BIODIVERSITY PROTECTED
“THE VOICE OF LIFE4MEDECA”
Biodiversity Protected
Air pollution has been one of Europe’s main political concerns since the late 1970s. European Union policy on air quality aims to develop and implement appropriate instruments to improve air quality, the ultimate goal is to protect public health. The main instruments are a series of Directives (Directive 2008/50/EC, Commission Directive (EU) 2015/1480) setting ambient air quality standards to provide protection from excessive pollution concentrations, based on the latest research on the health effects of air pollution. In fact, air pollution is a major cause of premature death and disease and is the single largest environmental health risk in Europe. The latest estimates by the European Environment Agency (EEA) show that fine particulate matter (PM2.5) continues to cause the most substantial health impacts. The EEA itself estimates that, in 2018, approximately 379.000 premature deaths were attributable to PM2.5 in the 27 EU Member States and the UK.
On the 10th of December 2021, at COP 22 of the Barcelona Convention in Antalya, Turkey, 22 signatory governments agreed to establish in Mediterranean Sea a sulphur emission control area (SECA) for shipping, under MARPOL (Annex VI), with the proposal to be submitted for adoption to MEPC 78 in June 2022. This “ECAMED” will mandate from 1st January 2025 the use marine fuels at 0.1% sulphur content, instead of current levels of 0.5% (since the 1rst of January 2020), in the Mediterranean Sea. All the focal points representing the Mediterranean states had reached an agreement in May 2021 on a draft submission to the IMO. This draft submission was then approved by the focal points of the Mediterranean Action Plan (stemming from the United Nations Environment Program) which met from September 10 to 17 this year. To date, the Mediterranean Sea does not benefit from any special status in this regard, unlike the Channel, the North Sea, the Baltic and the USA / Canada zone, all designated as control zones for atmospheric emissions of pollutants (known as SECA zone for sulfur oxides and particles, and NECA for nitrogen oxides, ECA for both.
In this sense, governments agreed to establish in Mediterranean Sea a sulphur emission control area (SECA) from 1st January 2025.
From an environmental side, overall shipping traffic in the Mediterranean accounts for approximately 7% of global shipping’s energy use and emissions. In terms of vessels operating in the area, AIS data shows that roughly 30.000 vessels are operating annually in the Mediterranean and CO2 emissions from shipping cause here for about 10% of the Mediterranean coastal states CO2 inventories.
The creation of ECAs will have a positive environmental and socio-economic impact in the area while triggering its Green Transition through the desired Restoration of the Mediterranean, protecting its resources and biodiversity, as well as facilitating the achievement of EU strategic objectives and its Missions.
With regard to the introduction of SECA – and with regard to an eventually forward-looking introduction of NECA – in the Mediterranean, changes for shipping in fuel demand and fuel costs are to be expected. Taking into account that fuel costs in general represent 30% to 60% of operational costs – clearly depending on speed – any changes in fuel costs are considered as a sensible issue – as also diverted effects could arise.
The SECA deep sea shipping presentation covers the world container fleet in the Mediterranean
by ship details and environmental characteristics with regard to the deployment of container vessels in a SECA Med. In addition, the forwad-looking NECA deep sea presentation provides TIER-related information by TEU size-classes, by Year of built, by type of technic and by operator.
Mediterranean Biodiversity

The proposal scenario aims to integrate biodiversity and the protection of the environment for the protection of ecosystem services, forest care and reduction of the acidification of continental waters and marinas, the protection of historical heritage, the protection of the cardiovascular and pulmonological health of people, as well as promoting diversification economy by addressing the challenge of maintaining and valuing ecosystem services. Compelling scientific evidence and a better understanding of the economics of climate change have moved the issue to the forefront of the international agenda (from Kyoto to Copenhagen).Greenhouse effect Gases (GHGs) and pollutants (NOx, SOx, PM, VOCs) emissions from international shipping are increasingly drawing attention andpossible mitigation measures are being considered, both at the regulatory and industrial levels.Emissions caused by combustion of fossil fuels in shipping industry havenegative consequences on environment, adding pollution into the atmosphereand promoting global changes in Climate behaviour.

