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Bunker delivery note amendments enter into force as sulphur 2020 requirement looms

Amendments to the bunker delivery note relating to the supply of marine fuel oil to ships which have fitted alternative mechanisms to address sulphur emission requirements entered into force on 1 January 2019.

The amendment enters into force as the shipping industry counts down to 1 January 2020, when the limit for sulphur in fuel oil will be reduced to 0.50% m/m outside emission control areas (ECAs), from 3.5% currently. The new limit under IMO’s MARPOL treaty will have significant benefits for the environment and human health.

In ECAS, the limit will remain at 0.10% m/m.

The amendments to Appendix V of MARPOL Annex VI are intended to address situations where the fuel oil supplied does not meet low sulphur requirements, but has been supplied to a ship which is using an alternative compliance method permitted under regulation 4 of MARPOL Annex VI (“Equivalents”) to reduce the sulphur oxide emissions of the ship in order to comply with MARPOL requirements. An equivalent means may be abatement technology such as an exhaust gas cleaning system (“scrubber”), if accepted by the flag State of a ship as an alternative means to meet the sulphur limit requirement.

The bunker delivery note shall include a declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied is in conformity with regulation 18.3 of MARPOL Annex VI and that the sulphur content of the fuel oil supplied does not exceed:

  • the limit outside ECAS (currently 3.50%, falling to 0.50% from 1 January 2020) under regulation 14.1;
  • the limit in emission control areas (0.10% m/m) under regulation 14.4;  or
  • the purchaser’s specified limit value, on the basis of the purchaser’s notification that the fuel oil is intended to be used:
  1. in combination with an equivalent means of compliance; or
  2. is subject to a relevant exemption for a ship to conduct trials for sulphur oxides emission reduction and control technology research.

The 0.10% m/m limit applies in the four established ECAS: the Baltic Sea area; the North Sea area; the North American area (covering designated coastal areas off the United States and Canada); and the United States Caribbean Sea area (around Puerto Rico and the United States Virgin Islands).

In October 2018, IMO’s Marine Environment Protection Committee (MEPC) adopted a further amendment to MARPOL Annex VI, which will prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship – unless the ship has an equivalent compliance method. This amendment is expected to enter into force on 1 March 2020, and will (among other things) amend the form of the International Air Pollution Prevention Certificate (IAPP Certificate), so that it specifies that, for a ship without an approved equivalent arrangement, the sulphur content of fuel oil carried for use on board the ship shall not exceed 0.50% m/m as documented by bunker delivery note. (See briefing 19/2018).

North Sea and the Baltic Sea nitrogen oxides (NOx) ECAs
Also on 1 January 2019, amendments to MARPOL Annex VI to designate the North Sea and the Baltic Sea as emission control areas (ECAs) for nitrogen oxides (NOx) entered into force.

Both ECAs will take effect on 1 January 2021, and will result in considerably lower emissions of NOfrom international shipping in those sea areas.

In NOx emission control areas, ships are subject to so-called “Tier III” controls to limit NOx emissions.

Data collection on fuel oil consumption begins 
From 1 January 2019, ships of 5,000 gross tonnage and above need to start collecting data on their fuel-oil consumption, under the mandatory data collectionreporting requirements which entered into force in March 2018.

The MARPOL Annex VI regulation on Collection and reporting of ship fuel oil consumption data requires ships of 5,000 gross tonnage and above to collect consumption data for each type of fuel oil they use, as well as other, additional, specified data including proxies for transport work.

The aggregated data is reported to the flag State for each calendar year and the flag State, having determined that the data has been reported in accordance with the requirements, issues a Statement of Compliance to the ship.  Flag States are required to subsequently transfer this data to an IMO Ship Fuel Oil Consumption Database. IMO is required to produce an annual report to the MEPC, summarizing the data collected.

The data collection system is one of the measures taken which will support the implementation of IMO’s Initial IMO Strategy on Reduction of GHG Emissions from Ships, adopted in 2018. The ships covered by the regulation represent approximately 85% of the total CO2 emissions from international shipping. The data collection system is intended to support the three-step approach towards addressing CO2 emission from international shipping: data collection, data analysis, followed by decision-making on what further measures, if any, are required.

Solid bulk cargoes (IMSBC) code 2017 amendment enters into force
The 2017 set of amendments (04-17) to the International Maritime Solid Bulk Cargoes Code (IMSBC Code) cargoes entered into force on 1 January 2019.

The amendments include requirements for the shipper to declare whether or not a solid bulk cargo, other than grain, is harmful to the marine environment.

Other amendments include updated carriage requirements for a number of specific cargoes and amendments to highlighting the responsibility of the shipper for ensuring that a test to determine the transportable moisture limit (TML) of a solid bulk cargo is conducted.

Souce: IMO

 

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A holistic plan for maritime Malta

Maritime Malta is one of the country’s prime assets. What we lack by way of natural resources is amply compensated for by our surrounding seas.

The sea is our source of living, our ‘hinterland’, our means of communication with the outside world. The sea does not isolate us – rather it is our bridge to the rest of the world.

Quoting from a recent feature penned by Professor Oliver Friggieri in The Sunday Times of Malta, ‘Towards a definition of an ultra-minor nation’: “A diminutive island which is equally a city and a nation, a geographical dot and a formidable fortress of history, standing midway between two continents, belonging to the south of Europe and so close to North Africa, looking very far ahead from herself”.

