www.bifa.org


Policy & Compliance


cleaning, or by making different route choices to reach a destination or pass through heavy weather. Owners and operators already have an


incentive to increase efficiency, so as to reduce fuel costs. The SEEMP planning process bolsters this by placing firmly on the agenda an opportunity to consider new technologies and practices at every stage in the operation of the vessel, thereby increasing the likelihood of their take-up, and of increased efficiency gains that will benefit owners, operators and the environment.


New ships For new ships, the Regulations require compliance with the Energy Efficiency Design Index (EEDI), which takes a phased approach to setting minimum energy efficiency improvements for ships. The EEDI applies to most ship types and for


each ship type and size sets a reference line, measured as grams of CO2


mile and based on the average efficiency of ships built between 2000 and 2010. The EEDI requires that energy efficiency is improved, in phases, such that CO2


emitted per tonne


BIFAlink


and measures to address the emission of methane and volatile organic compounds.


Mid and long-term measures Mid-term measures are to be concerned with the period 2023 to 2030 and long-term measures with the period 2030 onwards. It is predicted that these measures will account for at least 50% of the change that needs to occur in order for the IMO to achieve its ambitions. These measures are likely to require a high


degree of innovation and to result in the global uptake of new fuels and new technologies. From 2023 onwards the IMO will start focusing its activities in these areas. Candidate mid and long-term measures


include programmes to implement the use of low and zero carbon fuels, programmes to develop and provide zero carbon or fossil free fuels, further operational efficiency measures and market-based measures, such as emissions trading, emissions-related levies and emissions offsetting.


emissions


are progressively reduced below the reference line. During phase one, running 1 January 2015 to


31 December 2019, the EEDI required a 10% reduction of CO2


grams per tonne mile below the


relevant reference line for newly built ships. In phase two, running 1 January 2020 to 31 December 2024, the EEDI requires a further 10% reduction of CO2


grams per tonne mile.


Ships (MARPOL). Originally orientated towards the prevention of oil pollution, MARPOL has been developed to address pollution caused by GHG emissions; in July 2011, at the 62nd session of the MEPC, the IMO adopted the MARPOL Annex VI Regulations on Energy Efficiency for Ships (the Regulations). The Regulations, which came into force on


1 January 2013, are the first rules ever to establish CO2


standards across any global


sector. They apply to existing and newly built vessels, although in different ways, and set out various energy efficiency measures which ships must comply with.


Existing ships For existing ships, the Regulations require that all ships have a Ship Energy Efficiency Management Plan (SEEMP). This is a management plan for improving the


energy efficiency of the ship by operational means, such as by optimising vessel speed, increasing the frequency of hull or propeller


January 2021


New measures Pursuant to the publication of the initial strategy, the IMO is considering new short, mid and long- term measures for achieving its carbon intensity and GHG reduction ambitions. Short-term measures are to be finalised by


2023. These are goal-based, include technical and operational measures, and are aimed at achieving the 2030 target of a 40% reduction in the carbon intensity of international shipping. Some of the measures under consideration


include existing fleet improvement programmes, speed optimisation and reduction programmes,


Phase three of the EEDI, which is due to commence in 2025, requires an additional 10% reduction, meaning overall that ships being built in 2025 will be required to be 30% more carbon efficient than those built in 2000-2010. The MEPC also considered whether the EEDI


ought to be expanded in phase four to address all GHG emitted from ships, including methane – which is emitted by LNG-fuelled vessels and is also a potent GHG.


Impact on shipping The IMO’s GHG emission reduction measures impact shipowners on a number of fronts. For some time, shipowners have been required by the Regulations to plan for and manage ship efficiency and have been supported by the IMO to explore the available options and their likely impact. However, the tweaking and refining of current


practises and technologies will only take the industry so far towards the IMO’s goals. A major shift in technologies, especially in fuel preference, is envisaged by the initial strategy. Additionally, the industry can anticipate that


significant behavioural changes, such in ‘just-in- time’ arrivals at ports, are likely to either be required or more strongly incentivised in the future, so as to become widespread and normalised. These too will play a key role in accomplishing the targets set by the IMO.


Upcoming One criticism levied at the global regime advanced by the IMO is that it is simply not progressing fast enough. Despite shipping’s global nature, the EU was recently prompted by the IMO’s pace of change to take its own action in relation to GHG emissions from shipping, voting in July 2020 for emissions from shipping to be included in the EU’s Emissions Trading Scheme (EU ETS) with effect from 2023.


BIFA would like to thank Rachel Hoyland (Rachel.Hoyland@hilldickinson.com) of Hill Dickinson for contributing this article.


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