ports based on local regulations. Table 16
lists recommended storage requirements to meet the North American ECA for the indicated
routes. A similar analysis can be made for the North Sea / Baltic Sea ECA. Ships that call at
multiple ports within the ECA or are involved in coastwise trade will have much larger ECA
compliant fuel storage requirements and should be analyzed on a case by case basis. For ships
involved in typical international trade, the recommended storage capacity is the capacity based on
the indicated number of passages plus the minimum reserve that should be retained onboard. In
general, to avoid bunkering for the ECA every voyage, it is recommended to have storage
pg 20
capacity to make at least two round trip voyages to North America (four passages), with the
possible exception of voyages to US Gulf ports, such as Houston. To reach Houston and other
US Gulf ports from the Atlantic requires a long passage within the ECA, and if a ship is only
making occasional calls at one of these ports, it seems unnecessary to store so much ECA fuel
onboard, and so minimum storage is based on two passages (voyage to and from the US port).
For ships which trade regularly to the US Gulf, having capacity for four passages would make
sense. That is why for Houston there are two recommended storage capacities shown in Table 16,
one based on two passages and one based on four passages.
Table 16 - Storage Capacity for LSHFO and MGO for North American ECA Operation
Route
English
Channel to
New York
English
Channel to
Houston
English
Channel to
Houston
Shanghai to
Seattle
Shanghai to
Los Angeles
US West
Coast to
South
Alaska &
Hawaii
Nominal
Speed
Per Passage
ECA LSHFO
Consumption
ECA MGO
Consumption
(kts)
(tons)
(tons)
14
39.1
37.1
18
65.1
22
No. of Passages
for Storage
Capacity
Minimum
Reserve
Recommended Storage
LSHFO
MGO
(tons)
(tons)
(tons)
105
261
253
61.8
225
485
472
88.8
84.3
375
730
712
14
136.4
129.5
105
650
623
18
227.3
215.9
225
1134
1089
22
309.9
294.4
375
1615
1553
14
136.4
129.5
105
378
364
18
227.3
215.9
225
680
657
22
309.9
294.4
375
995
964
14
41.7
39.6
105
272
263
18
69.4
66.0
225
503
489
22
94.7
90.0
375
754
735
14
33.9
32.2
105
240
234
18
56.4
53.6
225
451
439
22
76.9
73.1
375
683
667
14
54.7
52.0
70
289
278
22
165.7
157.4
250
913
880
Notes:
1. Minimum Reserve is 3 days daily fuel consumption except for Alaska & Hawaii where 2 days consumption is used as
reserve
The minimum required reserve and frequency of bunkering is up to operator requirements and
judgment. The figures listed in the table are just illustrative estimates. Minimum reserve of ECA
fuel for three days FO consumption is recommended for most ships because there may be a need
to extend operation within the ECA and to supply generators while in port. For ships in regular
pg 21
trade to Alaska and Hawaii, minimum reserve is estimated as two days since those ships are
regularly in ports where bunkering is available.
In considering how the ECA fuel requirements will impact existing ships, Table 17 lists typical
fuel capacities for existing tankers, containerships and bulk carriers. Most existing ships are
designed to use MDO as the distillate fuel. As the requirement to use 0.1% low sulfur fuel comes
into effect, this can currently only be met by using MGO.
Table 17Typical Existing Ship Fuel Storage Capacities and Estimated ECA Fuel Required
Capacity
HFO
Ship Type/Size
Description
2500 TEU
Feeder Containership
6 HFO stor +
10 HFO stor +
Post-Panamax Containership
2 Sett + 2 Serv
9000 TEU
12 HFO stor +
Post-Panamax Containership
2 Sett + 2 Serv
50,000 DWT
2 HFO stor +
Panamax Tanker
1 Sett + 1 Serv
110,000 DWT
4 HFO stor +
Aframax Tanker
1 Sett + 1 Serv
160,000 DWT
4 HFO stor +
Suezmax Tanker
1 Sett + 1 Serv
300,000 DWT
4 HFO stor +
VLCC Tanker
2 Sett + 2 Serv
35,000 DWT
4 HFO +
Bulk Carrier
1 Sett + 1 Serv
Capesize
4 HFO +
Bulk Carrier
1 Sett + 1 Serv
3,200
1 Sett + 1 Serv
6000 TEU
Estimated LSHFO
(1)
or MGO for ECA
MDO
8,000
10,000
1,500
3,000
4,000
5,500
1, 500
4,000
Description
1 DO Stor
+ 1 Serv
2 DO Stor
+ 1 Serv
2 DO Stor
+ 1 Serv
1 DO Stor
+ 1 Serv
1 DO Stor
+ 1 Serv
1 DO Stor
+ 1 Serv
1 DO Stor
+ 1 Serv
1 DO Stor
+ 1 Serv
2 DO Stor
+ 1 Serv
300
600-800
400
800-1000
800
1200
150
250-400
250
400-600
350
500-750
450
600-850
100
250-450
350
500-750
(1): Lower capacity is for traveling to US East and West Coasts only. Larger capacity is for travel to US Gulf ports and for
occasional travel to multiple ports along the coast. Larger capacities also apply for Hawaii and Alaska because ships encounter the
ECA at both ends of the passage.
Most ship owners do not want to carry three types of fuel on the ship, so once the requirement to
operate on MGO comes into effect, the ship will convert to using only MGO as ECA fuel. This
means for all times when HFO is not used the ship should be capable of using MGO. In the right
hand column of Table 17 are estimated amounts of MGO or LSHFO (during initial years of the
ECA) required for operation in the ECA for these ships. The indicated quantities are derived
from the route specific estimates given in Table 16. The lower values are for operation
exclusively to the US East and West Coast ports and the larger values are for occasional operation
pg 22
to US Gulf ports or if the vessel will call at multiple ports within the ECA. The higher values
would also apply for vessels that trade regularly between the US West Coast and Hawaii or
Alaska because they encounter the ECA twice each voyage. The estimated quantities for LSHFO
and MGO in Table 17 can also be used as guidance for new ships.
6. Ship Design Impacts of an ECA

