The status of SECA enforcement - an EMSA view

At a recent conference hosted by ECSA and Transprime in Barcelona, Mr Sergio Alda, Project
Officer, Marine Environment & Port State Control, European Commission, Agency for
Maritime Safety (EMSA) provided an update on the status of sulphur regulation and enforcement. EMSA is the EC body responsible for the actual implementation of Sulphur regulations. 

In his presentation, entitled New Sulphur requirements, best practices and the way ahead, Mr Alda drew a picture of the status so far when it comes to enforcement of sulphur regulations. There are a couple of slides in particular that will stand out to those of us concerned with adequate enforcement of Sulphur regulations. 

2015 inspections vs requirements

EMSA_Inspections.JPG

The EC requires all governments in the SECA to perform inspections of at least 10% of the vessels visiting its ports. As can be seen in the above graph, there is still some way to go to reach this objective. 

Only 34% of non-compliance cases penalised

Of those cases where carriers were found to have been in violation of the SECA regulations, only 34% have been penalised. 

EMSA clearly see that there is more to be done, and in his final slide Mr Alda outlined the key focus areas ahead. 

Reported by Anna Larsson, Chairman of the Trident Alliance, VP Sustainability for Wallenius Wilhelmsen Logistics

Trident Alliance member Crowley receives FMC Chairman’s Earth Day Award

Crowley Maritime Corp., a member of the Trident Alliance, has been honored with the 2015 Federal Maritime Commission (FMC) Chairman’s Earth Day Award in recognition of the organization’s companywide environmental stewardship initiatives. 

“Crowley has been chosen for its broad commitment to active environmental efforts across their lines of business and throughout the company. Crowley’s efforts include: ordering two new LNG powered ships built in Pascagoula, Mississippi; participation in the spill protection program of the State of Washington, Department of Ecology; and, its membership in the Trident Alliance, a coalition of ship owners advocating robust enforcement of fuel sulfur restrictions,” said Chairman Cordero.

The FMC Chairman’s Earth Day Award is given annually and highlights technologies, programs, or practices of the maritime transportation industry that, through efficiency or innovation, benefit the environment. The award also looks to emphasize efforts that provide a reduction in environmental harm, emissions or pollutants, and increase the public's awareness of the maritime transportation industry's hard work to protect the environment.

“Crowley’s decision to align itself with the Trident Alliance makes sense on many levels,” explained Mike Roberts, Crowley’s senior vice president and general counsel. “First and foremost, Crowley’s long-standing support for and compliance with the sulfur regulations has been demonstrated throughout the years in no small part because, as a leader in the maritime industry, it is the responsible thing to do for the environment. Second, Crowley supports the fair leveling of the ‘sulfur playing field’ for the benefit of all parties involved.”

The Trident Alliance welcomes new members Crowley and Intermarine

With the 0.1 % Sulphur limit in ECA zones in place for more than three months, significant gaps in enforcement remain. Ship owners and operators continue their work through the Trident Alliance, the shipping industry initiative for robust enforcement of maritime sulphur regulations, and new members join.

“Efforts to improve enforcement in ports are underway, however how to ensure effective and robust enforcement on the high seas is only beginning to get the attention it deserves”, says Roger Strevens, Chairman of the Trident Alliance. 

Recently Trident Alliance has been highlighting this issue at a range of events including the high-profile enforcement meeting held by the 16 SECA nations in Denmark. 

“Given how critical it is for both environment and business, this challenge cannot be shied away from no matter how difficult it may be to resolve”, says Strevens.

New members
With the addition of the two US-based members Crowley Maritime Corp. and Intermarine, the Trident Alliance now has 35 member companies from across the world. Member company CEO’s have each signed a Statement of Commitment, in which they commit to supporting robust and transparent enforcement of sulphur regulations as well as to comply with said regulations. 

Jacksonville-based Crowley is a privately held family and employee-owned company. The company provides project solutions, energy and logistics services in domestic and international markets by means of six operating lines of business: Puerto Rico Liner Services, Caribbean and Latin America Liner Services, Logistics Services, Petroleum Services, Marine Services and Technical Services. 

“Crowley’s decision to align itself with the Trident Alliance makes sense on many levels,” explained Mike Roberts, Crowley’s senior vice president and general counsel. “First and foremost, Crowley’s long-standing support for and compliance with the sulfur regulations has been demonstrated throughout the years in no small part because, as a leader in the maritime industry, it is the responsible thing to do for the environment. Second, Crowley supports the fair leveling of the ‘sulfur playing field’ for the benefit of all parties involved.” 