This, in my opinion, is the definition of maritime Malta because it was from the sea that our forefathers arrived on this land and back to the sea our capabilities reach out to earn a living, create livelihoods, devise entrepreneurship and create wealth.

Our maritime industry is made up of a composite of a multitude – in Maltese terms – of small and medium-sized commercial entities each one competing for its share of the maritime resources to deliver a service, create wealth and by doing so generate an economic activity. There is no doubt that maritime Malta is a main contributor to our GDP, notwithstanding its low profile and at times, prejudiced negative PR.

Malta has to be proud of its maritime achievements because considering the limited geographical size and population, it has made incredible successes which much bigger nations try to emulate. The capability to turn an arid island into a major international maritime hub is a feather in our cap – thanks to the foresight of our predecessors. The hubbing concept is manifest in today’s trans-shipment industry (containers, conventional cargo, petroleum products, cruise passengers, offshore oil industry – some of the leading examples). Hubbing attracts vessels to call at Malta but hubbing on itself would not survive without infrastructure and support services.

Our infrastructure – harbours, quays, terminals, berths, water depth – plays an essential role to attract shipping lines to call at Malta because this infrastructure impinges directly on the smooth operation for a vessel to enter port, berth and turnaround. Considering the capital intensiveness of this industry, a vessel’s time in port is literally measured by the minute and the success of a hub relies heavily, if not exclusively, on the efficient turnaround of ships.

Shipping is dynamic – the only constant is change – and all the time experimenting with new systems and strategies. Unless maritime Malta is an intrinsic part of this movement it becomes anachronistic and stuck in its past.

This is where we feel that a holistic approach to planning is required. Given the dynamics of this industry, where ships are becoming bigger, we have to keep developing our maritime infrastructure, in an environmental-friendly manner, to remain relevant to the international maritime industry. If we look at the investment made by Malta Freeport Terminals over the years (over €250 million since October 2004) we have a template that can be emulated.

Without such investment Malta Freeport would not be able to handle the largest container vessels (20,000TEU capacity) that are plying the seas today.

Grand Harbour is a different story. It cries out for a vision and action. The investment made in Grand Harbour over the years has been pitiful and it is with grave concern to note that up to the last budget presented by government in October, there were no funds voted for infrastructural development in Grand Harbour. If I have missed the point, I stand to be corrected.

The holistic approach that is required entails an in-depth consultative process with all the stakeholders. This should lead to the identification of the strategic direction to be taken followed by an action plan that is monitored and kept on track. If we were able to do it on the development of the road infrastructure, there is no reason why we cannot do it on the ports infrastructure.

The reality, however, and unfortunately, is different. Take Deep Water Quay (DWQ) as an example – we, the stakeholders have lost track when the works started and when they are supposed to be completed. What we do know is that in the meantime the opportunities to berth ships on DWQ are passing us by, and that the works undertaken to date have failed to address the endemic problem of not providing sufficient quay strength to withstand pressure from quay cranes.

We do understand that at present there is yet another study being undertaken regarding the regeneration of Grand Harbour. We wish to appeal to the respective authorities to consult with the stakeholders to avoid having a study which makes interesting reading but lacks in practicality.

The plan for maritime Malta must necessarily address environmental considerations, safety requirements, the exigencies of the vessels and related activities, the demands being made and the potential that can be obtained from the blue economy and the adaptation of IT to assist in better processing of information. Certain work practices which might have been relevant five decades ago – such as working time during summer – are gate stoppers in today’s environment and yet they are not being addressed.

Looking towards the future, maritime Malta needs vision, planning, resolve and action. The endemic fault in our planning model for maritime Malta has been and still is the lack of a holistic approach. There are so many competing interests in this industry that it takes real effort for the policy maker to override the pressures of the various interests and develop a holistic plan which ensures Malta’s leading role as a maritime hub. The removal and perpetuation of maritime Malta from a standalone, focused, ministerial portfolio and the amalgamation of same within Transport Malta is a fundamental mistake which epitomises the policymakers’ lack of understanding and appreciation of the contribution of this industry.

Fortunately I cannot be accused of political bias when making such a statement because this decision was introduced by one administration and retained by another political administration – both are at fault and misguided.

The focus required to plan strategically for maritime Malta entails constant engagement, active awareness of the developments in the international maritime industry, political courage to take decisions and an ongoing consultative process with the industry players.

The consultative process is one of the objectives for which the Malta Maritime Forum was set up.

One must not lose sight of the positive developments that maritime Malta has managed to achieve, but we cannot for a moment relax and assume the winning formula of the past is a guarantee of our future success. Ships of larger sizes need to be accommodated in our harbours, environmental considerations need sustainable solutions, work practices have to be brought in line with present and future exigencies, standards must rise and enforcement of rules and regulations brought to play to ensure that quality of service remains our hallmark. These are but some elements that we wish to see in the planning for maritime Malta of tomorrow.

