The IMO’s 73rd Marine Environment Protection Committee (MEPC) session was held last week in London. A number of issues relating to the IMO’s global 0.5 per cent sulphur cap, which is due to enter into force in 14 months’ time, were discussed and some resolutions adopted, including a carriage ban on non-compliant fuel and guidance to increase the transparency of the fuel supply chain. VPO Global looks at some of the key issues discussed on fuel management and energy efficiency.
Carriage ban on non-compliant fuels
A carriage ban on non-compliant fuel for propulsion or operation on-board a vessel was adopted by the MEPC. Only a vessel fitted with a fully functioning scrubber capable of removing the emissions of SOx to 0.5 per cent or less, may carry and burn fuel with a sulphur content of more than 0.5 per cent.
This carriage ban enters into force on 1 March 2020; two months after the 1 January 2020 ban on using non-compliant fuel oil for propulsion or operation on-board a ship.
One issue that will need to be discussed is determining the definitions of low-sulphur fuel and heavy fuel oil (HFO), and what they mean in terms of their sulphur content. Tiejha Smyth, deputy director (FD&D) of the North P&I Club explained to journalists earlier this year that the industry is likely to require clearer definitions on low-sulphur fuel and HFO to avoid charter party disputes as the price differential between fuels increases.
The ban on HFO carriage will also require owners and operators to ensure they have a good relationship with their bunker suppliers to ensure they can obtain the right fuel for their operations that is both compliant and compatible in 2020.
Fuel management and safety
Flag states and shipping organisations have previously raised their concerns about the safety of low-sulphur fuels. Many have suggested an “experience building phase” to monitor the implementation of the sulphur cap in 2020. However, there had previously been some hesitancy regarding the phase as some believed it could delay the implementation of 2020. MEPC 73 agreed to invite further proposals on the matter to expand knowledge on handling various fuel qualities and reporting non-availability of compliant fuels.
MEPC 73 approved the Guidance on Best Practice for Fuel Oil Suppliers, which assures the quality of fuel oil delivered to ships. The Guidance addresses quality control during production of fuels and in the entire fuel supply chain, including storage and transfer of the fuels. Sampling will be carried out throughout the supply chain to improve transparency in the chain and expand knowledge on the quality of fuels via quality analysis reports.
During MEPC 73, guidance for developing a non-mandatory plan for ships to consistently implement the 0.5 per cent sulphur cap by January 1, 2020 was approved. The Ship Implementation Plan (SIP) will help owners plan and demonstrate the steps they have taken to ensure compliance. This includes a risk assessment and mitigation plan on the impact of using new fuel blends on-board. It also includes planning for the bunkering of new fuels including tank cleaning, segregation, changeover, documentation and reporting, and securing compliant fuel with bunker suppliers.
The plan also allows shipowners and operators to prepare for potential operational issues from bunkering incompatible fuel, as well as preparing crew for handling new fuels and fuel changeover from non-compliant to compliant fuel.
Fuel oil and data collection
MEPC 73 approved three interpretations for the collection and reporting ship specific data relating to fuel consumption from January 1, 2019.
Ships that use boil-off gas (BOG) for propulsion or operation will be required to collect and report data on fuel consumed under the data collection system.
Ships which have their keel laid prior to January 1, 2019 but are delivered on or after this date should be provided with a Ship Energy Efficiency Management Plan (SEEMP) that includes a methodology for collecting fuel consumption data required by regulation MARPOL VI, regulation 22A.
Data on the source of fuel consumption will not be required to be kept on-board the vessel as long as the data source can be accessed and provided by the company.
MEPC 73 discussed the IMO’s energy efficiency design index (EEDI) and the implementation date of phase 3 of the EEDI for various ship types. Phase 3 requires vessels to reduce CO2 emissions by 30 per cent per tonne mile compared with a baseline average for ships built between 2000 and 2010.
It was agreed that the provisional start date of January 1, 2025 for tankers and bulk carriers for phase 3 will remain, but for container ships, general cargo ships, gas carriers, refrigerated cargo carriers, combination carriers, LNG carriers, and cruise passenger ships with non-conventional propulsion it has been proposed to move to 2022 following support from IMO members.
For container ships, the current phase 3 reduction of CO2 emissions would be increase from 30 per cent to 40 per cent.
Amendments for bulk carriers, tankers including oil, chemical and NLS will be discussed at MEPC 74.