Meeting the requirements for sustained operation on low sulfur, low viscosity fuels will have two
major impacts on the design of ships besides the impacts on the engines and boilers themselves.
One is that the storage capacity for low sulfur fuel, either LSHFO or MGO, will have to be
sufficient for the quantities discussed in the previous section. The other is that changes to fuel
systems and equipment will be needed to segregate and handle two quite different types of fuels,
with different viscosities, densities and handling temperatures. New ships can be designed
specifically to incorporate the needed features, but since the ECA requirements apply to all ships,
some modifications may be necessary on many existing ships, as well. This section will discuss
how these changes impact the design and arrangement of a ship.
Existing Ships
Finding ways to achieve the required ECA fuel capacity on existing ships may be a challenge for
many. If a ship is not already set up for LSHFO capacity, existing HFO tanks can be converted to
LSHFO storage since existing fill and transfer piping and pumps can be used for both fuels.
Existing HFO storage tank heating capacity should be adequate for LSHFO. The use of LSHFO
is particularly easy when there are two HFO Settling and Service tanks, since one can be used for
regular HFO and the other for LSHFO. However, some ships have only single HFO Settling and
Service tanks, with the backup provided by MDO Settling and Service tanks. For those ships,
adding a second HFO Settling and Service tank is not normally feasible, and considering the use
of LSHFO will be allowed in the ECA for only 2.5 years (Aug 2012 to Jan 2015), it may not be
cost effective to add a tank. For ships with single HFO Settling and Service Tanks fuel switching
is still possible, but is more time consuming. For those ships the normal method is to reduce the
level of regular HFO in the Settling and Service Tanks to a low value, such as 20% of capacity,
and then refill with LSHFO prior to entering the ECA. The switch should be made far enough in
advance that the regular HFO is consumed prior to entry in the ECA. This will consume extra
LSHFO because of the need to start well ahead of the ECA. As required by the ECA regulations,
a procedure should be prepared describing the fuel switching process and careful documentation
maintained of fuel switching times and tank levels since it will not be obvious when the ship has
fully changed over to LSHFO. Starting in 2015 only distillate fuel will meet the ECA
requirements, so LSHFO will no longer be needed in the ECA, and the key issue will become the
distillate capacity of the ship.
Ships which are currently set up for storage and use of MDO can be converted to the storage of
MGO relatively easily. The difficulty arises with the operation of the machinery plant on MGO,
pg 23
not with its storage. MDO filling, storage and transfer systems can be used for MGO. If there is
inadequate existing storage onboard, this becomes more difficult to address. The primary way to
do this is to convert some tanks from some other liquid to MGO. Since MGO does not require
heating non-fuel tanks can be changed to MGO storage or new tanks created from voids or holds.
HFO fuel tanks can also be changed over to MGO storage or designed for dual use, either HFO or
MGO. Particularly when planning to fill a tank with MGO that was previously filled with HFO,
adequate safeguards should be put in place to segregate the MGO from HFO contamination (such
as separate suction/fill connections to the tank for HFO and MGO). After emptying HFO from a
tank to be converted to MGO, thorough cleaning of the tank and any piping used with both fuels
should be carried out before bunkering MGO. When adding storage capacity to a ship for
sustained operation on MGO the following issues should be considered:
1. Evaluate whether the diesel oil (DO) transfer pump has adequate capacity for the larger
quantity of DO to be stored onboard.
2. Evaluate whether the diesel oil fill pipes are large enough for the larger quantities to be
taken onboard.
3. Evaluate whether a DO purifier is needed because of sustained operation on MGO.
Having a single HFO purifier suitable for DO purification may not be suitable since if it
fails there is no way to purify MGO. While MGO is a relatively clean fuel, it is still risky
to operate without purification.
4. Evaluate how a second DO service tank can be added as a backup in case of
contamination of the primary DO service tank. One of the existing DO storage tanks can
probably be converted to a second service tank or to act as a settling tank for purification
purposes. Class rules require two DO fuel service tanks for dual fuel ships. This rule is
intended for ships which operate diesel generators on distillate fuel only and its
interpretation for ships operating with dual fuels in an ECA needs to be clarified.
However, depending on the HFO service tank as the standby fuel source when in an ECA
can lead to fines for the ship if it is forced to change to HFO because of problems with the
MGO, so it is not recommended. It should also be remembered that switching from MGO
to HFO cannot be done rapidly, and will not allow for the immediate response that may be
necessary when in coastwise/harbor areas to avoid collisions or groundings.
5. Any new MGO tanks should not have more than limited contact area with heated HFO
tanks, since heating the MGO can excessively reduce its viscosity and generate excessive
amounts of fumes from the tank vents.
Fuel System Design Impact