Contrary to the traffic sector ashore, excesses of emissions limit values can notbe quantified, qualified and linked to seashore activities. Without any reliable monitoring dedicated to maritime activities, environmentallegal controls and policies can not be effective because violations are notdetected. Maritime and port operations today, face increased demands for operationalefficiency, effective facility management, comprehensive security, and sensitiveenvironmental management. These diverse challenges require access todetailed, up-to-date information and careful analysis to produce optimal resultsregarding decision making issues. Intelligent monitoring of main atmospherepollutants that remain in the location and in the harbour surroundings to providedecision making tools and their advantages is required. Shipping industry and port operations generate an important volume ofpollutants. To this respect, the air pollution in harbours areas is a key factor tobe highly considered when environmental policies and actions must be taken inthe global warming control. Green house effect gases (GHG) are involved inglobal climate change and those which come from shipping industry must bemonitored in order to measure their direct impact on the atmosphere. The port can modify the marine ecosystem and produce a biodiversity loss. It is necessary to understand the interactions with the ecosystem.
The EU Habitats Directive is the most important legislation on environmental matters in Europe. This Directive establishes, amongst others, a list of species for which each Member State must create Special Areas of Conservation with specific protection objectives and measures. These areas set up a global European network of protected areas, called the Natura 2000 Network. To date it is probably the most successful conservation tool currently in place, which covers almost 18% of the terrestrial lands.
Unfortunately, this success is hindered by Member States’ poor performance when it comes to the marine environment. With only five habitats and 18 marine species included in the Habitats Directives’ annexes, and only a 1% of European waters are now protected. The lack of representativity of marine ecosystems in the annexes of the Directive is a real obstacle for Member States to complete their Natura 2000 network at sea. It also reveals the necessity of protect our marine environment, while more and more pressures on the oceans are putting European livelihoods at threats.
The Habitats Directive was created in 1992 to address the commitments assumed after the United Nations Convention on Biological Diversity to protect at least 10% of the world ecoregions and as a way to tackle the decline of EU habitats and species. This directive includes measures focused on protecting and recovering the environment and includes five annexes specifying the habitats and species that will be protected.
The main human activity that emits CO2 is the combustion of fossil fuels (coal, natural gas, and oil) for energy and transportation, although certain industrial processes and land-use changes also emit CO2. The main sources of CO2 emissions in ports can be direct or indirect and are described below.
Direct, i.e., transportation and industry.
The combustion of fossil fuels by use of transport. Such as gasoline and diesel to transport people and goods is the second largest source of CO2 emissions. This category includes the marine travel and vehicles.
Industry. Many industrial processes emit CO2 through fossil fuel combustion. Several processes also produce CO2 emissions through chemical reactions that do not involve combustion, for example, the production and consumption of mineral products such as cement, the production of metals such as iron and steel, and the production of chemicals. Note that many industrial processes also use electricity and therefore indirectly cause the emissions from the electricity production.
Indirect, i.e. electricity.
Electricity is a significant source of energy and is used to power homes, business, and industry. The combustion of fossil fuels to generate electricity is the largest single source of CO2 emissions in the port. The type of fossil fuel used to generate electricity will emit different amounts of CO2. To produce a given amount of electricity, burning coal will produce more CO2 than oil or natural gas.
Carbon dioxide is constantly being exchanged among the atmosphere, ocean, and land surface as it is both produced and absorbed by many microorganisms, plants, and animals. However, emissions and removal of CO2 by these natural processes tend to balance. Since the industrial revolution began around 1750, human activities have contributed substantially to climate change by adding CO2 and other heat-trapping gases to the atmosphere.
A carbon sink is a natural or artificial reservoir that accumulates and stores some carbon-containing chemical compound for an indefinite period. The process by which carbon sinks remove carbon dioxide (CO2) from the atmosphere is known as carbon sequestration.
Seagrass are plants (Magnoliophyta) adapted to living in the marine environment that have stems, leaves and rhizome adapted to the special conditions of the sea and they reproduce both sexually through flowers, fruits and seeds, as asexually (cloning) by elongation its rhizomes and formation of new shoots with identical genetic information, hence the name “clonal plants.” Seagrass generates a series of services to the marine (Borum et al., 2004) of our coast. That makes it essential to the functioning of the ecosystem and its conservation.
