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Alternative Fuels

IUMI: How can liability and compensation regimes adapt to alternative bunker fuels and cargoes?

Existing international liability and compensation regimes do not fully cater to the changes that the use of alternative marine fuels will bring.

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By Tim Howse, Member of the IUMI Legal & Liability Committee and Vice President, Head of Industry Liaison, Gard (UK) Limited

The world economy is transitioning, with industries across the board seeking to reduce their carbon footprint and embrace more sustainable practices. As part of this, there is a huge effort within our industry to look to decarbonise, using alternative fuels such as biofuel, LNG, LPG, ammonia, methanol, and hydrogen.

Until now there has been much focus on carbon emissions and operational risks associated with the use of alternative fuels. This includes increased explosivity, flammability, and corrosivity. An ammonia leak causing an explosion in port could result in personal injuries, not to mention property damage, air, and sea pollution. In addition, alternative fuels may not be compatible with existing onboard systems, increasing the risk of breakdowns and fuel loss resulting in pollution. Apart from these safety concerns, which particularly concern crew, air pollution and other environmental impacts need to be addressed.

However, the green transition also presents us with a separate regulatory challenge, which has received less attention so far. So, whilst carbon emissions and safety concerns are rightly on top of the agenda now, the industry also needs to prioritise the potential barriers in the legal and regulatory frameworks which will come sharply into focus if there is an accident.

If anything, historic maritime disasters like the Torrey Canyon spill in 1967, have taught us that we should look at liability and compensation regimes early and with a degree of realism to ensure society is not caught off-guard. With our combined experience, this is perhaps where the insurance industry can really contribute to the transition.

Currently, existing international liability and compensation regimes do not fully cater to the changes that the use of alternative fuels will bring. For example, an ammonia fuel spill would not fall under the International Convention on Civil Liability for Bunker Oil Pollution Damage (Bunkers Convention), potentially resulting in a non-uniform approach to jurisdiction and liability. Similarly, an ammonia cargo incident would not fall under the International Convention on Civil Liability for Oil Pollution Damage (CLC). Uncertainties may also exist in the carriage of CO2 as part of Carbon Capture and Storage (CCS) projects, which may be treated as a pollutant, with corresponding penalties or fines.

A multitude of questions will arise depending on what happens, where it happens, and the values involved, many of which may end up as barriers for would be claimants. How will such claims be regulated, will there be scope for limitation of liability, and would there be a right of direct action against the insurers? In the absence of a uniform international liability, compensation and limitation framework, shipowners, managers, charterers, individual crew, and the insurers may be at the mercy of local actions. Increased concerns about seafarer criminalisation (even where international conventions exist, ‘wrongful’ criminalisation does still occur) may emerge, creating another disincentive to go to sea.

When being carried as a cargo, the International Convention on Liability and Compensation for Damage in Connection with the Carriage of Hazardous and Noxious Substances by Sea (HNS), which is not yet in force, may resolve some of these issues for alternative fuels and CO2. However, until HNS comes into force, there will be no international uniformity to liability and compensation for the carriage of alternative fuels and CO2 as cargoes. This creates uncertainties for potential victims and their insurers, who may face increased risks and costs, due to the potential inability of existing regulations to provide protections.

The situation is even less clear in the case of bunkers. The rules for using alternative fuels as bunkers might require a separate protocol to HNS, a protocol to the Bunkers Convention, or a whole new convention specifically for alternative fuels.  Relevant considerations for the appropriate legislative vehicle include states’ preparedness to reopen the Bunkers Convention, the ability to conclude a protocol to HNS before it comes into force, and whether a multi-tier fund structure is needed for alternative fuels as bunkers (perhaps unnecessary because bunkers are usually carried in smaller quantities compared to cargoes).

Until then, what we are left with are the existing international protective funds, designed to respond at the highest levels to pollution claims resulting from an oil spill, without any similar mechanism in place to respond to a spill of alternative fuels, which are themselves so central to a green transition. Somewhat perversely, victims of accidents involving an oil spill may therefore enjoy better protections than victims of an alternative fuels spill.

In summary, while the use of alternative fuels will no doubt help to reduce the industry's carbon footprint, there are safety and practical hurdles to overcome. Stakeholders must also come together to find solutions to complex - and urgent, in relative terms - legal and regulatory challenges.

 

Photo credit: Manifold Times
Source:  International Union of Marine Insurance
Published: 13 June 2024

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Ammonia

GCMD in midst of developing emergency response plan for ammonia STS ops

GCMD is working with Oil Spill Response Limited, BlueTack and Stream Marine Technical to develop a draft ERP for ammonia STS operations, with the aim of adapting it for bunkering.

