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The 2020 Sulphur Cap on Shipping – scrubbing some of the hot air


The shipping industry has been overwhelmed by the amount of MARPOL Annex VI over-analysis during the summer of 2018. This article will try to breach a few myths that seem to have gained traction in the frenzy.


Myth 1: “The industry needs time to adjust”


What The Herd hasn’t done in ten years, it won’t do in an extra two or five years. By The Herd I mean shipowners, cargo interests, oil majors, cocktail shakers (as in traders that take the majors’ produce and apply mixology), and engine/ship/equipment manufacturers. 


The discussion on a ‘stepped’ plan on Sulphur happened between 2004 and 2006 as MARPOL Annex VI came into force; anyone who wanted to make their input could have done so then. In 2008 I sat in a company-wide presentation by the Bunker Manager of the shipowning and operating group where I worked, who talked us through a diagram consisting of a downward staircase stretching away over 2 decades (a graphical representation of allowable sulphur content in % m/m). The 2020 step was there, just as the 2010, 2012, 2015 steps. As to a hypothetical ‘huge change’ in circumstances or technology, neither happened since.


So lets be realistic: when the first limitations on Fuels were introduced, the commercial side of shipping didn’t even realise they had happened. From the first Emission Control Areas and introduction of International Air Polution Prevention Certificates through to the stepped changes in 2008 and 2010, suppliers did their thing and engineers sorted the resulting technical challenges. So at each stage, if you looked for it, product was there. 


Then 2012 loomed, and the worldwide limit went down from 4.5% to 3.5%. Traders at the oil majors had to rehash their supply patterns of sweet vs sour crude, liaising with their colleagues in the refineries to meet their demand by which to turn out the new product. Come the date, product was there.


Importantly, the U.S. EPA formalised the process by which to file a Fuel Oil Non-availability Disclosure (a “FOND”) by means of filing a Fuel Oil non-Availability Report (a “FONAR”). This guaranteed that bunker spots and shipping lanes peripheral to the affected region did not suffer disruption or windfalls, but in time adjusted supply to new demand. This form of instrument is absolutely critical to the stakeholders’ decision-making process for 2020, and I will expand further ahead.


Unsurprisingly, the 2015 step arrived 3 years after 2012 (#algebra). Now 2015 was a serious change; 0.1% sulphur content was a very high standard to reach. But again come the date, the product was there, at least in form of Distillate initially, then Fuel Oil in Europe initially, then Houston. 


The IMO’s MEPC decided to a) review this ‘downwards sulphur staircase’ in 2016 after the 2012 and 2015 steps were bedded in, and b) to then proceed with the 2020 change as scheduled. This earned my respect and that of many of the bunker-cognizant people I talk to. We guess they have concluded like us, that the only way for the product to be there was if they stared down the oncoming headlights just like in all the previous steps.


Myth 2: “The situation has become clearer in 2018”

Also phrased as “Now that it has become apparent that the choice is binary, between compliant fuel or scrubbers…”


Behold ‘there is nothing new under the sun’, at least in respect of this particular arena. In 2005, Regulation 14 of MARPOL Annex VI already stated that exhaust gas treatment or other equivalent abatement technology was the alternative to buying expensive (and at that point largely unavailable) compliant fuels. Smokestack scrubbers have existed for nearly a century, and for many decades specific content scrubbers have been developed and improved. 


But the size and value of a marketplace dictates its pace of development, as well as the compression of margins. So the initial steps in sulphur content did not bring to bear enough price pressure on compliant fuels for the wider industry to sit up and pay attention, and for the abatement suppliers (e.g. scrubbers) or alternative fuels (e.g. gases, bios) to enjoy a thriving marketplace.


The only new thing under the sun (but not really, because it was predictable!) is that now, the potential market for abatement technology is ‘everybody’. And also predictably, pressures on the feedstock markets and increased desulphurisation units in refineries will push up the price of the Compliant Fuel – and perhaps the ‘old’ high-sulphur fuel too.


But it is not actually a “binary choice between Compliant Fuel or Scrubbers”; the latter option is actually “Abatement Technology”, with a raft of choices within it. But from those, The Herd is going for the open-loop scrubbers en masse. This is solely because of the need for a Level Playing Field in our near-perfect-competition world of shipping, and that the IMO hasn’t addressed the discharge of these effluents. I.e. if nobody is going to pay me for a high-OpEx Membrane Scrubber or Dry Scrubber, or to discharge sulphurous sludge from my vessel’s closed-loop scrubber, or from my in-line fuel scrubber, how can I choose one of these other technologies, and still compete with The Herd who will be legally discharging the sulphur and the other residual chemicals to the oceans?


