SHORT-TERM GHG REDUCTION MEASURES WILL NOT DELIVER DECARBONISATION

Lars Robert Pedersen, Deputy Secretary General of BIMCO

 

 

흥미로운 MOTORSHIP 기사다. EEXI 와 SEEMP 랑 CII 을 어떻게 규정할수 있느냐에 대한 문제가 계속 대두되어 왔지만 정확한 프로토콜이나 절차 수립없이는, 흐지부지한 법안이 될 가능성도 있다. 

이산화탄소 규제의 대세는 거스를 수는 없겠지만, 다음차 회의에 얼만큼 구체적인 방안들이 수립될 지 지켜봐야 할 일이다.

 

-Article from Motorship Quote-

 

Lars Robert Pedersen, deputy secretary general of BIMCO assesses MARPOL Annex VI amendments approved at the 75th session of the Marine Environment Protection Committee (MEPC 75)

Speaking before MEPC 75 approved the technical and operational measures, how prepared do you feel your members are for the introduction of Energy Efficiency Existing Ship Index (EEXI) and an operational Carbon Intensity Indicator (CII) measures? 

Because EEXI is basically EEDI applied to existing ships, its mechanics should not come as a surprise to members. However, some important differences apply.

Firstly, because we are talking about existing ships, documentation for speed in the reference condition may be missing. Members should thus start preparation of the basis for EEXI certification of ships by digging out from their documentation those aspects which can be used in the process, such as sea trial documentation for speed and power – if it exists.

Secondly, power limitation may become the tool many ships will rely on to bring them into compliance with the EEXI requirement. Limiting power may cause operation within a barred speed range for a main engine and operation at a load point different from what currently is the norm. These aspects need investigation.

The Carbon Intensity Indicators (CII) is a different issue. Ships will need to comply with mandatory limits for their operational efficiency. This is a novel piece of regulation. To our knowledge, this has not been attempted in any other industry before. Members are certainly not prepared for this.

And they can’t be prepared at this stage, because the metric for calculating the mandatory CII is still unknown. We simply do not know how the CII shall be calculated and thus which variables will be available for influencing the CII. The metric will also determine if an improved CII will lead to a reduction of total GHG emissions from the shipping sector. This is not necessarily the case if for example the CII variable to improve it is to reduce the cargo intake of ships.

Unlike the EEXI rules, the Carbon Intensity Indicators (CII) that are being proposed have not been clearly defined. Should we be considering emissions per tonne mile of cargo? 

The decision on the metric for the CII holds the answer to, whether improved CII over time will lead to a reduction of GHG emissions from the fleet. What the metric will be, will also determine how soon it can be enforced by the regulation. This is because data is needed to calculate the starting point for each ship (the baselines). If the EEOI is chosen as the CII (which is g[CO2]/cargo ton*mile) we do not have data yet to derive baselines. The IMO Data Collection System (DSC) does not hold data on cargo mass carried. This means several years will need to be spent collecting this data before baselines can be calculated.

On the other hand, the DSC holds data to calculate baselines for AER (g[CO2]/DwT*mile). If this becomes the CII, the introduction can start early. The downside is that the only variable ships have an influence on in this metric, is the fuel used. In effect, slowing down or reducing cargo capacity are the readily available options for owners. Especially the latter option would require more ships to carry the same cargo, and may therefore lead to increased overall emissions from the fleet.

As I said before, regulating operational efficiency is a novel art, and we must be careful that this is not counterproductive to industry’s and IMO’s long term ambition – to decarbonise.

Do you feel that EEDI reference lines calibrated by DCS or MRV fuel consumption data are appropriate as a basis for reduction factors? 

The EEDI reference lines are merely lines representing the average technical efficiency of ships of same size within each ship type. Importantly, the scatter of the data from which the average is derived is large. The same goes for operational efficiency - the scatter is large. Whereas the scatter is not a variable for each ship under EEDI, it is very much so when it comes to the operational performance. It varies greatly from one year to another for the same ship. It all depends on its commercial utilisation, the weather conditions it is subjected to at any given time, how much ballast voyage is performed in a year, if the cargoes need energy for heating or cooling, and there may be many more variables involved. Only a few of these are under the control of the ship itself.

I think the above answers the question – we do not think this methodology is appropriate. It can be done, but it leaves ships subjected to something which is largely arbitrary.

Despite criticism of the ISWG 7 proposals from some quarters, it will introduce significant energy efficiency requirements. 

EEXI will improve the technical efficiency for existing ships. In effect, it will limit ships ability to speed up and thus overall keep the speed in the fleet down for the years to come.

CII may, or may not, lead to real improvements. It may even lead to more ships used to carry the trade and thus inefficiency overall. This depends entirely on how efficiency is defined for the individual ship.

Do you feel that the necessary technical solutions are available for different vessel types? 

In general, yes. There are issues for some ship types where the EEDI formula has been manipulated to express something which is no longer a correlation of power over speed. Such ship types may have to resort to alternative means to comply with the EEXI. For CII, it all depends on the metric.

Finally, how do you see the effect of additional pressure from regional schemes, such as the proposed extension of the EU’s Emissions Trading System to cover emissions from shipping, affecting moves to meet IMO decarbonisation targets? 

Regional schemes to address GHG emissions from ships are doomed to be merely distractions, in the sense that such regional measures while costly to the industry, will have only marginal effect on total emissions from ships – if at all. There is only one way to make the shipping industry transition to a low carbon future, and that is by allowing the IMO to accomplish the ambition set out in the IMO initial strategy on reduction of GHG emissions from ships. In this regard, the present focus on short term measures and how much they may be, or may not be, aligned with the overall ambitions is misplaced. Short term measures cannot deliver the long-term goals anyway.

 

Source : Motorship Article