It generates between 4 and 20 liters of oxygen per square meter per day this makes it to one of the most important sources of oxygenation of the sea. One part of this oxygen is released to the Earth’s atmosphere during the periods of maximum productivity. Furthermore, Seagrass produces an average of 38 tons of biomass by dry weight per hectare. 30% of primary production of seagrass, in form of dead leaves, is dragged into deeper waters. These leaves provide nutrients to the lower floors of the trophic chain, during the decompose process, formed by bacteria, protozoa and fungi as well as predators such as fish in the links higher. The EU proposes protection of seagrass beds by the Habitats Directive (Directive 92/43 of 21 May 1992), include the List of Wildlife in Special Protection Regime, which included both Posidonia oceanica as Cymodocea nodosa.
The main regressions of marine Magnoliophytas observed in the Mediterranean Sea are associated with changes in the coastline, to the management of living resources (fisheries and aquaculture), the dumping of solids and liquids, the adaptation of recreational activities and tourism (cruise), and the introduction of exotic species. More recently, the increase in water temperature and the sea level rise could explain some of the regression phenomena observed (Marbà & Duarte, 2010). While these regressions are mostly focused on emblematic species, Posidonia oceanica, other species are also affected by anthropogenic effects (Boudouresque et al., 2009). Globally regression of marine Magnoliophytas sea seems relatively small (between 0 and 10% throughout the twentieth century; Boudouresque et al., 2009) although the regressions, in specific areas subjected to strong anthropogenic pressures may be much larger (5 to 8% per year; Marbà et al., 1996).
As an example in Western Mediterranean it is estimated that Posidonia oceanica could be responsible for an annual net storage of about 25 million tons of carbon in the Mediterranean. The annual emissions of CO2 into the atmosphere from the burning of fossil fuels and deforestation, the global balances of carbon use estimated at about 200 million tones the carbon fraction of thoseemissions “unassigned” to any known carbon sink. In the case of Posidonia oceanica, primary production is estimated at between 45 and 542 gC m-2 a-1, and a significant proportion of fixed organic carbon (10 to 25%) is sequestered within the sediment (matte), constituting a long-term carbon sink (a few decades to several millennia). Inversely, the calcification mechanisms of certain Rhodobionta and “invertebrates” provide the atmosphere with a significant source of CO2. In Posidonia oceanica meadows, calcareous organisms produce emissions of 28 to 83 gC m-2 a-1. Even though caution should still be exercised when looking at values currently available, the observation of organic carbon sinks (sequestration) and sources of non-organic carbon (calcification) seems to indicate that Posidonia oceanica meadows could be a major sink of CO2. On the scale of the Mediterranean, the average quantity of fixed carbon could be in the region of eight million tons per year.
TOOLS TO INCREMENT THE TERRITORY RESILIENCE
CIMNE collaborate with regional council of Catalonia (Generalitat of Catalunya) to include all simulations and the resilience studies of territory in a public platform (piksel platform (https://piksel-web.cimne.com/) and create financial support mechanisms to increase the territory resilience. PIKSEL is a project financed by the Advanced Digital Technologies Program of the Generalitat de Catalunya.
In this sense, CIMNE carry out additional socio-economic impact evaluations at national level in Tarragona and Barcelona Ports to asses the NOx impact on deep sea shipping, short sea shipping and on other relevant activities including, biodiversity, fishing, and tourism to identify needs, bottlenecks and barriers in the context of a MED ECA.
Restoration biodiversity in ports environment is essential to assure the incement of CO2 sink.
Climate change origen in Western Mediterranean Extract of conference of Arnau, P. in the (Arnau, P., Cycle ¡SOS, Aquí la Tierra!, in the ‘Residència d’investigadors del CSIC, Barcelona, Spain, 2022)
In the past fifty years, there has been a substantial change in how the contributions of freshwater from the coast are produced and how they influence marine circulation. The progressive warming of sea reduces the capacity to absorb gases from the sea. This is due to the summer, coinciding with the increase in the emission of gases to the environment produced by the use of internal combustion engines with SOx, NOx and CO2.
Water management problems will undoubtedly be aggravated by climate change. Climate change problem are their origin mainly in intensive water resources use. The increase of salinity in waste water, for example, for use of desalination technologies as reverse osmosis (RO), has a negative impact in several ecosystems services. Changes in salinity coastal have a profound impact in climate. For example, in NW Mediterranean, the loss of salinity gradients between coastal and marine waters modifies the intensity of marine circulation. In this area, thanks for gradients of salinity (lower near of coast) the Liguro-Provenzal current is of cyclone type. With this configuration, current contribute to maintain the seasonality of rains, contributing colder waters from the Gulf of Lions.
