30 May 2023
MEPC 79 – New amendments & IMO GHG Strategy
What are the new amendments and GHG strategy that resulted from the IMO MEPC 79? This is everything you need to know.
The 79th session of the IMO’s Marine Environment Protection Committee (MEPC 79) took place from 12 to 16 December 2022. Highlights include the adoption of a Sulphur Emission Control Area (SECA) in the Mediterranean Sea from 1 July 2025. Additionally, further discussions on the revision of the IMO GHG Strategy scheduled for 2023 and future technical and market-based measures.
Table of Contents
- Adoption of amendments to MARPOL Annex VI to include information on the flashpoint of fuel in the Bunker Delivery Note (BDN);
- Adoption of a new Sulphur Emission Control Area (SECA) in the Mediterranean taking effect from 1 July 2025;
- Consideration of revisions to the IMO GHG Strategy and future technical and market-based measures;
Adoption of amendments to mandatory instruments
Regional reception facilities within Arctic waters can provide for regional arrangements as an acceptable way to satisfy MARPOL obligations to provide port reception facilities that cover ports within Arctic waters. Consequently, the 2012 Guidelines for the Development of a Regional Reception Facilities Plan was amended to be aligned with the MARPOL amendments. The amendments will enter into force on 1 May 2024.
Garbage Record Book
Amendments to MARPOL Annex V make the Garbage Record Book mandatory also for ships between 100 and 400 gross tons. The amendments will enter into force on 1 May 2024.
Mediterranean Sulphur ECA
Amendments to MARPOL Annex VI, adopted to establish a Mediterranean Emission Control Area for sulphur oxides and particulate matter. The requirement will be the same as for other sulphur ECAs. Thus, mandating the use of fuel oil with a sulphur content not exceeding 0.10% or the use of an exhaust gas cleaning system. The amendments will enter into force on 1 May 2024, and the requirements take effect on 1 May 2025.
Information to be included in the BDN Amendments to MARPOL Annex VI, Appendix V were adopted. Hence, to also include the flashpoint of the fuel oil, or alternatively a statement of the measured flashpoint at or above 70°C. The amendments will enter into force on 1 May 2024.
Ship Fuel Oil Consumption Database
Amendments to MARPOL Annex VI, Appendix IX, adopted to include the below for submission to the IMO Ship Fuel Oil Consumption Database.
- Attained and required Carbon Intensity Indicator (CII) values;
- CII rating;
- Attained Energy Efficiency Design Index for existing ships (EEXI);
The amendments will enter into force on 1 May 2024. However, administrations should consider an early application from 1 January 2024. Hence, ensure that the CII data for 2023 will report to the IMO.
Harmful aquatic organisms in Ballast Water Record Book (BWRB)
MEPC 79 revised the format of the BWRB in Appendix II of the Ballast Water Management (BWM) Convention Annex. The revised BWRB introduces code letters (A-H), similar to the oil record book. It aims to improve the recording of issues around BWM systems. The amendments will be circulated for adoption at MEPC 80 in July 2023.
Ballast Water Treatment Systems: Up to speed
This is everything you need to know for Ballast Water Treatment Systems (BWTS). Why? How it works? Types available, Pros & Cons.
Grey water and treated sewage in ballast tanks
MEPC 79 agreed to permit the use of ballast tanks for the temporary storage of treated sewage and grey water. Guidance will follow at the next MEPC to set out appropriate actions and uniform procedures. Thus, ensuring compliance with the BWM Convention. Particularly, the D-2 standard, when the ballast tanks return to ballast water storage.
MEPC 79 discussed and established a list of fundamental principles to consider when developing further guidance for ships calling ports with challenging water quality. Ships will expectedly return to D-2 compliance after experiencing challenging uptake water. Therefore, bypassing a BWM system should only be a last resort. Communication with the port receiving the uptake water is crucial. Further work on guidelines will follow at MEPC 80 in July 2023.
Air pollution and energy efficiency – EEDI
The committee revised the EEDI calculation guidelines to include:
- CO2 conversion factor for ethane;
- Reference to the updated ITCC guidelines;
- Clarification in the case of a ship with multiple load line certificates. The maximum certified summer draft will stand when determining the deadweight;
Moreover, MEPC 79 discussed applying the shaft and engine power limitation concepts to the EEDI. Thus, agreed that, in principle, these concepts should follow in a future revision.
Discussions for a possible Phase 4 of the EEDI, with several member states advocating for developing it into an energy-based index by removing the CO2 conversion factor. In the meantime, others wanted to also include methane (CH4) and nitrous oxides (N2O). However, no decisions were taken, and further discussions were deferred to later sessions of the Committee.
