We welcome a new post by John Graykowski on the subject of LNG as a marine fuel. He describes this period as a “crossroads moment” requiring parties to hold fast to the original timeframe for vessel emissions reductions as set by the IMO in MARPOL Annex VI.

Despite many indications that LNG is gaining acceptance as a marine and transportation fuel, ship owners still appear reluctant to fully embrace the new fuel. Many owners are hedging their bets by installing dual fuel engines and other LNG-specific features on their new vessels, but delaying the installation of the fuel tank and fuel gas system until some later date. Others are placing new build orders with conventional propulsion systems, effectively dismissing LNG as a credible alternative.

Since stringent worldwide limits on fuel sulfur content are scheduled to become effective in 2020, these decisions might seem questionable. A provision in MARPOL Annex VI, however, creates significant uncertainty whether the IMO will in fact hold to this schedule, thus allowing some operators to make a strategic calculation that the limits will be delayed.

Adopted in 2008, Annex VI created a two tiered regulatory structure to phase in fuel sulfur requirements. For those states that implemented emissions control areas (ECAs), fuel sulfur limits were reduced in two stages from 1.5% to 1% in 2012 with a final reduction in January 2015 to 0.1%. Outside the ECAs, the current 3.5% limit is scheduled to be reduced to 0.5% in 2020. However, this will happen only after a mandatory 2018 IMO review which must find that sufficient compliant fuel will be available in 2020; otherwise the limit will remain at 3.5% until 2025.

At that time, there were only two “viable” compliance options for ship owners: use marine gas oil (MGO) or install exhaust gas scrubbers. The natural gas “revolution” was in its infancy and there was little, if any, discussion of LNG as a cleaner and more economical alternative to either MGO or scrubbers. Despite giving fuel suppliers over a decade of advance notice to prepare, the potential magnitude of demand for compliant fuel and concerns that MGO production would be insufficient led the IMO to create this 2018 “gate” before the 0.5% limit would become effective.

A fortuitous confluence of factors led to the emergence of LNG as an alternative marine fuel. The ECAs created unambiguous regulatory imperatives and hard deadlines; the unforeseen increase in worldwide gas production led to a steep decline in prices; and there were no technological barriers to the use of LNG as a propulsion fuel. MGO and scrubbers involve significant expense, provide less comprehensive emissions reductions, and, in the case of scrubbers, increased risk, In contrast, LNG offers compliance with sulfur limits, significant improvements across the entire spectrum of emissions and long term cost advantages. Even with the current drop in oil prices, LNG is projected to maintain its economic and environmental advantages for many years to come. The ECAs made it possible for the first adopters to move forward in the U.S.; the EU to propound a formal policy to support LNG deployment throughout Europe; and Norway to emerge as a dominant player in the marine LNG world.

Experience in the ECAs has demonstrated that concerns about fuel availability are largely unfounded, and that the fuel supply industry can and will respond to demand signals, particularly those driven by clear regulatory requirements and deadlines. The phased approach in the ECAs allowed fuel suppliers and operators to first adjust to the 1% standard and then to prepare for the lower limits in 2015 and resulted in a smooth transition to MGO earlier this year with no apparent supply shortages. This approach had another important impact on marine operators in the ECAs who began looking at LNG as a credible alternative to either MGO or scrubbers.

The Annex VI review provision allows the IMO to consider “other relevant issues” and thus offers the means to include LNG in the analysis of fuel availability. LNG adoption that has already occurred is directly related to the implementation of the ECAs with their interim steps and fixed deadlines. The IMO should emulate this approach by requiring global fuel sulfur limits to be reduced to 1% in 2020 with a permanent reduction to 0.5% in 2025. The ECA experiences and the growth of LNG as a marine fuel provide ample justification to support this decision, rather than simply allowing the 3.5% limit to remain in place.

By 2018, more than 150 vessels worldwide will be using LNG as a fuel; the EU will have bunkering capabilities in several of its major ports; LNG powered ships will be operating in the US; China will be well on its way to transforming its inland fleet to LNG, and Singapore and Korea will be in the midst of building LNG bunkering infrastructure. The adoption of an interim 1% standard would likely galvanize the world shipping community to accelerate the movement to LNG when new vessels are ordered. In turn, this would be an unequivocal signal to the gas supply industries to move forward with infrastructure development, thus banishing forever the chicken and egg cliché in connection with LNG development.

This is a crossroads moment for the IMO and it can make a clear, definitive, and compelling statement to advance environmental quality and affirm its commitment to continued reductions. The US, Canada, and the EU made the hard political decisions to implement stringent marine emissions standards, and the markets have adjusted. As 2018 approaches, the IMO will be under increasing scrutiny from many parties, including those with a vested interest in LNG development. I would urge those nations that have implemented ECAs, or are contemplating them, those that have enacted formal policies to encourage the development of LNG as a marine fuel, and the natural gas suppliers and the environmental communities –admittedly a somewhat nontraditional alliance – to insist that the IMO adopt this phased approach.

Anything less would be a lost opportunity to take a giant step forward in the effort to reduce marine air emissions, and likely would slow the pace of LNG adoption for another five years.   John Graykowski