The reduction in salinity gradients for intensive use of water resources is altering the climate in region. The reduction of gradients of salinity in Catalan coast modifies the circulation of cold water from north. This reduction in current intensity is causing a progressive heating of the waters of lower latitudes. The reduction of intensity of current increase the diffusion process in ocean and the reduction of advection process for the increment of size of mesoscales gyres. The increment of diffusion process facilitate the increment of solar heating of water column. This heating of sea implies the increment of interchanges of heat with atmosphere. The heating of the air masses, with steam increment modify the precipitation regime in region. This alteration has been significant since 1960 in Mediterranean Spain watersheds with the progressive regulation of natural courses and has intensified in recent years due to the intensive use of water in all sectors and the modification of its properties.
Associated to the progressive warming of sea there are a reduction of the capacity to absorb gases, because the seawater have lower capacity to absorb gases when increment their temperature. This is critical in the summer, coinciding with the reduction of freshwater contributions to sea for rivers and aquifers, and the increase in the emission of gases to the environment produced by the increment of marine activities and the use of internal combustion engines with SOx, NOx and CO2.
The reduction in salinity gradients for intensive use of water resources is altering the climate in region. The reduction of gradients of salinity in Catalan coast modifies the circulation of cold water from north. This reduction in current intensity is causing a progressive heating of the waters of lower latitudes. The reduction of intensity of current increase the diffusion process in ocean and the reduction of advection process for the increment of size of mesoscales gyres. The increment of diffusion process facilitate the increment of solar heating of water column. This heating of sea implies the increment of interchanges of heat with atmosphere. The heating of the air masses, with steam increment modify the precipitation regime in region. This alteration has been significant since 1960 in Mediterranean Spain watersheds with the progressive regulation of natural courses and has intensified in recent years due to the intensive use of water in all sectors and the modification of its properties.
FUNDING AGENCIES
The LIFE4MEDECA project is a LIFE project in which CIMNE participates as a partner, by donating support to the preparation of Emissions Control Zones (ECA) in the Mediterranean Sea and promoting further decarbonization. As part of the MED ECA political and governance strategies, we are meeting with Jorge Ureta, head of the International Marine Protection Unit (Ministerio de Transición Ecológica y Reto Demográfico) of Spain in the conference ‘Un transporte marítimo más limpio en el Mediterráneo’, organized by GreenTransition company and CIMNE in Madrid, in October 2022. Furthermore, CIMNE participates in the development of a Territorial Prediction Platform within the framework of the PIPLATES/PIKSEL project, a project financed by the Advanced Digital Technologies Program of the Generalitat de Catalunya.
CIMNE collaborate with regional council of Catalonia (Generalitat of Catalunya) to include all simulations and the resilience studies of territory in a public platform (piksel platform (https://piksel-web.cimne.com/) and create financial support mechanisms to increase the territory resilience.
As reference documentation, we include the proposal for a COUNCIL DECISION establishing the position to be taken in HELCOM and IMO concerning the designation on the Baltic Sea as Nitrogen Oxyde Emissions Control Area (NECA), 2013/0153 (NLE).
1. Context of proposal
The International Maritime Organisation (IMO) and its International Convention for the Prevention of Pollution from Ships (MARPOL, Annex VI) provide for the possibility to designate emission control areas, in order to reduce air pollution from shipping, at the request of the riparian States of the area concerned. A North American NECA has already been agreed and in the EU, a Baltic Sea NECA application is ready for submission to the IMO, while work on preparing the North Sea NECA is progressing. NECA provisions will enter into force in 2016, and will apply only to ships built after that date entering a NECA. As part of the NECA submission preparation, HELCOM performed a comprehensive analysis to estimate NOx emissions from ships operating in the Baltic and their impact.
The designation of the Baltic Sea as a NECA is expected to result in a reduction of 16% of NOx emissions from shipping in 2020 and 46% in 2030. It is expected that all ships will meet NECA requirements in the Baltic only around 2040-50, with a third equipped by 2030. The costs and benefits of the Baltic Sea NECA will therefore accrue gradually, due to the relatively slow replacement rate of ships, which varies by vessel type. The Baltic NECA will be an important contribution to the reduction of air pollution, especially as several Member States in the Baltic Sea region do not meet the emission standards set by the Ambient Air Quality Directive. It will in addition result in health benefits and reduced eutrophication, one of the major environmental challenges faced by the Baltic Sea, as well as a diminished acidification and ozone formation.