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GCMD in midst of developing emergency response plan for ammonia STS ops

The Global Centre for Maritime Decarbonisation on Tuesday (23 July) said it has been developing an emergency response plan (ERP) draft with industry partners specifically tailored to accidental ammonia release.

The partners GCMD is working with are Oil Spill Response Limited, BlueTack and Stream Marine Technical.

“GCMD is working with industry partners to develop a draft ERP for ammonia STS operations, with the aim of adapting it for bunkering,” it said in an update. 

Given ammonia’s toxicity, GCMD said it was important to have a well-defined emergency response plan (ERP) to minimise the impact of accidental ammonia release and safeguard life, property, and the environment.

“Existing ERPs for oil and chemical spills can provide a valuable foundation, especially in areas such as tiered response levels based on the severity of release,” it said.

“This, in turn, determines resource needs and multi-agency coordination protocols. However, it is important to recognise that we will need to supplement these plans with procedures tailored to ammonia’s properties.”

The provisional ERP report is scheduled to be released in Q4 of 2024. 

Note: GCMD’s visuals for a preview of the ammonia release ERP it is working on, highlighting some of the scenarios when ammonia is released both into sea and air, can be found here

 

Photo credit: Global Centre for Maritime Decarbonisation
Published: 23 July 2024

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Alternative Fuels

MMMCZCS publishes report on preparing tanker vessels for conversion to green bunker fuels

Converting tankers to green fuels can be technically and economically feasible when carefully considered in the context of fleet transition planning and asset age profiles, says MMMCZCS.

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MMMCZCS publishes report on preparing tanker vessels for conversion to green bunker fuels

The Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping (MMMCZCS) recently released its latest publication that sheds light on the technical, economic and environmental impact of preparing tanker vessels for conversion to alternative bunker fuels.

The publication titled ‘Preparing Tanker Vessels for Conversion to Green Fuels’ aims to understand the technical requirements and cost of converting from fuel oil to methanol or ammonia and from liquefied natural gas (LNG) to ammonia.

The publication outlined the project results related to converting tanker vessels to methanol or ammonia fuels.

“To decarbonise the global shipping industry, the world fleet needs to transition to using alternative fuels,” it said.

“However, shipowners are met with a big scope of challenges as they build their decarbonization strategies and determine how to most effectively time their investments in alternative fuel and technologies.”

The report considered reference designs for two types of tanker vessels: LR2 and VLCC. 

These vessel types are two of the largest in the tanker segment, often travel long routes, and have a high fuel consumption ― therefore, they can provide a good illustration of the economic and environmental impacts of different choices relating to vessel conversion. 

For each vessel design, the center defined five levels of preparation for alternative fuels, ranging from no preparation (Level 0) to a dual-fuel newbuild ready to operate on methanol or ammonia (Level 4).

For the LR2 design, the center’s model indicated that the total add-on cost of newbuilding and conversion to operation on methanol or ammonia, depending on preparation level and range, is:

  • 14-27% of the cost of a standard fuel oil newbuild for fuel oil-methanol conversions
  • 25-42% of the cost of a standard fuel oil newbuild for fuel oil-ammonia conversions
  • 47-62% of the cost of a standard fuel oil newbuild (or 21-34% of the cost of an LNG newbuild) for LNG‑ammonia conversions

 The main takeaways from its publication are:

  • Converting tankers to green fuels is technically and economically feasible with careful fleet transition planning and consideration of asset age. The industry possesses the necessary technology and engineering expertise for these conversions.
  • The economic impact of conversions varies based on the chosen green fuel and vessel range.
  • Conversion to alternative fuels affects a vessel’s operating envelope due to differences in energy density and fuel tank size requirements.
  • To maintain the same operational range as fossil fuels, shipowners may need to add tanks on deck (impacting DWT) or sacrifice part of the cargo capacity for fuel tanks.
  • This project focuses on options that reduce the vessel’s operating range but preserve its cargo capacity. Such solutions are believed to have commercial applicability based on industry knowledge.
  • Conversions after ten years of operation on fossil fuels can still considerably reduce a vessel's lifetime greenhouse gas emissions, though financial viability of conversions at this stage of the vessel’s lifetime must be considered.

Note: The full report by MMMCZCS can be viewed here.