On the alternative of ‘ready to go’ Compliant Fuel for existing vessels, one thing hasin fact become clearer. ExxonMobil, Shell, Sinopec, the list grows by the month – all state they already in field tests and will be in production for the 2020 deadline. And most of them are talking about straight-run 380 CST Fuel-Oil, not the mixology which I have heard some Chief Engineers speak of with rolling eyes. It would appear that the producers have not been asleep; it would appear that, as on all the other key dates, come the time, product will be there.


Myth 3. “The only practical Compliant Fuel option will be Gasoil”

Also phrased as “It will be very risky to remain dependant on sourcing compliant fuel”


Lets get this clear: refineries have always had these magic things called desulphurisation units. Meaning, one can “scrub” the fuel just like one can “scrub” the exhaust gas; indeed there are on the market mature offerings for scrubbing the fuel on board the ship prior to consumption. Done on an industrial scale in a bunker-production area it’s not necessarily a big deal for an oil major. If there were a wide market – say, 85 or 90% of the ships of the world that didn’t have scrubbers– it would bring economy of scale.


Some marketplaces already provide 0.1% low-sulphur fuel oil, albeit at prices (and specifications) pretty close to gasoil. Reportedly over 2 million tons were traded in Rotterdam last year; during 2017 it has become available in Houston as well. Prices have been at a discount of 10 to 20% below the gasoil alternative.


Besides, there are ‘sweet’ crudes out there that come very close to the 0.5% sulphur content already – which surely was one of the factors in the IMO’s choice of this particular number. Both of these points would back the claims by most of the oil majors during the last 12 months that they will be ready with compliant Residual Fuel, i.e. we will not be competing with “city diesel” to run ships round the world, and we won’t be paying highway gas station prices.


Myth 4. “Not knowing the fuel price spread, Return On Investment [for abatement equipment] is risky”


Well that would require the difference between compliant fuel (the new low-sulphur product) and non-compliant fuel (the old high-sulphur product) to tend to zero; or for the old product to become widely unavailable. I see both concepts as unreal. 


The formula for the question “to buy or not to buy the scrubber” is as follows. In its greatly simplified form e.g. without finance costs, increased fuel consumption, or scrubber running costs, it goes a bit like this:


Payback time= Up-Front Costs, divided by fuel cost Savings per year

Fuel cost Savings per year= Tons of Fuel this ship usually spends in a year, times “The Spread”

“The Spread”= $/ton difference between regular high-sulphur Fuel Oil and the 0.5% Fuel Oil, in the years after 2020


So, to take conservative figures all round for an example - say for a US$ 2m upfront cost, on a ship that typically burns 6,000 tons of FO a year, if the ‘spread’ were to average $150/ton after 2020, would get its investment paid down in


Payback in years = 2m / (6000 x 150) = 2.2 years


But of course “the Spread” is the factor where all the non-practitioners fall apart because the market isn’t there yet.


We have just seen a recent uttering by a listed shipping company that whilst significant CapEx is required for fitting scrubbers, there is “virtually no visibility of a return on capital” and this is a reason for not doing it. With no personal disrespect, such a statement could only be made if there had been no interview with seasoned professionals taking a broad view of the petrochemical industry (which is the recurrent story of most of the utterings of 2018 on this matter).


I say there is good visibility of a range of payback periods – if considering that all other investment decisions in shipping are based on even wider ranges rather than exact numbers. Even the consumption per year is more variable than the spread: if port congestion takes off, a dry bulk vessel could see the annual consumption plummet as it remains at anchor burning 2 tons a day; if oil trades envisage a particular situation in the near future, tankers’ consumption plummet as they become floating storage units.


For practitioners such as myself, the range of payback periods (to simplify the term) for all vessel sizes, for newbuilds or average retrofits, sit between less than one year, and 4 years - even if skewing the variables to the extremes (90% probability).


The 4-year result is pretty extreme i.e. spread at less than $100, which has a likelihood below 2% in my modelling. Of course a complicated, expensive retrofit on a small or economic vessel would tend towards these longer payback times. 


