Recap: IMO MEPC 75

Highlights from the IMO Marine Environment Protection Committee, held online from 16 to 20 November 2020 and attended by SYBAss.

The 75th session of the IMO’s Marine Environment Protection Committee (MEPC 75) was held remotely from 16 to 20 November 2020. This meeting addressed environmental issues under IMO. This includes the control and prevention of ship-source pollution covered by the MARPOL treaty, including oil, chemicals carried in bulk, sewage, garbage and emissions from ships, including air pollutants and greenhouse gas emissions. Other matters covered include ballast water management, anti-fouling systems, ship recycling, pollution preparedness and response, identification of special sensitive sea areas. Lorenzo Pollicardo, SYBAss’ Technical and Environmental Director, was in attendance and ensured that member interests were well-represented on the global regulatory stage.

The committee agreed on the relevant updates to the MARPOL Convention and other IMO instruments on maritime safety, as follows:

  • Adopted amendments to MARPOL Annex VI on fuel oil sampling and verification of sulphur content and the Energy Efficiency Design Index (EEDI).
  • Adopted amendments to the Ballast Water Management Convention on commissioning testing of ballast water management systems (BWMS).
  • Approved amendments to MARPOL Annex VI on the Energy Efficiency Existing Ship Index (EEXI), Carbon Intensity Indicator rating (CII) and enhanced Ship Energy Efficiency Management Plan (SEEMP).
  • Approved amendments to MARPOL Annex I, with a prohibition on the use and carriage of heavy fuel oil for use as fuel by ships in Arctic waters.
  • Approved amendments to the Anti-Fouling System (AFS) Convention to include controls on cybutryne.

Air pollution and energy efficiency: IMO Tier III NOx Emissions:

  • No further extension in deadline was granted for the Tier III NOx emissions regulations for large yachts of 24m load line length or over and less than 500 GT, meaning that the Tier III NOx emission levels will be applicable for such yachts with keel laid after 1 January 2021. Possible additional proposals are now expected to be discussed at MEPC 76 in June 2021.

More details about the draft amendments to the MARPOL convention to cut ship emissions:

The draft amendments to the MARPOL Convention would require ships to combine a technical and an operational approach to reduce their carbon intensity. This is in line with the ambition of the Initial IMO GHG Strategy, which aims to reduce carbon intensity of international shipping by 40% by 2030, compared to 2008. The amendments were developed by the seventh session of the Intersessional Working Group on Reduction of GHG Emissions from Ships (ISWG-GHG 7), held as a remote meeting 19-23 October 2020.

The draft amendments would add further requirements to the energy efficiency measures in MARPOL Annex VI chapter 4.  Current requirements are based on the Energy Efficiency Design Index (EEDI), for new build ships, which means they have to be built and designed to be more energy efficient than the baseline; and the mandatory Ship Energy Efficiency Management Plan (SEEMP), for all ships. The SEEMP provides for ship operators to have in place a plan to improve energy efficiency through a variety of ship specific measures.

The draft amendments build on these measures by bringing in requirements to assess and measure the energy efficiency of all ships and set the required attainment values. The goal is to reduce the carbon intensity of international shipping, working towards the levels of ambition set out in the Initial IMO Strategy on reduction of GHG emissions from ships.

The set of amendments includes: the technical requirement to reduce carbon intensity, based on a new Energy Efficiency Existing Ship Index (EEXI); and the operational carbon intensity reduction requirements, based on a new operational carbon intensity indicator (CII).

The dual approach aims to address both technical (how the ship is retrofitted and equipped) and operational measures (how the ship operates).

The EEXI will impose a requirement equivalent to Energy Efficiency Design Index (EEDI) Phase 2 or 3 (with some adjustments) to all existing ships regardless of the year of build and is intended as a one-off certification. The EEXI is to be verified and a new Energy Efficiency Certificate issued no later than the first annual International Air Pollution Prevention (IAPP) survey on or after 1 January 2023.

All cargo and cruise ships above 5,000 GT need to calculate a CII (e.g. Annual Efficiency Ratio [AER]) given in grams CO2 per dwt-mile) and will be given an annual rating of A to E. The rating thresholds will be increasingly stringent towards 2030. For ships that achieve a D rating for three consecutive years or an E rating in a single year, a corrective action plan needs to be developed as part of the SEEMP and approved.

On or before 1 January 2023, all ships above 400 GT need to have an approved SEEMP on board, and the implementation of the SEEMP will be subject to audits. For ships above 5,000 GT, the SEEMP also needs to include mandatory content, such as an implementation plan on how to achieve the CII targets.

The amendments are expected to be adopted at MEPC 76 in June 2021 with entry into force on 1 January 2023.

SYBAss members will soon receive, as usual, a detailed report on this IMO Marine Environment Protection Committee meeting.