Sulfur Oxides (SOx)
As far as SOx is concerned, in the past, MEPC 70, after assessing low sulphur fuel availability, agreed to retain the current text of MARPOL Annex VI, Regulation 14. Specifically, two studies were conducted; one by BIMCO and one by the MEPC, the first found that the refining industry will lack sufficient capacity in 2020, to fully respond to the Global Sulphur Cap, while the other study said there was enough availability to supply sufficient quantities to meet demand for marine and non-marine fuels.
Accordingly, as of January 1, 2020 we will have a SOx 0,5% Regulation (the sulphur content fuel oil used by ships globally is not to exceed 0.50% m/m). One of the latest developments is the Pollution Prevention and Response (PPR) 5 which is referring to the Consistent implementation of regulation 14.1.3 of MARPOL Annex VI and the carriage ban on non-compliant fuel of non-compliant fuel oil.
SOx PPR5 agenda
- Development of the draft Guidelines for consistent implementation of regulation 14.1.3
- Development of the draft amendments to MARPOL Annex VI: Proper definition of "Sulphur content" (amendments to regulation 2); Testing and verification procedure of in-use fuel oil samples
- Development of draft amendments to existing Guidelines: 2009 Guidelines for PSC (resolution MEPC.181(59)); 2010 Guidelines for monitoring the worldwide average sulphur content (resolution MEPC.192(61), as amended; Guidelines for onboard sampling for the verification of the sulphur content (MEPC.1/Circ.864).
The Committee finalized draft amendments to MARPOL Annex VI and to the Supplement to the IAPP Certificate for a prohibition on the carriage of non-compliant fuel oil for combustion purpose with a sulphur content exceeding 0.50%, for submission to MEPC 72 for approval as an urgent matter, with a view to adoption at MEPC 73. It is imperative that operators have scrubbers on board, otherwise they won’t even be able to carry non-compliant fuel on board! Furthermore, the proposal for inclusion of a transition period, did not receive sufficient support.
As mentioned above, MEPC70 approved to designate the North Sea and the Baltic Sea as Emission Control Areas for nitrogen oxides with effect possibly to ships constructed on or after 1 January 2021 and operating in the Baltic and North Sea ECAs.
Exemptions will allow ships fitted with dual fuel engines or with only Tier II engines to be built, converted, repaired and/or maintained at shipyards located in a designated NOX ECA, although may not meet the Tier III requirements because they are not intended to be operated in a NOX ECA or, in the case of gas engines, their Tier III compliance strategy is unavailable due to safety requirements.
NOx PPR5 agenda
- NOx Technical Code SCR amendments;
- These amendments reflect previous IMO decision that Scheme A and Scheme B should be made equally applicable;
- IACS UI MPC51 on engine test cycles required by the NOX Technical Code (NTC) 2008;
- Engine multimaps: U.S. have strongly opposed this, but this position possibly changes; Much needed major update to cover electronically controlled engines better;
- EGR bleed off water guidelines.
Looking at the EEDI, there have been some updates as well. The Commission talked about some correction factors for the ice class ships, however, no changes would be made at the moment, as this issue is going to be discussed at the next session of the MEPC. Furthermore, as far as the reduction rates are concerned, there will be a thorough review of EEDI phase 3 requirements, looking on the possibility of establishing a phase 4 for some vessels.
Obviously, one of the most effective ways of reducing a ship’s EEDI is by reducing the ship’s design speed by selection of a smaller main engine or main propulsion motor. There is a need to limit the use of this method of EEDI reduction so that it does not lead to unsafe and underpowered ships that may lose maneuvering capability under adverse weather condition.
There are several ongoing projects - among them one in Japan and one in Greece - including three assessment procedures; the minimum power lines, minimum power check and minimum power assessment. The projects are of the view that they will further consider the draft revised Guidelines and submit a joint proposal, including the full text of the draft revised Guidelines, to MEPC 71. The Current IMO interim guidelines on minimum propulsion power are applicable to tankers bulk carriers and combination carriers and provide a definition of “adverse conditions” in terms of wave parameters and wind speed.
The project’s draft revised guidelines show (see images below) a decrease as far as tankers are concerned while in the bulk sector there has been an increase regarding small bulk carries and a decrease regarding the large ones.
Roadmap for IMO Strategy on Reduction of GHG Emissions
Looking at the IMO Roadmap for GHG Emissions below, we see that there are many things that already happened. What is of high importance is the MEPC 72 in Spring 2018, when the initial IMO Strategy will be adopted including short-, mid- and long-term measures.
Another important part of the roadmap is the Adoption of Revised IMO Strategy at (MEPC 80) in Spring 2023. Part of the mid-term strategy will be the possible adoption of Marker Based Measures (MBM) which are basically aiming to put either Levy/Tax Fuel or start an emission trading scheme which is already happening in other industries, such as the shore-based power or the aviation, where there is a 10 US$ per ton of CO2 price.
