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In advance of an intergovernmental meeting next month at the International Maritime Organization (IMO), the International Chamber of Shipping (ICS) has called on IMO member states to "give careful consideration to shipowners' concerns about the implementation of an avalanche of new environmental regulations, which are about to impact on ship operations at more or less the same time".

ICS Chairman, Masamichi Morooka, explained: "The shipping industry is not in any way questioning the need for these important new IMO rules and is fully committed to implementation. But governments need to address some very important issues if they wish to avoid confusion and market distortion."

In advance of next month’s IMO Marine Environment Protection Committee (MEPC), the ICS board of directors, which met in London last week, reviewed the solutions that ICS is proposing to governments with respect to what it describes as "the serious implementation concerns associated with entry into force of the IMO Ballast Water Management Convention, and new MARPOL regulations to reduce sulphur emissions". The ICS Board also reviewed the continuing debate at IMO about additional measures to reduce ships’ CO2 emissions.

Sulphur rules

The 0.1% sulphur in fuel requirements in Emission Control Areas (ECAs) is due to come into effect on 1 January 2015, but ICS says there is still "much uncertainty" as to how they will be implemented by governments.

According to ICS, the board agreed that it should continue to encourage the Paris memorandum of understanding (MOU) on Port State Control to ensure that there is a harmonised approach to implementation and thus avoid market distortion. In particular, ICS says it is encouraging the acceptance of bunker delivery notes (BDNs), rather than fuel sampling, as prime face evidence of compliance, unless there are clear grounds for suspecting otherwise; and a sensible approach towards minor technical violations as opposed to the deliberate use of the wrong grade of fuel.

Mr Morooka remarked: "With respect to the issue of fuel availability and the impact on price, there is perhaps even greater concern about the 0.5% global cap in 2020. The increased demand for diesel grade fuel from shipping may have an impact on land based industry too."

"ICS is disappointed that IMO now looks unlikely to advance the conduct of the IMO fuel availability study from 2018 (as required by MARPOL) when it will be far too late to encourage any action needed from governments to help ensure that refiners produce sufficient quantities of fuel, so that ship operators are able to comply," ICS added.

CO2 reduction discussions

The ICS board noted the pressure from some governments for the industry to do even more to reduce carbox dioxiede (CO2) emissions, despite the fact that shipping is already by far the most carbon efficient form of transport. ICS reiterated its support for the development by IMO of a global system of mandatory CO2 data collection from ships, provided that the system is simple to administer and is primarily based on fuel consumption.

However, ICS also reiterated that the global shipping industry has not agreed to the development of any kind of mandatory operational efficiency indexing system which might be used to penalise ships that are deemed less efficient.

Mr Morooka commented: "No two voyages are the same due to factors such as weather and ocean conditions and many of our members think there is a danger that the development of such an operational indexing system would lead to serious market distortion."

"ICS is keen to stress that IMO has not yet agreed to such an indexing system either, although ICS fears there is a risk that this might still be developed by stealth, with many of those governments involved in the IMO discussions about data collection proposing metrics that might form the basis of such a system," ICS said.

ICS also noted that some governments have been very explicit about their intention to use operational indexing as a means to apply financial penalties to existing ships (in addition to the extra fuel which they already have to pay for).