Latest Issues Facing Shipping

Transcription

1 North American Panel October 31, 2018 Latest Issues Facing Shipping JOSEPH ANGELO Director, Regulatory Affairs and the Americas

2 Ballast Water Management 2020 Fuel Oil Sulphur Cap Greenhouse Gas Emissions Global Maritime Security

3 Ballast Water Management IMO IMO Ballast Water Management Convention Adopted in 2004 Entered into force on September 8, 2017 Currently 73 countries representing 75.35% have ratified the BWM convention Main concerns were BWMS guidelines and implementation schedule for ships to install BWMS

4 Ballast Water Management IMO MEPC 71 (July 2017) approves installation schedule 1. Ships constructed on or after Sept 8, 2017, must comply upon delivery. 2. Ships constructed before Sept 8, 2017 must comply beginning on Sept 8, 2019 through phase-in: a. the first renewal survey of the MARPOL Annex I IOPP Certificate after Sept 8, 2017 if,.i the survey is completed on or after Sept 8, 2019, or.ii a renewal survey is completed on or after Sept 8, 2014, but prior to Sept 8, 2017; b. the second renewal survey of the MARPOL Annex I IOPP Certificate if the first renewal survey after Sept 8, 2017 is completed prior to Sept 8, 2019

5 Ballast Water Management IMO MEPC 71 takes additional action 1. Approved the Code for approval of Ballast Water Management systems (BWMS Code) 2. Approved guidance on contingency measures when ballast water to be discharged from a ship is not compliant 3. Approved circular on Application of the BWM Convention to ships operating in sea areas where ballast water exchange in accordance with regulations is not possible 4. Adopted MEPC resolution on the experience-building phase associated with the BWM Convention which states that a ship should not be penalized (sanctioned, warned, detained or excluded) solely due to an exceedance of the performance standard

6 Ballast Water Management IMO IMO BMW.2/Circ.62 Guidance on Contingency Measures 1. Measures when a ship is unable to manage ballast water in accordance with its approved Ballast Water Management plan to meet the D-1 or D-2 standard 2. Communication between ship and port State on a case by case basis should consider the following:.1 actions predetermined in the BWM Plan;.2 discharge ballast to a reception facility;.3 manage the ballast with a method acceptable to the port;.4 ballast water exchange; or.5 operational actions, e.g. modifying sailing or ballast discharge schedules, internal transfer of ballast or retention on board.

7 Ballast Water Management USCG USCG has shifted from implementation to compliance and enforcement Two main issues are: 1. Extensions (revised compliance date to install a CG approved BWMS) 2. CG approval of BWMS

8 Ballast Water Management USCG EXTENSIONS CG has granted more than 13,000 extensions However, policy for granting extensions has changed Extension requests must include: 1. why CG approved BWMSs are not compatible, are unavailable or cannot be installed by the compliance date; 2. plan to install a CG approved BWMS, including the timeline for installation and a contract for the specific BWMS that will be installed No extensions will be granted to an installed Alternative Management System (AMS) Extensions will not be linked to vessels next scheduled drydocking and in general will not be more that 12 months

9 Ballast Water Management USCG USCG BWMS Type Approval Status Approved (11) Under Review (9) Optimarin OBS/OBS Ex De Nora BalPure Alfa Laval PureBallast JFE Engineering Ballast Ace OceanSaver Mark II Panasia GloEn Patrol SunRui BalClor Headway Oceanguard Ecochlor NK-03 BlueBallast II Erma First Fit Envirocleanse Techcross Electro-Cleen NK-03 BlueBallast II Plus Samsung Purimar DESMI Oceanguard BIO-SEA B Wartsila Aquarius UV Wartsila Aquarius EC Hyundai HiBallast

10 Ballast Water Management USCG US COAST GUARD GUIDANCE CG-CVC Policy Letter (Feb 14, 2018) Guidelines for Evaluating Potential Courses of Action When a Vessel Bound for a Port of the United States has an Inoperable Ballast Water Management (BWM) System Navigation and Vessel Inspection Circular (March 1, 2018) Ballast Water Management for Control of Non- Indigenous Species in Waters of the United States When issues arise, contact nearest COTP asap to discuss contingency plans If these discussions occur with enough advance notice, it is possible to avoid penalties and operational delays

