The dry bulk industry could meet the International Maritime Organization’s (IMO) mandate on greenhouse gases (GHG), through the use of alternative fuels such as ammonia, battery and hydrogen fuel cells, according to Star Bulk Carriers chief executive Hamish Norton.

In this interview, Norton discusses where the company stands in meeting the IMO 2030 GHG goals, how the IMO’s sulphur regulation has affected bunkering operations and more. This interview has been edited for clarity and brevity.

Did the IMO 2020 sulphur regulation have an effect on your bunkering operations, like a lack of high sulphur fuel oil (HSFO) or very low sulphur fuel oil (VLSFO) availability?

We rarely encountered non-availability of both sorts of fuel and that was only occasionally in specific ports, e.g. Fujairah, or smaller Chinese ports, and we learned of potential delays in many ports, large and small.

However, neither availability nor timing became a problem for us because we were able to deal with both potential problems by planning ahead. Instead of beginning the process of finding fuel three or four days before we needed it, we started planning 10 days or even two weeks ahead.

Additionally, we entered into term contracts, which guaranteed availability. The market has calmed down quite a bit now for both fuel grades, and we are back to lead times of 6-8 days.

Have you encountered off-specification VLSFO batches ?

We have not encountered off-spec VLSFO as we burn essentially no VLSFO. As the vast majority of our fleet are equipped with scrubbers, we burn primarily HSFO and supplement that with low sulphur marine gasoil (LSMGO). We have not experienced off-spec HSFO or LSMGO.

How much bunker fuel does Star Bulk burn per year, and do you procure bunkers on a spot basis, a term basis or both?

We burn approximately 700,000 tons/yr, depending, of course, on the average speed of the fleet in a given year, which correlates positively with charter rates and negatively with fuel prices.

We have not hedged fuel prices so far, although we have hedged the spread between HSFO and VLSFO for about 100,000 tons this year. We do not only procure bunkers on a spot basis but have also entered into term contracts.

How many vessels does Star Bulk have with scrubbers? Were there plans for more installations in 2020 that were delayed or cancelled?

We have 114 vessels fitted with scrubbers. No scrubber installations were cancelled.

As with every other shipowner who has installed scrubbers, there were delays, which became progressively worse after the first quarter of 2019. We were able to get all the scrubbers installed successfully by the end of the first quarter of 2020.

Has procuring HSFO to burn on your vessels with scrubbers been a problem? If so, in which ports?

We have not had any trouble procuring HSFO, but to a greater extent than before 2020, we must think about which ports to use for bunker procurement, and we have to plan ahead to a greater degree.

There are certainly fewer ports with HSFO (Indian ports, for example, or occasionally South Africa) but overall HSFO supply has been much better than anticipated in late 2019.

Do you expect interest in scrubber investments to grow once the pandemic is over?

We believe that the economics of owning scrubbers will improve when consumption of refined petroleum products increases, which should cause refinery utilization to increase.

We have no idea if the improved economics will reignite interest in scrubber investments.

Are there any particular fuels (such as hydrogen, LNG, ammonia, etc.) that you think the dry bulk shipping industry will embrace more than others to achieve IMO’s 2030 and IMO’s 2050 greenhouse emissions reduction targets?

If we had to guess what fuels the dry bulk shipping industry will use to meet the 2030 mandate, we would probably guess liquid petroleum products, augmented with speed reductions, engine improvements, hybrid electricity production on board, hull and propeller improvements and hull friction reduction.

There are several zero emission fuels which are currently being assessed by the industry, such as biofuels, hydrogen from renewable sources and ammonia from renewable sources.

Are there particular low-carbon fuels Star Bulk is considering?

Ammonia seems to be an attractive scenario except for its toxicity as it is truly carbon free if made from renewable electricity and is also scalable. Batteries or hydrogen fuel cells could also be promising for shorter-distance shipping.

Biofuels may also contribute to the industry’s decarbonization, however, demand from other sectors is expected to limit the availability of truly sustainable biofuels.

Other shipping companies say they achieved IMO 2030’s greenhouse gas emission goals in 2019. Is Star Bulk on track to achieving IMO’s 2030 goals, and by what means?

Star Bulk is on track to achieving IMO’s 2030 goals. Star Bulk has an energy efficiency management plan in place and has been taking a series of operational measures to optimize our fleet’s performance, including the application of weather routing systems and speed management practices.

Since 2018 we have utilized our vessel performance monitoring system to measure greenhouse gas emissions, and we are happy to report an improvement in our fleet’s energy efficiency operating index.

Do you think IMO’s 2030 greenhouse gas emission goals are ambitious enough?

Given the current state of energy saving technology, we view the 2030 emission goals as relatively ambitious, though we would be happy if the shipping industry performed even better than the goals that have already been set.

Do you think IMO’s 2050 greenhouse gas emission goals are easily achievable?

The 2050 goals require the introduction of carbon neutral fuels, along with the infrastructure to produce, transport and store them as well as the technology to burn those.

It is probable that decarbonization of the shipping industry will be driven by more than one zero emission fuel and different infrastructure technologies.

Star Bulk is also participating in feasibility studies for certain fuels that have the potential of being carbon neutral. We believe that it is only through partnerships and collaboration among different industry stakeholders that the transition to 2050 can be achieved.

How has the US-China trade war affected dry bulk rates, and do you expect it to during the second half of the year? Do the US election result play a role?

US-China trade clearly affects the psychology of the market, but it does not affect ton-miles very much. China buys soybeans, and their purchases of soybeans have been increasing as their pig population has been recovering from African Swine Fever.

But the alternative sources of soybeans in Latin America produce more ton-miles of demand than the relatively closer supply from the US Gulf.

We do not believe the election in the US is likely to have much influence on the dry bulk market.

A number of shipowners said emissions regulation uncertainty prevents them from ordering more ships. Is this uncertainty a major factor in your newbuild orders? What is Star Bulk’s orderbook?