The second area affected by operation on low sulfur fuel is the design of the fuel service system.
Since it is required to document that the correct fuel is used throughout the period of time a ship
operates in an ECA, it is best to have the low sulfur fuel segregated at all times from out of
compliance fuel. Keeping this segregation right up to the fuel supply pumps to the engines or
boiler burners allows for the quickest fuel switching and easiest determination of the time when
pg 24
the fuel switch was completed (outside the ECA). It also allows better demonstration that the fuel
was uncontaminated and met the required sulfur level since only the sulfur level as bunkered need
be considered, without any consideration of the effects of mixing beyond the short period of time
for switching. The following changes to the engine fuel systems should be considered before
starting sustained operation on MGO in an ECA. These are only a few of the issues involved and
knowledgeable and experienced persons should be brought in to make an evaluation on what
changes are needed for any particular ship. For boilers the change to MGO raises other issues and
changes in fuel system design and boiler operation need to be separately considered.
1. Fuel supply and circulating pump capacities need to be checked for their ability to pump
low viscosity fuel. Many pumps lose capacity with low viscosity fuel and may need to be
replaced to allow full power operation. Proper lubrication of rotating parts must also be
considered.
2. Consider adding an MGO Chiller or Cooler for operation on low viscosity MGO,
particularly while in summer or tropical conditions. A means of cooling MGO is needed
because its viscosity can become less than engine maker allowed lower limits at
temperatures above 40 C at the engine inlet, which is possible in high ambient conditions
considering fuel is recirculated through the hot engine (except on common rail engines).
An MGO Cooler that uses the central fresh water cooling water as the cooling medium
may not be adequate, since the cooling water temperature is usually set to 36 C, which is
too high when trying to cool fuel below 40 C. A Chiller with a refrigeration system is
better, since it can cool the fuel down to 20 C to 25 C. It should also be noted that a new
revision of the ISO Fuel Specification 8217 has modified the minimum viscosity of MGO
Category ISO-F-DMA to be 2.0 cSt at 40 C (was 1.5 cSt at 40 C) and added a new
MGO category ISO-F-DMZ that is identical to DMA, except that it has a minimum
viscosity of 3 cSt at 40 C. If DMZ fuel becomes widely available there may not be a
need for an MGO Chiller.
3. Consider if the size of the fuel mixing tank is adequate since a small tank, as used on
newer ships, means the fuel is quickly recirculated through the tank so changes in
viscosity will happen quickly when changing from high viscosity HFO to low viscosity
MGO or vice versa. This can cause viscosity shock to the engine unless the main engine is
slowed down significantly to extend the time for fuel switchover.
4. A similar issue is the rate of fuel temperature change that occurs during the switching
process. Engine makers recommend 2 C per minute as the maximum rate of fuel
temperature change, and if fuel switching is done too quickly the rate of temperature
change will exceed that value as fuel temperature is rapidly adjusted by the viscometer to
keep the quickly changing viscosity within limits.
5. For the reasons discussed in the previous two items, a simple 3 way valve for fuel
switching may be difficult to properly manage manually and an automated fuel switching
system, such as the MAN diesel switch or similar, is needed. This type of system controls
the fuel source changeover and slowly switches from one to the other, while it keeps the
pg 25
temperature rate of change and viscosity within limits by also controlling the fuel heaters
and MGO chiller, if provided.
6. As a separate but similar issue, for a slow speed engine a dual cylinder oil system should
be considered so two types of cylinder oil can be stored and supplied to the engine to suit
the two types of fuel.
7. Designing New Ships for the ECA