Godwin Xerri is the managing director of Focal Marine and board member of Malta Maritime Forum.

www.mmf.org.mt

 

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UK publishes no-deal Brexit plans for shipping industry

Batch of 28 documents in total published today, including contingency plans for driving licences and passports. For the maritime industry, there are details on getting an exemption from maritime security notifications

Guidance on getting an exemption from maritime security notifications and the recognition of seafarer certificates of competency are among 28 documents published today by the UK government as part of its planning for a „no deal‟ Brexit

THE UK has published guidance documents on how seafarers and shipping companies would be affected by a no-deal Brexit, drawing the ire of the country’s largest maritime union.

They are among a batch of 28 documents in total published today, including contingency plans for driving licences and passports.

For the maritime industry, there are details on getting an exemption from maritime security notifications.

“In a „no deal‟ scenario EU countries would be unable to issue exemptions to vessels, irrespective of registration / flag, operating scheduled services from the UK,‟‟ the technical notice says.

A separate document tackles the recognition of seafarer certificates of competency if there is no Brexit deal.

The paper says currently every European Union country recognises the certificates issued to seafarers by the other EU countries.

“The certificates must be accompanied by an „endorsement attesting such recognition‟, issued by the country recognising the certificate,‟‟ the document says.

It says that in the event of no deal the UK government will to continue recognising all certificates it currently recognises, including those issued by EU and European Economic Area countries after exit.

It will also seek third-country recognition of UK certificates by the EU under the international standards of training, certification and watchkeeping convention.

The main opposition Labour Party’s shipping spokesperson Karl Turner told Lloyd‟s List the government was failing to protect the interests of UK seafarers, passengers, employers and the country‟s maritime skills base.

“Rather than seeking a transitional deal to buy more time to ensure reciprocal recognition of seafarers‟ qualifications, the government is pretending to show willing whilst doing nothing to prepare for a skills shortage,” he said.

UK-based maritime union Nautilus International slammed the government for not addressing questions about the long-term arrangement for mutual recognition, which they claim reveals the government is actually unprepared for a no-deal Brexit.

Nautilus International general secretary Mark Dickinson wrote in an e-mailed statement: “Whilst the government says that this is „not an outcome that we expect to occur‟, ministers were meeting only today to discuss no deal preparations and this notice does not tell our members what they should be doing now to mitigate the impact of the UK crashing out of the EU without an agreement.”

Seafarers’ certificates

Nautilus reported that according to the European Maritime Safety Agency, the UK issued 24,375 Certificates of Competency to masters and officers in 2016, the most by any EU member state. Meanwhile, 3,410 seafarers with original CoCs issued in the UK had valid endorsements by other EU member states.

The government clarified that EU countries‟ endorsement of UK CoCs issued before the country‟s exit from the bloc would be valid until their expiration date.

“So if you‟re a UK-trained seafarer with an endorsement issued by an EU country, you would be able to continue working on board vessels flying the flag of that country until the endorsement expires,” the government said.

Those countries that want to keep recognising UK CoCs after Brexit will have to address the European Commission directly to secure permission.

“The European Commission, with the assistance of the European Maritime Safety Agency, would assess our training and certification systems under this procedure,” the government said.

The commission put forward a proposal in May 2018 to simplify regulation on the mutual recognition of seafarers within the union. Nautilus said feedback had been submitted and deliberations were entering the second round with the European Community Shipowners‟ Associations drafting a position paper.

“It is disappointing that the technical document makes no acknowledgement of the ongoing consultation on amending the EU directives in question, and contains no much-needed advice to seafarers on what they should or could be doing to ensure their future employability,‟ he pointed out,” Mr Dickinson said.

The UK‟s Brexit Secretary Dominic Raab said a no-deal Brexit was unlikely, but that the government would manage the challenges.

“With six months to go until the UK leaves the European Union, we are stepping up our „no deal‟ preparations so that Britain can continue to flourish, regardless of the outcome of negotiations,” Mr Raab said ahead of publication of the papers.

Other technical notices published today cover the impact on areas including environmental standards, mergers, data protection and certification for manufacturers.

“Our members deserve better than this,” Mr Dickinson said.

“In or out of the EU, Britain depends on shipping and seafarers and my members need clarity and certainty for the years ahead, to ensure that Brexit does not create new barriers to their continued employment. This document does not do that.”

 

Source: Lloyd’s List

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EU to invest nearly €700 million in sustainable and innovative transport

The European Commission has proposed to invest €695.1 million in 49 key projects to develop sustainable and innovative transport infrastructure in Europe across all transport modes. Selected projects will provide infrastructure enabling greater use of alternative fuels and electric cars, modernise Europe’s air traffic management, and further develop waterborne and rail transport.

EU Commissioner for Transport Violeta Bulc said: “Our investment plan for Europe is delivering: today we are proposing to invest €700 million in 49 key transport projects through the Connecting Europe Facility (CEF). These projects are concentrated on the strategic sections of Europe’s transport network to ensure the highest EU added-value and impact. This will allow us to further accelerate our transition to low-emission mobility across Europe, and firmly deliver on the EU’s agenda for jobs and growth. We expect it to unlock a total of €2.4 billion of public and private co-financing.”

The largest part of the funding will be devoted to modernising European air traffic management (ATM – €290.3 million), developing innovative projects and new technologies for transport (€209.5 million), as well as upgrading the railway network, maritime connections, and ports and inland waterways (€103.6 million). In supporting the selected projects, the Commission is firmly delivering on the objectives outlined in its Clean Mobility package.

