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Black Sea Law Company is the organizer of the must-attended global maritime event which takes place in Odessa, Ukraine.

It is a very useful and reliable professional networking platform for Ukrainian Shipping, Financial and Trading business. IMIS is the place where you can meet necessary for you people from all over the world, but IMIS is focused on the representation of the Ukrainian business for international services: legal and insurance.

It should be noted that the Odessa region has one of the highest levels of economic development of Ukraine and the Odessa city is the “Maritime Capital” of Ukraine.

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IMO 2020

Everything you need to know about ship fuel supply in 2020 The importance of protecting the environment from the effects of human activities has become the trend of the outgoing year. However, the shipping industry anticipated a trend for environmental standards rise, as from January 1, 2020, new standards for the sulfur content in fuel […]

Everything you need to know about ship fuel supply in 2020

The importance of protecting the environment from the effects of human activities has become the trend of the outgoing year. However, the shipping industry anticipated a trend for environmental standards rise, as from January 1, 2020, new standards for the sulfur content in fuel are applied, which were approved long before the environmental movement was popularized.

Ukraine is a party to the International Convention for the Prevention of Pollution from Ships (“MARPOL”). MARPOL entered into force for Ukraine in 1994. On June 24, 2009, the Cabinet of Ministers of Ukraine adopted Resolution No. 631 on accession to the 1997 Protocol. This MARPOL Protocol is supplemented by Appendix VI “Regulations for the Prevention of Air Pollution from Ships”. Thus, Ukraine has been familiar with international requirements to limit emissions from ships since it joined the 1997 Protocol. The requirements set out in the original version of Appendix VI were not sufficient to ensure a clean atmosphere.

On October 10, 2008, the International Maritime Organization (“IMO”) adopted Resolution MEPC.176 (58) on Amendments to the Annex of the 1997 Protocol, which amended the International Convention for the Prevention of Pollution from Ships, 1973, in accordance with paragraph 16 (2 ) (f) (iii) of the Convention. The above mentioned refer to MARPOL article 16 on amendments. According to article 16, paragraph (2) of the Amendment after consideration by the Organization: (f) an amendment shall be deemed to have been accepted in the following circumstances: (iii) an amendment to an Annex to the Convention shall be deemed to have been accepted at the end of a period to be determined by the appropriate body at the time of its adoption, which period shall be not less than ten months, unless within that period an objection is communicated to the Organization by not less than one-third of the Parties or by the Parties the combined merchant fleets of which constitute not less than fifty per cent of the gross tonnage of the world’s merchant fleet whichever condition is fulfilled.

According to the text of Resolution MEPC.176 (58), the above period was set until January 01, 2010. Thus, after the specified period has passed, amendments to Appendix VI “Regulations for the Prevention of Air Pollution from Ships” are adopted. The greatest resonance was caused by a change in the boundary standards for the sulfur content in the fuel used on ships. Regulation 14 of Annex VI establishes that the sulfur content of any fuel used on board a ship must not exceed the following limits:

– 4.50% m/m until January 01, 2012;

– 3.50% m/m as of and after January 01 2012;

– 0.50% m/m as of and after January 01 2020.

Thus, from the deadline, participants of the international shipping market are required to make sure that the vessel is provided with fuel of good quality with low sulfur content. It should be noted that Annex VI exclusively sets the boundary standards and defines the features of the application of such standards, but in no case does it concern sanctions for non-compliance with such standards. The decision to increase the standards for marine fuel requirements was preceded by lengthy preparation and discussion. The International Maritime Organization has considered the possibility of postponing the implementation of a toughened limit on sulfur content until January 01 2025 if the international community is not ready to meet the market demands for low sulfur fuel.

The maritime industry has formed a sufficient number of options for proper compliance with standards starting January 01 2020.

The party responsible for the fuel supply must ensure that all supplied fuel meets the sulfur requirements in accordance with Regulation 14, for compliance purposes, fuel means means any fuel delivered to and intended for combustion purposes for propulsion or operation on board a ship, including distillate and residual fuels. According to the Annex VI interpretation, fuel compliance must be proven and guaranteed by the supplier.

The ISO 8217: 20176 standard is used to ensure that the properties of the fuel that is supplied are consistent with the standard, which means that they comply with MARPOL Annex VI. The existing ISO 8217: 20176 standard for marine fuel takes into account the diverse nature of marine fuel and includes a number of categories, although not all categories may be available at each point of delivery.

It should be borne in mind that the purchase of appropriate fuel is not the only way to reduce emissions from the ship.

