6/18/2018: Posidonia 2018 – Coast Guard perspective on IMO 2020 Sulphur Cap

Rear Adm. John Nadeau, assistant commandant for prevention policy, represented the U.S. Coast Guard at the Posidonia international shipping conference in Athens, Greece earlier this month and participated in several panel discussions on topics relevant to the international maritime community. This post kicks off a four-part series highlighting Nadeau’s presentations, for the benefit of our readers who were unable to attend the conference.

In our first post, Nadeau gives his perspective on enforcement of the upcoming IMO 2020 global sulphur cap. These remarks are not as delivered, but are a condensed version of those given during the Hellenic Marine Environment Protection Association’s (HELMEPA) conference on air emissions.

Photo of Rear Admiral Nadeau speaking during the conference

Coast Guard perspective on the IMO 2020 Sulphur Cap

“Good morning. IMO started discussing fuel oil quality and air pollution in the mid 80s. MARPOL Annex VI was adopted in 1997 and entered into force in 2005 and was subsequently revised. It established limits on sulfur oxide (SOX) and nitrogen oxide (NOX) emissions. It established a global cap of 4.5 percent on sulfur content of fuel oil. This was lowered to 3.5 percent in 2012 and, as we all know, will be lowered to 0.5 percent in approximately 18 months.

Annex VI also established emission control areas – ECAs – to reduce emissions further in the Baltic Sea, North Sea, North America, and the U.S. Caribbean; SOX and particulate matter limits dropped all the way down to 0.1 percent by January 2015.

In 2015, there was some anxiety as the 0.1 percent sulfur limit approached. Vessel operators needed to think about how to: source their fuel; develop bunkering procedures to avoid unintentional mixing of the ECA compliant fuel with high sulfur content fuels; develop strategies and procedures for changing over and switching fuels before entering and departing the ECA boundary; develop procedures and plans and conduct training to do this safely; and, finally, keep records and logs of these actions.

Generally speaking, the availability of compliant fuel oil has not been a problem. In many cases failure to get compliant fuel is a result of poor voyage planning, not a shortage. If despite, their best efforts, vessel operators were unable to acquire ECA compliant fuel because it was not available, they could report these instances to the EPA.

We don’t believe there will be a shortage of 0.5 percent compliant fuel. The study done by the IMO concluded there may be instances of regional non-availability during implementation of the new cap, but this can be managed through the transport of compliant fuels to areas where it is not available.

The Coast Guard conducts approximately 9,500 regularly scheduled Port State Control exams every year, and Annex VI compliance checks and enforcement are a part of those. In the last three 3.5 years, we’ve seen 80 deficiencies and over a dozen enforcement actions resulting in civil penalties or fines for, among other violations, failure to switch fuels before entering the ECA, failure to burn compliant fuel, and incomplete bunker delivery notes and other records.

We agree with industry concerns that without consistent global implementation and enforcement of the 0.5 percent global cap in 2020 some ship owners will be afforded a competitive advantage over those companies that do comply. As with all environmental requirements, you can expect to see a strong effort within our Port State Control program to ensure compliance with these sulfur limits. If during a Port State Control boarding we discover that a vessel has used fuel exceeding the sulfur cap beyond our ECA, we will refer the evidence to the vessel’s flag state for further investigation and enforcement action. On U.S. vessels we will take action just as we do now.

If IMO adopts a carriage ban on fuel exceeding the 0.5 percent sulfur cap, we will participate in enforcement as appropriate. The IMO Pollution, Prevention, and Response Subcommittee is meeting next month to consider measures to support consistent implementation of the global cap. The U.S. supports this effort and stands ready with our colleagues to share lessons and experience.”

Editor’s note: Coming up tomorrow in part two of our series, Nadeau continues his discussion at the Hellenic Marine Environment Protection Association’s conference on air emissions, shifting to a discussion on the role of the regulator in the global maritime shipping industry.

Read the other posts in our Posidonia 2018 series.

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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