From now onwards new ships intended for trading beyond the boundaries of the ECA should be
designed to operate as dual fuel ships to reflect the reality of the already known ECAs plus the
expectation there will be more ECAs in the future, while retaining the capability to use low cost
HFO while outside the ECA. A true dual fuel ship should be able to operate on a sustained basis
on either fuel. However, looking farther into the future, it should be noted that the IMO has
designated 2020 as the year all marine fuels shall have a maximum sulfur content of 0.50%,
bringing into question whether HFO will be available with this low sulfur content after that date.
It is possible that only distillate fuels will be used full time once the sulfur limit is reduced to
0.50% and dual fuel capability will no longer be needed. This means any new ship should have
full capability to operate on distillate fuel, including MGO, at all times and in all conditions of
ambient temperature. A ship being built in the near term should also have separate storage,
settling and service tanks for LSHFO.
Figure 5 shows the suggested fuel filling and transfer system for the dual fuel ship of the near
term as it includes LSHFO capability. The number of settling and service tanks is increased to
two for each fuel, and sizing of pipes and pumps should be based on the actual capacities. The
traditional small fill line and transfer pump for diesel oil will no longer be sufficient. The DO
transfer pump connection to the MGO service tank is shown as normally closed (NC) because it is
expected the DO purifier will be used to fill the MGO service tank. The following items should
be included or considered when designing the fuel fill and transfer system for a new ship:
1. Two MGO service tanks are recommended to fully meet Class Rules for dual fuel ships and to
have a backup available in case of contamination of one tank, since HFO should not be used
as a backup fuel while in the ECA (starting in 2015). Service tanks should be sized based on
the combined fuel consumption rate of the main engine and diesel generators.
2. Two HFO settling and service tanks are recommended, so one set can be used for LSHFO.
3. Since MGO is a clean distillate fuel, no settling tank is necessary, but the fuel should pass
through the DO purifier when filling the service tank from the storage tanks to ensure any dirt
and water are removed.
4. Fill and transfer pipes for diesel oil should be sized based on the total capacity divided by the
expected bunkering time. Since MGO storage capacity is expected to be nearly double what
was the standard previously, the diesel oil fill line should be significantly larger than on most
existing ships.
5. Similarly, the DO transfer pump needs to be sized based on the larger diesel oil capacities.
pg 26
Figure 5 Fuel Transfer System for the New Dual Fuel Ship
Figure 6 shows the recommended fuel purification system for a new ship. A DO purifier is
indicated, since just depending on one HFO purifier to also purify MGO is probably not adequate
since no MGO purification will be available if it fails. There may also be a need for operating
both HFO purifiers for HFO purification, leaving neither available for MGO purification.
Regarding the fuel service system, all the items discussed for existing ships in the previous
section should be incorporated into a new ship. They should be easier to install as there are fewer
restrictions in adopting them.