Over €250 million of CEF funding will be invested in 26 projects dedicated to developing new technologies in transport notably promoting alternative fuels, such as:

greening the maritime transport link between Swinoujscie port in Poland and Ystad port in Sweden;

deploying hydrogen public transport infrastructure in Denmark, the UK and Latvia;

building a network of bio-liquefied natural gas stations on roads connecting southern Spain and eastern Poland, via France, Belgium, the Netherlands and Germany;

developing zero-emission public transport services for Amsterdam airport, as well as electrifying urban and regional bus routes in Croatia, Italy, Slovenia and Slovakia.

The selected projects will also contribute to the establishment of a Single European Sky via modernising European air traffic management in 23 EU Member States and Serbia, the upgrading of the Ampsin-Neuville lock complex on the Middle Meuse river in Belgium, and the upgrading of the maritime ports of HaminaKotka and Leixões.

An additional €450 million is made available to finance alternative fuel infrastructure through the InnovFin Energy Demo Projects (EDP) and CEF Debt Instrument. They are managed by the European Investment Bank.

Background

All proposed projects were selected for funding via two competitive calls for proposals, open to projects in all EU Member States:

The 2017 CEF Transport Blending call launched on 8 February 2017, takes an innovative approach, making available an indicative budget of €1.35 billion of EU grants, to be combined with financing from the European Fund for Strategic Investments (EFSI), the European Investment Bank (EIB), National Promotional Banks or private sector investors. Some 69 applications, requesting a total of €1 billion in co-funding, were received by the second deadline. Of these, 35 projects were selected, totalling €404,8 million. Previously, 39 projects had been selected for funding, totalling € 1 billion in CEF Blending funding.

The CEF Transport SESAR call launched on 6 October 2017 aims to modernise ATM in Europe and provide a high performing ATM infrastructure that will enable the safe, efficient and environmentally friendly operation and development of air transport. The CEF Transport SESAR call was open for project proposals on the deployment of new and mature technologies and practices that support harmonised ATM systems and standards in Europe. Some 33 applications requesting €406.9 million were received, out of which 14 projects were selected, totalling €290.3 million.

The EU’s financial contribution comes in the form of grants, with different co-financing rates depending on the project type. Under the CEF programme, €23.2 billion is available for grants from the EU’s 2014-2020 budget to co-fund TEN-T projects in EU Member States. Since 2014, the first CEF programming year, there have been four yearly waves of calls. In total, CEF has so far supported 641 projects with a total amount of €22.3 billion.

Next steps

Following EU Member States approval of the proposal, the Commission will adopt a formal decision in the coming weeks. The Commission’s Innovation and Networks Executive Agency (INEA) will then sign the grants with the project beneficiaries by January 2019.

 

Source: DG Move

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Sulphur 2020 – cutting sulphur oxide emissions

The main type of “bunker” oil for ships is heavy fuel oil, derived as a residue from crude oil distillation. Crude oil contains sulphur which, following combustion in the engine, ends up in ship emissions. Sulphur oxides (SOx) are known to be harmful to human health, causing respiratory symptoms and lung disease. In the atmosphere, SOx can lead to acid rain, which can harm crops, forests and aquatic species, and contributes to the acidification of the oceans.

Limiting SOemissions from ships will improve air quality and protects the environment.

IMO regulations to reduce sulphur oxides (SOx) emissions from ships first came into force in 2005, under Annex VI of the International Convention for the Prevention of Pollution from Ships (known as the MARPOL Convention). Since then, the limits on sulphur oxides have been progressively tightened.

From 1 January 2020, the limit for sulphur in fuel oil used on board ships operating outside designated emission control areas will be reduced to 0.50% m/m (mass by mass). This will significantly reduce the amount of sulphur oxides emanating from ships and should have major health and environmental benefits for the world, particularly for populations living close to ports and coasts.

Below you will find answers to some of the frequently asked questions about the sulphur limit.

You can also download a more detailed set of FAQ here.

Limiting SOx emissions from ships will have a very positive impact on human health: how does that work?

​Simply put, limiting sulphur oxides emissions from ships reduces air pollution and results in a cleaner environment. Reducing SOxalso reduces particulate matter, tiny harmful particles which form when fuel is burnt.

A study on the human health impacts of SOx emissions from ships, submitted to IMO’s Marine Environment Protection Committee (MEPC) in 2016 by Finland, estimated that by not reducing the SOx limit for ships from 2020, the air pollution from ships would contribute to more than 570,000 additional premature deaths worldwide between 2020-2025.

So a reduction in the limit for sulphur in fuel oil used on board ships will have tangible health benefits, particularly for populations living close to ports and major shipping routes.

Why are ships already less harmful than other forms of transport?

​Ships do emit pollutants and other harmful emissions. But they also transport large quantities of vital goods across the world’s oceans – and seaborne trade continues to increase. In 2016, ships carried more than 10 billion tons of trade for the first time, according to UNCTAD.

So ships have always been the most sustainable way to transport commodities and goods. And ships increasingly becoming even more energy efficient. IMO regulations on energy efficiency support the demand for ever greener and cleaner shipping. A ship which is more energy efficient burns less fuel so emits less air pollution.

