The Naval Architect: September 2017
The looming implementation date of D-2 standard of the Ballast Water Management (BWM) Convention, which becomes effective from 8 September 2017, has been an ongoing cause of angst for shipowners. In March’s The Naval Architect we reported on the confusion surrounding the time frame for implementation of the Convention, particularly with regard to vessels built (keel laid) before the effective date.
So while the outcome was not entirely a surprise, many will be relieved that MEPC 71 saw the approval of a revised implementation schedule for BWM compliance, with its adoption at MEPC 72 next year thought to be a formality.
As expected, vessels built after the effective date will need to comply with the D-2 standard immediately, but a more pragmatic timeline has been determined for existing ships. These will have to meet the requirements by the following deadlines:
- The first MARPOL IOPP survey on or after 8 September 2019, if it has been surveyed in the
three years leading up to 8 September 2017
- The second IOPP survey after 8 September 2017, if its first survey is due in the two years prior to
8 September 2019
In other words, shipowners have a minimum of two years to ensure their vessel is D-2 compliant but could have as long as seven years; the final cut-off date by which all vessels must have a system installed being 8 September 2024 (the latter deadline also applies to vessels not subject to IOPP renewal).
Unsurprisingly, while shipowners welcomed what might be perceived as a stay of execution, it has drawn a more mixed response from ballast treatment system manufacturers, many of whom may have a further wait before any retrofit windfall, and the very real possibility that for many vessels already in service — such as bulkers — scrapping will be deemed a more cost-effective option.
However, Tom Perlich, founder and president of BWTS specialists Ecochlor said the delays agreed at MEPC 71 were widely expected in the industry. He adds that in the case of Ecochlor the different ballast system standards applied by the US Coastguard (USCG) mean it’s unlikely to impact upon business: “A majority of shipowners in midsize to large bulkers and tankers have routes in United States waters and they are Ecochlor’s primary market. Therefore, because the USCG regulations are currently in place, and having now received USCG Type Approval, we are expecting to be very busy through to the end of 2017 and beyond.”
During MEPC 70 in 2016, the Committee adopted the BWMS Code, which formalised the G8 guidelines for approval of ballast systems. Ballast system manufacturers will now need to carry out their testing in accordance with the revised G8 standards no later than October 2018 (in reality of course most will already be doing so), with the compliance of vessels coming into effect two years after that date. However, shipowners who installed systems compliant with the earlier standard will not be penalised.
IMO has also said that there will be a three-year “experience building” phase beginning from September 2017. This is partly an act of clemency towards those shipowners who adopted the earlier ballast systems who will be allowed to continue using them providing they are maintained in operable condition (even if they can’t demonstrate biological efficacy). A recent report published by classification society ABS revealed that in a survey of shipowners and operators, only 57% of ballast systems were being operated, the rest being deemed ‘inoperable’ or ‘problematic’.
The experience building phase also allows for a period of data gathering, analysis and operational implications related to ballast systems. “The data gathering is intended to let us know how we’re doing with respect to how many vessels have installed systems and how many have been put into commission and whether the experiences are favourable or not,” explains Thomas Kirk, ABS’s director of Environmental Performance, who attended MEPC 71. “That information will be submitted by the flag to IMO who will provide data analysis. At the end we will revisit the Convention and see if there’s anything that needs to be changed, with respect to the code, the testing standards or inherent problems with given technologies and manufacturers.”
There remains confusion about the different standards set by the IMO and the USCG, but Kirk stresses that they are, loosely speaking, equivalent to each other. “The big difference with US protocol [which is enshrined in law] is the rules are felt to be more transparent and rigorous. When the G8 guidelines were revisited in 2016 they were informed by the US regulation but don’t necessarily comply with each other. The important thing is manufacturers should be testing with both protocols in mind with a view to certification to both standards.”
Air pollution and energy efficiency
In January this year, the fourth meeting of IMO’s Pollution Prevention and Response (PPR) sub-committee made specific recommendations for consideration at MEPC. Of these, the MEPC adopted amendments to the guidelines on selective catalytic reduction (SCR) systems but decided that proposals to amend MARPOL Annex VI and the NOx Technical Code to address multiple engine operation profiles – e.g. the electronic programming of engines to optimise fuel consumption in different operating modes — required further consideration.