11 INTERTANKO PUBLICATION (March 2018) BALLAST WATER CONTINGENCY MEASURES FOR TANKERS Part 1 IMO Requirements Part 2 US Coast Guard Requirements Part 3 Contingency Measures for Tankers Part 4 Reporting Annex 1 Model Ballast Water Contingency Measure Request Form Annex 2 Ballast Water Management System (BWMS) Failure Reporting Form

12 2020 FUEL OIL SULPHUR CAP MEPC 70 agreed to the date of 1 January 2020 as the effective date of implementation for ships to comply with the global 0.50% sulphur content During the debate a considerable number of concerns and potential problems were identified with respect to implementation of this decision MEPC recognized these concerns and requested the Pollution, Prevention and Response Subcommittee (PPR) to develop new work program item on what additional measures may be developed to promote consistent implementation of the 0.50% sulphur limit

13 2020 FUEL OIL SULPHUR CAP 1. Initial transitional issues 2. Impact on machinery systems 3. Verification issues and mechanisms 4. Any regulatory amendments or guidelines needed 5. Development of a draft standard format for reporting fuel oil non-availability 6. Development of guidance that may assist Member States and stakeholders 7. Request to ISO to consider the framework of ISO Safety implications relating blending fuels

14 2020 FUEL OIL SULPHUR CAP Shipping Industry Associations submitted 5 papers to PPR Working Group 1. Ship Implementation Plan (SIP) proposes that ships develop a plan on how they will comply 2. Fuel Oil Non-Availability Report (FONAR) proposes standard reporting format 3. Fuel oil verification procedures proposes uniform approach to determining fuel oil sulphur content 4. Fuel oil sampling points proposes designation of sampling points to be used for taking representative samples of fuel oil being used on board the ship 5. Safety implications highlights concerns of impact of new fuels on ship s machinery systems

15 2020 FUEL OIL SULPHUR CAP Outcome of PPR Working Group, July 9 13 Draft Ship Implementation Plan (SIP) with guidance to develop SIP to be sent to MEPC 73 (October), including: 1. Indicative example of SIP 2. Guidance on impact of machinery systems 3. Guidance on tank cleaning Progress on the following to be sent to PPR 6 (February 2019) and then MEPC 74 (May 2019): 1. Fuel Oil Non-Availability Report (FONAR) 2. Fuel oil verification procedures 3. Fuel oil sampling points 4. Update of Annex VI Port State Control Guidelines

16 2020 FUEL OIL SULPHUR CAP In addition, MEPC will adopt: Amendment to Annex VI prohibiting the carriage of fuels with Sulphur content > 0.50% on board ships which do not have a scrubber (entry into force 1 March 2020) Is developing best practices for: 1. Fuel oil providers (bunker suppliers) 2. Member states/coastal states And has approved: MEPC.1/Circ.875 Guidance on best practice for fuel oil purchasers/users for assuring the quality of fuel oil used on board ships

17 2020 FUEL OIL SULPHUR CAP Main principle of best practice for fuel oil purchasers/users: Fuel oil purchasers are responsible for correctly specifying the fuel oil which is to be supplied. It is the responsibility of the supplier to deliver fuel oil which is compliant with the agreed specification. Fuel oil purchasers should strive to purchase fuel oil from quality-oriented fuel oil suppliers. It is recommended that the fuel oil purchaser has a sample of fuel oil collected during bunkering analysed to confirm that it complies with the agreed specification in the contract.

