IMO to work on ways to address global sulphur cap implementation challenges
Concerns raised by IBIA and others regarding issues expected to arise due to the global 0.50% sulphur cap have been heard and taken into account at the International Maritime Organization, and work will begin to identify ways of addressing them.
As the 70th session of the IMO’s Marine Environment Protection Committee decided to implement the global cap in 2020, the Committee recognised that there are challenges surrounding the implementation phase and agreed to task the Sub-Committee on Pollution Prevention and Response (PPR) to develop a plan for effective implementation based on MEPC 70/5/2 and new proposals.
PPR will meet in January 2017 for its 4th session. Outcomes from PPR 4 will be considered when MEPC meets for its 71st session in May 2017.
IBIA was one of several co-sponsors to MEPC 70/5/2 along with the World Shipping Council, BIMCO, CLIA and ICS and helped with drafting the document, which invited the Committee to consider a process to examine how implementation of the 0.50% sulphur limit may be enhanced. The submission was co-sponsored by several member states; Japan, Liberia, Marshall Islands, Panama, Republic of Korea and Vanuatu, and it was supported in plenary by many more.
There was also significant support among member states at MEPC 70 for IBIA’s stand-alone submission, MEPC 70/5/35, including the idea of a phased approach. However, as this would require amending MARPOL Annex VI there was no appetite for it, but some of IBIA’s proposals for easing the transition may be taken into account.
The joint submission, MEPC 70/5/2, warns that failing to implement the global cap in a uniform and even-handed way could lead to an uneven playing field where shipping companies that comply consistently would be at a financial disadvantage. Uneven implementation could also potentially create uncertainty about actual market demand for 0.50% sulphur marine fuel, which in turn would increase the difficulty for the marine fuel oil supply chain to plan effectively to meet demand and for ship operators to assess the viability of investing in exhaust gas cleaning systems.
To address these issues, MEPC 70/5/2 calls for the IMO to consider how port State control officers (PSCOs) can detect and take action against ships using fuel oil that exceeds the 0.50% limit unless that ship is equipped and certified to operate an approved alternative compliance system, such as a scrubber.
While not explicitly stated in the paper, this could be simply achieved by banning vessels from carrying higher sulphur fuel in their fuel tanks unless they have an alternative compliance system or a valid exemption. This was indeed suggested during MEPC 70, although one of the member state co-sponsors had reservations about this approach.
MEPC 70/5/2 has also suggested developing a standard format for reporting fuel oil non-availability for situations when the ship is unable to obtain compliant fuel. IBIA’s stand-alone submission, MEPC 70/5/35, explained how this would become particularly important during the initial phase when non-availability may be frequent in some ports. Ports may also have availability some of the time but not all the time, hence a credible and consistent non-availability report format would be required to give ships and PSCOs confidence in the validity of the document.
MEPC 70/5/2, which is being sent to PPR, also asked MEPC to consider how to accommodate any transitional actions that may be necessary, consider a timeline for developing uniform implementation measures, and other actions as appropriate.
The open-ended nature of these possible actions may leave scope for PPR to develop measures to help with effective implementation while recognising that the transition to full implementation of a global 0.50% sulphur cap may be challenging. IBIA told MEPC 70 that it would support efforts to work out how these challenges can be addressed.
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