It has sometimes been quoted that just a few ships (all using fuel oil with maximum permitted sulphur content) emit as much harmful air pollutants as all the cars in the world (if the cars were all using the cleanest fuel available).

Not only is this the very worst case scenario, but this does not take into account the amount of cargo that is being carried by those ships and the relative efficiency. It is important to consider the amount of cargo carried and the emissions per tonne of cargo carried, per kilometre travelled. Studies have shown that ships are by far the most energy-efficient form of transportation, compared with other modes such as aviation, road trucks and even railways.

It is also relevant to remember that shipping responds to the demands of world trade. As world trade increases, more ship capacity will be needed.

How can ships carry so much cargo so efficiently?

Ships are the largest machines on the planet and the world’s largest diesel engines can be found on cargo ships. These engines can be as tall as a four-storey house, and as wide as three London buses. The largest marine diesel engines have more than 100,000 horsepower (in comparison, a mid-sized car may have up to 300 horsepower). But the largest container ships can carry more than 20,000 containers and the biggest bulk carriers can carry more than 300,000 tons of commodities, like iron ore.
So powerful engines are needed to propel a ship through the sea. And it is important to consider how much energy is used to carry each ton of cargo per kilometre.  When you look at the relative energy efficiency of different modes of transport, ships are by far the most energy efficient.
Ships can reduce air pollutants by being even more energy efficient, so they burn less fuel and therefore their emissions are lower.

What is the current regulation on SOx in ships emissions and by how much is that going to be improved?

​We are going to see a substantial cut: to 0.50% m/m (mass by mass) from 3.50% m/m.

For ships operating outside designated emission control areas the current limit for sulphur content of ships’ fuel oil is 3.50% m/m.

The new limit will be 0.50% m/m which will apply on and after 1 January 2020.

There is an even stricter limit of 0.10% m/m already in effect in emission control areas (ECAS) which have been established by IMO. This 0.10% m/m limit applies in the four established ECAS: the Baltic Sea area; the North Sea area; the North American area (covering designated coastal areas off the United States and Canada); and the United States Caribbean Sea area (around Puerto Rico and the United States Virgin Islands).

Fuel oil providers already supply fuel oil which meets the 0.10% m/m limit (such as marine distillate and ultra low sulphur fuel oil blends) to ships which require this fuel to trade in the ECAs.

What must ships do to meet the new IMO regulations?

The IMO MARPOL regulations limit the sulphur content in fuel oil. So ships need to use fuel oil which is inherently low enough in sulphur, in order to meet IMO requirements.

Refineries may blend fuel oil with a high (non-compliant) sulphur content with fuel oil with a sulphur content lower than the required sulphur content to achieve a compliant fuel oil. Additives may be added to enhance other properties, such as lubricity.

Some ships limit the air pollutants by installing exhaust gas cleaning systems, also known as “scrubbers”. This is accepted by flag States as an alternative means to meet the sulphur limit requirement. These scrubbers are designed to remove sulphur oxides from the ship’s engine and boiler exhaust gases. So a ship fitted with a scrubber can use heavy fuel oil, since the sulphur oxides emissions will be reduced to a level equivalent to the required fuel oil sulphur limit.

Ships can have engines which can use different fuels, which may contain low or zero sulphur. For example, liquefied natural gas, or biofuels.

Are low sulphur blend fuel oils safe? Can new low sulphur fuels cause problems for a ship’s engine?

​All fuel oil for combustion purposes on a ship must meet required fuel oil quality standards, as set out in IMO MARPOL Annex VI (regulation 18.3). For example, the fuel oil must not include any added substance or chemical waste that jeopardizes the safety of ships or adversely affects the performance of the machinery.

IMO is currently discussing how to identify any potential safety issues related to new blends of fuel oil as it is recognized that if these fuels are not managed appropriately, there could be compatibility and stability issues. If needed, additional guidance for crew and ship operators could be developed.

An International Standardization Organization (ISO) standard (ISO 8217) specifies the requirements for fuels for use in marine diesel engines and boilers.

Could the 0.50% limit be delayed?

​No. There can be no change in the 1 January 2020 implementation date, as it is too late now to amend the date and for any revised date to enter into force before 1 January 2020.

Will new fuels be needed to meet the 2020 limit? Will there be enough?

It is likely that new blends of fuel oil for ships will be developed, For example, a gas oil, with a very low sulphur content can be blended with heavy fuel oil to lower its sulphur content. ​

These new blends are likely to cost more initially than the “heavy fuel oil” bunkers (fuel) used by the majority of ships today.  Ships can also choose to switch to a different fuel altogether. Or they may continue to purchase heavy fuel oil, but install ”scrubbers” to reduce the output of SOx in order to have an equivalent means to meet the requirement.

Of course, some ships are already using low sulphur fuel oil to meet the even more stringent limits of 0.10% m/m when trading in the already-established emission control areas. So those fuel oil blends suitable for ECAS, will also meet the 0.50% m/m limit in 2020. However, there is a cost differential, and these blends are more expensive than heavy fuel oil.

A study commissioned by IMO into the “Assessment of fuel oil availability” concluded that the refinery sector has the capability to supply sufficient quantities of marine fuels with a sulphur content of 0.50% m/m or less and with a sulphur content of 0.10% m/m or less to meet demand for these products, while also meeting demand for non-marine fuels. The full study can be downloaded here.