Investment costs are mitigated due to some ship-owners having already opted to equip their new ships with NECA compliant engines to enable their ships to enter the North American NECA. In these cases, only additional operating costs arise, and will result a in a gradual increase, until 2040-50, of costs of maritime transport in the Baltic Sea. Further information on the costs and benefits of the Baltic Sea NECA for the EU stems from the Impact Assessment accompanying the Commission’s 2010 proposal for the revision of Directive 1999/32 as regards sulphur content in marine fuels[1]. According to this document, benefits associated with full IMO compliance are at least between €3 and €13 for every €1 spent[2]. The benefit/cost ratio associated with the designation of the Baltic Sea as Emission Control Area is considered highly favourable. Available technologies to reduce NOx emissions from shipping are exhaust gas recycling (EGR), LNG and specific catalytic reduction (SCR).
2. Developments to Date.
In 2010, the Ministerial meeting of the Helsinki Convention on the Protection of the Marine Environment of the Baltic Sea Area (HELCOM) decided to “work towards submitting, preferably by 2011, a joint proposal by the Baltic Sea countries to the IMO applying for a NOx Emission Control Area (NECA) for the Baltic Sea”. In its meeting of 9-10 March 2011, the Baltic Marine Environment Protection Commission agreed that the Baltic Sea should be designated as a NECA. It noted however that some parties were not yet ready to take an immediate decision. In its meeting of 6-7 March 2012, the Baltic Marine Environment Protection Commission agreed that the NECA application prepared in HELCOM fulfilled the IMO criteria. In their meeting of 14-15 June 2012 the Heads of Delegation of HELCOM stressed that the only decision remaining was the timing of the submission to IMO. In their meeting on 3-4 December 2012, the Heads of Delegation of HELCOM decided to organise a stakeholders meeting on the Baltic NECA application on 4 March 2013. They agreed that the final date of submission to IMO was to be taken prior to the October 2013 Ministerial Meeting. They agreed to report to the Ministers accordingly. A stakeholder meeting specifically targeted at the Baltic Sea shipping industry took place on March 4, 2013. Once the date of submission has been agreed in HELCOM, the NECA submission will be transmitted for adoption to the IMO Marine Environmental Protection Committee (MEPC) by Baltic riparian States. IMO will then examine whether the requirements of a NOx Control Area under Annex VI of MARPOL are fulfilled. If so, the Baltic NECA will be agreed. However, no substantive discussion will take place at MEPC.
3. EU Position.
The EU has supported in principle the designation of the Baltic Sea as a NECA, as agreed in the Council Shipping Working Party of 7 November 2011. The Working Party also considered that the designation of the Baltic Sea as a NECA was the most cost efficient measure to reduce NOx emissions, to meet ambient air quality standards and good environmental status regarding eutrophication as required under the Marine Strategy Framework Directive. It noted the request by the Shipping Working Party of 8th November 2010 for a detailed impact assessment, recognised that the further developed draft IMO submission for designing the Baltic Sea as a NECA included some elements on the risk of modal backshift but that in principle, a cost benefit analysis is not required by IMO when applying for an emission Control Area and that the economic analysis made in the application was sufficient to meet IMO requirements. On 17 October 2012, the shipping Working Party also took note of the progress on the Baltic Sea NECA and further noted that in case that IMO designates the Baltic Sea as a NECA, the Commission will assess the need to transpose this provision into EU legislation, and that this decision process might require further impact analysis.
It is now necessary for the Council to adopt the position to be expressed by the EU on the date at which the Baltic NECA submission will be transmitted to the MEPC, in line with article 218 (9) TFEU, before the next meeting of the HELCOM Heads of Delegation on 17 June 2013. The applicable IMO rules[3] foresee that NECA rules will apply as of 2016, independent of the date of submission of a proposal to designate an area as NECA. A rapid submission is therefore in the interest of the shipping industry and engine manufacturers, which need sufficient lead time to adapt and avoid possible higher retrofitting costs.
