The framework for a global mandatory reporting system for ship fuel consumption is taking shape and work will continue to assess whether the energy efficiency design standard for new ships should be made more ambitious. Some controversy surrounded both these elements during discussions at the 71st session of the Marine Environment Protection Committee last week at the International Maritime Organization headquarters in London.
MEPC 71 adopted 2017 Guidelines for Administration verification of ship fuel oil consumption data, to support the implementation of Regulation 22 A; the mandatory MARPOL requirements for ships of 5,000 gross tonnage and above to collect consumption data for each type of fuel oil they use, as well as additional specified data, including proxies for transport work, from the start of 2019.
There was a clear political division in the Committee regarding the guidelines with two options for developing the guidelines put forward for consideration. The second option, which was supported by a number of countries, was ultimately rejected by a significant majority.
Many delegations said it went beyond the scope and purpose of Regulation 22 and would introduce an undue burden on industry and administrators. Looking at which countries supported this controversial option, it may be surmised that it was more closely aligned with the European Union’s monitoring, reporting and verification (EU MRV) of CO2 emissions here from maritime transport than the IMO’s data collection system (IMO DCS).
MEPC 71 also adopted 2017 Guidelines for the development and management of the IMO Ship Fuel Oil Consumption Database, and approved an MEPC circular on how ships from a state that is not Party to MARPOL Annex VI can also submit data to the IMO data collection system.
Discussions continued at MEPC 71 with regards to MARPOL Annex VI regulations that took effect in 2013, requiring new ships to be built to increasingly tight energy efficiency standards. MEPC 70 decided not to change phase 2 of the Energy Efficiency Design Index (EEDI), but to consider introducing phase 3 sooner and add a phase 4 with more stringent requirements.
A correspondence group (CG) has been working on the review and reported to MEPC 72, which agreed to re-establish the CG. The CG will report on progress by MEPC 72 and make a recommendation to MEPC 73 on the time period and reduction rates for EEDI phase 3 requirements.
Before that decision, however, MEPC 72 discussed papers submitted by the Clean Shipping (CSC) providing information on a study to investigate trends in the design efficiency of ships built between 2009 and 2016 using the Estimated Index Value (EIV).
The study found that a considerable number of ships in different ship categories already comply with phase 2 and even phase 3 requirements 10 years ahead time, which CSC said is further evidence that EEDI requirements need strengthening.
The study also found, however, that design efficiency improvements appear to have stalled in 2016, with the average design efficiency of new bulk carriers, tankers and gas carriers being worse in 2016 than in 2015. The study also suggested that a surprisingly large share of the ships that entered the fleet in 2016 had efficiency (EIV) scores suggesting that there may be non-compliance with the EEDI.
The evidence presented by CSC in support of tightening the EEDI requirements was not accepted because, it was argued, the EIV used in the study is substantially different from the EEDI as it fails to reflect the complexity of the latter; hence a comparative study is misleading.
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