Tanker operators will be keen to know exactly what they need to do to comply with MEPC 75 – if they will be able to keep a certain vessel in compliant operation until 2030 just through slow steaming, and when they need to consider switching to LNG fuel.
At a webinar organized by DNV GL about MEPC 75
on November 26, 2020 stated.
“You need to consult with your trusted
classification society and see how they can help you with specific vessels. It depends
on age, trade profile, investment willingness. There are a lot of factors
playing into what is the most appropriate solution for each individual ship.”
Although “we think you can achieve 40 per cent
improvement in efficiency with the toolkit we have available today. It won’t always
be cheap, but it can be done.” In other words, we can manage until 2030 without
new fuels.
“Getting to the absolute reduction levels of 2050
is a different ballgame - there we need other options.”
The MEPC 75 meeting was held online over November
16-20. Because people were attending
from their home countries, rather than travel
to the IMO building in London, and all working in different time zones, the
decision was made to restrict discussions to 3 hours a day, so 15 hours in
total for the meeting.
The online format also did not allow as much interaction
as usual. Many items were postponed to the next meeting (MEPC 76). Since the
MEPC 75 meeting was originally planned for April 2020, it means some items are being
postponed for a year. MEPC 76, planned for 2021, is also likely to be virtual,
and so have a constrained agenda, and some issues may slide into MEPC 77.
A planned revision of guidelines for Exhaust Gas
Cleaning Systems was pushed to MEPC 76.
Correspondence groups have been established to
look at licensing fuel oil suppliers, a shaft power limitation concept, and
interim minimum power guidelines.
The work to agree a definition of Phase 4 of EEDI
was “deprioritized”. Phase 4 will apply to newbuilds of a number of ship types
from 2022, and anticipated to come into force after 2025, so not considered
urgent to discuss now.
Agreements at MEPC 75
At the November 2020 meeting, approval was given to the 4th IMO greenhouse gas study, by a consortium led by CE Delft, which counted emissions from shipping in 2018 of 1056 MT CO2 equivalent, up 9.6 per cent from 2012.
Methane and nitrous oxide emissions were included (and converted to a CO2 ‘equivalent’ amount). This study says that shipping’s share of global emissions was calculated to be 2.89 per cent in 2018, up from 2.76 per cent in 2012.
The study says that the overall “carbon intensity”
of shipping decreased by either 21 per cent or 32 per cent over the period 2008
to 2018, depending on how it is calculated – 21 per cent if calculated by
“capacity mile” or based on voyages, and 32 per cent if calculated by “tonne
mile” (cargo carried). Carbon intensity is a measure of how much carbon is
emitted per “transport work”.
If no additional policies are adopted to decarbonize,
emissions are projected to end up growing by between 90 and 130 per cent by 2050,
relative to 2008.
The focus of the MEPC work is to get emissions
to a peak as soon as possible, and then reduce “carbon intensity” by 40 per
cent by 2030, compared to 2008. (Note, 21 to 32 per cent reduction has already
been achieved).
On the technical side, MEPC75 approved plans
for an EEDI (Energy Efficiency Design Index) rule on existing ships, known as
the “EEXI” (Energy Efficiency Existing Ship Index).
This is described in more
detail below.
On the operational side, it approved plans to ask shipping companies to write a “SEEMP” (Ship Energy Efficiency Management Plan), showing how they will reduce their operational emissions. It is based around a Carbon Intensity Indicator – CII. This is also described in more detail below.
Each member state is encouraged to develop its
own national action plan, an example being Norway’s Green Shipping Program.
MEPC75 considered a proposal from a number of
shipping industry associations, including the International Chamber of
Shipping, World Shipping Council, Intertanko and the International Parcel
Tankers Association, to raise money for research and development of fuels, levied
on fuel purchases.
The meeting also did not discuss plans to set GHG / carbon intensity guidelines for other fuels, also including emissions made in producing the fuels and delivering them to vessels (“well to tank”), methane slip, nitrous oxides, and emissions from VOCs.
So, for now, the
regulations only relate to the amount of CO2 you emit per the amount of cargo
tonne miles you make.
EEXI
EEXI is what will concern tanker operators the
most. It follows EEDI, the “Energy Efficiency Design Index”, which says that
new ships being built over 2025 to 2030 must have a 30 per cent improvement in
energy efficiency compared to a baseline, calculated as the average efficiency
for ships being built between 2000 and 2010.
Under EEXI, existing tankers need to achieve a
“delta”, or improvement, of 15 to 20 per cent, compared to the baseline, with
the same time periods as for EEDI for achieving the improvement and the base
line. The delta is different for different ship types. Cruise ships and LNG
carriers must get 30 per cent, gas carriers must get 20 to 30 per cent.
