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.