The proposal, which the EC submitted to IMO on the 8th February deadline, calls for “evaluation and harmonisation” of scrubber discharges across all ports, worldwide and is intended for consideration by IMO’s MEPC 74, which meets in May, in London.
“This proposal is an attempt by the European Commission to push forward restrictions on scrubbers, which are accepted globally by the IMO, EU and others as acceptable means of improving air emissions quality in controlled areas,” said CSA 2020 executive director, Ian Adams.
“Within two weeks of a draft surfacing, the Commission had taken the proposal to a one-day working party review and then submitted it to IMO,” he claimed. “Clearly this was planned to avoid the open discussion and deliberation that a proposal with such far-reaching impact requires. In the absence of credible evidence to justify such a major departure from the existing rules, the proposal is instead based mostly on speculation.
“CSA 2020 members, who represent over 30 leading commercial and passenger shipping companies have been investing for years to prepare their ships in time to meet emissions abatement targets in accordance with existing IMO and EU rules, which endorse the use of open and closed-loop scrubbers in all waters,”said Adams. “To see the Commission take this step within months of the entry-into-force of the Global ECA is beyond disappointing.”
Noting the broader issues facing the industry, Adams added: “The EC initiative is needlessly creating baseless concerns at a time when there are already very real issues in the maritime industry regarding the future availability, suitability and cost of fuels and the effects on global trade and shipping that this will have. There could also be safety implications should ships be required to change fuels in high traffic areas close to ports.
“I am sure Brussels is very aware that existing scientific data shows significant air emissions improvement from scrubbers, with no likely impact on the ocean environment, but it appears the submission to IMO was prepared with speed rather than accuracy,” he stressed.
In a letter to its membership seen by CSA 2020, a European national shipowners’ association, said: “The EC submission does not identify any scientific evidence of potential risks but is lost in assumptions and speculation about possible contaminant levels and claimed risk potentials.”
In its proposal, the EC refers to the interim result of a study to be completed in May, 2019 by the Federal Maritime and Hydrographic Agency (BSH) for the investigation of scrubber wash water from closed loop and open loop systems. But as the preliminary conclusions of the BSH study do not appear to align with the EC’s proposal, it is far from clear whether it will contain any suggestion of new restrictions on scrubber wash water.
This week, CSA 2020 also presented results of a three-year study of the composition and quality of exhaust gas cleaning system (EGCS) washwater, based on samples taken from cruise ships.
The Carnival-led study collected 281 washwater samples from 53 EGCS-equipped cruise ships, claimed to be the largest washwater data set in the marine industry, which were then assessed against 54 different test parameters by ISO accredited independent laboratories.
The resulting laboratory analysis reports were then evaluated by class society DNV GL’s Maritime Advisory Services and the data compared against various water quality standards, after first confirming that the samples analysed were consistently well within the allowable IMO criteria and regulatory limits.
Then the results were compared to selected national and international water quality standards and land-based wastewater discharge limits.
According to CSA 2020, the EGCS results compared favourably with all of these standards.
“Comparing scrubber wash water to various other major water standards is useful to provide perspective and to illustrate EGCS wash water quality in a way that is easy to understand. These comparisons also provide relatable criteria for a number of specific EGCS parameters of interest, such as PAH concentrations, which also have limits within these standards,” Mike Kaczmarek, Carnival’s Senior Vice President for Marine Technology, explained.
“Although these are all recognised standards that are designed to regulate other waters, they do provide confirmation of the quality of water that operators of this technology are returning to the sea, and they provide strong support to the IMO’s decision to approve these systems as acceptable means of compliance throughout the world’s regional and 2020 global emission control areas (ECAs),” he added.
“We want to emphasise that this major study was intended to provide an objective assessment of the quality of scrubber washwater through a rigorous comparison to other world water quality standards, and it now represents the largest, most credible and verifiable data set available,”CSA 2020’s Adams said. “And importantly, the results reaffirm that exhaust gas cleaning systems are effective and safe for the ocean environment.”