在IMO 2020硫磺上限法规中提供比具有具体实施计划的船主更复杂。合规性将证明几乎在行业的几个部分中具有深远的效果。

At CMA Shipping in April, we spoke with Joe Gross (President, Connecticut Maritime Association), Jeffrey Lantz (Director of Commercial Regulations and Standards, U.S. Coast Guard) and Rear Admiral John Nadeau (Assistant Commandant for Prevention Policy, U.S. Coast Guard) about sulphur cap implementation, their views on how prepared the industry is for 1 January, and VIDA implementation.

准备IMO全球硫磺帽

康涅狄格州海事协会总裁总裁总裁粗略对行业的准备水平非常积极。他认为该行业正在做它需要做的事情。

"We got together as an industry, we developed the regulatory framework going forward, we are embracing the time-frame, and we realise that there will be an initial cost involved. But at the same time, we recognise that we have an obligation.”

While options for complying with the sulphur-cap are various, in an economic sense he believed it will impact everyone, no matter which compliance route is chosen. “The choices are either to install a scrubber and continue to use fuel oil - where the ship becomes part of the refining process to remove that last bit of sulphur. Or to clean your tanks and use an ultra-low sulphur oil that will be compliant with the new regulation. Whether one of those options has lesser or greater economic benefits, only time will tell,” Gross said.

“I think people are pretty well squared-away for the implementation of the new regulations." – Joe Gross, CMA

“对于那些使用超低低硫燃料油的人来说，他们将在燃料油上花更多的钱。正在选择安装洗涤器的业主将花费约1-2百万美元，以及船上的停机时间那些洗涤器。然后将有一个摊销期限，需要对他们的操作进行考虑 - 当决定安装洗涤器的业主已经支付了单位，并且它们从较低的燃料成本中受益。“

粗鲁先生指出，“业主正在与他们的违法行为合作，无论是他们在宪章或其租船人上有长期船只的业主，协调需要在序列中铺设坦克的垃圾需要完成。“

“They could be cleaning the tanks by hand or chemical dosing. I think people are pretty well squared-away for the implementation of the new regulations."

Mr. Lantz, from the United States Coast Guard, expects some bumps in the road to compliance. He believes confidence in the industry is “relatively high”, but that the industry will need to take appropriate action where needed.

Mr. Lantz said, "Reports are coming in that refineries have taken a very aggressive action to meet the demand for the 2020. From the perspective of the United States Coast Guard, we remain hopeful that issues of non-compliance or unavailability of fuel to be few and far between, but we need to be prepared and take the correct action should something pop up."

DNV GL的KNUTØRBECK-NILSSEN认为，许多问题仍有关于硫磺帽将带来的挑战。

“There's lots of questions about availability, compatibility, and the price. I think everyone has the intention to comply and there are different pathways to comply, whether you want to use scrubbers, or you want to use blended fuels.

“执法问题是一个真正取决于港口国家以及他们将如何执行这些法规。这可能取决于他们的地理位置的显着变化。我毫无疑问，海事行业将遵守。“

来自美国海岸警卫队的后海军上将约翰纳达法指出，由于可用性和燃料成本的差异，法规的管理可能很困难。

"There could be a lot of incentive to perhaps cheat or pursue areas of non-compliance due to price differentials.

“我认为大量的行业真的希望看到监管机构，港口州的当局和国旗国家都聚集在一起，以确保我们在执法中保持一致。我们需要在我们的研究结果中透明。我们都需要分享关于是否存在的信息燃料可用性问题，或者我们发现石油素质的问题。该信息需要与所有利益相关者共享，以便我们可以在我们试图处理可能出现的问题时参考。

“For instance, if I have a ship coming into the United States that was not able to get fuel. Reports need to be created so we can look back and see if others are having the same problem at the same locations, and we can use that information to determine what actions we should take. Again, allowing us to have a level playing field across the board for all stakeholders."

vida在地平线上

The VIDA act establishes a new framework for the regulation of vessel incidental discharges, adding a new Clean Water Act (CWA) which looks to establish a uniform set of standards for the management of discharges incidental to the normal operation of a vessel.

该法令为环境保护署（EPA）负责建立与船舶污染物排放有关的标准，以及USCG负责处方，管理和执行与这些标准一致的法规。

该法案还持续了VGP（船舶一般许可）的规定，并在4年的大约时间内得到了现有的USCG法规。

When asked about the implementation of VIDA, Mr. Lance said that “There are some tight deadlines for both EPA and the Coast Guard. We hope to make it as smooth as possible, and I can tell you that the Coast Guard and EPA are working very closely together to make that happen.

“It's hard to predict when regulations are involved how quickly they can get done, but I think both agencies are very committed to getting it out there and meeting the desires of the mandate.”

海军少将Nadeau指出,“维达是相当有限mprehensive new law passed in the U.S. in December of 2018. It looks at the entire framework for dealing with incidental discharges from vessel operations. It will require the Coast Guard and the EPA to work very closely together. The EPA is the first point of focus of this - to develop the discharge standards themselves. And then we (USCG) will take those standards and apply them to vessels in terms of equipment and operating procedures.

Like Mr. Lantz, Admiral Nadeau believes a close working relationship between the Coast Guard and the EPA is key to the success of VIDA, “…my staff are working with EPA on a frequently to ensure that we stay latched up tight. We recognize that we need to be closely aligned for this to work properly and minimize any unnecessary impacts on the stakeholders and industry."

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