Opening Keynote Address on Day 2 of the 2020 Sulphur Cap Conference, Amsterdam, by Don Gregory, Director of the EGCSA & Technical Director Gulf Oil Marine
The only commercial technology solution currently available to meet compliance with MARPOL Annex VI Regulation 14 is an exhaust gas cleaning system, namely scrubbing. Remember Regulation 14 requires ships to use 0.10%S fuel in ECAs and 0.50%S fuel globally from 2020. There are also regional ECAs with slight variations. Examples include the 0.50%S in some rivers and coastal areas in China.
The EGCSA was formed in 2008 by the founding members to protect the industry in its fledgling state at the time. Today, I believe and attempt to ensure, it represents high standards, quality, ethical behaviour and honesty. EGCSA offers impartial technical information, advice and opinions on many current and future issues and challenges related to emissions reduction and in my capacity as its director that I am speaking at this conference.
There are, in reality, about 17 months left to prepare strategies and implement actions to be ready for the global Sulphur Cap around September 2019. Leave it any later than that and there is a considerable risk that a fleet will not be in compliance on 1st January 2020.
In a presentation at the 2020 Sulphur Cap Conference on 17th April, David Cox of Nord Rederei advised that his company had no idea what their compliance will look like. David’s remark is a common theme I have heard over and over again.
There are four areas that seem to be part of the reason for the continuing hiatus of activity to meet compliance. In my view, these are uncertainty, quality of information, IMO regulations and, lastly, opportunity or possibly lost opportunity.
Starting with uncertainty there are many questions we continue to hear. Only on Monday, an EGCSA member emailed asking me if it was true the MEPC 72 had agreed to postpone 2020. That was a rumour in his market. Let us be clear: there is no postponement planned.
Other uncertainties include
• Will 2020 be enforced?
• Will High Sulphur Fuel Oil (HSFO) be available? There is no question it will be in surplus and available at rock bottom prices. However, the supply chain may have to be re-started if demand drops in 2020 and does not resume for a year or two.
• Should we choose alternative fuels?
• Do scrubbers work and can they really be installed in a retro-fit situation?
• How long does a retro-fit take?
• Aren’t scrubbers banned in open loop mode in ports in Europe and don’t they simply transfer pollution from air to sea?
Quality of information
Uncertainty can also be considered as affecting the quality of information in ship owner’s hands. It could also be labelled lack of real research on the part of ship-owners or opinion sourced data. Too often, a throw away comment such as, “open loop scrubbers are banned in Europe” becomes the factual position. The facts are that open loops scrubbers are used in all of Europe except Belgium where government legislation imposed a ban on all water discharges long before scrubbers came to the market. Germany also has a partial ban in some of its rivers but not everywhere. The facts are that there is no evidence whatsoever that scrubber discharges have or do cause harm to the aquatic environment. There is a large body of research on this from land-based scrubbers such as those at the Mongstad refinery in Norway or the scrubbers installed at Longannet Power Station in the Firth of Forth near Edinburgh.
Ship operators need to improve their information base and ensure it is reliable and factually accurate in order to make informed choices and the best decisions possible.
Some of the information they should be clear on would include;
• How are scrubbers installed in a retro-fit situation? Ship operators could talk to some of the specialist installer companies and ask to see case studies. They could also talk to some of the RORO companies in Europe. What were their main problems? Are they still a risk?
• When do scrubbers become cost effective? Is there an engine size or fuel consumption minimum to make the payback period for an installation cost effective? If the payback is short and there are no other downsides, then there is a real incentive to fit scrubbers.
• Ethically, are scrubbers likely to be better than a fuel switch? Professor Ralf Zimmermann, Full Professor of analytical chemistry at the University of Rostock has suggested that, at worst, both solutions have similar health effects in highly populated ports. At best, scrubbers may result in slightly less harmful emissions than using 0.10%S distillate.
• What are the real implications of the fuel compliance route? Is it simply using gas oil at 0.10%S for a few bunkerings. Ship owners should talk to Danny Evans of AW Shipmanagement, whose company has done the changeover for its ECA fleet. It has secured its long-term fuel supply, but it has also experienced non-compliance detentions. It is for ship owners important to examine real case studies and the facts. The fuel switch option may not be as simple as we think.
The paucity of real facts and the extent of opinion driven data is worrying. Those who don’t research the facts but rather provide their top management with information based on hearsay or assumptions may find they have made the wrong choices come 2020.
The EGCSA website can be used to source some of the information the industry may need. Access and use of the material is free to all. If data from the website is used in public, we would appreciate source acknowledgement.
IMO regulation
There has been a lot of press coverage of the ban on the carriage of High Sulphur Fuel Oil on ships not fitted with scrubbers. MARPOL Regulation 14 was poorly written in terms of compliance enforcement. The carriage ban is trying to fix that with more poor and not very well thought through regulations. The only benefit of the carriage ban is that is will give Port State Control (PSC) the legal power to tackle non-compliance rather than simply report it to the FSC. That is assuming that PSC has the resources needed to undertake the carriage ban inspection – a difficult and very demanding inspection.
As always with IMO regulations, there is an attempt to be fair and allow for circumstances outside the control of the ship operator to comply with the regulations.
This brings me on to the FONAR, the “Fuel Oil Non Availability Report”. On the face of it, it seems a simple idea to implement. All that ship owners need to do is, just state in the report why they could not obtain the compliant fuel and hand it to the PSC and FSC. Well, life it not that simple. How many ship operators accept a charter to anywhere without working out things like: is this a war zone?, can victualling be done?, are fuel and lubes available?, what are the berths like?, do we have a ship’s agent etc.? The FONAR is not a get out of jail free card and certainly needs to be used sparingly or perhaps not at all.
Just like the uncertainty surrounding ship operator decisions, the IMO has not yet prepared the ground for effectively managing the implementation of the global sulphur cap. Hence, there is a week long intersessional in July to propose, discuss and resolve the what-ifs. Ship operators and others in the industry are encouraged to contribute to the intersessional. I would therefore urge you to talk with your representing organisations and governments as soon as possible.
Let us finally look at the topic of opportunity.
The shipping industry lost an opportunity to make the transition to lower sulphur emissions much less painful and much more gradual. That would have been the effect if the industry had embraced an emissions trading scheme. This would have worked a little like banking and trading; a scheme that makes it possible for emissions allowances and reductions in emissions beyond the set limit to be monetised. Such a scheme would have allowed a much more cost effective and practical transition to take place.
But that is history. The opportunity we have now is a choice between ensuring that compliance choice results in, at worst, a neutral outcome, or to strive for a better outcome that results in a competitive advantage.
The street market trader lives on his or her knowledge of the competition and the customers.
The ship operator needs to invest in building that same awareness based upon facts and not opinion. All ship operators should:
• Understand the most cost effective and secure method of achieving compliance for their fleet.
• Be able to be in compliance well before the 1st January 2020.
• Work out how they can demonstrate compliance so their ships do not need to be inspected. Emissions monitoring and the availability of that data seems a sensible and rational option.
Once the strategy and plans have been crafted and are ready for implementation, ship owners need to be sure to let their key stakeholders know. If they need HSFO in certain ports or 0.10%S fuel in others, it would be wise to advise the bunker suppliers of their estimated demand. Likewise, they may need to make changes to their lubricant stems. Ship suppliers can only make preparations if they know what is going to be required.
There is a lot more to reflect on concerning the situation we are facing as 1st January 2020 looms, but I hope the topics of uncertainty, information, IMO regulations and the real opportunities to be had provide some food for thought.