We have no ships on order. Uncertainty about the economic life of a ship ordered today but having to operate in a future world in which regulations may change rapidly certainly affects our thinking about an investment in a ship, and we believe such uncertainty affects the thinking of most other shipowners in a position to order a ship.

We believe that such uncertainty is likely to keep the order book for ships of all types smaller than it would otherwise be. This reduction in ordering is a good thing and has to happen if the shipping fleet is going to meet the 2050 rules.

The shortage of ships over the long term will cause shipping rates to increase. The ships that will eventually become available to meet the 2050 standards will be expensive. One needs high rates to justify an investment in expensive ships. The market will solve the greenhouse gas problem if given the right incentives.


Shipowners are also lacking the finances to make purchases, according to Ralph Leszczynski, head of research at shipbroker Banchero Costa & Co. “Most shipping markets are coming from a relatively poor decade, 2009 to 2019, in terms of earnings so most shipowners do not have that much cash in their pockets,” he said. “External finance is also in short supply as banks

.

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Comments of the Day

28 August 2020

 

Video commentary for August 27th 2020

 

Eoin Treacy’s view

A link to today’s video commentary is posted in the Subscriber’s Area.

Some of the topics discused include: Fed is going to run the economy hot. Bonds suffer, gold eases, stocks form, Dollar volatile.

 

Powell Fed Shift Allows for Higher Employment and Inflation

This article from Bloomberg may be of interest to subscribers. Here is a section:

The new strategy is being undertaken to tackle years of too-low inflation. It hands the central bank flexibility to let the job market run hotter and price pressures float higher before taking action as it may previously have done.

“They really, really, really are not going to be raising interest rates any time soon,” said James Knightley, chief international economist at ING Financial Markets. “The Fed is saying rates will be lower for longer, but don’t worry inflation is not going to be picking up.”

While it doesn’t target a specific rate of unemployment broadly or for certain demographic groups, the approach may help address other weaknesses in the economy.

During the longest U.S. economic expansion on record until the pandemic hit earlier this year, many groups benefited — including minorities and women. With millions out of work and unrest flaring up across the U.S. over racial inequality, questions about how the Fed’s policy helps diverse communities have been raised.

 

Eoin Treacy’s view

The Fed is happy to run the economy hot. That begs the question what happens next? Will they attempt to support the Treasury market in what is already de facto yield curve control? As the economy responds to the trillions in new liquidity, how will the Fed react to the rise in the velocity of money? If they are willing to run the economy hot a somewhat steeper yield curve is desirable but stoking inflation can have many unintended consequences.

 

No One Wants to Buy Ships as Virus, IMO Rules Hit Demand Hard

This article by Krystal Chia and Annie Lee for Bloomberg may be of interest to Subscriber’s Area. Here is a section:

Shipowners are also lacking the finances to make purchases, according to Ralph Leszczynski, head of research at shipbroker Banchero Costa & Co.

“Most shipping markets are coming from a relatively poor decade, 2009 to 2019, in terms of earnings so most shipowners do not have that much cash in their pockets,” he said. “External finance is also in short supply as banks are now largely steering clear off shipping after the defaults they suffered after 2008.”

Still, fewer orders and slower fleet growth will likely bolster shipping rates. Lines are likely to continue to keep capacity in check into 2021 to minimize the impact from slowing global trade, said IHS Markit’s Kapoor.

That’s already translating to increasing costs for transporting goods by ocean liner, with one benchmark of trans-Pacific container rates more than doubling since late-May to a record. Bulk-carrier costs have also rebounded from a four-year low. Maersk, which idled about 20% of its capacity in April before gradually reinstating it in subsequent months, saw earnings beat estimates in part due to improved freight rates.

 

Eoin Treacy’s view

When new regulation imposes new costs that are greater than the value of the original asset it raises important questions about the sustainability of businesses. Installing new engines in new ships is an ideal solution but its expensive. Meanwhile the lesser of two evils are scrubbers to the emissions but these often exceed the value of older ships. This is a recipe for a loss of supply from the global shipping fleet.

 

Equity Insights: EU’s ‘Hamilton Light’ Recovery Plan Marks a Paradigm Shift, and Markets Cheered

This article by Anik Sen for PineBridge Investments may be of interest to subscribers. Here is a section:

The EC’s paradigm shift

By becoming the borrower through its issuance of €750 billion of debt, the EC sets a new precedent while becoming a major new force in the sovereign debt markets. It is also expected to demonstrate maximum flexibility in managing its debt to achieve the most favorable terms for the member states. The bonds are expected to be repaid through the EU budget through the end of 2058. New tax revenues have been proposed, such as a plastic levy, a digital tax, and a review of the EU Emissions Trading System.

The recovery plan marks a significant moment in which EU Leaders recognized the need to create a new structure for raising funds under the auspices of the EC and funded by the EU budget. This structure has a strong likelihood of becoming a permanent funding mechanism at the EU level for emergency programs and other funding needs for the fiscally weak member states. They have also acted swiftly to stem the risks to the eurozone’s stability from alarmingly high fiscal deficits, and to front-load the raising of funds in order to plug the enormous fiscal gaps into the future. They have recognized the need to move away from the failed austerity approach of the past and to adopt a pro-growth policy through grants and loans on attractive terms with light conditionality – a major departure from the past.

‘Hamilton light’ plan is an auspicious beginning

The recovery plan could well become a permanent feature for the EU, serving to underpin the debt issued by the periphery member states. This has enormous significance for the EU banking industry, which has become reliant on the ECB’s QE programs for its stability and capital adequacy. If the fear of default is truly removed for any eurozone sovereign debt, without assuming intervention by the ECB, there could be broader implications for financial system integration within Europe, with cross-border mergers and acquisitions within the EU finally taking place. This is sorely needed to drive greater scale in a banking system that has poor profitability compared to that of the US.

The recovery fund may not be quite as far-reaching as Alexander Hamilton’s re-ordering of the financial system in the newly born United States. However, the progress made by EU leaders this summer points to a measured yet pivotal step toward very similar ends.