Intermarine, L.L.C. is headquartered in New Orleans, Louisiana, and provides worldwide transport of project, breakbulk and heavy lift cargoes. Intermarine provides ocean transportation and marine logistics services with liner services from the United States to the Americas and West Africa, and chartering services around the world. The Company maintains 22 offices located in 16 countries. Intermarine also operates the largest fleet of U.S. flagged multi-purpose vessels engaged in the international trade. 

“As a U.S.-based company with a longstanding liner service from the U.S. Gulf to South America and Africa; substantial operations in Europe, and U.S. flagged vessels that are engaged in U.S based trade, Intermarine’s involvement with the Trident Alliance is consistent with the standards that apply to the company’s services,” said Will Terrill, Vice President, US Ocean and General Counsel. “The Trident Alliance will assist not only with leveling the playing field, but also with providing Intermarine with the opportunity to share its experiences with regard to different technologies and methods for compliance with sulphur regulations.”   

Media Contacts

Roger Strevens
Chairman Trident Alliance

VP Environment, WWL
Tel +47 410 43 864
Twitter: @RogerStrevens

Anna Larsson
Head of External Communications, WWL
Tel +47 484 06 919
Email: anna.larsson@2wglobal.com
Twitter: @ALarsso

Trident Alliance to hold Sulphur Enforcement event at European Shipping Week, Brussels.

February 24, 2015 – Trident Alliance, the shipping industry initiative for robust enforcement of maritime sulphur regulations, is inviting representatives from national and European authorities and NGO’s to discuss how effective enforcement of sulphur regulations can be achieved on the high seas. The event will take place on March 3, 14:00 - 16:00 pm, during the European Shipping Week in Brussels

The ECA zones 0.1 % Sulphur limit came into force as of January 1st, 2015. Robust enforcement is necessary to achieve the intended benefits to health and the environment, but is also critical to ensuring fair competition.

Compliance comes at unprecedented expense. Notwithstanding recent drops in oil prices, the price differential between HFO and MGO has changed little. Switching to lower sulphur MGO almost doubles fuel costs. Such high costs coupled with weak enforcement undoubtedly creates a temptation not to comply.  

Two months after the entry into force of the new sulphur limits, the Trident Alliance welcomes the opportunity to take stock and discuss with key stakeholders how a level playing field is ensured by robust and regular enforcement.

Roger Strevens, Chairman, says: “Individual Member States may be stepping up enforcement efforts in their territorial waters, but the effectiveness of enforcement on the high seas beyond those waters, yet still within the regulated area, is much in doubt. How and by whom will compliance tests on the high seas be undertaken?”  

Confirmed speakers:
•    Mr. Bill Hemmings, Programme Manager – Aviation & Shipping at Transport & Environment 
•    Benoît Loicq, European Community Shipowners’ Associations, Director - Maritime Safety and Environment
•    Mr. Kristian Teleki, Director of Global Engagement for the Global Ocean Commission
•    Roger Strevens, Chairman, Trident Alliance

For more information and details on how to register, please see the event details.

The seminar takes place in connection with a Trident Alliance Members meeting. The Trident Alliance is happy to welcome new members Hamburg Sud, from Germany, and Scandlines, headquartered in Denmark. This brings membership to a total of 33 companies. Member company CEO’s have each signed a Statement of Commitment, in which they commit to supporting robust and transparent enforcement of sulphur regulations as well as to comply with said regulations. 

The end of the world as we know it

By Roger Strevens, Chairman of the Trident Alliance and Head of Environment for Wallenius Wilhelmsen Logistics. This blog post was originally published in Bunkerworld.

I regret to inform you that the world as we know it is about to end.  Perhaps I should qualify that so as not to cause undue alarm: specifically, it is the shipping world that is about to end and only in the sense of ‘as we know it’. Of course the engine of world commerce will keep turning.

Forthcoming sulphur regulation, both in emission control areas (ECAs) and globally, is the driver of this transformative change. As an industry we’ve been addressing environmental issues through regulation for decades. This time is different though.  

Four factors combine to make it so: the scope – it concerns all vessels, the impact – the industry will need to adopt new fuels; the cost - way beyond what can be absorbed; and the uncertainty - knowing what to do, but not the best way to do it. 

