F38390 Spencer Jones FINAL.pdf

5 May 2026
TEL +64 4 473 0111
Level 11,1 Grey Street, Wellington 6011

PO Box 25620, Wellington 6140
Spencer Jones
New Zealand

[FYI request #34430 email]


Our ref:  F38390
By email
Dear Spencer,
Response to request regarding analysis of atmospheric and climatic impacts of shipping
emissions
I refer to your request to Maritime NZ on 8 April 2026 as follows:
““I request copies of any documents held from 1 January 2015 to present that:
        1.     Assess or analyse the atmospheric impacts of shipping emissions, including:
        •       sulphur dioxide (SO₂)
        •       sulphate aerosols
        •       particulate matter
        2.      Evaluate or discuss:
        •       aerosol–cloud interactions
        •       cloud condensation nuclei (CCN)
        •       cloud formation or reflectivity
        •       rainfall or precipitation effects
        3.      Relate to implementation or impacts of:
        •       MARPOL Annex VI
        •       Marine Protection Rules Part 199
        4.      Include any modelling, monitoring, or scientific assessments of:
        •       coastal air quality near ports
        •       secondary sulphate formation
        •       observable “ship track” phenomena
If no documents exist that evaluate rainfall or cloud effects, please confirm that no such analysis
has been undertaken or is held.”
We have now considered your request under the Of icial Information Act 1982 (the Act).
Question 1 – impacts of shipping emissions
We are refusing this question under s18(e) of the Act - the information requested does not exist.
Maritime NZ has no mandate to monitor emissions from ships therefore we have not undertaken any
assessment or analysis of the atmospheric impacts of shipping emissions. However as outlined
below, we do have responsibilities under MARPOL Annex VI.

MARPOL Annex VI
On 26 May 2022, New Zealand signed up to the International Maritime Organization (IMO)
convention known as MARPOL Annex VI. Maritime NZ has specific responsibilities for this Annex.
Annex VI of MARPOL seeks to address the impact of air pollution from shipping activities on human
health and environments in and around port communities, and the impacts of emissions from
shipping activities on climate change and ozone layer depletion.
The MARPOL Annex VI requirements are given ef ect by the Marine Protection Rules Part 199:
Prevention of Air Pollution from Ships, and the Engine Fuel Specifications Regulations (administered
by the Ministry of Business Innovation and Employment). The rules apply to New Zealand ships
voyaging anywhere in the world, and to all other ships in seas under New Zealand’s jurisdiction,
except for warships and ships of the New Zealand Defence Force.
The Marine Protection Rules Part 199: Prevention of Air Pollution from Ships (Part 199) brought the
requirements of Annex VI into effect in New Zealand law and came into force from 26 August 2022.
As stated above, Annex VI or the MTA and rules Part 199 does not provide Maritime NZ with a
mandate to monitor ship emissions.  Annex VI is designed to manage emissions through how
vessels are designed and constructed, and fuel used.
Questions 2 and 4 – cloud interactions and air quality
We are refusing these questions under s18(e) of the Act – the information requested does not exist.
Maritime NZ is a regulatory agency. As noted above in our response to question 1, we have no
mandate to monitor emissions from ships under the Maritime Transport Act 1994 (MTA) and our
responsibilities under MARPOL Annex VI are outlined above. As we are not an environmental
agency, we do not measure possible impacts of cloud interactions or air quality.
Please note that under the Resource Management Act 1991 (RMA), regional councils and unitary
authorities are responsible for monitoring local air quality and addressing local sources of pollution.
However, through regulations under the RMA, different Councils have interpreted their roles
differently and we understand that some Councils consider ship emissions a permitted activity. If you
want more information on this mechanism, you could approach the Ministry for the Environment or
the relevant Council for their interpretation of the RMA provisions.
Question 3 – Documents relating to the implementation/impacts of MARPOL Annex VI and
the Marine Protection Rules Part 199 from 2015
The process involved in New Zealand acceding to MARPOL Annex VI was a multi-year project
involving several dif erent agencies, and to provide all documents from 2015 would require us to
refuse this question under s18(f) of the Act, in that the information cannot be made available without
substantial collation or research. Both the Ministry of Transport and Maritime NZ have proactively
released material relating to the implementation and the impacts of MARPOL Annex VI and
therefore we are refusing this question under s18(d) of the Act as this information is publicly
available.
The Ministry of Transport’s material relating to the implementation and impacts of MARPOL Annex
VI can be accessed via the following link - MARPOL Annex VI Treaty | Ministry of Transport. In
particular I would draw your attention to the National Impact Analysis report available here -
MARPOL-Annex-VI-National-Interest-Analysis.pdf
Maritime NZ has also published material relating the implementation and impacts of MARPOL Annex
VI and these can be accessed via the following link - Prevention of air pollution from ships - Maritime
NZ. You might find this document, the Guide for Marine Protection Rules Part 199: Prevention of air
pollution from ships helpful - Guide for Marine Protection Rules Part 199

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You have the right to seek an investigation and review by the Ombudsman of this decision.
Information about how to make a complaint is available at www.ombudsman.parliament.nz or
freephone 0800 802 602.
Yours sincerely,
Caroline Gal
Acting Manager, Communication and Ministerial Services
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