 

Eoin Treacy’s view

Europe has just created Federal bonds which will be repaid from the bloc’s budget. New taxes are being proposed to increase the size of the budget and there are aspirations for the system to become permanent.

 

Eoin’s personal portfolio: last updated on August 11th

Eoin Treacy’s view

One of the most commonly asked questions by subscribers is how to find details of my open traders. In an effort to make it easier I will simply repost the latest summary daily until there is a change. I’ll change the title to the date of publication of new details so you will know when the information was provided.

 

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LONDON: Royal Dutch Shell has struck a deal with Dutch tank terminal firm HES International to partially restart a German oil refinery mothballed since 2011 in response to new restrictions on marine fuels, two trading sources told Reuters.

A new cap set by the International Maritime Organization (IMO) that will cut the sulphur content in shipping fuel to 0.5 percent from 3.5 percent from next year is set to be one of the biggest fundamental events to hit oil markets in years.

HES Wilhelmshaven Tank Terminal is in the process of reinstalling the vacuum distillation unit (VDU) at Wilhelmshaven to produce low-sulphur bunker fuels ahead of the implementation of the IMO rules, a spokeswoman for the company said.

HES said it had “reached a tolling agreement with a customer,” but declined to comment on the parties involved.

However, two trading sources with knowledge of the matter told Reuters the customer in question is Shell. Shell declined to comment.

The agreement is akin to a processing deal, whereby Shell brings in the feedstock and handles the end product, one of the sources said.

HES bought the 260,000 barrel per day (bpd) refinery from ConocoPhillips in 2011 and converted it into a large-scale tank terminal facility with capacity of 1.3 million cubic metres.

The plant’s refining capacity was shuttered at a time when several European refineries were finding it uncompetitive to remain operational, as newer, more complex mega-refineries emerged in other regions like the Middle East and Asia.

But as the new IMO rules dictate a massive shift in oil product slates from higher to low sulphur, the economics are shifting and oil companies and traders are resorting to creative ideas to meet the new demand.

The IMO sulphur restrictions will lead high-sulphur fuel oil demand to fall 60 percent to 1.4 million bpd next year, while marine gasoil demand will more than double to 2 million bpd, the International Energy Agency forecast this week.

Vacuum distillation is an integral part of the refining process. VDUs typically run on residual fuel produced from distilling crude to produce vacuum gasoil which is then used to feed upgrading units that make gasoline and diesel.

However, the Wilhelmshaven VDU will not be running on residual fuel, HES said.

One of the sources said the plan is to process heavy, low-sulphur crudes like Brazilian grades to produce a range of products, including maximum 0.5 percent sulphur fuel oil or distillate marine fuels.

HES is 70 percent owned by private investment firm Riverstone, with the remaining 30 percent held by the Carlyle Group.

Infrastructure funds managed by banks Macquarie and Goldman Sachs agreed in principle last year to buy the company.

Source: energy.economictimes.indiatimes


CMA CGM has introduced a Low Sulphur Surcharge (LSS20) effective December 1st, 2019 to cover the increase in fuel-related costs associated with the implementation of the IMO 2020 regulation.

As from October 1st, 2020, taking into consideration the current price of VLSFO, CMA CGM informs its customers that this Low Sulphur Surcharge is not applicable and may come back later as per our formula.

Please contact your local CMA CGM office should you require information about any other pricing information

(*) The associated basic freights are available here. Other Bunker related surcharges, THC (Origin and Destination), Peak Season charges and similar charges and Safety and Security-related surcharges may also apply and are accessible at http://www.cma-cgm.com/ebusiness/tariffs/charge-finder. Other charges such as Contingency charges and local charges may also apply.


  • The supply of VLSFO has proven more than adequate amid COVID-19.
  • Call on marine gasoil (MGO) as an expensive alternative has been less than expected.
  • Refiners have adjusted their crude sales and changed their blend component pools.
  • The use of marine gasoil in engines has not increased as rapidly.
  • This is attributed to the fact that ship engineers think in terms of volume rather than the energy content.
  • Competition for low sulphur heavy gasoil and waxy streams has increased.
  • The price of solar and wind continues to decrease steadily with increase in battery storage technology.
  • The cost of hydrogen production is plummeting due to a likely surge in the availability of cheap renewable power.

According to an article published in The Manifold Times and Petroleum-Economist, the new rules on the sulphur content of shipping fuels came into force this year. This article revisits 2018 predictions to see what turned out as expected and what surprised.

Demand weakens due to COVID-19

It is easy to forget that, pre-COVID, new International Maritime Organization (IMO) 2020 regulations reducing the maximum sulphur content in much of the world’s bunker fuels from 3.5pc to 0.5pc were expected to be one of the dominant narratives in the year’s oil price dynamics.

The demand hit in the wake of pandemic’s global restrictions has, as well as eclipsing IMO 2020’s significance, also dampened its impact, as anticipated pressure on supply has been greatly reduced. Nonetheless, the effects are being felt—if more in the background than might have been expected.

Story so far

Among the most notable observations as yet, the supply of very low sulphur fuel oil (VLSFO) has proven more than adequate, while the call on marine gasoil (MGO) as an expensive alternative has been less than expected.

Refiners have adjusted their crude sales and changed their blend component pools. And many have strengthened their direct position in the bunkering markets with their own—sometimes proprietary—blends of VLSFO.

The use of marine gasoil in engines has not increased as rapidly as we thought, perhaps as ship engineers still think in terms of volume rather than the energy content.

Competition for low sulphur heavy gasoil and waxy streams has increased, which has generated a revival in hydroskimming economics. And low sulphur vacuum gasoil (LSVGO) has become a reference both for cracker feedstock pricing and for bunker economics.

