With regard to the new sulphur cap of 0.5% w.e.f. 1st Jan 2020, list the challenges likely to be faced onboard. What are the options in case a vessel is unable to get compliant fuel.

Challenges likely to be faced onboard with the 0.50% sulphur cap (MARPOL Annex VI Regulation 14):

• Fuel availability and quality: compliant low-sulphur fuel (0.50% or 0.10% in ECAs) may not be available at all ports, or may be of variable quality (e.g. high viscosity, instability, incompatibility when blended, high pour point, or the presence of cat-fines/catalytic fines).
• Fuel management: the need to manage the fuel changeover (from high-sulphur to low-sulphur fuel) before entering an ECA, with the required changeover time and the record; the risk of incompatibility when mixing fuels in the tanks.
• Machinery operation: low-sulphur fuels (especially the new blends) may have different properties (viscosity, lubricity, ignition quality) that affect the engines, fuel pumps, injectors and separators; the risk of fuel-related problems (e.g. poor combustion, deposits, filter clogging, waxing in cold weather).
• Storage and handling: the need to segregate the compliant fuel, manage the tank capacity, and handle the fuel's properties (heating, viscosity control).
• Compliance and documentation: the need to maintain the bunker delivery notes (BDN), the fuel changeover log, and the records to demonstrate compliance; the risk of non-compliance (detention, fines) if the fuel is found to exceed the limit.
• Cost: the higher cost of compliant fuel, and the operational cost of the changeover and management.
• Scrubber operation (if fitted): the need to operate and maintain the exhaust gas cleaning system correctly, and to manage the washwater and the sludge.

Options if the vessel is unable to get compliant fuel:

• Use an approved equivalent method: an exhaust gas cleaning system (scrubber) that achieves an equivalent SOx emission reduction, allowing the use of higher-sulphur fuel (subject to the approval and the washwater requirements).
• Use a compliant fuel from another source: obtain the low-sulphur fuel from a different port/supplier, or carry the compliant fuel from a previous port.
• Blend/use the available fuel carefully: if only high-sulphur fuel is available, the ship may use it only if it can demonstrate that compliant fuel is not available (a "fuel oil non-availability" report), but this is subject to the flag/port State's acceptance and the ship must take all reasonable steps to obtain compliant fuel; the ship should report the non-availability and the steps taken.
• Use shore power in port (where available) to reduce the fuel consumption and the emissions.
• Plan the voyage and bunkering to ensure compliant fuel is available at the next port.
• The ship should follow the MARPOL Annex VI requirements and the flag/port State's guidance on fuel oil non-availability, and document the situation.