Striving for meaningful Carbon Intensity Indicator adjustments

Interferry’s Johan Roos explains how ferries can reduce greenhouse gas emissions

Striving for meaningful Carbon Intensity Indicator adjustments
Interferry is collaborating with other key industry stakeholders to lead the global ferry industry to a decarbonised future

By Johan Roos |

Just before the pandemic hit in early 2020, the maritime community had started to develop the International Maritime Organization’s (IMO) short-term greenhouse gas (GHG) measures, encompassing targets and requirements between 2023 and 2030. In doing so, IMO Member States, shipowners, ship operators, green non-governmental organisations and other stakeholders picked up the gauntlet of the European Commission’s so-called European Green Deal.

Even with the new remote working and ‘virtual meetings’ setting, I was cautiously optimistic that we could get the job done. However, key elements of the requirements that are due in force from 1 January 2023 are still of great concern to the ferry sector.  

Back in 2010 when developing the Energy Efficiency Design Index (EEDI), IMO Member States applied a continuous ‘fair and robust’ litmus test – the instrument had to reward organisations for doing the right thing and could not be circumvented. In contrast, this cannot be said of the well-intended, but ill-informed, Carbon Intensity Indicator (CII). This regulation looks at the annual fuel consumption for a ship of a given size in relation to the nautical miles it sails, and compares that with the average for ships in the same category. The ship is then given an annual rating ranging from A to E.

If your ship’s mileage and consumption is around the average for vessels of similar size within its segment, it will be rated C – the middle of the pack. With fair winds and following seas throughout the year, the ship might achieve an A rating, but above-average returns for fuel per nautical mile could find it in the dreaded E category for the given year. Within months you must then demonstrate a remedial action plan to class societies and flag states. However, taking a ship’s performance in the previous year as the basis for required improvements in the following year is fraught with problems.

Firstly, it does not recognise actual utilisation of the ship – the hallmark of any efficiency metric, which is the amount of GHG emitted per gross ton of the ship, per nautical mile sailed. Fully laden and completely empty ships of the same size would get the same ‘miles sailed’ performance score if they covered the same distance, but by default, the empty and lighter vessels will consume less fuel and thus rank better on the CII.  

Secondly, as per the original EEDI proposition, the CII has been developed without proper reference to different ship types. The EEDI has its merits for tankers and container ships, where smaller and larger vessels have broadly similar designs and service patterns. But applying statistical average methodology to a diverse design and operational population like the ferry sector will not produce a true basis on which to justify requirements costing multibillions of dollars. Interferry made this very point when successfully lobbying for sector-specific ‘fair and robust’ EEDI amendments. 

Thirdly, operators could inherit the sins of their forbearers. They might buy or bareboat a beautiful vessel that now requires them to find 50 per cent fuel savings because the former operator was less than careful; or they might out-charter a very efficient ship that returns to their fleet needing rectification due to a client’s over-ambitious itinerary.

Within the ro-pax fleet, the ‘CII scatter’ – non-conformity to the imagined true average – is immense, with a worrying number of ships falling below the tentative 2030 targets. We deem the consequent corrective requirements to be highly unrealistic for such vessels.

The IMO’s Marine Environment Protection Committee rubber-stamped the CII in June 2022 (MEPC 78). There was palpable apprehension about a regulation that blindly stipulates how much fuel a given ship should consume and retroactively penalises non-conformity to this narrow template. Many Member States indicated that they would adopt a soft approach and try their reasonable best, allowing more time to comply ahead of a review of the system due in 2026.

Meanwhile, Interferry is advising its members to establish the expectations of their classification societies and flag states during the CII’s initial three-year stint. We will also rally our membership to provide the data and insights indicating how poorly this instrument reflects the true performance of ferries. Our sincere aim is to help the IMO towards regulatory adjustments that enable the ferry sector’s optimum contribution in reducing GHG emissions.

This article was first published in the 2022 Autumn/Winter issue of Cruise & Ferry Review. All information was correct at the time of printing, but may since have changed.   

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