Each of these is impactful by itself, but taken in combination they will quite literally change the face of the industry.

At this point it is worth stopping to consider why these regulations are coming to an industry that many argue already delivers superior environmental performance relative to any other mode of transport. That view may be valid for CO2 due to shipping’s advantage in economy of scale,  but not for sulphur emissions. The most common marine fuel has about 1,000 times as much sulphur as what is used in land transportation.  It is well documented that sulphur emissions harm the environment and people’s health, leading to premature deaths. Like it or not, sulphur regulations for shipping are necessary. By the same token, it would be wise to anticipate the introduction of additional ECAs elsewhere. 

Regulatory focus on emissions reduction is unlikely to relent, and sustainability is no longer an option for any industry.  With this and the challenges of regulatory compliance in mind, proactivity is the best strategy. Waiting till the eleventh hour to find and implement compliance solutions is to have one foot in yesterday and the other in the grave. Companies that take the initiative by forming partnerships with relevant stakeholders and trialling solutions ahead of time are more likely to find the most efficient compliance solutions. Given the cost implications, this will help them retain or extend their commercial advantage and help them be viewed as a reliable long term partner by their customers.

Compelling as the previous two paragraphs may sound, in reality they only hold true when all shipping companies are compelled to face the same regulatory challenges. That is how it is supposed be, but that is not necessarily how it is.

Enforcement of sulphur regulations, particularly in Europe, is weak.  And, as regulatory cost increases it is enforcement, rather than regulation by itself, which is the driver of compliance.

Although the general consensus is that most shipping companies will comply, the temptation to cut corners is very real, especially given that markets are already fiercely competitive and the cost of compliance will exceed what can be absorbed.  In other words, environmental regulation has, for the first time, direct and ongoing commercial consequences: customers care.  

Companies that take their chances on non-compliance stand to realise major cost savings. Over time such savings can distort the competitive landscape and, without an appropriate response from the authorities, will lead to growth in the number of non-compliant operators. Also, the regulations will not have the desired health and environmental impacts, the development of technologies and new fuels to enable compliance will slow down, and compliant shipping companies will suffer, It is these concerns that led to the formation of the Trident Alliance , a network of shipping companies that see transparency and robust enforcement of sulphur regulations as a business imperative.  Founded in July 2014, the group now has over 20 members representing around 10% of the industry by fuel consumption. Its membership, covers all sizes of company and segments of the industry.

In recent months we have helped to draw the issue of enforcement out into the open, and it is now a regular headline issue.  Awareness is the first step towards a solution.  The Trident Alliance members also engage in supporting the development of enforcement mechanisms and technologies.  

But it does not have to be the case that regulatory problems necessitate regulatory solutions; given the right conditions industry can address the issue itself. The Trident Alliance is currently exploring a transparency initiative with the potential to redress the whole enforcement issue. If the idea bears scrutiny a variation on REM’s classic might apply: It’s the end of the world as we know it, but we feel fine.

Fourteen more shipping companies join Trident Alliance effort for enforcement of sulphur regulations

Trident Alliance, the shipping industry initiative for robust enforcement of maritime sulphur regulations, broadens its platform as some of Germany’s and Denmark’s most prominent shipping companies join its ranks together with new members from Chile, Greece, The Netherlands, Sweden, Norway and Belgium.

Roger Strevens, Chairman, is impressed at the level of industry engagement: “We are just a few weeks away from what will be a sea-change in the regulatory landscape for shipping, namely the introduction of the 0.1 % sulphur limits in ECA zones on 1 January 2015. It is reassuring to witness that so many companies want to make sure the new regulations are implemented in a way that ensures the expected environmental benefits as well as a level playing field.”

The Trident Alliance welcomes: 
•    Hapag-Lloyd
•    DFDS
•    Ionic Shipping
•    Euro Marine Logistics
•    Marinvest 
•    Grieg Star
•    Wijnne Barends
•    Seatrade
•    Spliethoff
•    Transfennica
•    Biglift
•    Ultrabulk
•    Ultragas
•    Ultratank

This brings membership to a total of 31 companies. The member company CEO’s have each signed a Statement of Commitment, in which they commit to supporting robust and transparent enforcement of sulphur regulations as well as to comply with said regulations. 