This is expected to be a starting point for shipping industry as well, however, if they see that there is need to push operators to do better they may go for the 20$ or 30$ scenario. Operators have bear in mind these measures and note what their strategy is for the future.
This new regulation on collection and reporting of the ships fuel consumption data, requires that operators start by adding the methodology in SEEMP; the Flag or R.O shall ensure the SEEMP complies with the regulation and then on the first agenda 2019 operators start the first reporting period. There are three different methods of maintain the figure; either BDN’s, Bunker fuel tank monitoring or Flow Meters.
Thus, operators need to aggregate data and report those collected at the end of the year, sent them to the Flag or R.O for verification and insurance of SoC. Finally, the Flag/ R.O will transfer the data to the IMO Ship Fuel Oil Consumption Data Base. In contrast with EU MRV, operators need a Flag or R.O approval as a verification rather than a company.
When it comes to vessels above 5.000 gross tonnage on international voyages, operators need to monitor the fuel consumption by fuel type in metric tons (MT) and the methods used for collecting fuel consumption data from January 1 until December 31. The flag administration needs verified data, so the guidelines need to be finalized. IMO has provided the actual report format called IMO DCS standardized data reporting format which is simpler though.
IMO DCS standardized data reporting format
- Rated power: the maximum continuous rated power as specified on the nameplate of the engine
- Method used to measure fuel oil consumption: Method using BDNs; Method using flow meters; Method using bunker fuel tank monitoring.
Ballast Water Management
Regarding BWM there have been not many changes, except of the USCG position and some guidelines; the CVC Policy Letter 18-02 Guidelines for Evaluating Potential Courses of Action when a Vessel Bound for a Port in the Unites States has an Inoperable BWMS.
A vessel that has passed its compliance date and has an inoperable BWMS may use one of the other BWM methods:
- BWE: must obtain approval from the District Commander or Captain of the Port (COTP) first. A vessel reporting its BWMS as inoperable for the first time may be allowed to use BWE in lieu of using the BWMS.
- A lack of consumables will not be justification to employ an alternative management method.
- Vessel's BWM Plan should include guidance on alternative BWM strategies.
- Training of the master and crew on the application of ballast water and sediment management and treatment procedures is important.
- The Coast Guard also highly encourages vessels to use their BWMS regularly, even if not bound to or departing from the United State, since this improves crew operational knowledge of the BWMS, thereby improving the BWMS' reliability.
It is obvious that procedures with respect to extensions are getting more complicated. A circular regarding the extensions came out recently stressing that extension will not be granted to vessels that plan to install an AMS or if they have an AMS onboard they will not get an extension. Moreover, extensions may be granted for no longer than the minimum time needed for the vessel to comply with the requirements.
On 16 August 2017, Saudi Arabia launched an initiative to conduct on board indicative sampling of ballast water of ships calling for loading at major oil loading terminals. As of 28 November 2017, over 500 ships have been sampled. The interesting thing is that Over 90% of indicative samples from ships that conducted ballast water exchange (either sequential, empty and refill, or dilution) passed D-2 standard testing and were found to have a low count of viable organisms remaining in discharged ballast water.
A considerable number of ships that have installed IMO-approved ballast water management systems (BWMS) and conducted treatment of ballast water before discharge were observed to have failed D-2 standards testing for samples taken.
Saudi Arabia proposes IMO to consider a re-assessment of the viability and effectiveness of both existing ballast water management methods, exchange and treatment, in relation to the prevention of the transport of invasive species.
The views expressed in this article are solely those of the author and do not necessarily represent those of SAFETY4SEA and are for information sharing and discussion purposes only.
Above text is an edited article of Antony Vourdachas's presentation during the 2018 GREEN4SEA Conference
View Antony Vourdachas's presentation on Maritime Industry Regulatory Framework during the last GREEN4SEA Conference herebelow
Antony Vourdachas joined ABS in April 2014 as a Principal Vessel Performance Analyst in the Piraeus office. Working for the Vessel Performance team in the Operational and Environmental Management department, he is part of the team responsible for providing the vessel performance analysis services to ship owners and operators and designing and updating the relevant software. In addition, he provides assistance to members of the Environmental team on MRV and ballast water issues. He started his career as a Design and Production Engineer at the Devonport Dockyard in Plymouth and moved on to become a Research Associate at the School of Marine Science and Technology at Newcastle University involved in a European Ballast Water project (MARTOB). Prior to joining ABS, he worked for OSG in a number of technical positions in project engineering and planned maintenance. Antony holds a B.Eng. in Small Craft Engineering and an M.Res. in Marine Engineering from the School of Marine Science and Technology at Newcastle University, England.