There has been some reporting in the media that might have given the impression that our Association (Hong Kong Shipowners Association) has conflicting views on Emission Control Areas (ECAs), in particular Sulphur ECAs.

It has been the position of the Association, since the revision of MARPOL Annex VI was first considered, that we did not like ECAs.  There were several reasons for this.  

Firstly ships would naturally be changing fuel at the last possible moment before entering an ECA, changing from high heat high viscosity fuel to low heat low viscosity distillate.  This is an operation that clearly can be managed, and many ships are changing fuels before entering Californian waters for instance.  But it is also an operation that can be mis-managed, and as we have seen off California, such mis-management can lead to main engine breakdowns.  We have to recognize in the figures that we have seen, that ships that trade to California are generally the better-managed ships, so the breakdowns that have taken place have to be seen in this light.

The situation is likely to be very different at the entrance to the English Channel ECA.  From 1st January 2015 and for a period of at least 5 years, ships will be switching fuel in a restricted area from a maximum of 3.5% sulphur to 0.1% sulphur.  We are not sure that this is a good idea, but time will tell if our fears are misplaced.

Secondly, we have always thought that ECAs represented regional regulation wrapped up in global regulation.  

It is countries that have the ability and resources to make the necessary research that are able to apply to the IMO to have their coastal areas declared an ECA.  Other countries, quite probably developing countries, do not necessarily have this ability or resources.  The decision to apply an ECA to an area of the world should not be determined on how wealthy or well resourced a country is, but how the local population is likely to be affected by the emissions from shipping.  Perhaps a naïve argument, but one that we have thought is important.  The IMO sets global regulations for global shipping, and IMO regulations should not discriminate against the less resourced countries.

That being said, we now have MARPOL Annex VI that determines areas of the world that are ECAs.  So if we want to reduce emissions from shipping in the Pearl River Delta, and if we are to do this in accordance with global regulation (which, of course, is a necessity) then we have to apply for an ECA.  

We might not like it, but it is the only solution, for the moment.

Arthur Bowring,