Supply of alternative fuels

Supply of other alternative fuels continues to be developed, most notably LNG—the fastest-growing and most scalable—with supply infrastructure expanding steadily. But these fuels, which also include methanol and ammonia, will act chiefly to achieve the targets set out in the IMO 2050 decarbonization agenda

On the other hand, scrubbing economics continues to hang in the balance. It is our expectation that scrubbing as a technology will be no more than a short-term solution, as shipowners switch to cleaner fuel alternatives.

Channoil revisited some work it did in 2018 on potential IMO 2020 impacts and looked in some depth at what it got right and wrong on the potential implications for various types of stakeholders compared with what we have seen so far (see Figs. 1-4).

Moving forward

Less than eight months in, and a highly unusual eight months at that, the IMO 2020 story is far from over. We must also look ahead to what might happen next. The outlook for fuels and distillate prices is confused due to a number of ‘known unknowns’, including:

  • Uptake of renewable fuels
  • Uptake of electric cars and their impact on power generation
  • The potential impact of carbon capture and storage
  • Growth in coker investments
  • Growth in LNG/LPG/methanol as bunker fuels
  • Impact of incompatibility within new blended fuels
  • Potential for cheaper scrubber technology
  • Other technological breakthroughs
  • A realistic price setting for carbon emissions.

Observations to be made on uncertainties

But there are certain observations we can offer on some of these uncertainties. For one, the price of solar and wind continues to decrease steadily. Coupled with the increase in battery storage technology, this has put the renewable argument to the fore. The cost of hydrogen production is also plummeting and—due to a likely surge in the availability of cheap renewable power—electrolysis is making hydrogen power a realistic contender for the fuel crown.

Forecast growth of electric and hybrid cars also continues to push further upwards. The effect of 1mn electric cars—assumed by 2035—is to reduce crude oil demand by 1mn bl/d. But we are conscious of the fact that, in developed economies, carpools are rotated every seven years. If the fashion for electric cars accelerates, then that timeframe could get rapidly shorter.

Policy goals to reduce diesel cars

European governments, for example, those of France and the UK, have also set policy goals to reduce the number of diesel cars. A big reduction in diesel engines will have an immediate effect on the price of the middle distillate. If coker investments carry on, then it is possible to imagine a scenario where the differential between diesel and HFO will narrow.

The use of marine gasoil (MGO) in engines has not increased as rapidly as we thought, perhaps as ship engineers still think in terms of volume ($/t) rather than energy content ($/mn Btu). There is also a lubricity argument in favor of higher viscosity fuels, while low viscosity MGO needs cooling before it enters the engine and thus, if VLSFO is available, it is more ‘engineer acceptable’. But the question will arise again once NOx and PMO specifications are tightened ­further.

Reflections on regulations and other unforeseen market dynamics in 2020

Søren Høll, CEO at International bunker trading firm KPI OceanConnect, on Tuesday (18 August) published an article sharing his reflections on regulations and other unforeseen market dynamics in 2020 have disrupted the bunker fuel market and outlines the relevance of his company’s role in weathering these forces:

IMO 2020, or ‘MARPOL Annex VI, regulation 14’ as it was less memorably known back when we started preparing for it in 2018, was always going to bring huge changes for shipping.

For some people, it was even going to be as substantial as ships’ switch from coal to oil in the early 20th century. Those predictions have fortunately proven to be unfounded so far, but there hasn’t been any shortage of challenges for our industry in the wake of IMO 2020’s arrival.

Mergers for expansion

During the last few weeks as we’ve been concluding our merger with OceanConnect and I’ve had a chance to reflect on how far we’ve come this year.

  • It’s easy to forget that crude prices started to slide not only because of Covid-19 in February and March but also due to disagreements within OPEC+ about how much oil they should produce. Covid-19 has reduced demand for oil and created a huge glut of both crude and refined products. Even if a vaccine emerges soon, we’re unlikely to see this oversupply abate entirely; not least because countries like Venezuela, Libya, and Iran with huge crude reserves are currently ‘offline.’
  • At times in January, it looked as though shipowners who’d invested in scrubbers for their fleets could see payback periods of less than two years in some cases. By March, however, the spread between 3.5% HSFO and 0.5% VLSFO dropped to as low as $40 a tonne from over $300, and payback periods are now commonly assumed to be at least four or five years. We’re unlikely to see sustained interest for retrofitting scrubbers as long as the spread remains low. On new builds, I’m slightly more optimistic about positive economics.
  • By common estimates, the three biggest cruise lines, Carnival, Norwegian, and RCCL together on average consumed about half a million tons of bunkers each month in 2019. For context, that’s more than 10% greater than total fuel sales of Panama registered by the AMP. Especially for physical suppliers in cruise hotspots like the Caribbean, which supports about a third of global cruise voyages, bunker demand is unlikely to return in full before 2022 at the earliest.
  • The bunker price volatility we’ve seen this year – and in many previous years – is a textbook example of why it pays to consult with your marine fuel supplier to help manage this risk. I was talking to a longstanding client last week, and for her, there are three big advantages to be gained from hedging and risk management: Reduced volatility reduces the cost of capital; knowing there will be no abrupt cost increases means that they can more easily plan ahead, and by smoothing out revenue and expenses they know they won’t need to borrow on unfavorable terms because they’ve got good liquidity.
  • The merging of KPI Bridge Oil and OceanConnect brings together a wealth of knowledge and expertise, new ideas and ways of thinking, and a renewed energy to a changing marketplace. There’s no shortage of challenges ahead for the shipping or bunkering markets, but I’m very optimistic about the company we’re building and the value we can provide.

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Source: Petroleum-Economist & ManifoldTimes


Joining forces to shape the fishery sector of tomorrow is the newly launched (3 September) publication prepared by IMO, ILO and FAO. The new brochure will help promote safe and decent work in fisheries through the application of international standards.

The publication provides an overview of the four main international binding fisheries conventions/agreements* that promote the safety of fishing vessels, safety of fishers, training of fishers, and responsible and safe fisheries operations.

Guidance for policy and decision-makers in the fisheries, maritime, and labour sectors is also provided with a view to encourage the ratification and implementation of the above-mentioned fisheries instruments.