 

Photo credit: Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping
Published: 23 July 2024

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Alternative Fuels

Argus Media Q&A: Aviation may pull feeds away from marine, says BV

Biofuel feedstocks could be routed away from marine fuels to meet demand from the aviation sector if the latter is willing to pay higher prices associated with sustainable aviation fuel, says Bureau Veritas.

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Biofuel feedstocks could be routed away from marine fuels to meet demand from the aviation sector if the latter is willing to pay higher prices associated with sustainable aviation fuel (SAF), Bureau Veritas (BV) Marine & Offshore's global market leader for sustainable shipping Julien Boulland told Argus. Edited highlights follow:

19 July 2024

Marine biodiesel has been the largest alternative fuel uptake, with over 1mn t sold in Rotterdam and Singapore last year. But with Argus assessments showing premiums above $225/t to VLSFO dob ARA, how do you see marine biodiesel demand in the medium- to long-term?

Shipowners and ship operators have to run an individual cost-analysis on whether the premiums could be offset by potential savings under EU emissions trading system (ETS) and FuelEU Maritime regulations, as well as any future regulations such as the International Maritime Organisation (IMO) economic pricing mechanism.

In terms of emissions, biofuels still emit CO2 on a tank-to-wake basis, but less on a well-to-wake basis compared to their fossil equivalents. This will also vary depending on the feedstock for the biofuel as well as the production process.

Under the current IMO regulations for energy efficiency, including the Ship Energy Management Plan (SEEMP) and its requirements for fuel reporting (DCS), there might be some indirect commercial benefits for owners, too. For example, a better CII (Carbon Intensity Indicator) score may make a vessel more appealing to charterers and help its owner secure more favourable rates.

There are also other factors to consider, such as Scope 3 emissions rights, which can influence demand, as we currently see from voluntary demand from cargo owners seeking those documents.

But this will also have a geographic impact on demand, as larger container liner companies usually utilise the east-west route and they might prefer to opt for bunkering the marine biodiesel blend in Singapore due to lower prices.

What are the risks associated with bunkering marine biodiesel in relation to conventional ship engines? How significant is the recent FOBAS report that implied a correlation between the use of "unidentified" biofuels and engine pump injector damage?

We have supported our shipowner clients in numerous pilots to trial biofuels such as fatty acid methyl ester (Fame) and hydrotreated vegetable oil (HVO) in variable blends.

Overall, these trials have gone smoothly, but we have learned a few things along the way.

Firstly, engines do not need to be modified, but since biofuels have slightly different physical properties, it is necessary to find the right engine adjustments. A very good knowledge of the fuel properties is key in determining the right adjustments, and the new revision of ISO 8217 on marine fuel specifications is crucial in supporting this process. Another key finding is the importance of receiving full information on fuel characteristics from the supplier. Finally, BV plays a key role in ensuring full fuel certification on several aspects, including sustainability and physical properties.

Used cooking oil (UCO) can also feed into SAF and with potentially greater refining margins. Do you think some feedstocks will be pulled away from marine?

When it comes to methanol, we believed marine would take up more of the feedstock compared with the chemicals industry due to greater willingness to pay larger premiums.

But with biofuels, it seems to be the other way around where aviation could end up pulling biofuel feedstocks away from maritime. In terms of fuel consumption, the marine and aviation industries are comparable but if aviation are willing to pay more, then it will likely get more of the feedstocks required to produce SAF.

What are the implications of the new ISO specifications, what are the key takeaways for marine biodiesel uptake?

More has to be done, but now we have parameters for assessing biofuel blend specifications.

It was very well accepted by the industry, and now operators and shipowners have a standard to rely on. 

But it doesn't resolve the question around feedstock cross-industry competition. However, it does also open the door for off-spec Fame residue blends to become ISO-certified — depending on further testing.

With IMO aiming for "global regulations for a global market", how do you see conflicts between different regulations affecting the market?

We are closely following the IMO development process for a global economic pricing mechanism.

IMO has assigned a working group of technical experts to look at this mechanism from an apolitical perspective.

In terms of potential regulatory conflicts, we have the example of the Netherlands, where the Dutch emission authority requires the delivery of Proof of Sustainability (PoS) certificates for applying to the scheme of Dutch renewable tickets (HBE-G) which can be traded, but this PoS cannot be used for other purposes, such as the EU ETS. To circumvent this hiccup, we may see the development of new digital certificates, such as an accompanying ISCC-certified Proof of Compliance (PoC).

By Hussein Al-Khalisy

Related: FOBAS announces publication of ISO 8217:2024 marine fuel specifications and FAQs

 

Photo credit and source: Argus Media
Published: 23 July, 2024

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