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A number of industry organisations – including the International Bunker Industry Association (IBIA) – have written to Dr Sian Prior of the Clean Arctic Alliance (CAA), after the environmental lobby group said that shipping’s use of IMO 2020-compliant very low sulphur fuel oils (VLSFOs) could ramp up vessels’ black carbon emissions.

Last week, the CSA called on the International Maritime Organization (IMO) to ‘support an immediate switch to distillate fuels for ships in the Arctic and develop a global rule prohibiting fuels with high Black Carbon emissions’.

Dr Sian Prior, Lead Advisor to the CAA, commented: ‘If immediate action isn’t taken by the IMO, the shipping industry’s use of VLSFO – introduced to comply with the 2020 sulphur cap – will lead to a massive increase in Black Carbon emissions, and this will both accelerate the melting of Arctic sea ice and have a major impact on Earth’s climate.’

As previously reported by Bunkerspot, a paper submitted by Germany and Finland to the IMO’s Pollution Prevention and Response (PPR) sub-committee has indicated that the new IMO 2020-compliant 0.50% sulphur fuel blends contain high aromatic compound levels, which can directly impact on black carbon (BC) emissions.

In an open letter to Dr Prior of the CAA, the industry bodies take issue with the assertion that VLSFOs exhibit high aromatic content.

‘Among the key points we identified in the JIG were that these 0.50% sulphur fuels were expected to be much more variable in terms of composition and characteristics than had been experienced previously,’ they said.

‘In your letter, you refer to fuels with a high aromatic content that show a potential link with black carbon emissions. We expected there to be a greater tendency for 0.50% sulphur fuels to be more paraffinic – not aromatic – in nature. The information available since the introduction of the 0.50% sulphur limit on 1 January 2020, suggests our expectations have been generally correct.’

The organisations also highlight that the Joint Industry Guidance: The supply and use of 0.50% – sulphur marine fuel (JIG) (JIG) was produced in August 2019 to address the safe handling and use of the new fuels that ship operators were expected to use post 1 January 2020 to comply with IMO’s 0.50% sulphur requirement.

They note that: ‘It was limited to operational aspects only and was developed to support suppliers, ship managers and seafarers prepare and implement the use of 0.50% sulphur fuels as safely as possible. Our document was wholly safety related and did not investigate or comment on any other issue.’

The letter concludes: ‘We fully agree that all black carbon related submissions (including the joint submission from Finland and Germany to IMO dated before the introduction of the 0.50% sulphur limit) should be reviewed thoroughly and seriously by the international fuel oil supply and shipping community.

‘The upcoming IMO Pollution Prevention and Response Sub-Committee is the most effective forum to progress that debate. It would not be appropriate for us to pre-empt the conclusions from that discussion.’

The signatories to the open letter to the CAA are:

The African Refiners & Distributors Association (ARA)

International Association of Classification Societies (IACS)

International Bunker Industry Association (IBIA)

International Council on Combustion Engines (CIMAC)

Institute of Marine Engineering, Science and Technology (IMarEST)


Japan Petroleum Energy Center (JPEC)

Oil Companies International Marine Forum (OCIMF)

The Royal Institution of Naval Architects (RINA).

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