After intense discussions on mandatory technical and operational requirements to reduce CO2 emissions from international shipping, the 76th session of the IMO Marine Environment Protection Committee (MEPC 76) adopted MARPOL amendments including the Energy Efficiency Existing Ship Index (EEXI), Ship Energy Efficiency Management Plan (SEEMP), and Carbon Intensity Indicator (CII).
We can note that the EEXI seems to be feasible for most ferries, and for non-compliant ships the option of engine power limitation should be a practical solution. All international ships need to have their EEXI verified by the first renewal survey after January 1, 2023.
Comprehensive calculation guidelines have been developed for the CII, but its application is not as straightforward as the EEXI and – importantly – the consequences of not meeting CII requirements are very uncertain. Currently the IMO member states seem to favour “soft implementation”, but how individual states enforce the approach is as yet unknown.
MEPC 76 agreed on CII reduction rates up until 2026 – providing an 11 per cent improvement compared to 2019 – but could not conclude on the full period until 2030, which is the first target year for the short-term measures agreed by the IMO in 2018. Member states were very far from each other on their target reductions by 2030, with some opting for 10 per cent and others wanting beyond 50 per cent. This uncertainty adds to Interferry’s major concerns over the implications of the CII for such a diverse segment as the ferry industry.
While we might agree that the world’s merchant fleet can on average improve by 11, 20, or even 30 per cent over the coming decade, we must note that, within our sector, we have individual ships that are more than 60 per cent off the starting point and therefore need to find such an improvement before even considering how to meet the yet-to-be-finalised eventual CII target.
With a heavy agenda of high-level issues, MEPC 76 was unable to address the many technical and practical details that need to be resolved. To this end, a correspondence group was established and will begin work in early July to be concluded by end-August.
Interferry will focus on two principal issues within the CG: (1) how to deal with high speed craft in the CII framework; and (2) how to distribute the CII burden within the Ro-Ro cargo segment – which is so diverse that some ships, simply due to their main dimensions, risk taking on a disproportionate share of the overall burden.
European Union proposals
Alongside the outcomes from MEPC 76, further details have been circulating among industry sources about a unilateral European Union initiative known as Fuel EU Maritime. It must be stressed that the information below has not been verified by any public announcements from the EU Commission, but this potential regulation – in combination with the IMO developments – would be of fundamental significance for our industry.
What is known is that the pending regulation will be applied to all ships >5,000 GT operating from an EU port (i.e. also for domestic operations) and will consist of several parts:
- Fuel standard
Gradual introduction of low-carbon content fuel, similar to what is already in place for road fuels. In relation to the 2020 GHG content of maritime fuels used, improvements have been set at two per cent by 2025, six per cent by 2030, 13 per cent by 2035, 26 per cent by 2040, 59 per cent by 2045 and 75 per cent by 2050.
- Mandatory use of on-shore power supply (OPS) at berth
From January 1, 2030, containerships and passenger ships will have to connect to OPS and use it for all energy needs at berth. Until 2035, ships that cannot connect due to lack of compatible port infrastructure will be exempted, but from then on such exemptions will only be tolerated five times per year. As far as is known, there is no commensurate requirement that the ports are obliged to provide the OPS facility.
- Monitoring, reporting and verification
The current MRV scheme will be further expanded, with declaration of well-to-wake emission factors, higher resolution of when fuels were used (i.e. different phases of the voyage) and the introduction of “compliance units” forming the basis of a future emissions trading system.
It is unclear if the EU can actually introduce mandatory penalties for non-compliance, but the draft proposal includes harsh fines for a ferry not connecting to OPS when in port.
Johan Roos is Director of Regulatory Affairs for worldwide ferry industry association Interferry.