In a world facing complex environmental challenges, the best legislative responses are always evidence-based. Whether it is a complex decision on transport infrastructure, where to build more houses or whether or not build a waste incinerator, we all hope that the big decisions which affect us, our families, our businesses and our societies will be made by legislators who have carefully and dispassionately considered the evidence.

Scott Poulter, Executive Director of Pacific Green Technologies

Scott Poulter, Executive Director of Pacific Green Technologies

Emotion-based policy is never a recipe for successful long-term solutions in the complicated real world. But emotion seems to be the order of the day for some port authorities.

This year a handful of port and regional authorities announced bans on open-loop wet scrubbers in their waters, citing concerns over the discharge of process effluence containing sulphur. These decisions fly in the face of their obligations under Marpol Annex VI and in many cases have been made without any reference to any scientific study or research. Not to mention the higher toxicity and particulate emissions of non-scrubbed low-sulphur fuels versus scrubbed fuels.

But rather than simply decrying the unscientific, populist approach taken by some port authorities to the issue of discharge waters from scrubbers, we need to better understand how policy makers think. We need to understand that the authorities, under pressure from newspaper headlines, social media and public opinion, only have time to gather limited information before they make fast decisions. A risk adverse public expects quick verdicts and quick fixes

Policy makers will therefore try to gather evidence as quickly as possible and they will also draw on emotion to come up with “solutions”. They will potentially have made their choice before the shipowner or scrubber manufacturer has time to say: “more research is needed.”

Make the emotional case

As an industry we need to understand that policy makers don’t just listen to scientific arguments, but also to emotional appeals and simple stories. We need to calibrate our lobbying and public outreach accordingly. We need to explain some of the basic science, like the fact that sulphates are naturally already present in the sea. Indeed, if all the sulphur in the world’s seas were removed it would form a 1.7m thick layer around the earth. All the sulphur in all the known oil reserves would add only another 10 microns to this layer. We need to simply and succinctly explain that scrubbers are a positive and proven technology which will save hundreds of thousands of peoples’ lives.

But we are pleased to note that there is one very important corner of the maritime industry where scientific evidence is put at the heart of any decision: the International Maritime Organization. As one of the largest scrubber manufacturers, Pacific Green Technologies welcomes the decision by the IMO to work with the United Nations’ Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP) to assess the available evidence relating to the environmental impact of discharges of exhaust gas cleaning system effluent. Its findings will be presented to the Pollution Prevention and Response (PPR 7) meeting in February 2020, with a target completion year of 2021. PPR 7 is expected to further review the documents that were submitted to the recent MEPC 74 in relation to the newly approved output. PPR 7 has been tasked with refining the title and scope of the output and will report the outcome of its consideration to the IMO’s Marine Environment Protection Committee (MEPC).

But where does the ongoing debate and uncertainty leave the ship operator thinking about installing a scrubber system? Our message is simple: invest in an open-loop, hybrid ready system. These do of course come with a price-tag attached, typically a 15% premium. However, they will give ship operators the flexibility they need. Flexibility will be the key to success for any shipping company navigating the complexities of IMO 2020.

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