The Marine Environment Protection Committee has concluded its 79th session this month and these are the main issues discussed with regards to technical measures.
A revised proposal to include all greenhouse gases emitted from ships in EEDI was submitted for review. It was suggested to develop EEDI phase 4 requirements based on tank to wake CO2e, including CO2, methane, nitrous oxide and black carbon using 20-year GWPs. The argument put forward stated that tightening the EEDI requirements when only focusing on tank to wake CO2 would encourage, and in some cases force, the use of LNG even with high methane slip engines, resulting in higher overall GHG-emissions.
Having said that, it was not proposed to include well to wake CO2e for EEDI requirements, as well to wake emissions vary based on fuel source and can in some cases determine whether a ship would meet the requirement or not. The fuel source is not known when the ship is built, and it can vary throughout the course of its life. It was emphasized that regulating well to wake emissions is important for decarbonizing the sector and that other regulations, such as a low GHG fuel standard and updated CII, are better suited for regulating well to wake CO2e emissions.
It was further proposed to include emissions reduction benefit from carbon capture system for ship exhaust gas (CCSE) in the calculation of EEDI, EEXI and CII. It is currently not included thus, operation of a carbon capture system onboard the vessel would result in additional emissions (ventilation, heating, compression process) without any benefit in the regulations. Due to time constraints, the Committee will revisit this issue in MEPC80 in 2023.
Another push to include CII correction factors for short voyages and waiting time was submitted for discussion. The 2022 Interim guidelines on correction factors and voyage adjustments for CII calculations (CII Guidelines, G5) does not include any corrections for short voyages and additional waiting time. Given the CII is strongly impacted by the relative share of port stays/anchorage/waiting (non-working) and sailing (working), vessels involved in trades with short sea passages or long waiting times are penalized. It is argued that ship owners have little influence on additional waiting time due to ports experiencing overloads in demand or quiet times awaiting charterers, and that penalizing short sea passages can have the unintended consequence of moving cargo transportation to road transport resulting in overall increase in GHG emissions. The same is also highlighted in Information on the effects of charterers' orders, distance travelled and waiting time on Carbon Intensity Indicators submitted by Intercargo. The document focuses on the significant CII impact due to charterers' orders, and that the key contributors to the CII rating is often outside of ship owners/managers control. Due to differing opinion on the matter, a decision is not expected prior to the review period in 2025.
The Committee examined the interim report of the Correspondence Group on Marine Fuel Life Cycle GHG Analysis, and the progress made on the development of emission factors for alternative marine fuels. The guidelines aim to create a well to wake calculation of total GHG emissions during a fuel’s life cycle from production to eventual use.
In order to develop the emission factors, the following steps will be taken:
The Correspondence Group has further agreed to focus on environmental factors linked to fuel production such as carbon source and stock, direct land use change and conservation and will not include economic and social factors until further consideration from the Marine Environment Protection Committee has taken place.
So far, the group has identified 101 fuels/fuel pathways to focus on and has expressed that black carbon will not be included in the draft guideline at this stage. It will, however, be considered at a later stage. The Group’s ambition is to have the draft guideline ready for the Committee to review by MEPC80 in 2023.