As fishing remains one of the most dangerous professions in the world, the sector needs to change to become more sustainable. This publication aims to support governments in achieving their commitments towards Sustainable Development Goal (SDG) 8: Promote sustained, inclusive, and sustainable economic growth, full and productive employment and decent work for all; and SDG 14: Conserve and sustainably use the oceans, seas and marine resources for sustainable development.

* The IMO (2012) Cape Town Agreement (CTA), The IMO (1995) International Convention on Training, Certification and for Fishing Vessels Personnel (STCW-F), The ILO (2007) Work in Fishing Convention (C188), The (2009) FAO Agreement on Port States Measures to Prevent Deter and Eliminate Illegal, Unreported and Unregulated Fishing (PSMA)

Source:imo


The International Maritime Organization (IMO) is taking initiatives to promote sustainability and reduce harmful sulphur gases emissions. While the new regulation to reduced maximum sulphur content (currently 3.5%) to 0.5% will be fully enforced on January 1, 2020, it is expected that the adjustment on bunker surcharge will come into effect already at the last quarter of 2019.

  • Impact on shippers

With the new regulations to be fully enforced on January 1, 2020, carriers are getting prepared during the course of the year with some options available:

  1. Switch to low-sulphur fuel
  2. Use Exhaust Gas Cleaning Systems which commonly known as a “scrubber” to clean up the sulphur oxide emitted from the vessel’s engine.
  3. Change the fleet to Liquefied Natural Gas Ships that are powered by Liquefied Natural Gas (LNG). LNG is considered as a cleaner fuel with less emission of greenhouse gases including sulphur oxide.

To ensure a smooth transition, carriers have to implement the above changes before January 1, 2020. Due to the investment in clean energy and cleaning systems, there will be an adjustment to the bunker surcharge formula which is expected to be effective from the last quarter of 2019.

  • What is IMO 2020?

IMO is proactively taking steps to reduce marine pollution and minimize the vessels’ impact on global warming. Currently, most of the cargo ships use heavy fuel oil which is derived from crude oil and contains sulphur oxide. The gases can cause acid rain and trigger respiratory diseases. Therefore, the tolerant of sulphur oxide emissions has been tightened progressively throughout the past decade.

Also known as “IMO 2020 fuel sulphur regulation”, IMO 2020 is an initiative from the IMO which aims to reduce sulphur oxide emissions from ships.

By the deadline of January 1, 2020, all carriers will have to comply with the new regulation, which imposes a 0.5% global sulphur cap on fuel content and replaces the current limit of 3.5%.

Source: dachser


The main type of “bunker” oil for ships is heavy fuel oil, derived as a residue from crude oil distillation. Crude oil contains sulphur which, following combustion in the engine, ends up in ship emissions. Sulphur oxides (SOx) are known to be harmful to human health, causing respiratory symptoms and lung disease. In the atmosphere, SOx can lead to acid rain, which can harm crops, forests and aquatic species, and contributes to the acidification of the oceans.

Limiting SOemissions from ships will improve air quality and protects the environment.

IMO regulations to reduce sulphur oxides (SOx) emissions from ships first came into force in 2005, under Annex VI of the International Convention for the Prevention of Pollution from Ships (known as the MARPOL Convention). Since then, the limits on sulphur oxides have been progressively tightened.

From 1 January 2020, the limit for sulphur in fuel oil used on board ships operating outside designated emission control areas is reduced to 0.50% m/m (mass by mass). This will significantly reduce the amount of sulphur oxides emanating from ships and should have major health and environmental benefits for the world, particularly for populations living close to ports and coasts.

Below you will find answers to some of the frequently asked questions about the sulphur limit.

Watch the video: IMO 2020 – cleaner shipping for cleaner air (1.27 minutes)

IMO 2020 – five key changes

 

Limiting SOx emissions from ships will have a very positive impact on human health: how does that work?

Simply put, limiting sulphur oxides emissions from ships reduces air pollution and results in a cleaner environment. Reducing SOx also reduces particulate matter, tiny harmful particles which form when fuel is burnt.

study on the human health impacts of SOx emissions from ships, submitted to IMO’s Marine Environment Protection Committee (MEPC) in 2016 by Finland, estimated that by not reducing the SOx limit for ships from 2020, the air pollution from ships would contribute to more than 570,000 additional premature deaths worldwide between 2020-2025.

SOx graphic.JPG sox 2.JPG

So a reduction in the limit for sulphur in fuel oil used on board ships will have tangible health benefits, particularly for populations living close to ports and major shipping routes.

IMO 2020 – A Breath of Fresh Air – download the infographic (PDF) by clicking on the image.

Why are ships already less harmful than other forms of transport?

​Ships do emit pollutants and other harmful emissions. But they also transport large quantities of vital goods across the world’s oceans – and seaborne trade continues to increase. In 2016, ships carried more than 10 billion tons of trade for the first time, according to UNCTAD.

So ships have always been the most sustainable way to transport commodities and goods. And ships increasingly becoming even more energy efficient. IMO regulations on energy efficiency support the demand for ever greener and cleaner shipping. A ship which is more energy efficient burns less fuel so emits less air pollution.

It has sometimes been quoted that just a few ships (all using fuel oil with maximum permitted sulphur content) emit as much harmful air pollutants as all the cars in the world (if the cars were all using the cleanest fuel available).

Not only is this the very worst case scenario, but this does not take into account the amount of cargo that is being carried by those ships and the relative efficiency. It is important to consider the amount of cargo carried and the emissions per tonne of cargo carried, per kilometre travelled. Studies have shown that ships are by far the most energy-efficient form of transportation, compared with other modes such as aviation, road trucks and even railways.

It is also relevant to remember that shipping responds to the demands of world trade. As world trade increases, more ship capacity will be needed.

Do small ships have to comply with the sulphur limit from 2020?