Myth 5. “It will be very complicated to value a scrubber-fitted ship”


When considering the decision of fitting a fuel-saving device – say, flow fins, mewis duct, rudder bulbs – there is no debate as to who will pay the CapEx, and where the Return on Investment will come from. That is, the Owners pays to fit the device (whether newbuild or retrofit) and the supplier/yard warrant its effectiveness. The Owner then takes the ship to market as being faster and/or consuming less tons of fuel per day; Time-Charterers then pay more for this ship than they will for the competing thirstier / slower vessel, because the Voyage Calculator shows better returns on their business. On Voyage Charters, the Owner quotes slightly more competitively than the thirsty/slow competing vessel and keeps the remaining savings on fuel and/or time. 


It deeply mystifies me that the community be speculating such complexity around remuneration for the scrubbers (or other sulphur emission abatement devices). Exactly the same market view will happen, naturally. Three ships ballasting towards a loadport get rated when competing for a Time-Charter Trip:


Ship A, non-scrubber= 13 knots at X tons a day of LSFO @ $600/MT = rated $14,000/day

Ship B, non-scrubber, Eco design=13 knots at X-Y tons a day of LSFO @ $600/MT = rated $14,500/day

Ship C, scrubber-fitted, Eco design=13 knots at X-Y tons a day of HSFO @ 400/MT = rated $17,400/day


Of course the unknown figure today, for those on or drawing up 5-year timecharters, is “The Spread”. But again there is nothing new under the sun: those familiar with long-term Contracts of Affreightment, from tankers to dry bulk and containers to parcels, have always dealt with the unknown future bunker component by means of a Bunker Adjustment Factor. The new fashion for the BAF in a scrubber-fitted ship will be about The Spread rather than the Platts price for 380CST Fuel Oil at Singapore.


Myth 6. The market will heave as it crosses into 2020


Regulation 18.2 of the Annex VI of MARPOL was designed long ago with a view to ironing out market anomalies due to lack of, or restricted, availability. The wording specifically states that a vessel will not need to deviate from its intended voyage – i.e. no availability in its intended ports of call – or be unduly delayed, i.e. restricted availability for which it would have to wait. 


It was important to the shipping world that in 2012 the United States laid out a black-and-white procedure by which vessel operators could make their decisions when faced with non-availability of compliant fuel (the FOND/FONAR mechanisms referred to earlier). This has been used in good faith over the years, and is what has been used as the yardstick in the discussions around worldwide availability (or not) of compliant fuel in 2020.


At a Marshall Islands Registry event earlier this year, the attending representative from IMO’s MEPC stated on no unequivocal terms that “there will be a FOND / FONAR mechanism”, and that the Committee had plans to produce guidelines for Port States to implement such mechanism in a relatively standardised form. 


In short, if compliant fuel is not available somewhere in the regular trading of the vessel, it will be the owner or operator’s problem. This has paved the way for those taking the decision to move onto use of compliant fuel in 2020, either as the longterm choice, or whilst awaiting the definition of market prices, shipyard availability, and the maturing of the equipment supply market.


So what are my guesses, and recommendations?


a. Favour “Eco” measures/vessels, whichever your chosen path


- With or without scrubber, fuel costs will increase

It is fair to say that the average price should go up with the need to either de-sulphurise or use mainly sweet crude, and re-jigging logistics for non-compliant product – therefore whichever your chosen path, the more economic ship will become worth even more.

I can see the argument of those saying that non-compliant fuel will get cheaper as demand shrivels to only scrubber-fitted vessels, currently expected to be less than 10% of the world fleet. However being familiar with the industry, my opinion is that two factors will counter that: firstly, production capacity in the marine segment is limited, and a large part of it will be switching to compliant fuel, because 90%+ of their market will be in that segment. 

Secondly, the local logistics at point of supply. Off the main East-West axis, storage and delivery means are surprisingly limited; they will have no interest in sacrificing capacity for cut-rate product that only attends 1 in 10 of the ships calling.


- Unpredictable geopolitics around oil price

The cost of fuel (bunkers) for a vessel is dependent on geopolitics and many macro factors. The outlook in Q4 of 2018 is jittery to say the least, because the use of renewable energy is on the increase but total demand is too, whilst several very large sources of crude have become uncertain for several different reasons. In the last quarter, we have seen the barrel of crude both climb and drop more than 25% whilst traders and analysts seem unable to provide coherent rhyme or reason. 


- GHG pressures coming, NOx, EEDI…what next?

