EDITORIAL COMMENT Rules revisited


Re-visiting old debates means that questions will be asked of the secretary-general, Kitack Lim, of the way rules are made


G


reen shipping regulation is strongly featured in this issue of The Naval Architect with


MAN Diesel & Turbo’s focus on Tier III regulations in the Engine Technology feature and the Shipboard Water Treatment feature’s look at the regulations governing the discharge of waste water. Both regulations came into force on 1 January this year, and these and other regulations are shaping the future composition of the maritime industry and the design of vessels that will come to operate within the rules. However, the implementation of some


of this regulation has been less than ideal at times, resulting in much reflection at


IMO and, in some instances, the


intensification of criticisms of regulations as it became clear that the rules have not met the required standards. Tis has not been the case for many of


the green regulations passed by IMO.In this month’s issue, both In Depth features have focused on environmental aspects of shipping. In the case of China Shipping News, the writer has emphasised the need for the Chinese shipbuilding industry to make great strides in order to catch up with their competitors, mainly in Japan and South Korea but also to a lesser extent in Europe, in the implementation of NOx and SOx regulations. Green shipping is an accepted element of the industry today and the regulations have been implemented with few complaints. However, in the second In Depth


story, the issues surrounding the Energy Efficiency Design Index (EEDI) indicate


The Naval Architect March 2016


that its application to ro-ro and ro-pax vessels has not been without heated debate. Te discussion about how EEDI could


be applied to ro-ro ships reached its peak in 2013, and it was thought to have been settled. However, the issue has resurfaced and will be discussed further at MEPC in April. Debate over the application of the EEDI


formula reached its apparent denouement at the IMO’s MEPC (65) (Marine Environment Protection Committee) when Denmark, Japan and Norway proposed the use of a cubic capacity correction factor while Sweden and Germany proposed the use of the Froude number to calculate an EEDI number. Te Swedish and German proposal was


accepted at MEPC in May 2013, and many industry observers, including such bodies as Interferry, supported the proposal. However, at the time, representatives from Denmark were particularly adamant that the German/ Swedish proposition was unworkable. Three years on and MEPC is set to


debate the issue again following difficulties in making the preferred Swedish/German proposal into a workable solution for ro-ro vessels of all types, including ro-ro, ro-pax and car carriers. A number of industry figures and some


major academic institutions are now addressing the problem of correction factors for EEDI calculations that appear to make EEDI targets so punitive that ro-ro ship operators are in danger of becoming less competitive than road transport operators or even to cargo


moving by air. Tere now appears to be common agreement that the formula in its original form is unworkable. The need to revisit such a significant


regulation raises the question of whether it was evaluated with sufficient rigour. A parallel can be drawn here with the development of another IMO regulation governing the treatment of ballast water. The original Ballast Water Management Convention was adopted at IMO in February 2004, more than 12 years ago. However, the rule has yet to come into force as owners have complained it is unworkable. Te issue is further complicated by the


introduction by the US of ballast water rules that are more stringent than those proposed by the IMO. The failure of the rules to be


implemented after so many years is a consequence, in part, of owners’ lack of confidence in the technology that would clean the ballast water and the technology that would test measure the extent of live organisms following the cleansing process. The difficulties which industry is


experiencing and reporting with these two ecological regulatory issues also begs the question as to whether they are the result of a failure of the system which created them. Confidence in IMO’s role as rule maker would surely be improved by a review of the system and the processes which created them. Perhaps this should be a priority for secretary general, Kitack Lim. NA


7

Page 1  |  Page 2  |  Page 3  |  Page 4  |  Page 5  |  Page 6  |  Page 7  |  Page 8  |  Page 9  |  Page 10  |  Page 11  |  Page 12  |  Page 13  |  Page 14  |  Page 15  |  Page 16  |  Page 17  |  Page 18  |  Page 19  |  Page 20  |  Page 21  |  Page 22  |  Page 23  |  Page 24  |  Page 25  |  Page 26  |  Page 27  |  Page 28  |  Page 29  |  Page 30  |  Page 31  |  Page 32  |  Page 33  |  Page 34  |  Page 35  |  Page 36  |  Page 37  |  Page 38  |  Page 39  |  Page 40  |  Page 41  |  Page 42  |  Page 43  |  Page 44  |  Page 45  |  Page 46  |  Page 47  |  Page 48