Siddharth Mahajan, Senior Loss Prevention Executive,
Singapore, has noted in a recently published article that, with IMO’s Carbon
Intensity Indicator (CII) rating system for vessels coming into force next year,
cooperation between various parties would be key.
CII will be used to assess the efficiency with which a
ship operates in terms of its CO2 emissions. Mahajan said that the CII
regulation was likely to alter the traditional division of responsibilities
between owners and time charterers, and might change significantly the way
vessels are operated.
He wrote that “an initial step in the journey is to
understand the challenges ahead in order for owners and charterers to work
cooperatively to meet them”.
The Carbon Intensity Indicator or CII is a rating system
developed by IMO for all cargo, Ro-pax and cruise vessels above 5,000 gt whereby
vessels will be rated for their operational Carbon Intensity for each calendar
year, starting in 2023. Operational carbon intensity performance of different
types of ships from 2019 will be used as a reference.
IMO has agreed to various correction factors and voyage
adjustments which may be applied to the calculation of the attained CII, for
example any emission necessary for the purpose of securing the safety of a ship
or saving life at sea, fuel consumed in relation to STS voyages, fuel consumed
for production of electrical power used for refrigerated containers or cargo
/re-liquefaction systems on gas carriers, fuel used in cargo heating
etc. The need for further adjustments is still under discussion.
The IMO’s objective is to continuously improve a vessel’s
operational carbon intensity. A phased approach has been adopted under which the
carbon intensity limits will progressively reduce by 2% each year.
Vessels subject to CII regulations must develop a ship
specific Ship Energy Efficiency Management Plan (SEEMP) Part III to include
things such as:
SEEMP Part I relates to improving energy efficiency, while
Part II focuses on procedures for monitoring and collecting fuel oil
consumption data. The requirements for SEEMP Part I and Part II came into force
in 2018.
While the IMO is encouraging administrations and port
authorities to provide incentives to ships rated as A or B, there has as yet
been no guidance provided by the IMO on what form these incentives should take.
“We are not yet aware of any authorities introducing such incentive schemes
based on CII ratings, but we do expect to see some in the future” Mahajan
wrote.
As the formula stands currently, calculation of carbon
intensity is based on the consumption of fuel and its fixed carbon factor, and
not on direct measurements of the emissions at the engine exhaust side. Also,
there is no benefit given for carbon capture onboard. A lower numerator /or
a greater denominator can result in lower carbon intensity.
On the numerator side, the following factors can have a
positive impact on the CII rating for a given calendar year:
On the denominator side, the deadweight or gross tonnage
of a vessel will be constant and hence the only variable factor is the distance
sailed. Greater idling time, such as in port or anchorage can have a
detrimental impact. Frequent machinery breakdowns at sea can have a similar
affect. One of the consequences of having a fixed DWT or GT in the denominator
is that any reduction in cargo carried /or an increase in ballast voyages
will help the vessel achieve a better CII rating (by reducing fuel
consumption).
