IBIA observations regarding potential black carbon emissions from 0.50% sulphur fuels

The Clean Arctic Alliance (CAA) has published a letter addressed to the co-authors of the Joint Industry Guidance on “The supply and use of 0.50%-sulphur marine fuel”.  IBIA received a copy of this letter on Friday 24 January.  In response to multiple queries raised in the wake of CAA’s publicised letter, IBIA would like to share the following observations:

1. The development of the Joint
   Industry Guidance (JIG) was initiated in response to industry concerns on
   the safe use of the new fuel blends that were expected to
   come to market to meet the 0.50% sulphur limit imposed by MARPOL Annex VI
   with effect from January 1, 2020.  The rationale for the JIG document
   was presented both to the Maritime Safety Committee (MSC) and the Marine
   Environment Protection Committee (MEPC) of the International Maritime
   Organization (IMO).
2. The JIG effort was focused
   on covering practical and operational aspects of the 0.50% sulphur limit
   to prepare all relevant industry stakeholders for the transition and help
   ensure the safety of vessels and crews. Its remit was limited to these
   issues.
3. One of the main concerns
   addressed in the guidance related to the variability of
   the fuel blends that were expected to come to the market and the potential
   compatibility issues that may occur in the event of commingling of fuels
   of a different nature.
4. The CAA letter refers
   to a study submitted to the IMO dated
   November 15, 2019. This was before MARPOL Annex VI took effect and before
   many of the new fuel blends were widely available.  The study says:
   “The tested 0.50% sulphur fuels have been ordered as possible sample
   mixtures from refinery-streams most likely to be used in 2020.” IBIA is
   surprised by the study’s assertion that the 0.50% sulphur fuel oil blends
   are expected to have higher aromatic content than traditional high sulphur
   fuel oil (HSFO), especially as the expectation prior to 2020 was that many
   of the new marine fuel blends would be more paraffinic in nature.
5. The shift to 0.50% sulphur
   fuels is still in its early days and to the extent of IBIA’s knowledge
   there is no comprehensive overview available at this stage that documents
   the actual variability and quality of such fuels on the
   market. Early indications from several fuel testing agencies do, however,
   indicate that 0.50% sulphur fuels seen so far tend to be more paraffinic
   and less aromatic than the HSFOs they have replaced. As such, it seems
   premature to draw any valid and meaningful conclusions on the level of
   black carbon emissions associated with the use of 0.50% sulphur fuels.
6. IBIA supports a thorough,
   scientific debate of this issue at the IMO, which in our view is the
   proper forum for this discussion. IMO decisions should be firmly evidence
   based and it is important that all interested parties retain open and
   inquisitive minds. Reduction of the impact on the Arctic of black carbon
   emissions is on the agenda at the upcoming 7^th session of the IMO’s
   Sub-Committee on Pollution Prevention and Response.
7. The IMO has already agreed
   to start work to develop a ban on
   the use and carriage of heavy fuel oil (HFO) for
   combustion purposes by ships in Arctic waters, but first it needs to define
   what is meant by ‘HFO’. At present, there is a ban on the use
   and carriage of heavy grade oil (HGO) in the Antarctic under MARPOL Annex
   I. The IMO needs to examine whether the existing definition of HGO may be
   fit for developing a ban on the use and carriage of HFO in the Arctic.