Consistent compliance with the new limit is vital. What is IMO doing about that?

​Monitoring, compliance and enforcement of the new limit falls to Governments and national authorities of Member States that are Parties to MARPOL Annex VI. Flag States (the State of registry of a ship) and port States have rights and responsibilities to enforce compliance.

IMO is working with Member States as well as industry (including the shipping industry and the bunker supply and refining industry) to identify and mitigate transitional issues so that ships may meet the new requirement.

For example, developing guidance, developing standardised formats for reporting fuel oil non availability if a ship cannot obtain compliant fuel oil and considering verification and control issues.

Do small ships have to comply with the sulphur limit from 2020?

​Yes, the MARPOL regulations apply to all ships. Only larger ships of 400 gross tonnage and above engaged in voyages to ports or offshore terminals under the jurisdiction of other Parties have to have an International Air Pollution Prevention Certificate, issued by the ship’s flag State. But all sizes of ships will need to use fuel oil that meets the 0.50% limit from 1 January 2020.

Some smaller ships may already be using fuel oil that meets the limit, such as a marine distillate suitable for their engines. (Small ships operating in the already-designated emission control areas will be using fuel oil that meets the 0.10% limit in those emission control areas.)

​For more detailed information on the sulphur 2020 limit and its implementation, please download the IMO Sulphur 2020 FAQ.
Source: IMO

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How the new fuel regulations change the entire shipping industry

LSF2020 refers to the new “Low Sulfur Fuel” regulations, which will come into effect on 1 January 2020. These regulations are the biggest of a series of steps by the International Maritime Organisation (IMO) to reduce marine pollution (MARPOL) in response to the threat of climate change. The LSF2020 emission regulations mean ships will have to significantly reduce emissions on the high seas as well as in coastal areas. This change does not only concern Hapag-Lloyd but it challenges the entire shipping industry. The good news is however: Thanks to the regulations, the industry will become much greener.

Now, the question is how to comply with the new regulations and how much it will cost. Ship owners are effectively having to decide whether to switch to burning the more expensive low sulfur fuel, or place investment bets on Exhaust Gas Cleaning Systems (EGCS) or Liquefied Natural Gas (LNG) powered ships. There are however only limited facts and experience upon which to base these decisions, which will continue to have an impact on the profitability and competitiveness of liner shipping companies, long after the facts have become clear in hindsight.

Three main ways to go

The simplest way to comply with the new regulations is just to switch to using new, compliant 0.5 percent “Low Sulfur Fuel”. The problem: The lower the sulfur content, the higher the cost of bunker fuel. Oil industry experts estimate 0.5 percent Sulfur “Low Sulfur Fuel” will be 150 to 250 US Dollar more expensive per ton than the current 3.5 percent Sulfur “Heavy Fuel Oil”. According to estimation this will increase global average prices per TEU by around 80 to 120 US Dollar, or about 10 percent. All alternative approaches to enable ships to burn cheaper fuels, require considerable additional capital investment.

One option is to install an Exhaust Gas Cleaning System (EGCS), to remove the excess pollution from the exhaust gases – and continue to burn the cheaper 3.5 percent Sulfur “Heavy Fuel Oil”. EGCS are desulphurization systems that remove unwanted particles from industrial exhaust flows. The systems are installed inside the ship’s funnel and can work in a number of different ways. The two main kinds are “open-loop” and “closed-loop” (and “hybrid”, able to switch between open-loop and closed-loop operation). Operating in open-loop mode removes the pollution from the exhaust gases and then flushes it into the sea, instead of into the atmosphere. Operating in closed-loop mode retains the pollution in tanks on board the ship – but this is not practical for long distance journeys. The challenge: So far, these systems have not yet been used with large container ships, only with cruise liners and short sea ferries. There is also the risk that regulations will change in the coming years and will prohibit flushing the pollution into the sea at all.

Another alternative is to switch to Liquefied Natural Gas (LNG). Hapag-Lloyd currently owns 17 so called “LNG-ready” ships – these are ships with engines that can burn LNG as well as fuel oil. They just need an additional LNG fuel tank to be installed in a cargo bay, together with some additional piping and machinery. Then they are able to switch between LNG and fuel oil. The other approach is to build new ships, designed from the beginning to only burn LNG. The challenge: The capital costs to convert ships or to build them from new to burn LNG, are quite high. Moreover, since there is as yet little demand for marine LNG – a resource that is otherwise freely available onshore – there are as yet still only a small number of LNG bunker vessels available in a few ports.

Lastly, there are many limitations to how many ships can be converted to LNG or retrofitted with EGCS. It also takes time to build new ships fitted with scrubbers or designed to burn LNG. The vast majority of the global container fleet will therefore have no other choice than to switch to the new, much more expensive compliant 0.5 percent Sulfur “Low Sulfur Fuel” – or to break the law.

That shows: Each solution comes with its challenges. That is why right now there is no one right way to go. Liners have to individually decide the mix which seems best for them. However, low sulfur oil bunkering will have to start in the fourth quarter of 2019 due to the long round voyage times – which will mean higher costs for customers already by the end of next year. All in all, industry experts guess that the new fuel regulations will cost the shipping industry about 60 billion US Dollar per year.