​Yes, the MARPOL regulations apply to all ships. Only larger ships of 400 gross tonnage and above engaged in voyages to ports or offshore terminals under the jurisdiction of other Parties have to have an International Air Pollution Prevention Certificate, issued by the ship’s flag State. But all sizes of ships will need to use fuel oil that meets the 0.50% limit from 1 January 2020.

Some smaller ships may already be using fuel oil that meets the limit, such as a marine distillate suitable for their engines. (Small ships operating in the already-designated emission control areas will be using fuel oil that meets the 0.10% limit in those emission control areas.)

How can ships carry so much cargo so efficiently?

Ships are the largest machines on the planet and the world’s largest diesel engines can be found on cargo ships. These engines can be as tall as a four-storey house, and as wide as three London buses. The largest marine diesel engines have more than 100,000 horsepower (in comparison, a mid-sized car may have up to 300 horsepower). But the largest container ships can carry more than 20,000 containers and the biggest bulk carriers can carry more than 300,000 tons of commodities, like iron ore.
So powerful engines are needed to propel a ship through the sea. And it is important to consider how much energy is used to carry each ton of cargo per kilometre.  When you look at the relative energy efficiency of different modes of transport, ships are by far the most energy efficient.
Ships can reduce air pollutants by being even more energy efficient, so they burn less fuel and therefore their emissions are lower.

Does the sulphur limit apply only to ships on international voyages?

​The sulphur oxides regulation (MARPOL Annex VI, regulation 14) applies to all ships, whether they are on international voyages, between two or more countries;  or domestic voyages, solely within the waters of a Party to the MARPOL Annex.

What was the regulation on SOx in ships emissions and by how much has it improved?

​We have seen a substantial cut: to 0.50% m/m (mass by mass) from 3.50% m/m.

For ships operating outside designated emission control areas the previous limit for sulphur content of ships’ fuel oil was 3.50% m/m.

The limit is now 0.50% m/m, since1 January 2020.

There is an even stricter limit of 0.10% m/m in effect in emission control areas (ECAS) which have been established by IMO. This 0.10% m/m limit applies in the four established ECAS: the Baltic Sea area; the North Sea area; the North American area (covering designated coastal areas off the United States and Canada); and the United States Caribbean Sea area (around Puerto Rico and the United States Virgin Islands).

(Countries bordering the Mediterranean Sea are currently considering the possibility of applying to designate the Mediterranean Sea or parts thereof as an ECA. Read more here.)

Fuel oil providers supply fuel oil which meets the 0.10% m/m limit (such as marine distillate and ultra low sulphur fuel oil blends) to ships which require this fuel to trade in the ECAs.

What must ships do to meet the new IMO regulations?

The IMO MARPOL regulations limit the sulphur content in fuel oil. So ships need to use fuel oil which is inherently low enough in sulphur, in order to meet IMO requirements.

Refineries may blend fuel oil with a high (non-compliant) sulphur content with fuel oil with a sulphur content lower than the required sulphur content to achieve a compliant fuel oil. Additives may be added to enhance other properties, such as lubricity.

Some ships limit the air pollutants by installing exhaust gas cleaning systems, also known as “scrubbers”. This is accepted by flag States as an alternative means to meet the sulphur limit requirement. These scrubbers are designed to remove sulphur oxides from the ship’s engine and boiler exhaust gases. So a ship fitted with a scrubber can use heavy fuel oil, since the sulphur oxides emissions will be reduced to a level equivalent to the required fuel oil sulphur limit.

Ships can have engines which can use different fuels, which may contain low or zero sulphur. For example, liquefied natural gas, or biofuels.

Are all types of scrubbers allowed under IMO rules?

​Yes, so long as they achieve the same level of emissions reduction.

Regulation 4 of MARPOL Annex VI allows for Administrations (flag States) to approve “equivalents” – any  “fitting, material, appliance or apparatus to be fitted in a ship or other procedures, alternative fuel oils, or compliance methods used as an alternative to that required”  – that enables the same standards of emission control to be met.

For reduction of sulphur oxide emissions, some flag States have accepted and approved scrubbers – otherwise known as “Exhaust Gas Cleaning Systems”, as meeting the requirements for sulphur oxide reduction.

There is an important requirement in the same regulation on Equivalents, which says that in paragraph 4 “The Administration of a Party that allows the use of an equivalent …. shall endeavour not to impair or damage its environment, human health, property, or resources, or those of other States”.

IMO has adopted strict criteria for discharge of washwater from EGCS. Any residues, where generated by the EGC unit usually in a closed-loop configuration, should be delivered ashore to adequate reception facilities. Such residues should not be discharged to the sea or incinerated on board.

Open-loop scrubbers add water to the exhaust gas which turns sulphur oxides (SOx) to sulphates/sulphuric acid. Open-loop scrubbers return washwater to the sea. The washwater must meet strict criteria, so that discharge washwater should have a pH of no less than 6.5. There are also strict limits on discharge of PAHs (Polycyclic Aromatic Hydrocarbons) and nitrates.

The guidelines, with the washwater criteria, (last revised and adopted in 2015), have been under review in the IMO Sub-Committee on Pollution Prevention and Response (PPR). The Sub-Committee finalized its work on revising the 2015 Guidelines in February 2020 and they will be submitted to MEPC 75 for adoption.

The Marine Environment Protection committee (MEPC) at its session in May 2019 asked the PPR Sub-Committee to look into “Evaluation and harmonization of rules and guidance on the discharge of liquid effluents from EGCS into waters, including conditions and areas”.

To assist the discussions, a report from a task team established by the Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) was submitted. This report contains the conclusions of the task team in relation to the available evidence on the environmental effects of discharge water from EGCS, as well as recommendations on the data, tools and approaches that could be used as basis for conducting a risk assessment of the possible effects of discharges.

Following discussion in a working group, the PPR Sub-Committee (February 2020) agreed to recommend to the MEPC that its future work should look at evaluation and harmonization of rules and guidance on the discharge of discharge water from EGCS into the aquatic environment, including conditions and areas.

