BACKGROUND

In 2018, international shipping became the first industry segment to reach an accord on greenhouse gas (GHG) emissions. The IMO’s 180 Member States committed to a global 40% energy efficiency improvement by 2030 and a 50% improvement in absolute CO2 emissions by 2050 as compared to 2008 values.

As a truly global and very competitive business, shipping stakeholders always strive for international rather than regional or national regulations. The 2018 agreement is therefore helpful in maintaining a level playing field, but it should also be recognised that the various shipping sectors have very different capabilities in reaching CO2 reductions.

Historically, the IMO regulatory framework has been developed around a few ship types – bulk carriers, tankers and containerships – that represent the majority of world trade and, consequently, most of shipping’s CO2 emissions. While this seems like a rational approach, there is an expectation that all ship types should contribute to the reduction targets – and the methodologies developed for deep-sea ships do not necessarily fit well with smaller and much more diverse segments such as offshore supply vessels or ro-pax ships.

CURRENT STATUS

In order to reach the 2030 target, the IMO is developing short-term measures to be implemented by 2023. These were agreed in principle at the Marine Environment Protection Committee meeting last November (MEPC75), and are due for final approval at MEPC76 in June. The measures include stricter requirements on the Energy Efficiency Design Index (EEDI) for new ships, although this is unlikely to be applied in the ferry sector, where the EEDI has proven not to be a fair and robust method to determine theoretical energy efficiency.

More dramatic than such tweaking of requirements for the next generation of ships, from 2023 existing ro-ro and ro-pax vessels will also have to be certified to an efficiency performance standard, the Energy Efficiency Existing Ships Index (EEXI), which builds on the EEDI concept. Non-compliant ships will lose their licence to operate. In addition, certified ships must thereafter conform to a continuous improvement plan for operational efficiency, the Carbon Intensity indicator (CII). While the former measure is a one-off certification, the CII can be compared to every year having to report the actual mileage you have achieved in your car and if that isn’t good enough, next year you will have to improve. By 2030 your car must perform against a pre-defined mileage value, but defining such prescriptive values in a fair manner is very challenging.

The main compliance option under these measures is to limit the available power in the ship to meet the technical requirement under EEXI, or to reduce speed to meet the operational targets under CII. Interferry believes that, within diverse segments like ro-ro cargo and ro-ro passenger ships, the regulations should avoid banding all ships together in order to establish an average performance against which all ships in that segment are measured. While it is feasible to imagine an average oil tanker, it is much harder to define an average ferry.

To that end, Interferry successfully argued at MEPC75 that the EEXI compliance level for ro-ro cargo and ro-ro passenger ships had to be adapted to a realistic level. The way to calculate EEXI for these ships was delegated to an IMO Correspondence Group running from December to February 2021. Interferry also organized a dedicated team of experts to work on how the CII should likewise be adapted to meet the design and operational diversity of ro-ro cargo and ro-ro passenger ships. As with the tight timeline for EEXI deliberations, this work had to be concluded during February 2021. The association’s input has been greatly assisted by the excellent response to a survey asking members for fleet-wide energy related data.

NEXT STEPS

A deadline of March 12 has been fixed for the final submission of proposals to be decided at MEPC76 in June. Based on the intense work of the past few months, Interferry is now cautiously optimistic that the membership’s existing ferries will have paths to compliance for the eventual EEXI and CII requirements, but cautions that it may still prove difficult for some ro-ro cargo and ro-ro passenger ships to reach the targets. It should be noted that the targets reflect a deliberate policy approach by the IMO Member States, which seeks to cull poor performers and incentivise investment in new and more efficient tonnage.

References:

MEPC 75/6/9 MEPC 75-6-9 – Application of energy efficiency measures on existing ro-ro cargo and ro-ro passenger ships

EEXI for ro-ro / ro-pax