18 2020 FUEL OIL SULPHUR CAP Marshall Islands (etal) submission to MEPC 73 for Experience Building Phase (EBP) Concern over sufficient quantities of quality and safe fuel oils EPB to monitor implementation of 0.50% sulphur cap 1. Phase 1 Data collection to ensure adequate information on implementation 2. Phase 2 Data Analysis to ensure data is processed to yield useful and timely information on implementation 3. Phase 3 Review of Regulatory Framework to identify and, if necessary, develop amendments to improve framework of Annex VI requirements Facilitate pragmatic enforcement approach, applied in a consistent manner

19 2020 FUEL OIL SULPHUR CAP Practical and pragmatic approach by port State control authorities for consistent enforcement Industry associations proposed a period of three months after 1 January 2020 for those ships which are in possession of a Ship Implementation Plan PPR Working Group could not agree Matter referred to MEPC 73 on whether reference to "practical and pragmatic approach by port State control authorities" should be included in the draft MEPC circular on guidance for the Ship Implementation Plan

20 2020 FUEL OIL SULPHUR CAP Current wording in draft SIP Guidelines: Regulation of MARPOL Annex VI requires a Party to take into account all relevant circumstances and the evidence presented to determine the action to take, including not taking control measures. Administrations and port State control authorities may take into account the implementation plan when verifying compliance with the 0.50% sulphur limit requirement.

21 2020 FUEL OIL SULPHUR CAP OUTCOME OF MEPC73 Adopted amendment prohibiting the carriage of noncompliant fuels on ships which do not have a scrubber (entry into force 1 March 2020) Approved Ship Implementation Plan (SIP) guidelines Decided not to include practical and pragmatic approach by port State control in SIP Based upon INTERTANKO proposal, agreed that consistent enforcement by port states should be considered in the updated port state control guidelines Approved best practice for fuel oil providers Made progress on best practice for Member/coastal states

22 2020 FUEL OIL SULPHUR CAP OUTCOME OF MEPC 73 ON EBP Number of Member States in favour of EBP about equal to those that opposed EBP Chairman proposes compromise The Committee invites further concrete proposals on how to enhance the implementation of regulation 18 of MARPOL Annex VI, in particular on reporting fuel oil quality and non-availability of compliant fuel oils, including the enhancement of GISIS modules for data collection and analysis Compromise accepted by all

23 2020 FUEL OIL SULPHUR CAP Marshall Islands (etal) submission to MSC 100 to consider safety implications associated with the use of low-sulphur fuel oil Liberia (etal) submission to MSC 100 to address fuel oil safety issues proposes: Long term solution Review of Annex VI fuel oil safety issues with objective of bringing safety matters under the purview of SOLAS and the MSC Short term solution MSC Circular to recommend that all Member States take appropriate action to ensure that fuel supplier under their jurisdiction deliver fuels that comply with the agreed specifications and applicable statutory requirements

24 2020 FUEL OIL SULPHUR CAP OCIMF/IPIECA Guidelines Multiple industry associations, including INTERTANKO Issues to be addressed: 1. Expectations/responsibilities on fuel suppliers and users 2. Guidance on fuel characteristics and properties: a. Information on the potential variability of 0.50% max. sulphur fuels b. Fuel standards (ISO 8217 & PAS 23263) - interpretation and application c. Fuel properties, viscosity, flash point, cat fines, etc. d. Potential compatibility issues e. Test methods available for evaluating fuel quality f. Guidance on the supply of existing and new fuels g. Guidance on storage, handling and usage of fuels

25 2020 FUEL OIL SULPHUR CAP Additional INTERTANKO actions Bunker Subcommittee developing Action Plan for Members for fuel management plans with associated guidelines to be updated regularly and issued through the Weekly News Documentary Committee developing charter party clauses

26 2020 FUEL OIL SULPHUR CAP Exhaust Gas Clean Systems Association (EGCSA) reports 983 ships with scrubbers installed or on order (May 2018) EGCSA estimates 10,000 ships with scrubbers by ,000+ ships need to comply Veritas Petroleum Services (VPS) predicts about a 3 million barrel per day drop in demand for HSFO in 2020 In 2020 marine gasoil will account for 66% of the marine fuel market with accompanying increase in price Some developments in new fuels (Exxon, Shell, etc.) Report that one charterer required scrubber for tanker to be chartered If scrubber is ordered but not installed by January 1, 2020, vessel must use compliant fuel until scrubber installed

27 2020 FUEL OIL SULPHUR CAP Conclusions There will be NO DELAY of January 1, 2020 implementation date Ships which do not have a scrubber on board will be prohibited from carrying non-compliant fuels on and after 1 March 2020 Each tanker owner must consider which compliance option is best for their ships based on ship type and age 2020 brings challenges and opportunities to the tanker industry