MEPC further adopted the introduction of NOx Tier III (equivalent to an 80% reduction of NOx) emission control areas (ECAs) in the Baltic and North Sea regions, which will enter effect from January 2021. This means that new vessels operating in this region will be subject to the same standards already enforced in the North America and Caribbean ECAs since 2016. Temporary exemption will be granted to a vessel constructed in one ECA to allow it transit out of that region, or if it’s intended to come into an ECA for repairs.
Another matter of strong interest to shipowners will be the implementation of the global 0.5% sulphur limit (MARPOL VI reg. 14.1.3). A work programme has been tasked with ensuring what Kirk describes as “a level playing field” to ensure compliance in international waters. Its remit includes developing a standard format for reporting when low-sulphur-compliant fuel is not available and guidance that will help owners and operators be confident the sulphur content of delivered fuel is the same as that stated on the bunker delivery note. Given that fuels may be blended or hybrid, the International Organisation for Standardisation (ISO) has been requested to consider the framework of the ISO 8217 standard (which covers bunker fuel testing and compliance) with a view to establishing some consistency.
An ongoing concern the MEPC addressed was the ability of ro-ro vessels – both cargo and passenger – to meet the requirements of the Energy Efficiency Design Index Phase 2, given the limitations in achieving the necessary physical properties for these ship types. Therefore, MEPC has approved amendments to Regulation 21 of MARPOL Annex VI that will allow for a 20% offset to the EEDI baseline which will compensate for the discrepancies in the current calculations.
EEDI is essentially a ratio of the CO2 emitted by a vessel divided by the transportation work carried out (i.e. it’s directly related to the quantity of fuel consumed) and this consumption can be reduced by improving an engine’s efficiency or reducing its power. Determining the minimum propulsion power needed for adverse weather conditions was set out in Interim Guidelines in 2013 (MEPC. 232(65)) and it’s now likely that they will be extended to cover EEDI Phase 2 as the committee still feels they are not suitable for finalisation. Kirk explains: “Those discussions are continuing and we hope that by moving to more efficient vessels we’re never putting the crew at risk.”
Although there remain doubts to the efficacy of EEDI, IMO remains committed to the process and is considering both bringing forward the Phase 3 implementation date from 2025 to 2022 and whether there could be an additional Phase 4.
One area where less progress has been made is the development of a comprehensive IMO strategy on the reduction of GHG emissions in line with the Paris COP21 Agreement on climate change. However, MEPC noted a report from the Intersessional Working Group on Reduction of GHG Emissions which includes a draft outline for IMO’s initial strategy, its key points being:
- Context, including emission scenarios
- Levels of ambition /Guiding principles
- List of candidate short-, mid- and long-term further measures with possible timelines and their impacts on States
- Barriers and supportive measures; capacity building and technical cooperation; R&D
- Follow-up actions towards the development of the revised strategy
- Periodic review of the strategy
A three-stage approach is proposed, the first of which would be a comprehensive data collection system for fuel oil consumption. This would be followed by a period of analysis of that data before deciding what further measures may be necessary. The working group is scheduled to convene again in October and adoption is now being mooted for MEPC 72 in April 2018, but won’t now be entirely finalised before 2023.
For some, such as NGO Transport & Environment (T&E), it remains an ongoing source of frustration. Bill Hemmings, T&E’s shipping director, reflects: “Disagreement over how to distribute efforts and the potential costs of measures remain the biggest obstacle to progress.” He adds that given the IMO’s continued prevarications, alternative measures for cutting GHGs in shipping, such as the EU’s emissions trading system (ETS), must remain a viable option.
Nevertheless, other lobby groups are more optimistic. Patrick Verhoeven, secretary general of the European Community Shipping Association (ECSA) believes IMO can now deliver an “ambitious strategy”, adding that ECSA members are strongly committed to decarbonisation. “We are prepared to play our part in limiting greenhouse gas emissions and we were pleased to see there was a general willingness among governments to commit to developing a strategy as well,” he says.