The statement below was made by IBIA’s Director and represenative to the IMO, Unni Einemo, at the seventh session of IMO’s Sub-Committee on Pollution Prevention and Response (PPR 7) in February this year when discussing agenda item 8 – “Reduction of the impact on the Arctic of Black Carbon emissions from international shipping“.
Thank you Chair and good afternoon to all.
We thank all submitters of documents under this agenda item.
The measurement study described in PPR 7/8 from Germany and Finland examined a selection of fuel specimens with specific aromatic contents. It is clear from the study that while aromatic content is a factor, establishing the exact reasons for the formation of black carbon from combustion processes is complex and depends on a multitude of factors, and there were some discrepancies between the results depending on which black carbon measurement method was used. Previous studies have demonstrated that engine type, condition and operating profile are key factors impacting on black carbon emissions.
There are things that the study does not tell us. For example, what test method was used to establish the aromatic content. Aromatics span from benzene, relatively simple molecules which you also find in road fuels, to more complex, large molecules. The impact on black carbon emissions would likely vary depending on the type of molecules.
The co-sponsors of PPR 7/8 propose examining whether it is necessary to implement aromatic content, or a Hydrogen/Carbon ratio, in the ISO 8217 marine fuels specification. In PPR 7/8/1, Euromot also recommends considering the aromatic content, as well as estimated cetane number in the standard to better predict ignition and combustion characteristics. We believe the experts participating in the revision of the ISO 8217 standard are well placed to assess the most effective parameters and associated test methods to determine aromatic content and combustion behaviour.
Another thing the study did not actually tell us was whether the aromatic content in the particular fuel specimens used for the measurement comparisons are representative of all marine gasoils, high sulphur fuel oils and 0.5%S fuel oil blends. In short, they are not.
It is not a given that all high sulphur fuel oils contain 50% aromatics, and the high aromatic content in the 0.50% sulphur blends used in the study is definitely not representative of the typical 0.50% sulphur fuels introduced to the market. On the contrary, and as expected by the industry, 0.50% sulphur blends tend to be less aromatic and more paraffinic in nature than the HSFOs they have replaced.
The mistaken belief that the fuel specimens used in the German study were representative of typical 0.50% sulphur blends caused the co-sponsors of PPR 7/8/2 and PPR 7/8/3 to call for a ban on the use of 0.50% sulphur fuel blends in the Arctic and to restrict their use globally. As we have heard in several interventions, the actual 0.50% sulphur fuel blends that have replaced HSFOs are less aromatic and will likely reduce overall black carbon emissions from international shipping.
We would like to share some information that may be of interest to the sub-committee. In light of the recommendation to introduce a heavy fuel oil use and carriage ban in the Arctic, using the definition in regulation 43 of MARPOL Annex I, we were curious to find out what this might mean for current 0.5%S fuel blends. Based on information we obtained from three fuel testing agencies, some 93-95% of such fuels tested in January and part of February this year were above the combined viscosity and density limit, suggesting that the vast majority of 0.5% blends seen so far would be classified as HFO.