Biofuel Bunkers: Industry Makes Progress as IMO Stalls on Guidelines

IMO Headquarters. File Image. Image Credit: Ship & Bunker

If the number of companies reporting biofuel bunker trials is any indication, industry interest in the alternative fuel continues to grow.

And it's not just trials of biofuel, with the likes of cruise line Virgin Voyages last month saying it plans to set up long-term supply contracts with biofuel providers Argent Energy, GoodFuels and Twelve, and seeks to establish more partnerships along the same lines over time.

The attraction of biofuels is easy to understand: they can dramatically reduce lifecycle CO2 emissions and are 'drop in' replacements for traditional oil-based marine fuel, meaning today's vessels typically require no modification to use biofuel.

In contrast, the use of almost all other candidate alternative marine fuels of the future - hydrogen, ammonia, methanol, LNG, etc - require specific engines and / or fuel systems.

In other words, biofuels offer one of the only instant and commercially viable routes for most of the current fleet to dramatically cut GHG emissions today.

Still, there are several considerations ship owners and operators must make before using biofuels, not least of which is because the use of biofuels is still a relatively new phenomena within the marine fuels space and as such not all the appropriate regulations and guidelines are currently in place.

IMO

Unfortunately, progress in this area at International Maritime Organization (IMO)-level has been a little lacking, and the most recent IMO Sub-Committee on Carriage of Cargoes and Containers (CCC 8), that took place from 14 to 23 September, did not work on advancing the guidelines for low-flashpoint biofuels at all.

This subset of biofuels falls under IMO's work to develop interim guidelines for the use of oil fuels with a flashpoint between 52°C and 60°C. This covers not just biofuels, but all oil-based fossil fuels, synthetic fuels, and any combination thereof.

"This work has stalled chiefly due to a raft of new safety concerns being raised by some parties. There have also been calls by some to drop any further work on this as there has not been a shortage of distillate fuels meeting the minimum 60°C flashpoint limit in SOLAS to meet demand for lower sulphur fuels," the International Bunker Industry Association (IBIA) said, who took part in CCC 8.

"IBIA and others have fought to keep this work on the agenda and make progress, and to expand the scope, which was originally covering only oil-based fossil fuels, to include synthetic fuels, biofuels and blends.

"We have emphasised that such fuels are already used in other sectors, and will likely play an increasingly important role in decarbonising transport fuels, including fuels for international shipping. Moreover, fuels with lower flashpoint have been used by ships on inland waterways."

It was agreed at CCC 8 that work in the area will continue, but how quickly this transpires remains to be seen.

NOx

Until then, shipowners wishing to use any biofuel bunkers currently have several regulatory hurdles to overcome, perhaps the most notable of which concerns compliance with NOx regulations.

MARPOL regulation 18.3.2.2 states that "a fuel oil for combustion purposes derived by methods other than petroleum refining shall not cause an engine to exceed the applicable NOx emission limit set forth in paragraphs 3,4,5.11 and 7.4 of regulation 13."

Meeting this requirement in practice does not appear to be an issue. Not only does evidence from test data to date indicate biofuels and blends thereof do not cause excess emissions of NOx, but IBIA has noted that tests submitted to IMO indicate NOx is typically comparable or less than traditional oil-based fuel.

Rather, owners are finding the challenge is performing the appropriate testing to prove a biofuel is compliant. This is because it requires either on-board emission testing and monitoring, or engine and fuel-specific NOx emissions validation testing, with the added complexity of not being able to define a reference biofuel.

One thing IMO has done in this regard is in June introduce new rules that consider blends of 30% biofuel (known as B30) or less be treated in the same way as regular oil-based bunkers.

For those looking to use higher blend ratios, there are other exceptions that can be made.

For one, MARPOL Annex VI provides exceptions for 'Trials for Ship Emission Reduction and Control Technology Research', although IMO has previously noted that ships taking this route may face restrictions from certain ports due to national or local regulations.

Biofuel Ready

In the absence of any further guidance on biofuels from IMO, a number of industry players have taken steps to help those owners and operators who are looking to burn biofuels.

Bureau Veritas (BV), for example, at the end of August released a new 'Biofuel Ready' notation aimed at helping shipowners to be prepared for the use of biofuels or biofuel blends.

"From a general perspective, it is true that biofuels are seen as 'drop in' fuels, meaning that they don't require any changes in terms of storage, handling, or engines. This is a characteristic that distinguishes them from other alternative fuel options, such as methanol, ammonia, or hydrogen," Laurent Courregelongue, Director Rules Development, Bureau Veritas Marine & Offshore, told Ship & Bunker.

"However, when you look at the practical details needed to switch to biofuels, there are still some operational considerations that must be taken into account. Our BIOFUEL READY notation provides a framework for those considerations.

"For example, a technical analysis must be carried out to identify and assess any potential consequences of the use of the specific biofuel or biofuel blend on the engine or boiler performance and available power, NOx emissions, and the safety of the ship given the fuel properties, such as viscosity, corrosivity, toxicity, etc.

"The elements that must be considered in this assessment include fuel change-over, tank cleaning if needed, and any foreseeable fuel compatibility issues, onboard fuel transfer, clogging issues, material compatibility issues, onboard fuel storage, including fuel aging and the possible need for heating.

"In addition, we need to consider the operation of engines, boilers, and other equipment, such as oil discharge monitoring equipment, and importantly, the functioning of safety systems, including fire extinguishing systems. Any change of engine setting or onboard equipment also needs to be identified and documented."

Skuld, meanwhile, noted earlier this month that it is receiving an increased number of technical inquiries both on P&I and Hull related to the use of marine biofuel grades, either as an alternative fuel or for main engine testing for future use.

"Skuld recommends its members and clients who are now using, or intending to use, biofuels to always obtain confirmation from their Classification Society or Flag State for an exemption to use such fuels and also to ask the Flag State for a determination of the NOx emissions in accordance with the relevant provisions of the NOx Technical Code 2008," it said.

"Also, if the vessel has an existing Flag State approval for the use of restricted biofuel blends, to obtain confirmation that higher ratio of biofuels may be used without the need for further NOx emission trials."

Discussion on the full range alternative future bunker fuels will take place at the upcoming IBIA Annual Convention in November.