‘No Possibility of Delay’ to Sulfur Limit Rule for Marine Fuels

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International shipping is coming under increased scrutiny due to its role in global environmental emissions. S&P Global Platts had an exclusive opportunity to interview Kitack Lim, Secretary-General of the International Maritime Organization, recently to address some of these concerns.

Why has it taken so long for shipping to implement emissions regulation compared with other industries?

First, it’s important to clarify that shipping is regulated by governments, through the International Maritime Organization. Shipping has been subject to increasingly tighter, more comprehensive emissions regulations for over 20 years since a new annex covering air pollution was added to MARPOL, the main convention on pollution from ships, in 1997.

This annex has been widened and strengthened. Today, it regulates a whole series of harmful emissions from ships. Amendments adopted in 2008 actually made shipping the first industry to be globally subject to binding international regulations to control greenhouse gas emissions, and these too, have been strengthened in subsequent years.

If serious problems with implementing the sulfur limit rule become apparent in early 2019, would you advocate putting it on hold temporarily?

At this point, the regulation which brings into force the 0.5% limit in sulfur in fuel oil from January 1, 2020 (outside designated emission control areas where the limit is already 0.1%) cannot be changed from a legal perspective, so there is no possibility of delay.

An inter-sessional group under the auspices of the Sub-Committee on Pollution Prevention and Response is meeting in July to develop some very detailed guidance on implementing the 0.5% limit.

This will include guidelines on preparatory and transitional issues, relating to how ships can prepare for implementation, including relevant time schedules; impact on fuel and machinery systems resulting from new fuel blends or fuel types; verification issues and control mechanism and actions, including port state control and in-use fuel oil samples; a standard reporting format for fuel oil non-availability; and safety implications relating to the option of blending fuels.

The Working Group will report directly to the Marine Environment Protection Committee in October, on the development of ship implementation planning for 2020.

Will the carriage ban on HSFO for ships without scrubbers be enough for effective compliance to the rule; does the IMO propose/plan other measures to ensure this?

This will be one measure that will be important in terms of ensuring consistent implementation of the 2020 sulfur limit.

MEPC 73 in October is expected to consider, with a view to adoption, the draft amendments to MARPOL Annex VI to prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship.

In terms of whether this will be “enough”, we have seen over the years that the maritime industry and maritime administrations have been able to cope with the entry into force of new regulations.

Member states have also shared experiences of implementing emission control areas.

Of the 172 member states, only about half have ratified Annex VI. Will this pose hurdles in compliance?

To date, MARPOL Annex VI has been ratified by 91 parties who between them represent 96.89% of world merchant shipping tonnage. So the majority of tonnage is covered by flag states that are party to the regulations. The parties also represent a large proportion of trading states.

If a ship from a “non-party” state trades to a party, it will need to be compliant. Given the broad acceptance of the regulations in tonnage terms, we should see correspondingly broad levels of compliance.

It is also worth noting here that IMO regulations are applied to all ships. Furthermore, the principle of non-discrimination and the principle of no more favorable treatment is enshrined in MARPOL and other IMO conventions.

So the number of parties to MARPOL Annex VI should not pose a hurdle to compliance.

ISO is going to provide guidance on 0.5% sulfur compliant marine fuels specifications. Does the IMO have any view on this?

IMO’s MEPC requested ISO to consider the framework of ISO 8217 to ensure consistency between the relevant ISO standards on marine fuel oils and the implementation of the sulfur rule.

At the last MEPC session, ISO provided information regarding the development of ISO Publicly Available Specification — PAS 23263. The Committee has invited ISO to keep it updated on the progress.

Are regulations coming up to address NOx, particulate matter emissions?

When it comes to nitrogen oxides, on January 1, 2019 we will see the entry into force of Amendments to MARPOL Annex VI to designate the North Sea and the Baltic Sea as ECAs for NOx under regulation 13 of MARPOL Annex VI. Both ECAs will take effect on January 1, 2021, thereby considerably lowering emissions of NOx from international shipping in those areas.

Black carbon is also being considered by the PPR Sub-Committee. IMO has been looking at how to measure and report on black carbon emissions, as part of its work to consider the impact on the Arctic due to such emissions from international shipping.

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Source: Platts

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