April 2018 saw the adoption, with much fanfare, of the Initial IMO Strategy for Reduction of Greenhouse Gas (GHG) Emissions from Ships. For those at Marine Environment Protection Committee (MEPC) 72, there was a huge sense of achievement and the feeling that this might just be the start of a real transformation in shipping.
At MEPC 73 in October 2018 a follow-up programme of actions was agreed and is designed to guide the delivery of actions and measures needed to deliver on the intent of the Initial IMO Strategy, including measures needed to peak GHG emissions as soon as possible.
However, at MEPC 74 earlier this year, momentum was waning. It was clear that deciding what Member States would agree as the approach to reduce carbon intensity in the short-term, whilst also laying the groundwork for the radical change needed to decarbonise the shipping industry, could take some time.
As we near the end of 2019 there is one round of intersessional discussion to go before MEPC 75 in April 2020. Whilst positive progress was made at the intersessional negotiations held in November, the industry is not benefitting from the lack of certainty around what shipping will be required to do. Member States and international organisations should remember that they are not negotiating in isolation – whether bull or bear, the business of designing, building, owning, operating and chartering ships continues.
Whilst LR has high ambitions for the decarbonisation of the shipping industry, we are acutely aware that the uncertainty around the short-term actions to reduce carbon intensity is not good for the industry and is delaying discussion on the uptake of alternative low- and zero-carbon fuels.
When it comes to procedures, there is an imperative to agree measures which reduce carbon intensity at least before 2023. The detail of the procedures is not important; the consequence is. If IMO wants to agree and adopt measures to start reducing carbon intensity before 2023 and then beyond to 2030, it needs to do this by October 2020 (MEPC 76). There is a deadline and in a strange twist to the story, it might just be the procedures so often criticised for slowing things down at the IMO that force the pace.
Short-term measures
Whilst intersessional negotiations between now and April 2020 cannot yield decisions, they can yield an indication of the measures most likely to grace the pages of MARPOL Annex VI. The discussion to watch is the one around the most mature proposals currently on the table:
- A technical goal-based measure using an Energy Efficiency Design Index for Existing Ships (EEXI). The scope of options to achieve the goal is limited to technical efficiency measures and emphasis is placed on shaft power limitation. The simplest of the mature proposals, but not without its difficulties, including its true impact on CO2 abatement if weather continues to be more extreme because of climate change;
- A operational goal-based measure establishing a series of carbon intensity targets which can be met by technical and operational means. This would be more complex to implement but offers owners and operators greater scope to consider technical, operational and organisational ways of reducing carbon and will support IMO achieve its vision for 2050; and
- A proposal from a coalition of Member States and international organisations effectively proposing a hybrid approach, allowing owners and operators to pursue pre-certification based on the EEXI concept, or a purely goal-based approach. More interesting because of the breadth of co-sponsorship than its technical content.
Other options, including speed reduction, speed optimisation, and shaft power limitation in specific sectors, as well as, papers addressing the challenges of measuring performance against a specified target will add interest to proceedings.
As a Recognised Organisation (RO), LR is engaged in developments closely to ensure that the implementation of measures can work and deliver a globally consistent playing field for industry.
Uptake and safety of alternatives fuels
Yes, LR has a high-level of ambition for decarbonising shipping, but as a classification society we recognise that this change will need to be accompanied by the work necessary to make the use of alternative low- and zero-carbon fuels safe.
The uptake of low- and zero-carbon fuels is also on the table for discussion before MEPC 75. This will be focused on thinking about how to incentivise the displacement of fossil fuels and is an essential starting point if zero-emission vessels are to be entering the fleet by 2030. Hopefully, the lessons of the IMO 2020 sulphur cap will be learned – early commitment and decisions are needed when compliance in-sector relies on substantial change outside of the industry.
Elsewhere in IMO, work is underway looking at the safety of alternative fuels. The Sub-Committee on Carriages of Cargoes and Containers (CCC) in September 2019 agreed guidance addressing the increasing interest in the use of ethanol or methanol as fuel. These are expected to be approved and ready for use by May 2020. Work to complete similar guidelines for ships using fuel cell power systems is also expected to be completed in September 2020 and should be available for use in 2021.
At the same meeting, the issue of hydrogen was raised in working groups considering amendments to the IGF and IGC Codes. Given the appetite for IMO to respond to the interest in hydrogen as fuel, it is expected that proposals to begin work may be made in 2020. This will be separate from existing Interim Recommendations for Carriage of Liquefied Hydrogen in Bulk.
Challenges ahead
The principal challenges ahead for IMO include: providing the industry with the certainty it needs on short-tern measures; and the measures it will take to incentivise the uptake of low- and zero-carbon fuels. The latter needs to be supplemented by ongoing activity to understand the hazards of alternative fuels and provide requirements to support their safe use on ships.
The IMO has, for the first time, a strategic intent that spans at least 30 years with interest from both inside and outside of the sector. LR supports this strategic direction but also recognises that the vision and ambition it embodies needs swift but considered decisions early on – success will be determined by the choices made before the year 2023. The pressure is on the IMO to demonstrate it is in control of its own initial strategy and continues to have the vision to deliver on it.