How do the new ratings work? Based on a ship’s CII, its carbon
intensity will be rated A, B, C, D or E (where A is the best). The rating indicates a major superior, minor superior, moderate, minor inferior, or inferior performance level. The performance level will be recorded in a “Statement of Compliance” to be further elaborated in the ship’s Ship Energy Efficiency Management Plan (SEEMP).
A ship rated D for three consecutive years, or E for one year, will have to submit a corrective action plan to show how the required index of C or above will be achieved. Administrations, port authorities and other stakeholders as appropriate, are encouraged to provide incentives to ships rated as A or B.
A ship can run on a low-carbon fuel clearly to get a higher rating than one running on fossil fuel, but there are many things a ship can do to improve its rating, for instance through measures, such as:
- hull cleaning to reduce drag; - speed and routeing optimization; - installation of low energy light bulbs; and
- installation of solar/wind auxiliary power for accommodation services.
How do the measures fit into IMO’s
decarbonization strategy?
The introduction of mandatory EEXI and CII comes under the framework of the Initial IMO Strategy for Reduction of GHG Emissions from Ships, adopted in 2018. The Initial Strategy sets out candidate short- mid- and long-term measures.
The introduction of EEXI and CII measures falls under the Strategy’s short-term measures which commit IMO to a target of reducing carbon intensity of international shipping by 40% by 2030, compared to 2008.
How will the impact of the new regulations be assessed? IMO’s Marine Environment
Protection Committee (MEPC) is to review the effectiveness of the implementation of the CII and EEXI requirements by 1 January 2026 at the latest and develop and adopt further amendments as required.
The review paragraph says: Regulation 28 Operational carbon intensity:
11 A review shall be completed by 1 January 2026 by the Organization to assess:
.1 the effectiveness of this regulation in reducing the carbon intensity of international shipping;
.2 the need for reinforced corrective actions or other means of remedy, including possible additional EEXI requirements;
.3 the need for enhancement of the enforcement mechanism;
.4 the need for enhancement of the data collection system; and
.5 the revision of the Z factor and CIIR values.
If based on the review the Parties decide to adopt amendments to this regulation, such amendments shall be adopted and brought into force in accordance with the provisions of article 16 of the present Convention.
In adopting the measure, MEPC also considered the outcomes of a comprehensive impact assessment of the measure which examined potential negative impacts on States, and agreed to keep the impacts on States of the measure under review so that any necessary adjustments can be made. MEPC also agreed that disproportionately negative impacts of the measure should be assessed and addressed, as appropriate.
80 | ISSUE 106 | DEC 2023 | THE REPORT
What about support for developing States in particular small island developing States (SIDS) and least developed countries (LDCs)?
IMO has a comprehensive programme of support for developing States to implement IMO regulations. In addition to IMO’s Integrated Technical Cooperation Programme (ITCP), the dedicated IMO GHG TC Trust Fund support developing countries with the implementation of the Initial IMO GHG Strategy. There are also a number of global projects specifically targeting GHG reduction measures, including: GreenVoyage2050; GHG SMART; NEXTGEN; IMO CARES; the Global MTCC Network; Innovation Forum.
What is the next stage for IMO’s GHG Strategy?
Member States are working on the revision of the Initial Strategy. The Revised Strategy is set to be adopted in mid-2023 at the Marine Environment Protection Committee (MEPC 80) session in July 2023.
What about mid- and long-Term IMO GHG reduction Measures?
IMO Member States have already initiated discussions on various proposals for IMO’s next set of GHG reduction measures, such as a maximum carbon-content for marine fuels as well as on economic measures, such as a GHG levy, emissions trading scheme (ETS), feebate or an incentive scheme for zero emission vessels.
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