IMO’s Sub-Committee on Pollution Prevention and Response 8th session (PPR 8) was held in a virtual session on March 22-26, 2021. Russian Maritime Register of Shipping (RS) representatives took part in the event as members of the Russian Federation delegation.
Further advancement of the issues discussed during the session may be of concern for shipowners.
Amendments to MARPOL Annex I introducing a prohibition on the use as fuel and carriage for use as fuel of heavy fuel oil (HFO) by ships in Arctic waters enter into force from 2024. Earlier, at the IMO MEPC 75 session the originally planned entry into force date (from 2022) was postponed until July 1, 2024.
A decision on granting an exemption from the requirements of the new amendments will be made by Maritime Administrations taking into account the specific IMO Guidelines on Mitigation Measures to reduce risks of use and carriage of heavy fuel oil as fuel by ships in Arctic waters.
The draft Guidelines development has been coordinated by a representative of the Russian Federation. The version adopted during PPR 8 includes two types of requirements – those intended for ship operators and those for Maritime Administrations. The Guidelines will be additionally considered by IMO NCSR, SDC and HTW Sub-Committees in terms of the requirements on radio communication, stability, ship structure, etc. and thereafter will be further reviewed at the next Sub-Committee session (PPR 9) and submitted for adoption at MEPC 78 in 2022.
The 2024 heavy fuel ban for ships in the Arctic and the resulting imposed switch from the heavy fuel oil to distillate fuels will impact both existing ships and the economy of the Russian Arctic regions as a whole. The exemption granting procedure with due account for the Guidelines under development will help mitigate this pressure to a certain extent.
At the same time, it is expected that the ban will not cover state-owned ships and naval ships, vessels engaged in securing the safety of other ships or in a search and rescue operation and oil spill response.
Moreover, the postponement until July 1, 2029 will be granted to all ships with structural protection of fuel tanks in compliance with the requirements of the MARPOL Convention and the Polar Code. In addition, until July 1, 2029, the Arctic coastal States will have an opportunity to waive the ban for the ships flying their flags while operating in waters subject to the their sovereignty or jurisdiction, taking into account the IMO Guidelines on Measures to Reduce Risks of Use and Carriage of Heavy Fuel Oil as Fuel by Ships in Arctic Waters.
Reducing the impact of black carbon emissions
The issue of impact on the Arctic of black carbon emissions from international shipping is closely related to the use of heavy fuel oil. This topic has been long causing heated discussions under IMO agenda. Black carbon is fuel incomplete combustion product and its emissions are recognized to be one of the factors affecting the climate.
The PPR 8 noted a certain progress achieved by a special correspondence group as well as results of performed studies and measurements. However, the difference in the positions of Member States delegations did not allow agreeing on a set of concrete recommendatory or mandatory measures. The participants arrived at a conclusion of a two-step approach that would enable the following way forward: the development of the Guidelines in the short term period with a further possibility of introduction of mandatory measures in the long term. Upon the discussion, the PPR 8 recognized the need to extend the term of development of this topic until the end of 2022.
The existing standards on sewage water treatment and on operational testing of Sewage Water Treatment Plants were adopted in 2012 by MEPC.227(64) Resolution introducing dedicated Guidelines (on Implementation of Effluent Standards and Performance Tests for Sewage Treatment Plants) referred to in the Regulation 9 of MARPOL Annex IV. The Sub-Committee considered the interim results of the development of the revised Guidelines and draft amendments to MARPOL Annex IV and agreed to extend the term of development until the end of 2023. An RS representative will participate in the intersessional correspondence group established until the next Sub-Committee meeting (PPR 9).
The adoption of the MARPOL Convention amendments and the revised Guidelines will ensure the implementation of new sewage water treatment standard but at the same time may impose additional burden both on ship crew (maintenance, record keeping, etc.) and on Recognized Organizations (possible increase as per scope and number of surveys).