Sulfur warrior

Download PDF

Dr Edmund Hughes, the IMO’s head of air pollution and energy efficiency, discusses the UN body’s approach to emissions regulation in an interview with S&P Global Platts.

What can the IMO do to help ensure widespread compliance with the 0.5% sulfur limit in 2020?

Shipowners and operators must make sure their ships comply with IMO regulations. Day-to-day responsibility will also lie with ship masters, chief engineers and other crew.

Monitoring, enforcement and compliance is the remit and responsibility of states, as flag states and as port and coastal states. Flag states issue certificates and must ensure ships meet requirements, while port states can exert port state control on ships of any flag. So enforcement will come from all sides.

IMO as an organization is helping by providing a forum where any issues relating to compliance can be discussed and by developing and issuing supporting guidelines and guidance.

What lessons from the lowering of the marine fuels sulfur limit can be applied to how the IMO approaches emissions regulation in future?

This was a timely process, based on widespread research, with appropriate industry input from the beginning. It was adopted by consensus among IMO member states and will achieve a specific result with clearly identifiable benefits.

This is how IMO regularly operates, so it confirms that IMO’s model for developing and amending shipping’s regulatory framework is an effective one.

Do you see any argument for regulating shipping’s emissions at the regional level when IMO member states are unable to agree at the global level?

A universal set of regulations and level playing field for all is desirable. However, international law recognizes that states can take “other measures” to control emissions from ships supplementary to those measures adopted by IMO. To reflect this possibility, IMO does have provisions for special areas and Emission Control Areas.

There is an established procedure, set out in Appendix III of Marpol Annex VI, for bringing a proposal to IMO, in order to establish such an area. In this way, any areas needing special protection can have that special status – but the proposal is brought to IMO so that all states can have input to the decision to designate an Emission Control Area. This does not preclude member states from taking unilateral action, as permitted under [the UN Convention on the Law of the Sea] in territorial waters, as we have seen in China.

Do you see the use of scrubbers as a short-term solution for reducing sulfur emissions in time for 2020, or as something that is likely to be a feature of the shipping landscape for a long time to come?

IMO regulations allow for “equivalents” to meet the required emission standards set out in the regulations. Under Marpol Annex VI, ships are allowed to be fitted with an “approved equivalent arrangement” to meet the sulfur limit – such as an exhaust gas cleaning system, or so-called scrubber.

With a view to addressing the concerns regarding the possible impacts on the marine environment by washwater discharged from scrubbers, in particular those of the “open loop” type, the Sub-Committee on Pollution Prevention and Response is undertaking a review of the 2015 guidelines for exhaust gas cleaning systems.

The forecasts are that scrubbers will be used by a minority of ships. It remains to be seen whether those ships that employ scrubbers now will continue to do so in several years’ time. The continued availability of heavy fuel oil in bunkering ports may be a factor in their future use.

How soon do you expect to see marine fuels with zero greenhouse gas emissions become available for the commercial fleet?

Biofuels and batteries are already available and being trialed, while other energy sources such as wind, solar and hydrogen cells are also in development. Of course, it is important to ensure that any new fuels are sustainably sourced.

I am not in a position to make a market prediction. It is clear that, as noted in the initial IMO GHG strategy, technological innovation and the global introduction of alternative fuels and/or energy sources for international shipping will be integral to achieve the overall ambition in the GHG strategy, which is to peak GHG emissions from international shipping as soon as possible and to reduce the total annual GHG emissions by at least 50% by 2050 compared to 2008, whilst pursuing efforts towards phasing them out. This aims for a pathway of CO2 emissions reduction consistent with the Paris Agreement temperature goals.

The initial IMO GHG strategy is ambitious, and I believe it will encourage innovation and R&D to reach the goals. The GHG strategy has sent a clear signal to the shipping industry and we have seen a reaction already from one of the largest shipowners that has set a goal to have a commercially viable carbon neutral ship by 2030 and have a net-zero CO2 emission target by 2050, and also a main engine manufacturer announcing plans to develop a propulsion system using hydrogen.

Could the IMO mandate slow steaming across the whole shipping industry as a means of cutting GHG emissions in the short term?

This would be a decision for the member states to make. Theoretically, member states could propose, discuss and agree to such a proposal. In addition to directly reducing GHG emissions from an individual ship, such a measure could arguably provide an incentive for the adoption of zero carbon fuels, as ships using these “alternative fuels” would not be subject to the same speed requirements and so could well have a significant market advantage. However, some member states and industry representatives have raised concerns about such an approach to reducing GHG emissions, stating that it may lead to market distortion and potentially impact trade in perishable goods.

The initial IMO GHG strategy lists, as a candidate short-term measure, “consider and analyze the use of speed optimization and speed reduction as a measure, taking into account safety issues, distance travelled, distortion of the market or to trade and that such measure does not impact on shipping’s capability to serve remote geographic areas.”

Possible short-term measures could be measures finalized and agreed by the Marine Environment Protection Committee between 2018 and 2023. Dates of entry into force and when the measure can effectively start to reduce GHG emissions would be defined for each measure individually.

At this stage, member states have been invited to submit concrete proposals to the next MEPC in May 2019.

Read the next article from the Turning tides report