IMO 2020 Sulphur Cap misplaced. Put Cap on regulators, not ships fuels.

Bulldozing through almost impregnable jungle of Sulphur Cap (SC)-related materials, marked by exceptionally bureaucratic, mind-blowing, style and language, I finally, stumbled on a “study” which I believe, is the basics, the main official explanation and justification of SC global rip-off. Here it is:
70th session Agenda item 5
IMO Aug 2016
Study on effects of the entry into force of the global 0.5% fuel oil sulphur content limit on human health.
Submitted by Finland.
It’s a typical “study”, with all typical characteristics of UN-branded junk science. All Made-in-UN studies are characterized by 3 basic components:
They’re built on assumptions, not proven facts;
They must include “computer-based” models’, graphics, tables and pseudo-scientific mumbo jumbo;
They must be supported by allegedly, indisputable scientific body – NASA is a favourite.
All of the above features are present in the “study” taken by IMO as a “scientific” justification of the Regulation, which will negatively impact all world population.
From Study: The World Health Organization (WHO) estimates that some 3.7 Million deaths annually are attributed to ambient air pollution; ship sulphate emissions are estimated to account for about 4-7% of all deaths from ambient air pollution.
It’s always “attributed”, or “linked to”, it’s never a proven fact. It’s an assumption. It can not be factual, because modern science can’t yet say what triggered disease like cancer, or cardiovascular diseases, or asthma in each case, it’s yet out of reach of modern science.

Sulphur Cap Regulation will reduce premature deaths worldwide. Well, allegedly.
Delay in implementation of global sulphur limits from 2020 to 2025 would, according to the study, contribute to more than 570,000 additional premature deaths compared to the implementation from 2020. Health benefits are related to the proximity of coastal communities and major shipping lanes.
Researches constructed 2 models: two scenarios: (1) an “on-time” implementation case; and (2) a “delay” implementation case, where it was assumed that the standard is delayed until 2025.
The Summary:
Suffice it to say that study upon study has continued to identify PM (particulate matter) as a significant contributor to premature mortality and morbidity, and the scientific community is in general agreement about the nature of these effects.
…total premature mortality is calculated as 50,400 and 158,200 for the “on-time” and “delay” scenarios…
That is, “scientific community” agreed on PM being significant contributor to premature deaths, and “linked” premature deaths to sulphur particles emitted by ships. Significant contributor, linked to…turned into exact figures of deaths caused by ships’ sulphur emissions. Is it science? The basic approach is incorrect, because it’s built on assumptions.
How do Sulphur Particles emitted by ships reach people far beyond shipping lanes and ports? Are ships’ sulphur particles something special, some trained killers hunting down every human being anywhere around the planet?
The whole IMO “study”, on which SC Regulation is built, isn’t about SC impact, it’s about alleged reduction in premature deaths, assumedly contributed to ships’ sulphur emissions, if SC to be implemented in 2020, and alleged rise in deaths rate, if it’s delayed until 2025.

Sulphur Cap Regulation will hit us all. No assumptions here, just facts and common sense.
Sulphur Cap Regulation is the first international regulation to hit all peoples and nations. How so, and to what extent? You won’t find answers to these questions. All you’ll find will be analysis of negative consequences for container shipping, because of course, SC will result in transportation costs hike.
But it is not one and only negative impact of SC, it is not even the main one. Cost of everything will go up, simply because some 95% of world trade is carried out by ships. Cost of fuels, raw materials and production components will go up. Respectively, energy costs will go up. Construction costs will go up. Food costs will go up. Production costs will go up. People will spend more on energy bills and basic food, and therefore, buy less consumer goods (let alone expensive goods and services, such as medicine, houses and cars, cruise/tourism and leisure/hobby items), causing production reduction. Production reduction will trigger wages and workforce cuts. It’s a vicious circle, a snake eating its’ tail. Economy will be pushed into a reverse mode.
With that said, we don’t know the extent of SC negative impact. Will it be survivable for all or at least, for the majority of peoples and nations? Will it trigger recession or global crisis?
SC will hit all people, globally, those who live in coastal cities and ports, and those who never saw ocean-going ships live, because they live in landlocked areas. Those living in regions with pristine air, in Himalayas for example, or in Siberian taiga, will be hit as hard as those living in heavily populated industrial coastal hubs. Populations of developing countries will be hit much harder than in developed ones, because their average income is much lower. Nobody asked them, if they agree to buy much less (including medicine and energy) and live much worse, in exchange for a very vague perspective of breathing “clean air”, and reduced risk of meeting premature death, which is probably, linked to ships pollution.

