Insight: is there a compelling case to turn the Mediterranean Sea into a sulphur ECA?
Can and should the Mediterranean Sea, or part of it, become an emission contorl area for shipping?
If so, it could mean vessels in the Mediterranean, even those transiting to and from the Suez Canal, could be forced to use more expensive fuels, and potentially be built to be NOx tier III compliant if some lobby groups get their way. The possibility came a step nearer this month as the IMO regional body REMPEC announced the start of a feasibility study into the possibility of the Mediterranean being a sulphur emission area.
REMPEC, the Regional Marine Pollution Emergency Response Centre for the Mediterranean Sea, said the study will assess the benefits, costs and feasibility of implementing an ECA for sulphur. This is not the same as assessing the costs to shipowners who would be expected to comply with any eventual Mediterranean Sea SECA or other requirements.
The development of such a SECA has been muted for a number of years, with a consortium of lobby groups being formed a year ago to push forward the proposal.
But can a Mediterranean ECA be created?
First there are the political challenges, and then there is the link to the soon to be enacted 2020 global sulphur in fuel cap which goes somewhat to achieve a similar goal but applies to everywhere outside an ECA. So, let’s start with the emission control areas where marine fuels need to have less than 0.1% sulphur unless abatement technology, a scrubber, is used.
There are currently two main areas that have been designated SECAS, North America and Northern Europe.
The North American ECA is the largest by far, extending across the US and Canadian exclusive economic zone, parts of the Caribbean and the Great Lakes and its waterways. That’s over 13m square km. Strictly speaking the he Northern Europe ECA (it limits NOx emissions as well as sulphur) is three separate but adjacent sea areas; the Baltic Sea, the North Sea and the English Channel. The West coast of the UK and all of Ireland are outside the ECA. It’s roughly an area of about 1.2 m square km.
The number of emission control areas is only going to grow. The five existing ECAs include the three north European ones (Baltic Sea, North Sea and English Channel) and the two in North America (The 200 nm off the US and Canadian Coastline and the Caribbean islands). Both areas are sulphur ECAs, and while the North American ECA is also a NOx ECA, the Baltic Sea will be in 2021.
China has also initiated an emission control area around certain ports, which largely are in preparation for the global sulphur cap, local groups point to a phrase in the plans that at a date which has yet to be advised after 31 December 2019 there will be an assessment made by the Chinese authorities with a view to reducing the maximum sulphur content to 0.1% for vessels operating in the emission control area and even to expand the geographical size of the emission control areas, as well as any other initiatives.
There have been other discussions over the years of ECA regions being created to reduce sulphur, nitrous oxide emissions, and also black carbon.
All of the current ECAs have a sulphur in fuel limit of 0.1% unless there are equivalent means, namely having scrubbers installed that allow for the use of (hopefully, for those owners that take this option) cheaper heavy fuel, oil that has a higher sulphur content. The North American ECA was driven mostly by one country, the USA. The North European ECAs came about partly because the surrounding 14 states are all European, apart from Russia in the Baltic Sea, but which is one of the nine members of the Helsinki Commission, Helcom.
The Mediterranean has 11 European member states bordering it, and a further eight states stretching round its eastern coastline and then across the north African coastline. Bringing all 19 states to an agreement may be a challenge in this politically charged age, with the prospect of poor enforcement being a problem if such an ECA is designated. However, all the members are signatories to the Barcelona Convention in a similar way to the Baltic Sea members being signatories to the Helsinki Convention.
It is notable that this feasibility study is partly funded by the IMO’s Integrated Technical Cooperation Programme (ITCP) which gives assistance to developing countries to implement and comply with the IMO’s regulations, as the issue of enforcement will be key to the success of a Mediterranean SECA.
But the consortium of lobby groups pushing for this ECA, and even the REMPEC announcement, does recognise the difficulty in getting all coastal Mediterranean states to agree to the proposal; hence the wording that the feasibility study will look also at the option of parts of the Mediterranean.
More than sulphur
Birdlife Malta is one of the consortium pushing for a Mediterranean ECA. It wants more than a sulphur emission control area though. In an email to Fathom News, the organisation said that even when the global sulphur cap (of 0.5% sulphur in fuel) comes into force on January 1, 2020, it still considers ships a significant source of air pollution that will be harmful to human health and the environment, and contribute to climate change.