The scope of the work should include:

  • risk assessment (development of risk assessment guidelines for the evaluation of possible harmful effects of the discharge water from EGCS, taking into account existing methods and mathematical models);
  • impact assessment (to consider developing impact assessment guidelines);
  • delivery of EGCS residues (developing guidance on delivery of EGCS residues to port reception facilities, regarding volumes and composition of residues);
  • regulatory matters (including assessing state of technology for EGCS discharge water treatment and control, identifying possible regulatory measures, developing a database of local/regional restrictions/conditions on the discharge water from EGCS;
  • database of substances (establishing a database of substances identified in EGCS discharge water, covering physico-chemical data, ecotoxicological data and toxicological data, leading to relevant endpoints for risk assessment purposes).

The MEPC was invited to approve the planned scope of work and to consider involving GESAMP for scientific advice.

Why have some ports already banned discharge of washwater?

​Some IMO Member States have taken a precautionary approach towards washwater discharge and have taken measures to limit or restrict discharge of washwater in their local ports and coastlines.

States have the right under UNCLOS to adopt their own laws and measures to reduce and control pollution  of the marine environment from ships in their ports, internal waters and territorial seas.

Where can I find out which ships have EGCS or are using other equivalents?

​The IMO GISIS module on MARPOL annex VI includes a list of notifications received from IMO Member States in relation to Regulation 4.2 Equivalent compliance method. You can view the database here.

Consistent compliance with the 0.50% limit is vital. What is IMO doing about that?

​Monitoring, compliance and enforcement of the new limit falls to Governments and national authorities of Member States that are Parties to MARPOL Annex VI. Flag States (the State of registry of a ship) and port States have rights and responsibilities to enforce compliance. IMO has adopted 2019 Guidelines for port State control under MARPOL Annex VI Chapter 3 (download here).

IMO has worked with Member States as well as industry (including the shipping industry and the bunker supply and refining industry) to identify and mitigate transitional issues so that ships may meet the new requirement.

For example, developing guidance, developing standardised formats for reporting fuel oil non availability if a ship cannot obtain compliant fuel oil and considering verification and control issues.

The MEPC has issued guidance on ship implementation planning, part of a set of guidelines being developed by IMO for consistent implementation of the MARPOL regulation coming into effect from 1 January 2020.

Guidance on best practice for fuel oil suppliers has also been issued. The Guidance is intended to assist fuel oil purchasers and users in assuring the quality of fuel oil delivered to and used on board ships, with respect to both compliance with the MARPOL requirements and the safe and efficient operation of the ship. The guidance pertains to aspects of the fuel oil purchase up to the loading of the purchased fuel oil on board.

A full list of guidance and guidelines can be found on the infographic.

In October 2018, IMO’s Marine Environment Protection Committee (MEPC) adopted a MARPOL amendment to prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship – unless the ship has an exhaust gas cleaning system (“scrubber”) fitted.

How have ship operators and owners planned ahead for the 0.50% sulphur 2020 limit?

​To assist ship operators and owners to plan ahead for the 0.50% sulphur 2020 limit, the MEPC approved various guidance and guidelines.

The 2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI adopted by resolution MEPC.320(74) are available here.

These comprehensive guidelines include a template for a “Fuel Oil Non-Availability Report (FONAR)” set out in Appendix 1 and a “Technical review of identified possible potential safety implications associated with the use of 2020 compliant fuels” set out in appendix 2.

Guidance on ship implementation planning (issued November 2018) can be downloaded here.

The ship implementation planning guidance includes sections on: risk assessment and mitigation plan (impact of new fuels); fuel oil system modifications and tank cleaning (if needed); fuel oil capacity and segregation capability; procurement of compliant fuel; fuel oil changeover plan (conventional residual fuel oils to 0.50% sulphur compliant fuel oil); and documentation and reporting.

See also outcome of MEPC 74 here.  A joint industry group has also developed its own guidance, which IMO has shared with its Member States and international organizations in a circular letter. You can view the Joint Industry Guidance on the Supply and Use of 0.50% Sulphur Marine Fuel here.

What is the “carriage ban” and how does it work?

​The carriage ban refers to the MARPOL amendment adopted in 2018 to prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship – unless the ship has an exhaust gas cleaning system (“scrubber”) fitted.

The amendment is intended as an additional measure to support consistent implementation and compliance and provide a means for effective enforcement by States, particularly port State control.

The specific provision requires that fuel oil used on board ships shall not exceed 0.50% sulphur limit. The amended provision to prohibit the carriage of non-compliant fuel oil reads as follows: “The sulphur content of fuel oil used or carried for use on board a ship shall not exceed 0.50% m/m.”

So, carriage of fuel oil for use on board ships has been prohibited since 1 March 2020  – if the sulphur content exceeds 0.50%.

Regulation 2.9 of MARPOL Annex VI provides the definition for ‘fuel oil’ – “Fuel oil means any fuel delivered to and intended for combustion purposes for propulsion or operation on board a ship, including gas, distillate and residual fuels.”

The provision does not apply to fuel oil being carried as cargo.

This MARPOL amendment will enter into force on 1 March 2020. The full text of the MARPOL amendment can be downloaded here. 

Is a FONAR a waiver?

​No.

The 2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI adopted by resolution MEPC.320(74) here clearly states (in APPENDIX 1):
“3.1 A fuel oil non-availability report is not an exemption. According to regulation 18.2 of MARPOL Annex VI, it is the responsibility of the Party of the destination port, through its competent authority, to scrutinize the information provided and take action, as appropriate.””3.2 In the case of insufficiently supported and/or repeated claims of non-availability, the Party may require additional documentation and substantiation of fuel oil non-availability claims. The ship/operator may also be subject to more extensive inspections or examinations while in port.”

“3.3 Ships/operators are expected to take into account logistical conditions and/or terminal/port policies when planning bunkering, including but not limited to having to change berth or anchor within a port or terminal in order to obtain compliant fuel.”