Source: Hapag-Lloyd

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European Shipowners encourage the European Commission to have sufficient recycling capacity on the EU approved ship recycling yards list

All vessels sailing under an EU flag will eventually be required to use an approved ship recycling facility, once the EU Ship Recycling Regulation effectively applies. This will be on 31 December 2018.

The current edition of the EU list of approved ship recycling facilities only features yards situated in Europe and has a capacity of around 300.000 light displacement tonnes (LDT). It is far away from the 2.5 million LDT mentioned in the Regulation. In the past, all European co-legislators agreed upon this figure: the EU Parliament, the EU Council and the EU Commission. It is based on international research and studies carried out to back the Commission’s legislative proposal in 2012.

“ECSA finds these figures[1] generally reflecting the reality”, ECSA Secretary General Martin Dorsman said.

“For ECSA, this demonstrates clearly that only when third country ship recycling yards will get EU recognition and added to the list, there will be sufficient capacity. This is a message we have tried to pass on to the European Commission – for the moment, the yards on that list will not be able to respond to the recycling capacity demand”, said ECSA Secretary General Martin Dorsman.

“We only have another six months to go before the regulation will come to effect and oblige the European flagged ships to be dismantled in the facilities on the EU list. There is no time to waste but new, also outside-EU, yards that comply with the EU Regulation should urgently be accepted on the list”, he concluded.

On Monday 18 June the EU Member States’ experts on ship recycling met in Brussels to discuss the current situation. ECSA shared its experience with the EU legislators regarding the continuous progress which is taking place today in several Indian Ship Recycling Facilities. One of the most important drivers for the improvements in the Indian facilities is in fact their ambition to work towards approval and inclusion in the EU list of facilities. An important tool in that process is technical cooperation on the ground and a close monitoring of the recycling process, wherever the ship recycling facility is located for that matter.

[1], An indicative calculation shows that the real capacity needed is in line with the data from the recognised studies. In 2016 around 10 mio LDT has been recycled. The EU fleet (incl. Norway) is, expressed in GT, around 22 % of the world fleet. 22 % out of 10 mio is around 2.2 mio LDT.

Source: ECSA

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PORT RECEPTION FACILITIES: ESPO WELCOMES DRAFT REPORT BUT CALLS FOR STRICTER APPLICATION OF THE ‘POLLUTER PAYS’ PRINCIPLE

The European Sea ports Organisation (ESPO) welcomes the proposals put forward by the European Parliament Rapporteur Ms Gesine Meissner in the draft report of the Transport Committee on the review of the Waste Reception Facilities Directive (Com (2018) 33).  The Draft Report will be discussed in the Transport Committee meeting of 10 July.

The proposals of the Parliament’s rapporteur are aiming to better protect the marine environment and decrease the administrative burden for stakeholders. ESPO welcomes in particular proposals such as the definition of catering waste which would increase the quantities of recycled plastics and contribute to the targets of the European Plastics Strategy.

European ports believe however that the ‘polluter pays’ principle, which has been the cornerstone of the EU’s environmental policy, needs to be strengthened. Introducing a fee system whereby ships would deliver unreasonable quantities of garbage, including dangerous waste for a fixed fee would be a severe divergence from the ‘polluter pays’ principle. It risks to discourage reducing waste at the source.

“The report of Ms Meissner is clearly a step forward. Overall, the report pursues the objectives of the circular economy and aims to reduce administrative burden for authorities and stakeholders. We strongly believe however that the ‘polluter pays’ principle needs to be better reflected in the new Directive. We cannot accept a regime whereby ships are not incentivised to limit waste at the source and ports have to carry the costs of delivering unreasonable amounts. Additionally, we oppose an automatic rebate for “green” ships. Any green rebate, if not corresponding to a real cost reduction, will have to be borne by the port authority. Not all port managing bodies have the financial ability to cover this cost and to give such rebates. We plead for an efficient, but responsible management of ship waste. We count on the rapporteur and Transport Committee members to further optimise the Directive in that sense” says ESPO’s Secretary General, Isabelle Ryckbost.

Any mandatory green rebates for waste, as proposed by the Commission proposal, would prevent ports from addressing local environmental challenges. In some areas, waste pollution is a great environmental concern while in others it is air quality and emissions. Furthermore, mandatory rebates disregard the existence of different business and governance models in ports across Europe.

The Commission has been preparing an EU submission to the IMO proposing a 100% indirect fee without quantity thresholds at international level (here).  “I regret that a submission is being introduced to the Council when Parliament has not expressed any views, and negotiations with the Council have not even started. This initiative seems to bypass the ongoing democratic process and lacks legitimacy” adds ESPO’s Secretary General, Isabelle Ryckbost.

 

Source: ESPO

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European shipowners support the proposal for better waste handling Port Reception Facilities

The recently published proposal for a new Directive on Port Reception Facilities is welcomed by ECSA, as it addresses major issues with the current system in place. The new proposal will help in ensuring there are adequate port reception facilities available, require an advance waste notification from ships as well as a waste delivery receipt for reception facilities, and facilitate monitoring and enforcement through existing systems for electronic reporting and the exchange of information.