Questions with no answers
What about negative, maybe devastative, effects of SC? Here are some obvious questions, which should be asked and answered:
• What does that premature mortality “attributed to”, or “linked to”, sulphur particles, exactly mean? Any exact figures and facts? Anything for sure? Anything not assumed, but proven?
• What about rise of premature mortality, caused by drastic reduction in consumption (including energy, food and medicine) by the majority of the world population? Did the UN “scientists” evaluate negative consequences of SC Regulation implementation, embracing all its’ negative domino effects?
• How will SC impact global shipping and global economy?
• How will SC impact coastal communities in developing countries?
• Why people living in landlocked areas, or areas remote from shipping lanes and ports, should pay the same price as people living in major ports or industrial coastal zones?
• What will be the rise in living costs, in rough approximation? How will it affect middle and low classes in developed and developing countries?
• What’s the threshold of misery/poverty? Will inevitable rise of cost of living push the cost beyond misery/poverty/survival threshold, and what populations in what countries are most vulnerable to this risk?
• What about countries, heavily dependant on coastal shipping? Their populations will be hit twice as hard, having to pay twice as more. Any studies here?
• What about macro economical effects? What about possibility, however small (or probably, very real), of SC triggering economy recession or even crisis, by nations, by regions, globally?

“Public health concerns”? How about humanity concerns?
So what do we have? On one hand, highly hypothetical premature mortality, attributed to sulphur pollution. It can’t be assessed, to become a fact of reasonable certainty, at modern level of medicine and science in general, because we aren’t that far advanced yet (medicine can’t yet say what are the roots of cancer and other diseases, it can only assume, that this or that factor contributed to disease). On the other hand, we have very real, not in the least hypothetical, calculable threats to the economy and the very lives of billions of people, especially those populating developing countries.

Were there any studies of above listed risks, assessments, discussions? No, there weren’t. What we see is not just total lack of any such studies, but total lack of any mentioning of a possibility of such risks. Nothing. Zero. Such risks are non-existent, if we’re to believe UN/IMO, and their servants. When Indonesia and India tried to voice their apprehension and anxiety over possible negative effects of SC implementation, on coastal shipping, considering its’ vital importance for coastal communities survival, they’ve been immediately and ferociously attacked by all the mob, from IMO to “international shipping associations” and murky, faceless NGOs and Foundations/Associations/Funds mob.

Why don’t they raise awareness on possible very negative outcomes of SC for Indonesian/Indian coastal communities, why didn’t they even mention it?
The World Shipping Council (WSC), BIMCO, the Cruise Lines International Association (CLIA), and the International Parcel Tankers Association (IPTA) call on IMO member states to fully implement the new global marine fuel sulphur cap mandated through the IMO.
The cost of compliance is high, so it is critical that the rule is consistently applied and enforced. There must be a level playing field if this important regulation is going to work.
“Recent reports suggesting that some nations might not fully implement the new rules are disturbing. Lack of full implementation would risk undermining improvements to public health and the environment,” said President & CEO of the World Shipping Council.
A chorus of angry or more correct, panicking industry CEOs lashed at India and Indonesia, only because these two countries voiced their concern. Why? If shipping “elite” is so worried about public health, it should at the very least, recognize and take into consideration arguments and fears of nations, threatened with possible disruption of their supply chains and coastal trade. Theirs are concerns, which obviously, require discussion, not hysterics a-la Greta “How Dare You”, demonstrated by CEOs, Presidents, Sec-Gens and the rest of the pack. What’s up, guys? What happened to your “public” concerns? Your SC Regulation may plunge into chaos dozens of millions, if not hundreds, of people, and you flatly dismissed this threat? You didn’t even mention it?

Are the “elites” afraid?
Yes, they are afraid, but afraid of what, exactly? Are they afraid that their profits, already pouring into their pockets, will diminish, if some countries will “desert” and dump SC, even if only in domestic shipping? Well, definitely, that’s part of their troubles, but very likely, not the biggest one. Here’s one possible and most frightening for them, outcome of their SC scheme – countries which will find themselves on the brink of economical and social collapse, thanks to sea trade disruption, may rebel, openly and uncompromisingly, driven by sheer desperation. Their governments will add two and two and get a right answer in no time, and after that, they may retaliate and demand from IMO answers to very inconvenient questions about the veracity of SC Regulation scientific grounds, and its’ adequacy to sulphur pollution true threat. Also, they’ll be undoubtedly, very curious about beneficiaries of SC. Who’re they, namely, in what form, what are estimated gains and profits, so on and so forth.

Who’s to profit?
These latter questions, indeed, should be the second batch of issues to be scrutinized in impartial, in-deep study of SC Regulation.
• What organizations, governmental agencies and companies are to profit from SC Regulation?
• Why SC was literally, shoveled into industry and global economy, without proper scrutiny and discussions, which should include all stakeholders?
• What about landlocked nations, were they participating? What about coastal communities of such countries as Indonesia, India or Philippines, were they participating or at the very least, properly informed and asked? Were their concerns and fears voiced?
• Are there any individuals, who’ll personally benefit (or already benefit), and in what form?
• Were potential beneficiaries in a position to influence legislative process?
A lot of other questions to be asked, but general picture is more or less drawn. We’re dealing with unprecedented in its’ scale and possible implications international regulation, which will soon add financial burden to all of mankind, all of us common people, and probably, seriously disrupt global trade and economy. Nobody knows how bad it all will be. Nobody knows the scale of negative consequences.
The only good news is, if (or when) the scheme explodes, busts like punctured balloon, we at least, won’t spend much time and efforts in nailing the culprits. From international organizations, NOGs and major companies, down to the names of most noticeable, in their enthusiasm and “public health concern”, individuals – the majority of them can be figured out and named in literally, hours.

