IMO FAQ ON SULFUR CAP OF 2020

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The IMO has launched a document answering frequently asked questions about the upcoming sulfur emissions regulations taking effect in 2020.

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IMO regulations to SOx emissions from ships first came into force in 2005, under Annex VI of the MARPOL Convention. Since then, the limits on sulfur oxides have been progressively tightened. From January 1, 2020, the limit for sulfur in fuel oil used on board ships operating outside designated emission control areas will be reduced to 0.50 percent m/m (mass by mass). This will significantly reduce the amount of sulfur oxides emanating from ships and should have major health and environmental benefits for the world, particularly for populations living close to ports and coasts, says the IMO.

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Answers to some frequently asked questions are:
 
Limiting SOx emissions from ships will have a very positive impact on human health: how does that work?

Simply put, limiting sulfur 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. 

A 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.   

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

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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 sulfur 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 kilometer traveled. 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.  

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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 kilometer. 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.    

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What is the current regulation on SOx in ships emissions, and by how much is that going to be improved?

We are going to see a substantial cut: to 0.50 percent m/m (mass by mass) from 3.50 percent m/m.

For ships operating outside designated emission control areas the current limit for sulfur content of ships’ fuel oil is 3.50 percent m/m.

The new limit will be 0.50 percent m/m which will apply on and after January 1, 2020.

There is an even stricter limit of 0.10 percent m/m already in effect in emission control areas (ECAS) which have been established by IMO. This 0.10 percent 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 U.S. and Canada); and the U.S. Caribbean Sea area (around Puerto Rico and the United States Virgin Islands).

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

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What must ships do to meet the new IMO regulations?

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

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 sulfur limit requirement.

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

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Could the 0.50 percent limit be delayed?

No. There can be no change in the January 1, 2020 implementation date, as it is too late now to amend the date and for any revised date to enter into force before January 1, 2020.
 
Will new fuels be needed to meet the 2020 limit? Will there be enough?

It is likely that new blends of fuel oil for ships will be developed, For example, a gas oil, with a very low sulfur content can be blended with heavy fuel oil to lower its sulfur content.

These new blends are likely to cost more initially than the heavy fuel oil bunker fuel used by the majority of ships today. 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 are already using low sulfur fuel oil to meet the even more stringent limits of 0.10 percent m/m when trading in the already-established emission control areas. So those fuel oil blends suitable for ECAS, will also meet the 0.50 percent m/m limit in 2020. However, there is a cost differential, and these blends are more expensive than heavy fuel oil.

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 sulfur content of 0.50% m/m or less and with a sulfur content of 0.10 percent m/m or less to meet demand for these products, while also meeting demand for non-marine fuels. 

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Consistent compliance with the new 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 and port States have rights and responsibilities to enforce compliance. 

IMO is working 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 standardized formats for reporting fuel oil non availability if a ship cannot obtain compliant fuel oil and considering verification and control issues.

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ABS ISSUES ADVISORY ON NEW FUELS AND 2020 GLOBAL SULFUR CAP

June 8, 2018

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ABS issued the ABS Advisory on Marine Fuel Oil to help industry prepare for the IMO’s 2020 global sulfur cap. The Advisory provides owners and operators with industry-leading guidance on the considerations and challenges with marine fuels, which are likely to be used in addressing the 2020 global sulfur cap requirements.

“The IMO 2020 sulfur cap requirement will introduce a significant demand change from heavy fuel to low sulfur fuel almost overnight. The industry currently is debating how to prepare as the consequences of this shift are difficult to predict,“ said Dr. Kirsi Tikka, ABS Executive Vice President and Senior Maritime Advisor. “The ABS Advisory addresses concerns about the safety impacts and quality of the new blended and hybrid fuels that are currently not covered by the ISO fuel standard, and provides guidance on fuel selection, modification considerations and operational challenges.”

In a recent informal poll of shipowners and operators conducted by ABS, 53 percent said their fleets were not yet ready to meet upcoming sulfur cap requirements. As the deadline for compliance approaches, it is vital that industry consider the available options and the impacts on their fleets. The ABS Advisory provides in-depth technical guidance covering a range of topics, from fuel properties to operational risks to potential preparations. Using this Advisory to understand the implications of different marine fuels, owners and operators can make smarter decisions on the future of their fleets.

The available options to comply with the global sulfur cap include exhaust gas cleaning, burning compliant fuel or alternative fuels. In 2010, ABS provided guidance on switching from heavy fuel to 0.1% sulfur fuel when entering Emission Control Areas. This Advisory has been widely used by the industry, and ABS has now updated this guidance to cover the regulation entering into force in January 2020.
The updated ABS Advisory includes background on air emission regulations and evaluates several relevant fuel types and the associated impacts and operational challenges for each.

ON "METHANE SLIP"

THE OFTEN-ASKED QUESTION ON "METHANE SLIP" 

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•    The methane slip is a side effect of low pressure concept, but engine technology (combustion chamber design, control of valve timing and fuel injection) can reduce it drastically.

•    Our engines offer a net reduction of CO2 emissions inclusive of methane slip which at design load can reach 25%.

•    NOx is a product of the internal combustion process itself, created from the air in the cylinder chamber by the temperatures and pressures of combustion. Engines emit NOx to varying degrees no matter what fuel is used. That is why many ships using natural gas as fuel also have catalytic NOx removal systems treating their exhaust gases. FORWARD wanted to control the engine’s NOx production so as to eliminate the need for exhaust treatment, but to do so they had to conquer the problem of ‘methane slip’ – the tendency of gas-fueled diesels to allow a small amount methane to leave the cylinder unburned, or ‘slip out’ into the exhaust. If you want to cut greenhouse gas emissions, you certainly don’t want methane slip. 

•    One traditional technical challenge to using gas a marine fuel has been an unavoidable trade-off between NOx production and methane slip, a problem that stems from a combination of thermodynamics and engine technology. Engines operate according to one of two thermodynamic cycles, Otto or Diesel. The Otto cycle – which is employed in automobile engines – is the lower-pressure of the two, and by nature generate very low NOx levels; the drawback to Otto engines when fueled by natural gas is that the generate methane slip. Diesel cycle engines, operating at higher temperatures and pressures, burn the entire charge of methane in the cylinder but generate far more NOx. The answer to this persistent problem was drawn from the engine itself.

•    We found the latest DF engine, which is much advanced over previous versions, gave us the possibility to adjust the methane slip. Through careful use of the technology in this new low-pressure system we were able to reduce the slip to very, very low levels, and achieve both objectives at once. And, once we identified the low-pressure system as the one closest to what we need, we developed the concept of two engines doing everything.

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For more information and the latest on this debatable subject, please check the study prepared  for SEA\LNG and SGMF by the company ThinkStep. You can download it here by registering your details or for the executive summary, please click on the report picture herein.  This study showed that on an engine technology basis, the absolute Well-to-Wake emissions reduction benefits for gas-fueled engines today compared with HFO fuelled ships are between 14% to 21% for 2-stroke slow speed engines, and between 7% to 15% for 4-stroke medium speed engines.  Data for the study was provided by the following Original Equipment Manufacturers: Catapillar, MaK, Caterpillar Solar Turbines, GE, MAN Energy Solutions, Rolls Royce (MTU), Winterthur Gas & Diesel, Wärtsilä.  The extensive industry experience and practical knowledge of the SEA\LNG-SGMF project oversight team ensured all the data used was the latest and best available. Forward Ships is a member of SGMF.