Sulphur Cap, EEDI and ballast treatment will feature at MEPC 74

Paul Gunton
Paul Gunton
ShipInsight

08 May 2019


Next week’s 74th meeting of IMO’s Marine Environment Protection Committee (MEPC 74; May 13-17) will be addressing some important themes and receiving some information documents relating to a topic that will become more prominent in the future.

A provisional agenda is available via IMO’s documents website, IMODOCS, which has long been used by delegates to access meetings papers and by members of the public once a meeting had finished. However, a large proportion of material is now being made available by its sponsors before meetings take place and this is the first MEPC meeting to benefit from that change in policy, as ShipInsight explained on 1 May.

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Among the important themes to be discussed are the 2020 sulphur cap, EEDI, greenhouse gas (GHG) emissions and implementing the Ballast Water Management Convention while the topic that will become more prominent relates to underwater noise.

Discussions about the 2020 sulphur cap will include consideration of draft guidelines and guidance documents, developed by the Sub-Committee on Pollution Prevention and Response at its sixth meeting in February this year.

These are expected to be accepted, but the Institute of Marine Engineering, Science and Technology (IMarEST) has submitted a paper pointing out a detail that must be addressed. It points out that PPR 6 agreed amendments to MARPOL Annex VI that require onboard fuel samples to be “drawn in accordance with guidelines to be developed by the organisation.” However, “there are currently no such guidelines,” IMarEST points out, and goes on to propose “how such sampling could be undertaken in a safe manner.”

In its pre-meeting briefing notes, IMO’s secretariat lists a number of other sulphur cap-related decisions expected to be taken, including guidelines for consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI and guidelines for port state control.

One topic that will come up at MEPC 74 and has already provoked discussion relates to IMO’s energy efficiency design index (EEDI). As reported by ShipInsight yesterday (7 May), The UK Chamber of Shipping has been critical of a proposal to MEPC 74 by France and Greece to limit ship speeds. That submission is not publically available in IMODOCS, but another organisation that has raised concerns has NGO status at IMO and has made its submission available.

That organisation is IACS and it describes some technical consequences of EEDI on ship machinery if engines are derated to reduce their EEDI. For example, ships can spend extended periods operating in a barred speed range which, among other risks, “causes concerns to the operators from the point of view of fatigue and from the vessel manoeuvrability point of view, particularly in bad weather,” its submission notes.

Other concerns are contained in a submission by Intertanko, which underlines a number of factors that make it difficult for VLCCs to meet EEDI requirements, because of their size. It plans to present a study on this topic to MEPC 75 but its submission to next week’s meeting reports that its preliminary findings indicate that “it may not be reasonable to expect VLCCs to achieve Phase 3 with a safe level of minimum power, prior to the switch to alternative fuels.”

MEPC 74’s discussions on GHG emissions will focus on its initial strategy, which was adopted in April last year. It will consider a report from an Intersessional Working Group that is meeting this week (May 7-10) and IMO’s secretariat said that MEPC is expected to approve the terms of reference and initiate a Fourth IMO GHG Study; the Third IMO GHG Study was published in 2014.

Among the many papers submitted for this topic is one from IMO’s secretariat about a proposal to establish a voluntary multi-donor trust fund to support its initial GHG strategy. The secretariat was tasked to prepare the proposal by MEPC 73 last October and its paper says the fund would provide a “dedicated source of financial support for technical cooperation and capacity-building activities to support the implementation of the initial IMO GHG Strategy on reduction of GHG emissions from ships” and to provide “the financial mechanism to support the sustainability of the Global Maritime Technology Cooperation Centres Network.”

But one flag state has queried the fund’s purpose, with the Marshall Islands commenting in a submission that, as currently worded, “the purpose of a trust fund would potentially disadvantage other country-led initiatives that are already mature and underway.” It has put forward an alternative wording for the committee to consider.

Although the documentation available on IMODOCS is not complete, it is clear that another of the topics that has attracted a large number of submissions is the implementation of the Ballast Water Management Convention, including applications for basic approval for two ballast water management systems and final approvals for four others.

With the convention now in force and implementation dates coming into effect, the main focus now “is on its effective and uniform implementation and on an experience-building phase, with a focus on gathering data on application of the BWM treaty,” IMO’s secretariat says. Submissions to the meeting include proposals related to ballast water sampling and analysis, among them revisions to the convention’s data gathering and analysis plan for the experience-building phase. A number of others refer to the specific situations of some specialised vessels when they come to apply the BWMC.

One submission, by China, looks at the practical difficulties of establishing a same-risk area (SRA), in which vessels are exempt from the BWMC because the organisms in the region are similar. At present, no SRA has been agreed and, since January 2017, China has carried out SRA-based research relating to ships operating in the Yellow Sea between China and South Korea.

In the process, it identified four difficulties, the two mains ones being that “there is no unified assessment guidance in the current SRA approach” and “the criteria for selection of species and quantity assessment remain unclear.” Its proposal is that MEPC should establish a correspondence group and set up a unified assessment system and analysis method for assessment conclusions.

MEPC will also consider proposals for it to undertake an environmental impact assessment of discharge water from scrubbers and to harmonise rules and guidance on their discharges. In a lengthy information paper based on an examination of existing literature, Panama notes that although there is no doubt that using scrubbers is effective in removing SOx, “a closer examination reveals that there may be significant issues regarding exhaust particulate emissions.”

Another theme that will be mentioned during the meeting is underwater noise. ShipInsight has written about a Canadian initiative and a workshop held earlier this year and a report from that workshop has been submitted to the meeting (but not made publically available on IMODOCS). A related joint submission by Canada and France reports that Canada “plans to hold policy discussions with all interested member states in autumn 2019 and winter 2020 on the contents of a new work output proposal for MEPC 75, which will aim to address the identified policy needs related to underwater vessel noise.”