Commercial Vessel Compliance

3/15/2018: CMA Shipping 2018 – IMO and environmental standards

Photo of Jeff Lantz giving remarks

Jeff Lantz gives remarks during CMA Shipping 2018.

Jeff Lantz, director of commercial regulations and standards, briefed attendees at Connecticut Maritime Association Shipping 2018 on the leading environmental issues the International Maritime Organization is facing. Lantz’s presentation was part of a panel titled, “The Economic Calculus of 2020.” Other members of the panel included executives from Exxon, Marsoft, Inc., Alternative Marine Technologies, GTT North America, and Methanex Corp. Neville Smith with Mariner Communications moderated the session.

Lantz, the U.S. Head of Delegation to IMO’s Maritime Safety Committee and Marine Environmental Protection Committee, said environmental matters have the greatest degree of IMO’s focus, perhaps more so than issues surrounding autonomous vessels.

“Environmental issues are the important issues at IMO; society and governments are more and more sensitive to environmental issues and currently, air emissions are where the future standards are being developed,” Lantz said.

Lantz said the biggest challenges IMO is tackling are associated with the impending .5 percent global sulfur cap that goes into effect at midnight Jan. 1, 2020.

“If anyone out there is thinking 2020 could be delayed or changed, that’s not going to happen; it will enter into force,” Lantz said. “But there are ongoing discussions on the main issues – fuel availability and consistent enforcement and compliance – and how the regulators will ensure a level playing field.”

Lantz said the Pollution, Prevention, and Response (PPR) subcommittee met in February to work on several items associated with 2020:

• Approved amendments to MARPOL that will make it illegal to carry non-compliant fuel if a ship is not using a scrubber or any alternate type of method. Those amendments will be considered by MEPC in April.
• Building guidelines for consistent implementation of the global sulfur cap to address non-availability.
• Reviewing exhaust gas cleaning systems, to address approval, emission testing as well as specific guidance on accidental breakdown, malfunction and perceived temporary non-compliance.

Lantz also discussed several issues associated with NOx requirements that are under consideration at IMO, even though NOx requirements have been around for quite some time.

At its most basic, Lantz said the issue involves the trade-off between fuel efficiency and NOx emissions.

“The issue here is whether or not the operating profiles of an engine can be changed in order to increase fuel efficiency throughout the operating ranges of the engine during voyages,” he said. “If so, the question is, what’s the impact on NOx emissions and will the engine and ship continue to meet the NOx emission standards.”

PPR 5 agreed to the definition of “Engine Operating Profile” and also the scope of the work, which is to decide if multiple engine operating profiles can be used.

“If multiple engine operating profiles are allowed, PPR 5 will look at what regulatory controls need to be applied, and if not, then they’ll look at what amendments are necessary to MARPOL Annex VI,” Lantz said.

PPR 5 also considered and developed amendments to the NOx Technical Code and the SCR Guidelines dealing with certification requirements for SCR systems.

The other issue facing the industry will be the increasing number of Emission Control Areas. Lantz said that, based on when ECAs are adopted, Tier III NOx requirements may have different application dates.

“This creates a myriad of applications and less consistency,” Lantz said. “This wasn’t intended when the ECA provisions were adopted, but as they’ve been adopted, IMO made these changes.”

Lantz also discussed two aspects of Green House Gas emissions – efficiency and future strategy.

The current path at IMO regarding ship efficiency is reasonably established. There are Energy Efficiency Design Index (EEDI) requirements for new ships, while existing ships must follow requirements in the Ship’s Energy Efficiency Management Plan. Lantz said industry should expect continual adjustments to the EEDI baselines for additional ship types as IMO continues to consider efficiency standards.

There is also the three-step process, applicable to all ships, to gather data on ships’ efficiency, analyze the data, followed by making necessary changes to ships’ efficiency standards. Starting in 2019, ships over 5000 GT and above will have to collect and report fuel consumption data.

Lantz then gave an overview of IMO’s holistic approach to developing a strategy that goes beyond simple ship efficiency. In 2016, at MEPC 70, it developed a “Roadmap for Comprehensive IMO Strategy on Reduction of Greenhouse Gas Emissions from Ships.” In following that Roadmap, IMO is due to complete the Initial Strategy at MEPC 72, April 2018.

To date, they’ve made progress, but Lantz said it has been slow.

“As has been throughout the discussion at IMO when it comes to GHG emissions, there are strong positions held by various groups, including those who want ambitious provisions to reduce GHG emissions as opposed to those that are very wary of any such provisions,” Lantz said. “IMO definitely feels the need to do something – although the maritime is the only mode to develop any mandatory measures to reduce GHG emissions – but there is concern that if IMO cannot reach an agreement, it could result in regional action, which runs counter to IMO’s purpose.”

Lantz said it comes down to two issues: the level of ambition and its timeframe and the political issues related to GHG emissions. Lantz was cautiously optimistic that IMO would succeed at MEPC 72 in April of this year.

To close, Lantz gave his views on the issue of black carbon in Arctic and that although it is not a significant issue now, IMO and industry must keep an eye on it because it could have a broader impact as Arctic traffic continues to increase.

“It’s not just about HFO [heavy fuel oil]; black carbon essentially comes from almost any carbon-based fuel,” Lantz said. He added that the PPR Subcommittee has agreed on measurement methods, finalized the voluntary reporting protocol, and established a workgroup to assess feasibility of future regulations or guidelines.

Want to read more of our coverage from CMA Shipping 2018? Check out these other posts:

3/29/2018: CMA Shipping 2018 – The critical role of integrating new technology within the regulatory approval process

3/13/2018: CMA Shipping 2018 – Summary of keynote address by Deputy Commandant for Operations, Vice Adm. Charles Ray

3/12/2018: CMA Shipping 2018 – Summary of remarks by Asst Commandant for Prevention Policy Rear Adm. John Nadeau

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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