The new IMO regulation for the reduction of sulphur oxide emissions is history.
From January 1, 2020 use of fuels with content over 0.5% sulphur is not allowed (except for vessels equipped with scrubbers). There are serious concerns about the sufficient availability of compliant fuels for shipping to continue to operate undisturbed but also concerns about the continued availability of heavy fuel oil for the ships equipped with scrubbers (since oil majors will be supplying de-sulphurized heavy fuel oil). It is certain also that ship stoppages and engine damages will increase, since most of the offered fuel will be a blend of distillates and heavy oils at high distillate ratio, which is known to be problematic.
The logic and scientific basis for this regulation has been questioned by many. SOx is a health issue. Once emitted its lifetime in the atmosphere is 2-3 days. On the other hand SOx from shipping helps against global warming, cooling the atmosphere by 0.25 0C (MIT estimate) at a time that we desperately try to stay below 1.5 - 2.0 0C post-industrial warming. In other words, this regulation will increase global warming by 0.25 C without counting the extra CO2 that will be emitted by refineries to make the extra MDO and MGO needed (15% more CO2 according to IPIECA). Considering the short lifetime of SOx, it makes sense to reduce it near inhabited areas and coasts (i.e. ECAs) but why reduce it in the middle of the ocean when it does not hurt people and moreover fights global warming?
However the upheaval to be caused to shipping due to the 2020 SOx regulation, although serious, will be -I believe- small potatoes compared to what’s coming next. The next huge issue is the reduction of CO2 emissions from ships in order to meet the IMO targets of 40% reduction per transport work by 2030 and 50% absolute total reduction by 2050. Possible short, medium and long term measures have been put on the table for discussion and already IMO is being flooded by submissions proposing many new methods and regulations for CO2 reductions.
The proposals range from reducing and limiting the allowed speed of ships, to strengthening the EEDI (and apply EEDI even for older ships), to installing a horsepower limiter on the tailshaft and many other fancy, but practically useless, ideas. These ideas are not only useless but a) they will cause huge disturbance to shipping transportation and b) they will most probably increase actual CO2 emissions rather than reduce them, although -on paper- one may claim reductions. EEDI (Energy Efficiency Design Index), for example, has very little connection with the ship’s real efficiency. It is a “sea trial” index and a ship that is designed for good sea trial performance will not necessarily be efficient in Beaufort 4 or at reduced loading drafts. On the other hand, ships optimized for real sea efficiency in various speeds and loading conditions, will not score the best possible EEDI. This is a known fact among professionals yet most (including unfortunately IACS who are the primary technical advisors of IMO) stay silent “for political reasons”. The result is that most others (environmentalists, politicians, etc) believe that EEDI is synonymous to efficiency. Sadly there is an EEDI which is much closer to the real ship efficiency but, for various reasons, it remains unused (and unknown by most). This is the EEDI-weather, which takes into account how much is the speed loss of the ship up to Beaufort 6. And based on this one can easily say which ship is efficient and which not in reality. But shipyards and most others prefer to keep it buried, since it is much easier to satisfy regulations or claim efficiency, on paper only, instead of at real operating conditions. The situation is even worse with the so-called “operational indices’, the most famous of which being EEOI, and which will be used to measure transport work. Again, while most think -or pretend- that these indices have some connection with real operational efficiency, the truth is they are “random number generators” being influenced much more by the weather, cargo availability nearby and the market forces, rather than the ship's operator.
With regard to the proposals to apply speed limits to ships, I consider this one of the most -potentially- destructive measures for the industry. The market requires a fixed amount of goods to be transported every year and reducing speeds or reducing the number of ships will not reduce the demand. When speeds are limited by regulation (and thus the transport demand cannot be met), the immediate market reaction is to require more ships. 10% speed reduction means about 7% more ships are needed, 20% speed reduction requires about 20% more ships etc. Proponents say that even with the more ships, if everyone is going slow, there will be a reduction of total CO2 emissions. What they forget to add is the CO2 emitted to e.g. make the steel for these -otherwise unneeded- ships, the CO2 emitted to build them etc. When that is accounted for, all the operational CO2 reductions are eliminated and then some. The measure is plagued by many other complications for example: a) What should be the speed limit? The average speed of all bulk carriers and tankers in the last years is already slow (11 - 11.5 knots). To achieve further reductions will the limit be set at 10 knots? (a speed which for most ships is way below their most fuel efficient range). b) the measure is unfair to new eco ships which can operate at their design speed (14 - 14.5 knots) and lower speeds at less than half the consumption of older or badly designed ships for the same speeds. c) the measure does not promote the uptake of new technologies (fuel consumption reducing retrofits, using new antifouling paints etc.) d) the measure does not promote better operational practices. A ship may have dirty hull and propeller burning 30% more fuel than an identical ship at any same speed, yet both will fully comply with the speed limit regulation.
Some of the proposals are reasonable such as those from ICS calling for effective strengthening of operational procedures (SEEMP) which will root out many operational inefficiencies. Another idea which, if properly implemented, can result in huge CO2 reductions is the proper and general application of the “virtual” arrival concept. Presently ships speed up to give Notice of Readiness (NOR) ahead of other competing ships, only to wait for days or even weeks at anchorage for a free berth. If their full speed arrival time was accepted by the port without the ship being there, all the ships waiting time at anchor could be translated to slower speed during the voyage. This could produce very substantial emissions reductions without causing any market disturbance or need for more ships.
Whenever any regulation works totally separated from market forces, the result is damage to the related industry and inability to achieve the regulation's goals. We cannot expect to reduce emissions simply by reducing the transportation amount when the market requires more. The only measures that will work and produce results are ones that work within the market such as a) optimization of operations, rooting out inefficiencies such as idle port times, speed and consumption optimization measures (use of weather routing services, cleaning of hull and propeller etc.) but most importantly b) a market based measure, in particular a generous tax or levy on fuel. Making fuel substantially more expensive will result in fuel consumption reductions within the "market" and the maximum uptake of new technologies and best operational practices. Every serious study that examined, recently or in the past, the various proposals for fuel consumption reductions, ranks the Levy as the best, easiest, most fair and most productive measure.
* Technical Director, Atlantic Bulk Carriers Management, Ltd.