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November 2012www.marinelink.com 35-ated into the level of demand for low sul- fur fuels that is needed to operate withinan ECA. With this knowledge, the refin- ers may be more prepared to invest in more production, which will ensure thatthere is enough product to meet demand. With a current premium in the region of $200-350 between low and high sulphur fuel oil at US West Coast ports, the in- creased burden placed on owners and op- erators who must operate within ECAwaters is considerable. Many container lines have recently announced low sulfur fuel surcharges. The Westbound Transpacific Stabiliza- tion Agreement rates are set at $11 per 40-foot container from West Coast ports and $38 per FEU for East and Gulfroutes. While this does lessen the strain, passing on additional costs is not goingto be a universal or sustainable solution in the longer term. On a positive front, there have been some developments that suggest the mar- ket will begin to stabilize. For the longer term, more compliant product is slowly coming to market across North America and Asia, to meet increased demand where it is most pro-nounced. However, significant improve- ments are not likely to be seen in the short-term. By working in partnership with fuel suppliers, owners and operators can stay informed of market develop- ments and can implement a bunkering so- lution that ensures cost and operationalefficiency savings aimed at protecting their bottom line. The other challenge that owners and operators face is making sure that the right documentation is in place to prove compliance. Under regulation 18.2 of MARPOL Annex VI, owners and opera- tors must demonstrate that all requiredmeasures have been taken to obtain com- pliant fuels; particularly important ifnone could be secured. A ship?s master must be able to produce a range of docu-mentation; everything from bunker deliv- ery receipts to written procedurescovering fuel oil change operations. And if they haven?t been able to secure low sulphur fuel oil, they must submit a fuel oil non-availability report upon inspec- tion.Non-compliance is a serious matter. Failure to comply with the regulations can result in a civil penalty of up to $25,000 per day, with an additional $5,000 if false records are submitted. Again, a robust fuel procurement and technical management strategy can miti- gate this risk. Looking forward, when it comes to im- pending regulations in 2015 and the po- tential establishment of other ECAs, suchas Hong Kong, Singapore and, as re- cently suggested, Australia, we must en- sure that we are all on the front-foot. This can be aided through more open dialoguebetween refineries, suppliers and owners and operators. All parties must take re- sponsibility for ensuring that there is aclearer understanding of market demand, and that issues surrounding supply infra-structure, technical limitations and the in-dustry?s ability to absorb any additional costs are clearly addressed and resolved. ECA regulation has shown us that the shipping industry has an ability to adaptto new pressures, but there is only so much room for maneuver. It is important that all factions of the shipping supply chain work together to ensure the future sustainability of the industry. Hans Staalis the Branch Manager forOW Bunker USA, headquartered in Houston, Texas. OW Bunker is one of the world?s leading independent suppliers and traders of marine fueland lubricants. MR#11 (34-41):MR Template 10/22/2012 12:38 PM Page 35