Two simple questions, and insane answers
The sheer insanity of assumptions, on which SC Regulation is built, can be illustrated by following examples:
1. Question – how many people worldwide meet premature death attributed to air pollution?
Answer – many, you have a wide range of estimates. Suit yourself with figures you like most:
2011: According European Environment Agency (EEA) estimates based on 2011 data, air pollution was responsible for about 458,000 premature deaths in 40 European countries.
2014: The World Health Organization (WHO) reports that each year 7 million people die as a result of air pollution exposure. In Europe, while air quality is slowly improving, air pollution remains the single largest environmental health hazard, resulting in a lower quality of life due to illness and an estimated 467 000 premature deaths per year, as reported by the European Environment Agency (EEA).
2019: Poor air quality caused 412,000 premature deaths in Europe in 2016, the most recent year data is available, according to an EU report released on Oct 16 2019.
Mar 2019: Air pollution causes 800,000 extra deaths a year in Europe and 8.8 million worldwide.
From IMO Study: The World Health Organization (WHO) estimates that some 3.7 Million deaths annually are attributed to ambient air pollution.
2018: “Air pollution contributes to 8 million deaths each year” – Richard E. Peltier, associate professor of Environmental Health Sciences at the University of Massachusetts Amherst.
Some debunking of air pollution fear-mongering fakes:

2. Question – the amount of sulphur emitted by ships is equal to how many millions of cars?
Perhaps, the most illustrative example of the hoax nature of SC Regulation is an attempt to answer this rather simple question. And it’s most amusing. You may search in Internet for something like “ship produces the same amount of sulphur as”, and you’ll get dozens of answers, all of them being different from one another, all of them contradicting one another, like those few examples below:
• 15 of the world’s biggest ships may now emit as much pollution as all the world’s 760m cars;
• 46 cruise ships emitted 10 times more sulphur than 260m cars;
• 200 of the world’s largest ships produce the same amount of sulphur as all the world’s cars combined ;
• One massive container ship equals 50 million cars
It’s a pure psycho, but it’s published and reposted, time and again, by all mainstream media including industry media. It’s so obviously insane that there’s no need in any analysis, one can’t seriously discuss sheer attack of psycho delusions. Here’s one curious issue, though. Anyone acquainted with UN Agenda and Green New Deal knows, that in order to save the planet, we must ban combustion engines and all private cars (except of course, elites cars). Ask Extinction Rebellion idiots, or any other idiot who’s backing the ban, why can’t we scrap some 10 biggest ships, and let private cars be, because their emissions will be neutralized. You’ll be answered with a salvo of their usual propaganda nonsense, and accused of being denier/racist/fascist…, i.e. you won’t get in return anything resembling common sense and sound mind.

Great Leap backwards
And finally, let’s have a broader view of SC – what does it mean in general, is it progressive or regressive, is it facilitating economy, or undermining it, is it a step forward or a leap backwards? Answer is obvious. It is an absolutely unjustifiable act, built upon unscientific assumptions, fakes and lies. It’s anti market, anti economy, anti human, regulation, enforced on mankind and economy by a bunch of power obsessed maniacs, and colluding with them “elites”, plus support of useful idiots, in various forms of “eco-activists”. Regulation is endangering global trade and economy, and literally, lives, of hundreds of millions of people. It will lead to supply chains disruptions and to general costs hike, hitting mostly, poor people with low incomes, especially in developing countries, heavily dependant on international and domestic shipping.
What’s the main goal of SC Regulation? It’s part of the UN narrative, it’s one more step in grabbing control over key industries of the global economy, including shipping. There are some lesser goals also, determined mostly, by insatiable greed and boundless stupidity of so-called shipping “elite”, utterly incapable of foresight and strategic vision. But we can hardly expect anything else, because industry environment was, during last decades, twisted and deformed beyond recovery. Independent analyze and critical thinking, common sense and social responsibility, and many other things required for a healthy industry and its’ growth, simply can’t exist in toxic atmosphere of modern shipping, and they don’t exist, they’re extinct.

Come to think of disasters, we have environmental emergency on our hands, all right. It’s just that we misplaced the environment. There is nothing wrong, let alone catastrophic, with Earth environment, but everything is wrong with shipping environment. We do need not one Cap, but many, to prevent the ongoing destruction of shipping industry.

Voytenko Mikhail
October 2019





My name is Mikhail Voytenko, I’m Russian, professional merchant marine navigator, by education and former experience. I own and run Maritime Bulletin website for more than 10 years. I've been involved in solving a number of piracy hijack cases, including the hijack of ro-ro FAINA, loaded with tanks. It was me who made public, and unravel, freighter ARCTIC SEA mystery. I've been also closely involved in a number of maritime disaster, one of them being MSC FLAMINIA major fire.