Sulphur caps are easy by comparison: few are paying attention to “the big one”, because most current decision-makers are hoping to be retired by 2050 (but that won’t be much fun in a world decimated by climate change). It is also fair to expect more unilateral measures from Port States (or even more local, e.g. California). Whatever form future restrictions or measures take, the ship with the more efficient engine, hull and appendages is in the best starting position compared to the broader field of competition. 


b. Bunker Purchasing patterns will change, whichever your chosen path




Whilst all the majors have taken to the lectern and the press release to state that they will be ready to supply the market with compliant fuel oil, in the same breath they confirm that their products will be even more diverse from each other than their current offerings. At the Q&A of a 2020 event, I heard the global head of R&D for Shell state that, whilst they had overcome the challenges with their product as to stability, lubricity etc, and competitors were as well, she was quite sure that no comingling would be viable with the product of other producers.


Practical measures:

- Avoid part-filling tankswhen making the bunker plan for a fixture or a particular voyage.

To achieve this, the question asked of the Master or the Owner needs to evolve from just the total Remaining On Board and amount Required  to Safe Reach X, and include the request for a “tank-wise” distribution of the Remaining On Board. For Time-Charter Trips, it will usually require mechanisms to price the settlement of the marginal excess or lack of Bunkers On Redelivery. 

- Partition tanks if possible

If engaged in spot trading and your ship has three or less Fuel Oil tanks, when of the next scheduled dry-dock, get quotes for gas-freeing a large tank, erecting a partition, fitting the extra pipe and valve (i.e., making two tanks from one), and Class certification. In worldwide dry bulk tramping, this will pay back in 2 years.

- When buying a ship,

All things being equal, favour the sister vessel that has a higher number of small tanks rather than few big ones!




It is my considered opinion that ‘high-sulphur’ Fuel Oil will remain in production, for the simple reasons that a) there already is a segment of market aiming at it, b) production is fully on-stream, and c) there is sour crude to be got rid of. 

Conversely it is my opinion that it will not be distributed and stocked everywhere, as Compliant Fuel will. Tankfarms, those unsightly big white pill-shaped things along the shore, are gold to traders and retailers, as are the delivery barges. Like any retail, having more Stock Keeping Units (SKUs) for the same volume of sales is anti-economical. Given a limited number of tanks, and for of every 10 ships showing up, 9 are looking for one product, would they bother stocking the other product? I would expect that suppliers off the main E/W trade axis (Rotterdam / Suez / Singapore / Panama / Houston), might not bother stocking high sulphur Fuel Oil at all.


Practical measures:

- Fill up where its available and cheap.

The payback on the CapEx investement depends on buying cheaper high sulphur Fuel Oil. When making the bunker plan for a fixture or a particular voyage, consider if you already know the next point of supply; else, fill it up. There are few deadweight cargoes in the wet or dry sectors where lost freight would cover the likely difference of $100/MT or $200/MT between the fuel types. 


c. Scrubber-ready newbuilds are a no-brainer


Very low cost to include additional piping / cabling / valves when at plan stage; if just leaving space, it can be virtually at no cost at all. A year or two after the deadline, the fuel price ‘spread’ will be known, scrubbers will be cheaper and better, yards will be hungry for fitting work.


d. Retrofit scrubbers are clearly case by case


To be practical, the real risk for retrofits is that of all and any technological investments: being the Early Mover, whereby you buy the machine before the improvements and before the price plummets with the fierce competition. In this case, there is the additional constraint of shipyard and technician availability which will likely command a premium for those not ready to hold their ground on pricing. Sorry to those who already committed when there were only 3 suppliers, with 1990s technology; my respect to those who are going to burn Compliant Fuel initially and play the scrubber market a bit after the frenzy dies down. 


Otherwise, the main issue is about how much real-estate is available in the engineroom and up the side of the main-engine exhaust within funnel casing. It is relatively cheap to re-route some cables and pipes to create space, but likely a showstopper if an auxiliary engine / generator needs re-siting. 


e. Personal view on the future spread


As I have stated above, I am not a believer that the 3.5% product will drop significantly in price as a result of this change; however the 0.1% gasoil may go up.


A year ago, when only geeks and nerds were talking about this subject, I was telling colleagues that my bets for eventually settled price level of the new 0.5% sulphur fuel was around 75% of the price gap between the two existing popular grades (3.5% fuel oil and 0.1% gasoil). Since then, I have been reassured to see that large bunker traders have publicly stated similar views.


But since then, the growing chorus of major producers saying they’ll be ready, the low proportion of scrubber adoption, and the confirmation by IMO that they will roll out a FOND/FONAR procedure, makes me think that the compliant fuel may end up lower on that % scale – perhaps at 60% of the gap, or even halfway. Note, this doesn’t necessarily mean a smaller Spread numerically, because of the influence this 0.5% segment will have on the 0.1% gasoil if the two compete.

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