Diesel and Marine Group director and European Maritime Independent Suppliers Association (EMISA) board member, James Hogg, presented a strong argument for a combination of testing and onboard monitors at the Sulphur Cap 2020 Conference in Amsterdam last month. “Testing is problematic” Mr Hogg said to a crowd of industry representatives, noting the number of variables at work including timing, locale, frequency and even the fuel tank chosen.

“I would’ve thought that it would be better to look at testing fuel when you bunker. By testing at the bunkering stage, you will get an average, and it will give you a pretty good figure,” he said.

Hogg was firm in his stance that while compliance with the new 2020 regulations may cause difficulty in the short term, the industry has a responsibility to society to abide by them. “This is also partly in your own interests. A strong enforcement system will discourage cheating,” he said.

He called for the industry and enforcement bodies to work together to ensure that enforcement of regulations is legally robust, practical, effective, consistent, and fair, across ports. “We need to look at the cost structure of enforcement. The whole cost structure, not just the costs that fall on shipowners.”

The talk iterated how the fragmentary landscape that currently defines emissions regulations enforcement makes it difficult to achieve consistency. “Historically speaking,” he said, “each nation can establish their own regulations about what is permitted in ports. There has been a lot of inconsistency between flag states, and over time more pressure has been placed on port states and coastal states.”

The real problem facing port states is getting clear evidence to determine compliance. Inaccuracies plague onboard paper records, and testing is problematic. While alternative forms of assessment are available, many of these are cost prohibited, limited in scope or ineffective in certain situations.

Drones, for example, costing somewhere in the region of €5 million, are too expensive for many port states, and are restricted by a limited range. Additionally, there is always a risk of crew members attempting to compromise the data.

“Sniffers have a role to play, perhaps,” said Hogg, “but I don’t believe sniffers bear discussing any further. They are simply too geographically limited, and the results too easily manipulated… satellites, too, are too inaccurate to reliably cut through disturbances in the atmosphere.”

The solution? On-board monitors that can provide the clear evidence that is required – data in digital format that can be electronically transmitted.

The data would then sit within the MRV reporting system and would cover the transition from SECAs to global enforcement. A computer would analyse the data, and inform you whether or not a vessel has complied. On top of this, they are relatively inexpensive.

“An effective system of enforcement is a cheap system of enforcement,” said James, while at the same time acknowledging that shipowners may not entirely agree.

“Installation of onboard monitors is between €60-90,000. Other downsides include the time needed for installation, the fact that the systems are not tamper proof, and reliability issues.”

These costs, while valid, could be offset by considerable savings for vessel owners. For example, monitors provide a single method of compliance for all emissions regulations, negating additional costs. Additionally, only one annual inspection would be needed to verify compliance. Frequent fuel testing would no longer be required, and the automation of the data collection would save further time and money for both shipowners and enforcement authorities.

The appeal of on-board monitors should become more apparent as shipowners realise that the system could meet current and future EEOI (Energy Efficiency Operational Indicator) requirements.

There is also the possibility of the NOx parameter system becoming redundant. “I personally believe the NOx parameter system is something of the past. We shouldn’t be using this kind of guesswork. It’s yesterday’s technology, as we all know from the Volkswagen example,” said Hogg.

“Is there any other solution available than mixing the testing of fuel with exhaust gas monitors? I leave that as the question.”