In view of the above, the Union should support the submission to IMO of the HELCOM proposal to designate the Baltic Sea as an Emission Control Area for Nitrogen Oxide, by Baltic Sea riparian states at the latest by the 66th meeting of the IMO Marine Environment Protection Committee in March 2014. It is therefore necessary for the Council to also adopt the Union’s position to be expressed by the EU Member States in IMO, in line with Article 218(9) TFEU.
The council of the European Union, having regard to the Treaty on the Functioning of the European Union, and in particular Article 191, in conjunction with Article 218 (9), thereof, having regard to the proposal from the European Commission. Whereas:
(1) The International Maritime Organisation (IMO) and its International Convention for the Prevention of Pollution from Ships (MARPOL, Annex VI) provide for the possibility to designate, at the request of the riparian states concerned, emission control areas (NECAs) in order to prevent, reduce and control emissions of Nitrogen Oxide (NOx) from ships.
(2) The European Union is a party to the Convention on the Protection of the Marine Environment of the Baltic Sea Area (HELCOM) which is the forum discussing the submission of a proposal for the Baltic Sea as NOx Emissions Control Area to IMO.
(3) Preparatory work has been undertaken under the auspices of HELCOM with regard to a draft submission to the IMO proposing the designation of a NECA in the Baltic Sea. Once the date of a NECA submission has been agreed in HELCOM, it will be transmitted for adoption to the IMO Marine Environmental Protection Committee (MEPC) by the Baltic riparian states. IMO will then examine whether the requirements of a NOx Control Area under Annex VI of MARPOL are fulfilled. If so, the Baltic NECA will be agreed. However, no substantive discussion will take place at MEPC.
(4) The EU ambient air quality directive 2008/50/EC and the NEC directive (2001/81/EC) set emission standards for air pollutants. In particular, directive 2001/81/EC provides that the Commission and Member States, as appropriate, shall, without prejudice to Article 218 of the TFEU, pursue bilateral and multilateral cooperation with third countries and relevant international organisations such as the International Maritime Organization (IMO) with the aim of improving the basis for the facilitation of emission reductions.
(5) The HELCOM Baltic Sea Ministerial Declaration of 2010 agreed to designate the Baltic Sea NECA, preferably by 2011.
(6) The Shipping Working Party of 8th November 2010 requested a detailed impact assessment as it recognised that the draft IMO submission for designing the Baltic Sea as a NECA included some elements on the risk of modal backshift. However, it acknowledged that a cost benefit analysis similar to preparatory work for future EU legislation is not required by IMO when applying for an Emission Control Area and that the economic analysis made in the application was sufficient to meet IMO requirements.In its meeting of 9-10 March 2011, the Baltic Marine Environment Protection Commission agreed that the Baltic Sea should be designated as a NECA. It noted however that some parties were not yet ready to take an immediate decision.
(7) In its meeting of 6-7 March 2012, the Baltic Marine Environment Protection Commission agreed that the NECA application prepared in HELCOM fulfilled the IMO criteria.
(8) In their meeting of 14-15 June 2012 the Heads of Delegation of HELCOM stressed that the only decision remaining was the timing of the submission to IMO.
(9) In their meeting of 3-4 December 2012, the Heads of Delegation of HELCOM agreed that the final date of submission to IMO was to be taken prior to the October 2013 Ministerial Meeting.
(10) If the decision is taken in HELCOM to submit a proposal to IMO to designate the Baltic Sea as an Emission Control Area for Nitrogen Oxide, the EU Member States should support the proposed designation of the Baltic Sea as an Emission control Area for Nitrogen Oxide.
(11) IMO Tier III obligations for NECA will enter into force as of 2016, it is important to give economic operators sufficient time to adapt.
Has adopted this decision:
Article 1: The position to be taken by the European Union in HELCOM shall be to support the submission by the Baltic riparian States to IMO of the HELCOM proposal to designate the Baltic Sea as an Emission Control Area for Nitrogen Oxide, at the latest by the 66th meeting of the IMO Marine Environment Protection Committee.
Article 2 :Following adoption of the decision in HELCOM referred to in Article 1, it shall be presented and supported in the IMO by the Member States acting jointly in the interest of the European Union.
[1] SEC (2011) 919
[2] An ongoing study by DG ENV currently estimates cost benefit ratios for the Baltic NECA in a range of €2.3 to €8.6 for every €1 spent.
[3] IMO Revised MARPOL Annex VI, regulation 13.