Active Participation
The Trident Alliance continues to participate in industry conferences, working groups and media outreach to realize its objective of raising awareness around the lack of enforcement of sulphur regulations and the entailing risk to human health, the environment and fair competition. 

Among other, the Trident Alliance has been invited to present at a European Parliament event in Brussels on sulphur compliance on December 11. The meeting, entitled “Cutting air pollution from ships – Will ships comply? Will ports enforce new sulphur directive?” is hosted by Jytte Guteland, MEP. 

“We welcome recent statements from the US Coast Guard and EPA, showing that they are taking coordinated action to step up enforcement activities to ensure compliance with the new requirements effective 1 Jan, 2015. The announced combination of checking bunker delivery notes, fuel oil sampling and in-the-field screening should be effective,” says Roger Strevens.

WWL put sulphur regulation enforcement in focus at SIBCON

On October 16, Wallenius Wilhelmsen Logistics’ Kari Haugen, Bunker Manager, Global Tonnage & Trade, participated in a round table discussion to share how the company looks at the main challenges regarding the upcoming 2015 ECA regulations:

ECA Compliance Roundtable: Reducing Sulphur violations through collaboration.

  • Current challenges in Sulphur compliance
  • Enforcement at PSC
  • Industry view on compliance requirements and audits
  • Evolving inspection regimes – what needs to change?

 Other participants in the panel were: Capt Robert E. Bailey, Chief, Office of Operating and Environmental Standards, U.S. Coast Guard; Arthur Bowring, Managing Director, Hong Kong Shipowners Association; and Meindert C. Vink, Senior Advisor, Netherlands Shipping Inspectorate.

Kari Haugen emphasised the company’s strong commitment to ECA compliance. Compliance costs will be hugely increased as of next year, when all vessels trading in the European and North American ECA has to burn fuel with max 0.10% sulphur.

“However, the main worry as we see it, is that the weak level of enforcement experienced today, combined with the huge increase in compliance costs, could tempt companies to cut corners on compliance.  This will not only reduce the environmental benefits - the whole intention behind the regulations in the first place - but also put the serious and compliant shipping companies at a competitive disadvantage,” Kari Haugen explains.

In order to maintain a level playing field, WWL takes an active role in the work of the Trident Alliance for a strong and transparent enforcement regime, with clear guidelines and universal assessment criteria. Kari Haugen also stressed the importance of authorities focusing their time and resources on deliberate noncompliance, versus minor compliance issues.

WWL is a founding member of the Trident Alliance – where members commit to supporting robust and transparent enforcement of sulphur regulations as well as to comply with them.

 

About Singapore Bunker Conference

The world’s largest bunkering event, held every 2 years with more than 1000 delegates from more than 50 countries. This year’s agenda emphasised a range of industry round table discussions to gain perspectives from oil majors, independents, traders, ship owners and testing agencies.

The Trident Alliance welcomes new members

Trident Alliance, the shipping industry initiative for fair competition through robust enforcement of maritime sulphur regulations, explores solution initiatives and welcomes five new members.

Since its inception in July, the Trident Alliance has engaged in a number of industry conferences, working groups and media interviews to realize its objective of raising awareness around the lack of enforcement of sulphur regulations and the risk to human health, the environment and fair competition that this entails. 

Among others, the Trident Alliance has contributed in the European Community Shipowners' Association's Sulphur Working Group and the World Shipping Council Environmental Affairs Advisory Committee. For a list of all up-coming engagements, see http://www.tridentalliance.org/events/ .

Exploring Solution Strategies

The Trident Alliance has also started exploring solution strategies that can facilitate more robust enforcement of sulphur regulations. At a recent meeting, Trident Alliance members presented research and discussed solutions including:

•    Handheld sulphur content instruments for fast and accurate measurement of sulphur levels in ships’ fuel
•    Satellite controlled drones for carrying compliance measuring sensors 
•    Automated reporting of fuel line temperature as indicator of whether a vessel is running on HFO or MGO  

Roger Strevens, Chairman, says: “The Trident Alliance has been contacted by several organisations and entrepreneurs, and members have taken initiatives to explore a range of different paths for facilitating measurement of sulphur emissions. It’s early days, and the outcomes are not certain, but these are important steps to support technology development.”  

