How Will Marine Air Emissions Changes Affect Shippers?

MARPOL Annex VI has endured regular change since its introduction in 2005. At that time instead of Emission Control Areas there were only Sulphur Emission Control Area (SECAs), which purely monitored Sulphur Oxide emissions (set at a limit of 1.5% in fuels in SECAs) with no restrictions on Nitrogen Oxide (NOx) and particulate matter (PM ) emissions.

The International Maritime Organization (IMO) updated these laws in 2010 to ensure that ECAs monitored emissions of all three types of emissions (SOx, NOx and PM). At the same time SOx emissions were further reduced to a limit of 1.0% in fuels within ECAs.

This has reflected a phased reduction of SOx emissions in ECAs which will see the Suplur Oxide content in fuel reduced to 0.1% in January 2015, just 10% of the current limits.

These changes are brought into effect with a view to having a beneficial impact on the environment.

In particular the restrictions around SOx emissions are aimed at improving the health of people, especially those who reside in port or coastal areas.

Unlike other pollutants such as NOx which can be emitted as a result of engine design, operation and combustion conditions, SOx emissions are almost exclusively a result of the Sulphur content in a ship’s fuel.

In the port of Rotterdam in 2013, marine fuel bunker statistics showed that the price of low Sulphur marine fuel was roughly $960 per metric ton, where its high Sulphur counterpart cost approximately $611 per metric ton.

Although marine fuel prices are highly volatile this does indicate that making the switch to a marine fuel with a low Sulphur content will prove costly for many shipping companies.

An alternative to using low Sulphur fuel which is also permitted by the IMO is to use exhaust gas cleaning systems also known as EGCSs or scrubbers.

The use of on-ship scrubbers is a potentially cost saving solution as ships can still continue to use cheaper Sulphur heavy fuels whilst complying with Sulphur Oxide emissions.

A study by Reynolds in 2011 suggested that any ship which annually uses more than 4000 metric tons of fuel in an ECA should potentially have a scrubber installed on board.

Monitoring compliance of these laws is understandably difficult given the large ECAs that ships travel in and need monitoring.

There are generally two ways in which ships can ensure compliance with MARPOL Annex VI Regulation 14.

Scheme A for emissions monitoring is an initial inspection of the ship upon which the certificate of performance is issued, which is later surveyed periodically to confirm performance.

The alternative method, in broad terms, is a continuous emissions monitoring system which relies on parameter checks in order to confirm compliance with MARPOL Annex VI Regulation 14.

The choice between emission monitoring systems is typically made by the scrubber manufacturer as a part of their offer with the scrubber.

Ultimately the new changes to MARPOL Annex VI Regulation 14 look like they will have a positive impact on the environment and human health.

Although these changes may appear costly at first to shipping companies, alternatives such as scrubbers can keep costs and emissions down.