 

It also suggests a reasonable, transparent and functional fee system forming an incentive to shipowners to deliver waste ashore. “We believe that the procedures in ports should be as efficient as possible, to keep costs at acceptable levels. Therefore, the 100% indirect system for MARPOL Annex V residues should exclude hazardous waste, as not all ships deliver this type of waste all the time”, said Martin Dorsman, ECSA Secretary General.

 

“Additionally, by requiring that ships have to deliver all their waste every time they leave for a port outside the European Union, the EU would ignore the importance of International Maritime Organization’s (IMO) international database of port reception facilities, in which IMO’s member states list all their approved port reception facilities. A better alignment with IMO rules and procedures would ensure that ships can deliver their garbage in any facility which is included in IMO’s Global Integrated Shipping Information System (GISIS) database and thus not only in European facilities”, he added.

 

With regard to Short Sea Shipping, the movement of cargo and passengers by sea over short distances, Martin Dorsman commented: “Shifting transport from land to water has many advantages. It would reduce current road congestions and lower external cost and the impact on our environment. This could well be achieved with the Directive if the right choses are made. Short sea vessels that are not sailing on fixed routes according to a published schedule, but may be calling regularly and frequently at the same ports, should be allowed to skip delivering waste every time they call at a port under the same conditions as for example ferries. This is not the case in the current proposal. Short Sea Ships should also be guaranteed differentiated fees as this will increase the competitive position”.

 

ECSA believes that applying differentiated fees for ships that treat waste in an environmentally sound manner is good. However, ECSA does not support defining a new concept of “Green Ships” at the EU level, as it is already carried out by the IMO. In addition, it would create yet another ranking system with already many such ranking systems operational.

 

Finally, vessels not having received a waste receipt will not be allowed to leave the port. ECSA suggests to have special arrangements in place for small ports, since they may need more time to issue a waste delivery receipt, especially outside normal working hours.
Source: ECSA (European Community Shipowners’ Associations)

Posidonia 2018: Shipowners Stand Alone in Cutting CO2 Emissions

The new environmental regulations have been at the center of attention at this year’s edition of Posidonia trade show in Athens, Greece, which took place from 4-8 of June.

The upcoming sulphur cap in 2020 and the initiative to halve shipping industry’s carbon footprint by 2050 have been in the spotlight together with the immediate implications of the ballast water management convention.

Despite being supportive of the overall aim behind the decarbonization drive, the “tsunami of regulations“ has not been very welcome by the industry due to the lack of pragmatism in their application and the availability issues with respect to effective infrastructural solutions to enable the switch to a cleaner future.

In particular, John Platsidakis, Chairman of Intercargo and managing director of Anangel Maritime Services, believes that the overall burden for reducing emissions from shipping is being unfairly put on ships and shipowners.

Speaking during the 6th Analyst and Investor Day within Capital Link’s Shipping Forum, Platsidakis stressed that such an approach “will take us nowhere“, adding that providers of assets, i.e., shipyards and engine manufacturers should be pushed to provide better equipment to owners.

“As a result, we have to stand up and raise our voice about the real issue here. Therefore, we are asking the providers of assets to come up with the adequate solutions and we will be the first ones to adopt it,” he emphasized.

Furthermore, the very fact that refiners have not committed to make the sufficient amounts of alternative fuel available by 2020 poses another uncertainty for shipowners.

In addition, he pointed out that it was “unfair“ and “highly regrettable“ that at the end of the day the consumers would be paying the price for the implementation of the new regulations.

George Prokopiu, Chairman of Dynagas LNG Partners, agreed, urging that the new regulative framework should be a task for manufacturers and shipyard, not owners.

Prokopiu insisted that shipping companies have very little voice in the overall decision making process about the new rules and that they were standing alone in the implementation process.

The message was echoed by Theodore Veniamis, President of the Union of Greek Shipowners, during the opening ceremony of the event saying that “shipping is often held disproportionately responsible for meeting environmental standards compared to other industries.”

“However, as shipowners, we have no say in the manufacturing of the ships’ engines, nor are we responsible for the quality of the fuels that we have to use. It is obvious that, while the links in the chain of responsibility are many, it has so far proved to be more expedient, at a political level, to solely focus on shipowners, a choice that is misguided and practically ineffective in the end,” he pointed out.

There is no silver bullet and the way forward for the industry to become complaint with the 2020 sulphur cap is attainable through three solutions: scrubbers, slow steaming and low sulphur fuel, Prokopiu said.

Finally, Platsidakis expressed concern over “what comes next in terms of regulations“, emphasizing that the industry is not afraid of new rules as long as they are pragmatic.

However, he stressed that a huge issue in the introduction of new regulations was the lack of proper analysis and understanding of the problem at hand.

“Regulators, with all the noble intentions in the world, often don’t know what they are talking about. Secondly, a lot of the said issues are politically motivated and promises politically motivated were not realistic,” he said.

Specifically, referring to the promise to halve shipping’s emissions by 2050 by upgrading propellers and ship designs, Platsidakis said that this was not feasible.

As explained, the only way for these reduction targets to be met is to introduce a carbon free fuel.

“With the existing types of fuel, we will never achieve the promised reductions,” he went on to say.

Reported by Jasmina Ovcina Mandra

Source: World Maritime News

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