pg 27
Figure 6 Fuel Purifying & Service System for the New Dual Fuel Ship
8. Conclusions
The following summarizes some of the key impacts of the adoption of the ECA on ship operation,
fuel costs and fuel storage and handling systems:
Vessel Routing will need to be optimized to minimize distance traveled in the ECA,
considering impacts on vessel schedule and operating costs of any deviations.
When 0.1% sulfur fuel is required starting in 2015, per voyage fuel cost impacts (into and
out of the ECA) can be on the order of $10,000 to $80,000 depending on port, route and
ship daily consumption. In the period of 2012 to 2015, when LSHFO is permitted in the
ECA, except California, the cost impact will be much less.
Annual fuel cost impact can be on the order of $75,000 to $900,000 for ships on regular
voyages into and out of the ECA starting in 2015.

pg 28
For ships with multiple port calls in the ECA or in coastwise trade fuel cost impact will be
higher.
The Unifuel ship of the recent past will have to become the Dual Fuel ship of the future.
Substantial increases in ECA compliant fuel storage capacity will be needed on most
ships, both existing and new.
Changes will be needed to most ships fuel transfer, purifying and service systems to
operate on the newly required low sulfur, low viscosity fuels.
Required modifications can be potentially costly on existing ships.
The analysis presented in this report shows how the advent of ECAs will impact ship operations
including vessel routing, schedules and machinery operation and will require increased focus on
safety and training so crews can carry out the potentially risky fuel switching process when
entering and leaving the ECA and safely operate with the newly required low sulfur fuels. These
are the realities of a modern world ever more focused on maintaining environmental standards as
the pressure of increasing world population and pace of business place ever greater strain on the
environment. The ship designer, owner and operator need to be aware of the impacts of these
changes and plan ahead to address them in a timely and efficient manner in order to successfully
make the transition to the new era of heightened environmental awareness at sea.

pg 29

Fuel Storage & Handling Systems and The Costs of Operating in ECAs, 2010

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Fuel Storage & Handling Systems and

the Costs of Operating in ECAs

April 29, 2010

Herbert Engineering Corp.

2. ECA Implementation Schedule

Operating Ships within Emission Control Areas (ECAs)

Herbert Engineering Corp.

3. Distances within the North American ECA

Herbert Engineering Corp.

Figure 1 English Channel to US East Coast Great Circle Routes

Operating Ships within Emission Control Areas (ECAs)

Herbert Engineering Corp.

Figure 2 English Channel to US East Coast Minimized ECA Routes

Great Circle Route

Minimized ECA Route

Table 2 ECA Mileages for Gibraltar to US East Coast

Great Circle Route

Minimized ECA Route

Operating Ships within Emission Control Areas (ECAs)

Herbert Engineering Corp.

Figure 3 Shanghai to US West Coast Great Circle Routes

Operating Ships within Emission Control Areas (ECAs)

Herbert Engineering Corp.

Figure 4 Shanghai to US West Coast Minimized ECA Routes

Great Circle Route

Minimized ECA Route

Table 4 ECA Mileages for Yokohama to US West Coast

Great Circle Route

Minimized ECA Route

Operating Ships within Emission Control Areas (ECAs)

Herbert Engineering Corp.

Hawaii & Alaska

4. Fuel Consumption and Cost Impacts of the North American ECA

Herbert Engineering Corp.

Transatlantic - Fuel Cost Impacts of the ECA

Operating Ships within Emission Control Areas (ECAs)

Herbert Engineering Corp.

Cost for Fuel

Min ECA Mileage

Deviation for Min ECA

Comparison - Min ECA

Min ECA Mileage

Deviation for Min ECA

Comparison - Min ECA

Min ECA Mileage

Deviation for Min ECA

Comparison - Min ECA

GC = Great Circle Route

Operating Ships within Emission Control Areas (ECAs)

Herbert Engineering Corp.

Cost for Fuel

Notes: Same as Table 5.

Cost for Fuel

Notes: Same as Table 5.

Operating Ships within Emission Control Areas (ECAs)

Herbert Engineering Corp.

Annualized Cost Impact of ECA - Transatlantic Routes

Annualized Cost Impact of ECA - Transatlantic Routes

Annualized Cost Impact of ECA - Transatlantic Routes

Herbert Engineering Corp.

Transpacific - Fuel Cost Impacts of ECA

Operating Ships within Emission Control Areas (ECAs)

Herbert Engineering Corp.