28 GREENHOUSE GAS EMISSIONS IMO Three Step, Phase In approach Phase I data collection (monitoring, reporting and verification) Phase II data assessment and setting targets for further CO 2 emission reductions from international shipping Phase III regulatory reduction mechanism and its enforcement

29 GREENHOUSE GAS EMISSIONS Data Collection Amendments to Chapter 4 of Annex VI of MARPOL 73/78 Adopted at MEPC 70 (October 2016) Entry into force March 1, 2018 On or before December 31, 2018, ship s SEEMP shall include a description of the methodology to be used to collect the data Data collection starts from calendar year 2019

30 GREENHOUSE GAS EMISSIONS Data Collection Ships of 5000 grt and above Data to be collected - IMO Number - ship type - maximum DWT (NOTE: no data on actual cargo) - total annual fuel consumption, by fuel type - distance traveled - hours underway

31 GREENHOUSE GAS EMISSIONS MEPC 70 (Oct. 2016) approved a Roadmap for a comprehensive IMO strategy to reduce GHG emissions from international shipping MEPC 72 (April 2018) adopted the Initial IMO Strategy on reduction of GHG emissions which included the RT proposals Next steps for IMO: decide on specific short ( ), mid ( ) and long (beyond 2030) term measures to reduce GHG emissions from ships and the timeline to finalize any measures

32 GREENHOUSE GAS EMISSIONS Main elements IMO Roadmap 2017/early 2018 proposals submitted/discussed Spring 2018 Adoption of initial IMO Strategy, including a list of candidate short-, mid- and long term measures 2019 Data collection begins, discussions continue Autumn 2020 Phase 2 begins, analysis of data 2021 Initiation of work for adjustments on initial IMO Strategy based upon data analysis Spring 2022 Phase 3, decision step discussions begin Spring 2023 Adoption of revised IMO Strategy, including short-, mid- and long-term further measure(s), as required, with implementation schedules

33 Vision commitment to reduce GHG emissions from international shipping & ambition to full de-carbonisation towards the end of Century Levels of ambition INITIAL IMO GHG STRATEGY a) general reduction of carbon intensity of ships (CO 2 /tonnemiles) through additional phases of the EEDI for new ships; b) carbon intensity of international shipping to be reduced as an average across international shipping by at least 40% by 2030, pursuing efforts towards 70% by 2050, compared to 2008; c) net GHG emissions to be reduced by at least 50% by 2050 compared to 2008 whilst pursuing efforts towards phasing them out.

34 INITIAL IMO GHG STRATEGY There are currently 21 different proposed measures in the strategy Candidate short-term measures Improvements on EEDI and SEEMP Speed optimization and speed reduction Technical and operational energy efficiency measures for both new and existing ships Establishment of an Existing Fleet Improvement Programme

35 INITIAL IMO GHG STRATEGY Candidate mid-term measures - suggestions for: Operational energy efficiency measures including indicators in line with three-step approach to indicate and enhance the energy efficiency performance New/innovative emission reduction mechanism(s), possibly including Market-based Measures (MBMs), to incentivize GHG emission reduction Implementation programme for the effective uptake of alternative low-carbon and zero carbon fuels Candidate long-term measures - levels of ambitions could only be linked to development of zero-carbon or fossil-free fuels

36 GLOBAL MARITIME SECURITY INTERTANKO, and other industry associations, with military support, have launched a new web site (June 2018) dedicated to providing comprehensive maritime security guidance to companies and mariners. The new website provides security-related guidance produced by the industry as well as links to other useful maritime and military security resources.

37 GLOBAL MARITIME SECURITY Website provides new best practice guides 1. Global Counter Piracy Guidance for Companies, Masters and Seafarers - a new publication containing guidance on piracy and armed robbery that can be used by mariners around the world. 2. BMP5: Best Management Practices to Deter Piracy and Enhance Maritime Safety in the Red Sea, Gulf of Aden, Indian Ocean and the Arabian Sea - contains updated guidance for region-specific threats in this region. 3. Third Edition of the Guidelines for Owners, Operators and Masters for protection against piracy and armed robbery in the Gulf of Guinea region

38 THANK YOU!