13 Mar 2014
In July 2011, the European Commission (EC) published proposed changes to the Sulphur Directive that it said would harmonise European Union regulations with the 2008 revision of MARPOL Annex VI.
Directive 1999/32/EC and the later amendment 2005/33/EC, also known as the EU Sulphur Directive, currently differs from MARPOL Annex VI in several areas, and already has some extra requirements.
One area the EC's proposed changes seeks to harmonise is the sulphur limit stipulated for emission control areas (ECAs), currently set at 1.5% under EU regulations, but 1.00% under MARPOL Annex VI (the stricter limit is observed). Both would fall to 0.10% in 2015 under the harmonised legal package proposed.
The current EU Sulphur Directive also stipulates an 'ECA standard' 1.5% sulphur limit for passenger ships on regular service between EU ports. Under the EC's proposed Sulphur Directive changes, the new 0.10% sulphur limit in ECAs should also be extended to passenger ships throughout the EU from 2020.
Also unique to the EC proposal is that it aims to ban both the use and sale of marine fuels with sulphur content exceeding 3.5% in the territory. Although this aligns with the 2012 global fuel sulphur limit, MARPOL Annex VI does not actually ban the use of higher sulphur fuels as long as measures are taken to ensure sulphur emissions are reduced, and it places no upper limit on the sulphur limit in fuels as sold.
Although the EC has adopted the new Directive, the legislative procedure that would bring it into force has not yet been concluded; it needs to be adopted by the European Council and European Parliament before being published in the official EU journal and becoming law.
Since the EC published its proposed changes, there has been intense lobbying by shipping organisations and some industries that rely heavily on shipping to delay the 0.10% sulphur limit in the Baltic and North Sea ECAs beyond 2015.
MPs in the UK are calling for the European Commission to 'stop gold-plating' the EU Sulphur Directive and not go further then MARPOL Annex VI, and want the tighter emissions limits for passenger ships outside ECAs to be removed.
On the other hand, MEPs at the European Parliament's Environment Committee have voted in favour of a legislative report that calls for the EU sulphur regulations for ships to go much further than the changes proposed by the EC.
Among the suggestions MEPs approved of was for the current sulphur limit of 3.50%, in force globally since January 1, 2012, to be cut to 0.50% by 2015 and to 0.10% by 2020 across European seas.
They also want a 0.10% sulphur limit for fuels used within 12 nautical miles of EU coast lines, and for the EC to assist with the groundwork towards designating new ECAs in the Mediterranean, North Atlantic and Black Sea.
Who will prevail in this 'tug of war' between those who want sulphur regulations in the EU to go further than the European Commission has proposed, and those who want to remove some elements to make it more closely aligned with MARPOL Annex VI?
The initial concept of "redistributing" sulphur was a sensible and practical approach. Based on fuel average sulphur content, and the range of sulphur contents available the idea of reserving low sulphur fuels for ECAs was sensible and the limits set appropriate enough within that framework.
But why are the limits being lowered so drastically both within ECAs and in global areas? It is evident that the only way this could be effective and still allow the use of HFO would be if the average sulphur content in an ample fuel supply market were lowered sufficiently. To some extent maybe this is so due to the increased use of residues from low sulphur crude processing but refiners have made it clear they will not invest in any desulphurisation projects - there are more profitable ways to reprocess the residue than simply as a fuel.
But on the basis under which SOX is being limited it makes no sense at all to reduce the global limits. (especially with Warmers contemplating how to get SOX into the atmosphere as a global cooling agent).
So the net outcome is likely to be a shortage of HFO with a consequent increase in price across the board and with a much higher LSHFO premium. Others will have to move to LPG or distillate fuels and the implications of supply and demand for prices is more problematic to interpret. Increased use of distillate fuels of course increases CO2 emissions.
In the meanwhile no one seems to have quantified the effect of reduced sulphur nor put in place any metrics to measure the actual benefits.
Shipping contributes about 3% overall to anthropogenic SOX.
The apparent reason for reducing SOX in ECAs is therefore not about climate or acid rain but about the effect on human health.
It is all very well declaring 60,000 deaths a year due to shipping but this is propaganda nonsense. More reliable reports for land based emissions and particulates talk about the effects on life expectancy based on long term exposure and the results of such studies in the UK seem to suggest that few people actually live in areas where the particulate exceed safe levels at any time and those that do experience them during peak travel times and close to major road networks (though this is obviously related less to SOX than previously since SOX from car and truck emissions has all but disappeared).
I would want to see a much more realistic estimate of the actual impact of SOX reductions on health that identify specifically the populations that are at risk and the extent of the risk and I would like to see the estimate of the benefit in terms of increased life expectancy.
I would also like to see a study that looks at the negative impact. It would be morally questionable if the beneficiaries are limited to a small proportion of the population of the richest countries having the highest living standards and best health and nutrition to the extent of a couple of weeks of extra life expectancy (and already the longest lived) if it is at the expense of those societies who enjoy none of the benefits but who would be critically affected by the impact of high fuel prices on their ability to export.
MARPOL has lots of high ambitions but a complete lack of quantification and a lack of metrics. I can't help feeling the IMO has been overly responsive to ill informed and ill-intentioned NGOs.
Its a hope, that around 27% of the answerers believe, that MEPs will succeed in their call for wider sulphur restrictions to the Question:
" Which way will the EU Sulphur Directive go".
It is only the hope from shipowners that further elements will be removed, but a must, to act now with reducing GHG for general.
It is a chance more for the rebirth of small vessels with sailingssystems, as www.b9sipping.com.
"www.nuskin.com". This is frustating, I want to read about your product, to get an impression of hope, that Fueloil may be used longer for the propulsion of ships, completely wrong
It seems it is a self-deception.
So I struggle again for windpowered ships.
greetings from www.windships.de, Heinz Otto
Shipping a Korean car or 20ft container to Europe? Use one of North Adriatic ports.... it will cut sailing time by 6-7 days and save huge amount of emissions as well as costs.