So, this should get existing ships “on par” with what is required for new ships, under EEDI phase 2 or 3. Ships need to comply with EEXI by early 2024. Specifically, the deadline is the “first annual, intermediate or renewal IAPP (International Air Pollution Prevention) survey after 1 Jan 2023.” So, by early 2024 - all ships which are in scope need to comply with EEXI.
The index is calculated by a complex formula which
takes ship’s emissions, capacity and speed into account, with the speed based on
that calculated in the sea trial, after the vessel was launched, or by other
methods.
The way to reduce the score involving the least
financial investment is probably to reduce the speed. The engine can be
“de-rated”, so it operates at a slower speed, or you can set a “virtual” limit
on engine power, basically an agreement that you will only operate the vessel with
a certain power level. You are only allowed to exceed it in an emergency.
Shipping companies need to put all of this in a technical file, which is verified and approved in the first IAPP survey after Jan 2023.
SEEMP
All ships above 400 GT need to develop a “Ship energy efficiency management plan (SEEMP), by Jan 1, 2023.
A rating system will be designed by IMO so that
if all ships are C or better, by 2030 shipping will reach its 40 per cent
target of improving carbon intensity.
It will probably be calculated in emissions per deadweight mile. The threshold for reaching “C” will get more stringent in time. Cargo and cruise ships above 5000 GT need to achieve rating “C” in their Carbon Intensity Indicator, every year from 2023, their SEEMP should show their plan to achieve this. The plan should also have a continuous improvement focus.
Any ship scoring “D” for 3 consecutive years, or an E, will need to implement corrective actions, which will be included in their SEEMP, and need to be approved, for a vessel to receive its annual statement of compliance. Offshore vessels, passenger vessels (not cruise ships or ROPAX) will not have any index. The reason is that these vessels are very diverse, so it is very hard to calculate how one vessel compares to others in its ‘class’. Although they are still required to collect and report data.
The policy will be reviewed by Jan 2026, looking
at strengthening the enforcement mechanism and corrective actions.
IMO’s 2050 target is that CO2 emissions should
be reduced by 70 per cent compared to 2008, counted as CO2 emissions per
transport work, and total GHG emissions from the industry should be reduced by
50 per cent, compared to 2008.
The company’s CII may become public, since it
is included on the vessel’s “statement of compliance”, which is a public
document in many jurisdictions. This means the data may be included in the
various online vessel rating schemes.
The verification and audit will be done by the organizations accredited as “recognized” by flag states – mainly the classification societies.
IMRDB
There is a proposal from industry bodies, including
ICS, World Shipping Council, BIMCO and Intertanko, to set up a research fund to
develop zero carbon technologies, paid for with a levy per tonne of fuel
purchased, proposed at $2 per tonne for all ships above 5,000 GT, building a
purse of $5bn over the lifetime of the program.
A full day of the MEPC 75 meeting (3 hours) was taken up by discussing this. IMO members were talking about it as a “market based measure”, although the industry had been careful not to present it as a “market based measure”, saying that the money would be for research only, not to make certain fuels more viable.
There were inconclusive discussions about whether IMO could take on the responsibility of making this a legal mandate, Mr Longva said. “IMO agreed to invite further comment, so discussion will come back in MEPC 76.”
Other amendments
Other amendments made by IMO are changes to
MARPOL Annex VI stating that you need to have a sampling point in your fuel
system, either fitted or “designated”, for inspectors to sample and verify
sulphur content. This needs to be approved by the first IAPP survey after April
2023. “There’s either technical or bureaucratic work to take care of,” Mr Nyhus
said.
There are new verification procedures for how samples
are to be analyzed and what kind of bandwidth is acceptable on sampling
results.
Also, at MEPC 75 the International Convention
on the Control of Harmful Anti-fouling Systems on Ships was amended to ban the
biocide cybutryne.
There was a ban on use and carriage of heavy fuel
oil in the Arctic from July 1, 2024, with exemptions for tanks with a double
hull, or for Arctic coastline states which want to exempt their own ships in
their own waters until 2029. This was a compromise agreed with certain Arctic
states to get the ban passed. Audience poll Audience members were polled to find out what they anticipated
their main measure would be to comply with EEXI.
21 per cent chose engine power limitation, 16 per
cent retrofit energy efficiency devices, 17 per cent operational improvements,
25 per cent alternative fuels, 19 per cent said “I have not started looking into this.”
Useful reference links
https://www.imo.org/en/MediaCentre/MeetingSummaries/Pages/MEPC-75th-session.aspx
https://www.imo.org/en/OurWork/Environment/Pages/Anti-fouling.aspx
https://www.iomshipregistry.com/media/1403/msn-047-anti-fouling-systems-convention.pdf
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