Stefka Wechsler of the global energy and commodity price reporting agency Argus Media on Thursday (16 April) published an interview with Roel Hoenders, IMO’s acting head of air pollution and energy efficiency on the suggested tightening of the Energy Efficiency Design Index (EEDI) regulations and its possible payoffs.

The International Maritime Organization (IMO) has two initiatives to cut the shipping industry’s carbon footprint — the already underway Energy Efficiency Design Index (EEDI) that phases-in up to 30% greater efficiency in new-builds through 2025 and beyond, and a greenhouse gas (GHG) regulation scheduled for 2023. Initial talks indicate the GHG rule would require vessels to reduce their CO2 emissions by 40% by 2030 and by 70% by 2050 from 2008 levels. Roel Hoenders, IMO’s acting head of air pollution and energy efficiency, discusses proposed tightening of the EEDI regulations, how the two initiatives impact newbuild vessels, as well as IMO’s plans for open loop scrubbers. The interview has been edited for length.

Some ship owners are reluctant to invest in new ships until the IMO comes out with a greenhouse gas (GHG) emissions regulation in 2023. Is IMO considering grandfathering existing vessels or those built prior to 2023?

In terms of newbuild ships, there are already clear regulations, relating to EEDI requirements.

Ships built now and in the future have to beat that baseline by a set amount, which will get progressively tougher over time. [According to phase 3 EEDI requirements] by 2025, all new ships will be a massive 30% more energy efficient than those built in 2014. These EEDI phase 3 requirements have already been reviewed and will be strengthened. The draft amendments bring forward the entry into effect date of phase 3 to 2022, from 2025, for several ship types, including gas carriers, general cargo ships and LNG carriers. This means that new ships built from that date must be significantly more energy efficient than the baseline.

For larger size container ships, the EEDI phase 3 reduction rate is enhanced significantly and moved forward to 2022 from 2025. For containerships with 200,000t deadweight (dwt) and above, the EEDI reduction rate is raised to 50%, for 120,000-200,000 dwt raised to 45%, for 80,000-120,000 dwt increased to 40%, for 40,000-80,000 dwt raised to 35%. The 30% limit is not changed for 15,000-40,000 dwt containerships, but the year is moved forward to 2022 from 2025.

IMO’s Marine Environment Protection Committee (ME%) will also look into the introduction of a possible phase 4 of stricter EEDI requirements.

So there is already a clear pathway setting out that new ships must be increasingly more energy efficient and legal certainty for future newbuilds in terms of meeting EEDI requirements. Moreover, to achieve the 2050 objective in our initial GHG strategy, ships that enter the market after 2025, and likely to still be part of the 2050 fleet, should generally be prepared to use low or zero carbon fuels. This is a clear message for ship designers and ship builders as well as shipowners and operators.

In terms of any new requirements that might apply to existing ships, which have already been built, these are still in the proposal and discussion stage.

Would EEDI phase 2 compliant vessels (built between 2021-2025 and 20% more energy efficient) be able to technically meet the regulation to drop CO2 emissions by 40% in 2030? If not, can they be grandfathered?

The 40% reduction of carbon intensity by 2030 compared to 2008 is an ambition which still needs to be laid down in concrete proposals to achieve. These have been submitted to IMO, but require further discussion. The 40% reduction ambition applies to all ships.

Ship design-related energy efficiency measures, may have to be complemented by operational measures (i.e. voyage specific measures) to achieve the ambition. This, including any grandfathering, will have to be decided by the next meeting(s) of the IMO’s Marine Environment Protection Committee (ME%).

Can EEDI phase 3 compliant vessels build after 2025 technically meet the future regulation to drop CO2 by 40% by 2030?

The 2030 ambition is a reduction of carbon intensity compared to 2008, whereas the EEDI reduction factor is relative to the reference line for specific ship types. The exact relation between the two still needs to be decided ME%.

Do you think that IMO postponing its meetings this year due to coronavirus will push the decision date for the GHG regulation from 2023 to 2024 or later?

The Covid-19 pandemic has had a significant impact on the organization, in that meetings have been postponed and will need to be rescheduled. However, it is worth bearing in mind that the decisions on the levels of the GHG strategy have already been made. This allows for a revised GHG strategy to be adopted in 2023.

It is worth pointing out here that the GHG strategy does not require decisions on regulations to wait until 2023. Measures can be discussed, agreed and approved and adopted any time before then. So for example, the strengthening of the EEDI requirement referred to earlier is ready to be adopted.

The IMO began collecting marine fuel consumption data from member states in 2019. Will that data be made available to the public and when?

From 1 January 2019, ships of 5,000 gross tonnage and above started collecting data on their fuel-oil consumption, under the mandatory data collection requirements which entered into force in March 2018. The data collection system is one of the measures taken which will support the implementation of IMO’s initial strategy to reduce GHG. The ships covered by the regulation represent approximately 85% of the total CO2 emissions from international shipping.

IMO is required to produce an annual report to the ME%, summarizing the data collected. The first annual report is currently anticipated to be ready in the second half of 2020 for submission to the ME%.

IMO currently does not ban the use of open-loop scrubbers, while some ports and countries. Is such a ban in international waters being considered?

There has not been any proposal to ban open loop scrubbers put forward by any IMO member country.

Currently, IMO has been considering issues related to the discharge of liquid effluents from exhaust gas cleaning systems (EGCS). The last session of the sub-committee on Pollution Prevention and Response (PPR), which met in February 2020, agreed to recommend that ME% should evaluate rules and guidance on discharge water from EGCS. The scope of the work should include:

• Evaluation of possible harmful effects of the discharge water from EGCS, taking into account existing methods and mathematical models.
• Consider developing impact assessment guidelines.
• Guidance on delivery of EGCS residues to port reception facilities, regarding volumes and composition of residues.
• Assessing state of technology for EGCS discharge water treatment and control, identifying possible regulatory measures, developing a database of local/regional restrictions/conditions on the discharge water from EGCS.
• Establishing a database of substances identified in EGCS discharge water, covering physico-chemical data, ecotoxicological data and toxicological data, leading to relevant endpoints for risk assessment purposes.

Do you hear from the member states about specification issues around the use of 0.5% sulphur fuel oil? Has the enforcement and policing been going smoothly thus far in 2020?

We have not been notified of specific issues around specification so far. But IMO’s Maritime Safety Committee (MSC) adopted in June 2019 resolution MSC.465(101), providing recommended interim measures to enhance the safety of ships relating to the use of oil fuel. The committee also endorsed an action plan to further consider measures relating to the flashpoint of fuel.

Given the Covid-19 pandemic, we are aware that port state control regimes have reported making fewer inspections than they might otherwise make. Nonetheless, we know that port state control inspectors continue to target high risk ships. The marine fuel sulphur regulation requires ships to keep their bunker delivery notes on board for up to three years so compliance can still be checked in a few months from now.

Source and photo credit: Argus Media
Published: 17 April, 2020