Interferry has identified major concerns over the core proposals for reducing greenhouse gas (GHG) emissions from existing ships.
With new requirements coming under discussion at two imminent International Maritime Organisation (IMO) meetings, the association urgently requests all members to call upon their respective IMO representatives to lobby for sector-specific solutions that recognise the diverse demands of ferry design and operation.
The IMO has set targets of 40 per cent energy efficiency improvements by 2030 and 50 per cent absolute reductions by 2050 compared with 2008 values – preceded by short-term proposals due to be implemented by 2023. Potential measures are being further developed this week at the IMO's GHG working group meeting (October 19 to 23), with the aim of being agreed at the November 16 to 20 session of the Marine Environment Protection Committee.
Interferry is cautioning that, due to the multi-various nature of ferry services, ro-ro passenger and cargo vessels stand to be penalised by the suggested Energy Efficiency Existing Ships Index (EEXI), a spin-off from the Energy Efficiency Design Index (EEDI) introduced for new ships in 2015.
"Ferries are a relatively small part of the IMO scope, so regulations are generally based on deep-sea factors that are not always appropriate in a short-sea context," explained Interferry Regulatory Affairs Director Johan Roos."
"The main compliance option under EEXI is power limitation. Ocean-going ships can typically limit their installed power and reduce speed to meet the required 'average performance' within a shipping sector. In contrast, the diversity of the ferry segment demands operational flexibility and there is no obvious technical solution to achieve compliance. This is an uncomfortably urgent situation because any ship that does not comply with the EEXI by its first renewal survey after January 1, 2023, will lose its licence to operate."
In a sample review of 125 Ro-Ro cargo ships and 110 Ro-Pax vessels in the existing European fleet, Interferry found that 55 per cent of each type would not conform to the proposed EEXI standards.
Interferry intends to use its consultative IMO status by supporting an additional proposal that would measure annual improvements on an individual ship basis under the so-called Carbon Intensity Indicator (CII). Calculated on the fuel consumption and distance sailed by a ferry in an agreed base year, the association says this would extend compliance options beyond slow steaming to solutions such as alternative fuels, shore power, better operational practices and future technological advances.
However, the nominal levels for annual improvements have yet to be decided, adding another unknown into the deliberations together with a common uncertainty for ferries on both the EEXI and CII – the lack of sector-specific analysis of the metrics for establishing historic and future CO2 efficiency.
As an example, the true capacity of a Ro-Ro cargo vessel should be measured in lane metres and total volume of the cargo decks rather than the deadweight tonnage method adopted by the IMO, which significantly disadvantages the recorded energy efficiency gains.
The association now calls for members to ask the IMO representatives in their national administrations to reserve their positions on the forthcoming discussions until demonstrable reductions in both relative and absolute GHG emissions are fully recognised by the regulatory instrument; the metrics used to define energy efficiency are valid for all ship types; and that there are actual compliance alternatives for existing ships in all segments.
We have always supported the IMO's efforts to find fair and robust mandatory emissions solutions and remain dedicated to helping ensure that the ferry industry is not dragged into a scheme that doesn't fit our unique nature. The expected new regulations will capture the vast majority of the shipping industry's CO2 emissions by being applied to the larger segments, but due consideration must be given to the special requirements of the smaller, short-sea segments.