“3.4 Ships/operators are expected to prepare as far as reasonably practicable to be able to operate on compliant fuel oils. This could include, but is not limited to, fuel oils with different viscosity and different sulphur content not exceeding regulatory requirements (requiring different lube oils) as well as requiring heating and/or other treatment on board.”

Are new fuels being used to meet the 2020 limit?

Yes, new blends of fuel oil for ships have been developed. For example, a gas oil, with a very low sulphur content can be blended with heavy fuel oil to lower its sulphur content. ​

Ships can also choose to switch to a different fuel altogether. Or they may continue to purchase heavy fuel oil, but install ”scrubbers” to reduce the output of SOx in order to have an equivalent means to meet the requirement.

Of course, some ships were already using low sulphur fuel oil to meet the even more stringent limits of 0.10% m/m when trading in the established emission control areas. So those fuel oil blends suitable for ECAS,  also meet the 0.50% m/m limit in 2020.

A study commissioned by IMO into the “Assessment of fuel oil availability” concluded that the refinery sector has the capability to supply sufficient quantities of marine fuels with a sulphur content of 0.50% m/m or less and with a sulphur content of 0.10% m/m or less to meet demand for these products, while also meeting demand for non-marine fuels. The full study can be downloaded here.

Are low sulphur blend fuel oils safe? Can new low sulphur fuels cause problems for a ship’s engine?

​All fuel oil for combustion purposes on a ship must meet required fuel oil quality standards, as set out in IMO MARPOL Annex VI (regulation 18.3). For example, the fuel oil must not include any added substance or chemical waste that jeopardizes the safety of ships or adversely affects the performance of the machinery.

IMO has discussed how to identify any potential safety issues related to new blends of fuel oil as it is recognized that if these fuels are not managed appropriately, there could be compatibility and stability issues. Guidance on best practice for fuel oil suppliers has also been issued. The Guidance is intended to assist fuel oil purchasers and users in assuring the quality of fuel oil delivered to and used on board ships, with respect to both compliance with the MARPOL requirements and the safe and efficient operation of the ship. The guidance pertains to aspects of the fuel oil purchase up to the loading of the purchased fuel oil on board.

An International Standardization Organization (ISO) standard (ISO 8217) specifies the requirements for fuels for use in marine diesel engines and boilers.

ISO has issued a further standard: ISO/PAS 23263:2019 Petroleum products – Fuels (class F) – Considerations for fuel suppliers and users regarding marine fuel quality in view of the implementation of maximum 0.50 % sulphur in 2020. It addresses quality considerations that apply to marine fuels in view of the implementation of the sulphur 2020 limit and the range of marine fuels that will be placed on the market in response. It defines general requirements that apply to all 0.50% sulphur fuels and confirms the applicability of ISO 8217 for those fuels. It gives technical considerations which might apply to particular fuels for the following characteristics: kinematic viscosity; cold flow properties; stability; ignition characteristics; and catalyst fines. Additionally, it provides considerations on the compatibility between fuels and gives additional information on ISO 8217.

Source: imo.org


The Chinese authorities have caught two vessels for low sulphur fuel violations, the first reported cases of breaches of IMO 2020.

The Standard Club said that the first vessel was in Qingdao when it underwent a Port State Control (PSC) inspection by the Chinese Maritime Safety Administration (MSA) and was found to be using fuel with a sulphur content of 0.6777% mm.

The second vessel was in Xiamen and found by the MSA to be using non-compliant fuel having been at a berth for six days after changing to compliant fuel.

However, it is likely that previous high sulphur fuel residue remained in the engine fuel system resulting in emissions over the China ECA limit. The ship was ordered to take effective measures to purify the fuel system.

The P&I insurer said it was unclear whether the Chinese authorities would fine the vessels involved. They can be fined no less than RMB10,000 ($1,445) up to a maximum of RMB100,000 under Chinese regulations.

The violations are the first reported since the 0.5% cap on sulphur for marine fuel came into force on 1 January, with the transition appearing to have been relatively smooth so far.

Read: IMO 2020 – A smooth transition?


The Just In Time Arrival Guide has been developed by the Global Industry Alliance (GIA) to support low carbon shipping, based on research and discussion amongst its membership, the International Maritime Organization (IMO) said.

As explained, the guide documents the findings of a series of industry roundtables which brought together nearly 50 companies and organizations who are key stakeholders in the port call process.

Widely recognized as a means of increasing port efficiency and port call optimization, the successful implementation of JIT Arrivals can have a significant environmental impact through reduced greenhouse gas (GHG) emissions from optimizing the ships’ speed to arrive just in time. The concept is based on the ship maintaining an optimal operating speed, to arrive at the pilot boarding place when the availability is assured of: 1. berth; 2. fairway; and 3. nautical services.

The JIT Arrivals concept is also said to contribute to reduced time at anchorage and therefore reduced congestion in the port area. It is estimated that ships spend up to 9 per cent of their time waiting at anchorage, which could be reduced through the implementation of JIT Arrivals.

The guide is said to provide “a holistic approach” to Just In Time Arrivals, considering contractual aspects to its implementation as well as operational. It is envisaged as a useful toolkit for many stakeholders including shipowners, ship operators, charterers, ship agents, shipbrokers, port authorities, terminals, nautical and vessel service providers. All these actors ultimately play a key role in implementing the necessary changes and facilitating the exchange of communication required to realize JIT Arrivals.

The Low Carbon GIA is a public–private partnership with the aim to identify and develop innovative solutions to address common barriers to the uptake and implementation of energy efficiency technologies and operational measures.

The Low Carbon GIA was originally established under the framework of the GEF-UNDP-IMO Global Maritime Energy Efficiency Partnerships Project (GloMEEP Project), and since the conclusion of the GloMEEP Project at the end of 2019, the Low Carbon GIA has been operating under the framework of the IMO-Norway GreenVoyage2050 Project.

Source: offshore-energy


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