Regulation 4 of Annex VI stipulates, that the Administration of a Party may allow 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 by this Annex if such fitting, material, appliance or apparatus or other procedures, alternative fuel oils, or compliance methods are at least as effective in terms of emissions reductions as that required by this Annex, including any of the standards set forth in regulations 13 and 14.

Thus, shipowners are given the opportunity to use alternative methods aimed at reducing emissions of pollutants into the atmosphere.

Guided by international practice, the use of a fuel with an excess sulfur content in the case of using a scrubber on the vessel, namely, a device for cleaning gases from impurities, may be allowed. Based on their work, marine scrubbers can be divided into “wet” and “dry” scrubbers. “Dry” scrubbers use hard lime as an alkaline cleaning material that removes sulfur dioxide from exhaust gases. “Wet” scrubbers use water that is sprayed into the exhaust fumes for the same purpose.

“Wet” scrubbers are further subdivided into closed or open loop scrubbers. In closed loop scrubbers, fresh or sea water can be used as a cleaning fluid. When fresh water is used in closed loop scrubbers, the quality of the water surrounding the vessel does not affect the performance and emissions of the scrubber wastewater. Open loop scrubbers consume seawater during the cleaning process. Hybrid scrubbers can use both indoor and outdoor operating modes either simultaneously or by switching between them. Hybrid scrubbers with sea water can work both indoors and outdoors, and seawater is used as a flushing medium.

The most controversial is the use of scrubbers with an open loop, since as a result of their work, the water that was used for cleaning is discharged. The system is extremely efficient, but requires a large capacity, since the required amount of sea water is quite large. An open loop system works quite satisfactorily when the seawater used for purification has sufficient alkalinity. However, seawater with a high ambient temperature, fresh and even brackish water is inefficient and cannot be used. An open circuit scrubber for these reasons is not considered a suitable technology for areas such as the Baltic, where salinity levels are not high.

The fact of water discharge can be qualified by local regulatory authorities as a fact of pollution of the water area. Thus, the use of open loop scrubbers in territorial and inland waters is associated with high risks for the shipowner. Many countries have already managed to impose bans or restrictions on the use of open loop scrubbers in territorial waters. Despite the fact that the influence of the work of such scrubbers on the cleanliness of the water area has not been fully studied, certain states have adopted a policy to prevent possible pollution.

The European Commission’s 2016 note on discharge of scrubber washwater, bans the discharge in ports and inland waters. China’s Ministry of Transport issued its ‘Notice on Regulating the Implementation of Supervision and Management of Ship Air Pollutant Emission Control Areas’ which states that from 1 January 2019 discharge of washwater from scrubbers is prohibited in the county’s inland waters and Bohai Bay waters. Discharge is prohibited in Singapore port waters from 1 January 2020. The official statement advises ships fitted with open loop scrubbers to “carry out the switch to either closed-loop mode or to compliant fuel well in advance of the vessel’s arrival at the port waters”. The Irish authorities’ Notice № 37 of 2018 “Prohibition on the Discharge of Exhaust Gas Scrubber Wash Water” stipulates that discharge of washwater is prohibited in waters under Dublin port jurisdiction. Under the amendments of 1 March 2019 to Regulation № 488 on the environmental safety of ships and mobile offshore units, use of open loop scrubbers is prohibited in the Norwegian fjords.

Thus, in addition to the general requirements of MARPOL, shipowners must also take into account local legislative changes, which were entailed by toughening requirements for the sulfur content in fuel.

Shipowners also have the right to use liquefied natural gas (LNG) as fuel that complies with MARPOL requirements. It is considered the cleanest fuel, producing 30% less carbon dioxide than fuel oil, and 45% less than coal. Its environmental impact is also considered excellent because when it spills on land or water, it is said to evaporate quickly and leave no residue, essentially claiming it does not pollute waterways.

The vessel issues a “Fuel Oil Non-Availability Report” (FONAR), which is an approval for the continuous use of non-compliant fuels with a sulfur content of more than 0.5%, issued on the basis that there is not enough available fuel in which the sulfur content is below 0 5%, which is a way to avoid regulation. To prevent abuse of this right, the IMO committee issued a guideline requiring the vessel to provide detailed documentation for the release of the “Fuel Oil Non-Availability Report” (FONAR) to explain why it has fuel that exceeds the limits established by IMO 2020. The vessel must provide evidence that that every effort has been made to obtain the appropriate fuel.

Thanks to the vigorous activity of the International Maritime Organization, the shipping industry entered into 2020 with new changes that would clearly entail a trend towards switching to LNG fuel, developing more efficient refineries, and conducting a detailed assessment of the environmental impact of the voyage.

IRINA DOLYA
Associate

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