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Hope for the future

The enforcement of the new legislation must be stepped up to ensure that it does
not pay to cheat.
The archaic enforcement method of spot checking bunker delivery notes and fuel
samples is cumbersome and not very accurate. The only way to quickly make
progress is through direct emissions monitoring in the funnel. That can record
exactly what the emission is for the ship at any time and at any location. Such
equipment is available, and such a system will remove the bureaucratic paperwork
for both crew and enforcement authorities.
Automatic and electronic emissions data collection can also be used for measuring
CO2 emissions which will have to be acted upon. Reliable data about the emissions
will be needed to be able to design a proper reward/penalty system. Let us invest in
new technology and save us the manual spot checks which are not that reliable
anyway.
Scrubber systems can remove almost all the SOx in the exhaust gas and other
pollutants as well. Such systems are however expensive to retrofit on ships.
However, nothing should prevent IMO of making it a requirement to have on all new
ships.
With the mentioned enforcement problems of the new legislation, perhaps the best
way to make progress would be to create incentives for those shipowners/operators
who invest in continuous monitoring equipment and scrubbers. Let the incentives
be financed by leveraging a small clean air fee on all containers/tons of
cargo/vehicles that move through a port. This should preferably be paid by shippers
and consignees as the shipowners need to spend their money on upgrading their
ships. Let ships with monitoring equipment and scrubbers get an incentive and use
the rest of the income for stricter controls the old-fashioned way. This is just one
idea. If there is a political will to incentivise the maritime industry, then get the
involved parties together and find a solution that benefits the clean ships and
penalises the cheaters.
Considering it makes socio-economic sense to lower SOx emissions in North Europe
and North America, why not in other coastal areas around the world? It would make
sense for EU to include all EU coastal areas in a SECA which also could give
opportunities for simpler regulation and enforcement.
Larger SECAs will make it more feasible for shipowners to invest in scrubber
systems. Currently, for ships that perhaps only spend six weeks per year inside a

SECA it may make little financial sense to invest in such systems and just pay for
more expensive fuel instead. The longer time to be spent in a SECA, the more
attractive the investment in a scrubber system becomes. Furthermore, the
scrubbers systems only become better and cheaper as increased sales allow for
additional research and development spending by the manufacturers.

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