Next-generation environmental requirements

Managing the impact of environmental regulations now entering into force is one of the most
challenging tasks facing shipping this decade. Nevertheless, the shipping community should start thinking about the potential business impact of emerging regulations.

Regulations take time – but are as inevitable as death and taxes One of the key characteristics of developing international maritime regulations is obvious; it takes time. The timeline for a regulation is normally long, with a number of complex and timeconsuming steps. There are of course exceptions. The post-9/11 International Ship and Port Facility Security Code was fast-tracked for obvious reasons, and the EEDI and SEEMP were a showcase of rapid action, taking “only” five years from inception to entry into force.

SOx, NOx, PM, BWMS, AMS, EEDI, SEEMP, MRV, IHM; the list of abbreviations is long and growing. What they all have in common is that they embody key pieces of environmental regulations that have recently entered into force or are likely to do so in the near future. However, it is crucial to realise that new environmental regulations entering the development pipeline will be just as challenging to respond to as anything we see today.

What are these emerging issues? The short answer is hull biofouling, soot emissions and underwater noise. While the work is still at an early stage, IMO has recognised all three as significant environmental issues and put them on the formal regulatory agenda. The time for the maritime industry to have its say is now.

The normal state of affairs is different; it is not unusual to see 10-15 years elapse from the date when an issue is introduced until the resulting regulation enters into force, see figure next
page. The flip-side of this is that once an issue has entered the regulatory pipeline it rarely gets dropped. In practical terms, the implication is that the issues that will have developed into regulations in a decade or so are the ones that are presently recognised as concerns.

Clean hulls, smokeless exhaust and quiet ships?

That is where we see hull biofouling, underwater noise and soot right now. The confluence of factors focusing attention on these three issues leads us to believe that we will see mandatory regulations addressing all of them. While the timing remains unpredictable, we would not be surprised to see regulations agreed on towards the end of this decade and entering into force in 2020 – 2025.

The work on biofouling has so far led to the development of early-stage voluntary guidelines. Research indicates that biofouling is a significant mechanism for species transfer by vessels which is not sufficiently covered by the anti-fouling or ballast water management conventions. Draft guidelines were agreed by IMO in 2011. The US has also developed and implemented national regulations which could influence IMO, and the EU may be moving
in the same direction.

The US raised the issue of underwater noise with IMO in 2008 as a matter of increasing public concern, with a focus on its possible impact on cetaceans. Whales have a special place in the public consciousness in a number of countries and the US has for example established a 10-knot speed limit in whale breeding grounds as a general protection measure. Underwater noise, primarily from propeller cavitation and machinery, is thought to have a detrimental effect on both whale breeding and navigation.

In response, IMO has worked on the issue for a number of years and concluded by adopting guidelines in April 2014. It can be expected that these guidelines will form the basis for regulatory initiatives as experience is accumulated.

The work on soot, or black carbon (BC) as it is more precisely known in technical jargon, is less mature, but is attracting a great deal of attention, including from outside IMO. Black carbon can be described as “a strongly light-absorbing carbonaceous aerosol produced by the incomplete combustion of fuel oil”. It is recognised as contributing significantly to both global warming and accelerated Arctic ice melting, and as such is deemed to be a significant problem. Shipping’s contribution to it remains unclear, but IMO is presently working on appropriate definitions and measurement methods and is likely to eventually consider potential control measures and regulations.

All three issues, hull biofouling, underwater noise and soot, could be subject to regulation as early as in 2020. The regulatory response and attendant mandatory measures are obviously not clear at this time. However, educated guessing nevertheless points towards soot being handled by either fuel change or smoke-stack particle filters, biofouling by mandatory hull cleaning under controlled circumstances, and underwater noise by changes in propeller design and acoustically insulating noisy equipment from the hull. It goes without saying that all of these will represent significant operational and technical challenges for the shipping industry.

The price of silence
The shipping community is presently struggling to cope with what is perceived as a veritable “tsunami of regulation”, while also keeping their ships running in a highly challenging business environment. Needless to say, lifting their eyes from the day-today concerns and trying to think strategically about what is going to happen in ten years’ time can seem like a waste of time and energy. As a result, the general industry response tends towards an “I’ll deal with it when I see it” attitude. Obviously, as most influence on regulations can be wielded at the early stages, this is not the best response when it comes to either shaping the final outcome or preparing for its business impact.

Industry needs to engage strongly and constructively now, not later, if it wants to ensure that what emerges from the regulatory pipeline has the desired environmental effect, is operationally practicable, technically feasible, reasonable from a cost/benefit perspective and safe. Owners and operators need to start thinking strategically about the potential business impact. Doing otherwise will make business needlessly difficult ten years down the road.
Source: DNV GL (Dry Bulk Update)