pi_circular Compliance & regulationOperational riskDecarbonization & energy Skuld
Voyage planning has always been important, and the new MARPOL Annex VI ultra low sulphur fuel oil regulations coming in to force as of 1 January 2015 will make it even more important to carefully plan voyages and fuel strategies. The development Members will already be aware of the very significant regulatory changes coming in to effect as of the start of 2015 with respect to the maximum permissible content of sulpur in marine fuels in desiganted Emission Control Areas (ECAs), i.e.: 0.10%. This change, which comes with a significant financial factor, will necessitate more careful voyage planning in the future to ensure the right fuel is available, it is clear for what periods it will be used and whether it is possible to avoid entering in to ECA zones altogether, or to limit the time spent within them. Such measures will come with the need to consider both legal and insurance implications or risk charterparty breaches as well as prejudice to cover. In the following sections, the Association will set out some of the key issues and principles which members need to consider. Deviating to avoid ECA zones Given the high cost of ultra low sulphur fuel, or indeed the high cost of installing and operating scrubbers, members may very well consider how best to route their vessels to avoid having to enter Emission Control Areas altogether, or at least significantly minimise the time spent within them. This would no doubt be a particularly keen consideration if the vessel will not ultimately call at a port within an ECA zone and the vessel might just transit through such a zone. It is very likely, however, that re-routing the vessel will present not merely physical challenges but also have consequences for charterparties, bills of lading and insurance coverage. This is because under many charter contracts as well as contracts of carriage the vessel will be obliged to proceed promptly and by the most direct route between given load and discharge ports. A failure to do so, may be
Deviation, voyage planning and low sulphur fuel oil
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