A growing group of companies

The Trident Alliance is happy to welcome five new members: 
•    Scorpio
•    Flinter
•    Solvang
•    Nordic Tankers
•    Ardmore Shipping Corporation

This brings membership to a total of 17 companies, representing approximately 7% of the industry’s global bunker consumption. The member company CEO’s have each signed a Statement of Commitment, in which they commit to supporting robust and transparent enforcement of sulphur regulations as well as to comply with said regulations. Several more companies are in the process of joining, and will be announced as their Statements of Commitment are filed. Membership will remain open to all shipping companies that wish to join.

The Trident Alliance formed, first members announced

July 7, 2014 – The Trident Alliance, a shipping industry initiative for robust enforcement of maritime sulphur regulations, has today been formally launched.  

The Trident Alliance is a coalition of ship owners and operators who share a common interest in robust enforcement of maritime sulphur regulation and are willing to collaborate to help bring it about. The Alliance will partner with other groups who share its interest in robust enforcement, to support this objective. 

A growing group of companies

The Trident Alliance welcomes all shipping companies that subscribe to the above. The current membership list includes: 

  • American Roll-on Roll-off Carrier (ARC)
  • EUKOR Car Carriers Inc.
  • Höegh Autoliners
  • J. Lauritzen
  • Maersk
  • Rickmers-Linie 
  • Stena 
  • Torvald Klaveness
  • UECC
  • Unifeeder
  • Wallenius Wilhelmsen Logistics

The member company CEO’s have each signed a Statement of Commitment, in which they commit to supporting robust and transparent enforcement of sulphur regulations as well as to comply with said regulations. Several companies are in the process of joining, and will be announced as their Statements of Commitment are filed. Membership will remain open to all shipping companies that wish to join.

Roger Strevens, VP Environment of Wallenius Wilhelmsen Logistics has been elected Chairman of The Trident Alliance. 

“Robust enforcement of sulphur regulation is needed for health and the environment and, from the perspective of maintaining a level playing field, it is a business imperative. Already during its formation the Trident Alliance has raised awareness of the current shortcomings of enforcement and related consequences, particularly in the European ECA. Now our work starts in earnest”, says Strevens.

Focus areas 

There is no one way to bring enforcement about. In part this is because the reasons for good or poor enforcement will vary from country to country. As such the Trident Alliance will pursue a range of different solution strategies to bring about robust and transparent enforcement. This approach will be made possible by the different skills and resources of the different members in the alliance and the stakeholders it partners with. 

The main focus will be on communication to raise awareness of the issue, supported by member companies’ transparency on compliance, as well as on initiatives to foster innovation in enforcement technology.

 

Trident Alliance Exploratory Meeting Announced

Trident Alliance, the shipping industry initiative for robust enforcement of maritime sulphur regulations, will hold an exploratory meeting in Copenhagen on May 28th.

Initially introduced at the Economist's World Ocean Summit earlier this year, the Trident Alliance initiative has garnered significant interest from ship owners and operators around the world, as well as from other members of the ocean community. Interested parties are now invited to take part in an exploratory meeting with a view to formally establishing the Trident Alliance. The meeting will include setting out the terms of reference and formally defining the objectives for the alliance.

Over the past years, significant steps have been taken to implement regulations to limit sulphur emissions from shipping. Whilst necessary, these regulations pose a significant cost and compliance challenge to the shipping industry. If the regulations are robustly implemented then compliance is the norm and competition is not distorted. However, when enforcement is weak a temptation is created to cut corners on compliance. The result is that regulations will not have the intended effect of protecting the environment and human health. Also, responsible shipping companies are put at a disadvantage relative to those who are intentionally non-compliant.

Wallenius Wilhelmsen Logistics (WWL) has long been highly engaged in the public debate around sulphur regulations, and has raised the issues the current lack of enforcement presents in several forums. In his talks with shipping companies, regulators, ports and environmental organisations, Roger Strevens, VP Environment for WWL, found widespread support for robust enforcement within the industry and for taking a collaborative approach to bring it about. To build on the momentum created and ensure that the ideas generated had a platform from which to grow, the concept of the Trident Alliance came to be.

The Trident Alliance will be a coalition of shipping owners and operators who share a common interest in robust enforcement of maritime sulphur regulation and are willing to collaborate to help bring it about. The alliance will partner with other stakeholder groups who share the interest in robust enforcement, to collaborate on initiatives that support this objective.

To join the effort and participate in the Copenhagen meeting on May 28, please contact Roger Strevens on LinkedIn