“Areas with high shipping traffic, as is the case for the Mediterranean Sea, are particularly affected by these toxic shipping emissions, given that an emission control area is not in force as it is the case for example for the North and the Baltic Sea.
Thanks to the creation of Sulphur Emission Control Areas (SECA), air quality got significantly better in these areas and a NOx Emission Control Area (NECA) will come into force from 2021 which will furthermore contribute to better air quality in the areas.,” the statement read.
“We see it as a necessity to reduce air pollutants caused by ships such as particulate matter, black carbon, nitrogen oxides and sulphur oxides to the same extent in the Mediterranean Sea by creating an ECA that will benefit humans and the environment in Southern Europe”.
There are a number of other environmental groups supporting this initiative, including Ornithologiki (Greece), Cittadini per l’Aria (Italy), Ecologistas en Acción (Spain) and France Nature Environnement (France).
Enforcement and compliance
The creation of a Mediterranean ECA will have to take into account how enforcement of the rules will be taken care of, and if a decision to have a regional Mediterranean ECA is taken how to position it to avoid vessels taking a (cheaper) non-ECA route that allows the use of 0.5% fuel instead of the 0.1% fuel if this then still leads to pollution moving over the ECA region and ashore.
The Mediterranean does have some significant choke points, notably the Suez Canal entrance and Gibraltar Straits, where the distance between Morocco and Spain is barely 15km, but also in the narrow stretch (about 135km) between the northern tip of Tunisia and Sicily).
If, for example, an agreement was made to have only European waters formed into an ECA it would squeeze east and westbound traffic, towards the African coastline.
Thanks to the North European ECA there is now a growing level of experience in north European states in monitoring and enforcement, but the results can be seen in a good, and bad light according to the chairman of the Trident Alliance, a consortium of shipowners who have made a public commitment to compliance and are pushing for strong and even application and enforcement of the ECA rules.
Trident Alliance chairman Roger Strevens says that if a Mediterranean ECA is to be developed, there should be close coordination on enforcement experiences among the relevant authorities, including any outside of the EU.
Reports from the member states in the North European ECA suggest a non-compliance rate of below 10%, he said, adding that this is not particularly good. “If you are competing with an operator in that percentage of the industry, then you could have an extremely unfair competitive situation to cope with,” he said, saying that a deliberate and gross non compliance level of under 1% would be a more acceptable target.
“It would be constructive for the different authorities to set out their approach to enforcement, including the consequences for non-compliance, ” says Strevens. “This would be effective from the perspective of ‘prevention being better than cure’ and as a way to demonstrate to other stakeholders, port and coastal communities, what authorities are doing to protect their interests.”
Sniffer drones have been one technology touted by European states, as well as EMSA, with Denmark also putting exhaust gas sensors under key bridges that span the main waterways leading into the Baltic Sea.
He also raised the question of how the 2020 global cap reduction will be enforced. The current ECAs are mostly in national EEZ waters and subject to national enforcement policies, when the rest of the world’s seas drop from 3.5% to 0.5% on January 1st 2020, this will cover international waters where there is no individual state with national jurisdiction.
Strevens says the IMO should be applauded here for its recent moves to ban the carriage of non-compliant fuels, so regardless of where the ship is after January 1, 2020, it can not have a fuel onboard with a sulphur content higher than 0.5%, unless it has an exhaust gas cleaning scrubber installed and operational.
Strevens also said the regulations on the bunker delivery note, a certificate handed over from bunker suppliers to the ship showing the specification of the fuel, will also be an important move. “To be positive, a lot of initiatives have been undertaken,” he says, “but whether the suite of tools is effective remains to be seen.”
But that then comes to the final query. Any decision to create a Mediterranean Sea where sulphur content in fuels, and therefore emissions, will drop to below 0.1% will not come before the global cap falls from 3.5% to 0.5%. No doubt there will be recommendations that industry waits to see the impact of this change to the IMO Marpol regulations.
But as the environmental lobby groups point out, a new ECA can be created for other pollutants than sulphur, so the discussion may still evolve to creating a new NOx ECA, whereby all newbuildings will have to be tier III compliant, which represents a significant drop in nitrous gases from ships.
If that gets the green light then it may put added emphasis on the ongoing green tech push in the maritime sector. However the REMPEC feasibility study is only focused on a sulphur ECA.