Licensing scheme for bunker suppliers
MEPC 79 discussed establishing a mandatory licensing scheme for bunker suppliers. However, there were no agreements to do so. But, encouraging member states to apply the voluntary licensing scheme in the Guidance for best practice for Member State/coastal State (MEPC.1/Circ.884/Rev.1).
Note that, the committee approved a clarification on the Unified Interpretation of Appendix IX of MARPOL Annex VI. Particularly, the DCS reporting includes boil-off gases (BOG) used for propulsion or operational needs (boiler, or burnt in a Gas Combustion Unit (GCU) for cargo tank pressure control). MEPC 79 approved an extension of the Unified Interpretation of Regulation 18.3 of MARPOL Annex VI related to NOx emissions when using biofuels, that it should also be applicable for fuels with a synthetic fuel content of up to 30%. In principle, such fuels fall under the definition of Marine Fuel Oil derived from petroleum refining (Regulation 18.3.1) with no further NOx testing required.
Additionally, approved Unified Interpretations of Regulation 26 of MARPOL Annex VI related to the Ship Energy Efficiency Management Plan (SEEMP). A new ship should comply with the requirement at the time of delivery. Furthermore, for ships delivered on 1 October or later, the following year counts as the first year of the 3-year implementation plan, and the attained CII for the remaining part of the year of delivery should not count when determining whether the ship should develop a corrective action plan under Regulation 28. MEPC 79 approved a Unified Interpretation of Regulation 28 of MARPOL Annex VI related to the plan for corrective action to achieve the required CII. The corrective action plan should plan for how to achieve the required CII in the second year after the reporting year that resulted in the third consecutive D-rating or an E-rating.
SEEMP (Part I, II, III) – Everything you need to know
What is SEEMP? From the year 2023, the ships subject to the CII rating will have to develop a SEEMP Part 3 (III) on or before 31 December 2022.
Reduction of GHG emissions
Revision of the IMO GHG Strategy
There was an extensive exchange of views on the scheduled revision of the IMO GHG Strategy. MEPC 79 revised the Guidance on the process and methodological elements for the conduct of comprehensive impact assessments (MEPC.1/Circ.885). There was, limited convergence between member states on the vision and levels of GHG reduction ambitions in the strategy.
The main divergence in views is between those calling for full decarbonization by 2050, and those calling for further assessments on the feasibility to achieve such ambition and the potential impacts on states before making such a decision. Still remains a divergence of views on the necessity of intermediate GHG reduction targets, set for 2030 and 2040. The MEPC will adhere to the established work plan on this matter and adopt the revised strategy at MEPC 80 in July 2023. Further discussions will take place at Working Group meetings (20-24 March, and during the week prior to MEPC 80 in July 2023).
Mid & Long-term measures to reduce GHG emissions
There was an extensive discussion on potential mid and long-term measures at a Working Group meeting held the week prior to MEPC 79. At this meeting, proposals for various measures laid down and there was an increased support for a basket of measures combining technical and economical elements.
On market-based measures there was a convergence towards a levy scheme. Hence, imposing a set price on well-to-wake or tank-to-wake GHG emissions. Possibly, in combination with a rebate system where the revenues are partly provided back to vessels to cover the price gap between fossil and low or zero-carbon fuels.
Additionally, there was significant support for a technical measure in the form of a well-to-wake GHG intensity fuel standard. Further discussions will take place at Working Group meetings (20-24 March, and during the week prior to MEPC 80 in July 2023). The decision on which measures to develop into regulations will solidify at MEPC 80.
Correction factors for the Carbon Intensity Indicator (CII)
Proposals for additional CII correction factors deferred to MEPC 80. Considering the diverging views expressed, it is likely that decisions to add further correction factors will only occur at the review point in 2025.
Revision of the Data Collection System (DCS)
In addition to the amendments to the DCS adopted at MEPC 79, there was a discussion on adding further elements, including mandatory cargo data reporting. The discussions will continue at future meetings of the MEPC.
On-board CO2 capture
A brief discussion held on provisions for considering on-board CO2 capture and storage in GHG regulations under MARPOL Annex VI. Due to time constraints, the issue deferred to MEPC 80.
Lifecycle GHG/carbon intensity for marine fuels
A brief discussion was held on developing guidelines on life cycle GHG/carbon intensity. The correspondence group will continue its work on the guidelines, and a first version will expectedly finalize at MEPC 80 in July 2023.
CII Calculation: Carbon Intensity Indicator Guide
How to calculate the CII rating? We debunk its complexity by simplifying the procedures based on IMO guidelines.
The classification society DNV recommends that operators complete their preparations for compliance with the upcoming EEXI, SEEMP, and CII requirements. From 1 January 2023, an approved SEEMP Part III needs to be on board and the necessary data to calculate the CII and relevant correction factors must be monitored and reported. By the first survey after 1 January, the EEXI Technical File needs to be approved.
SEEMP Part 3 – Easy compliance for 2023
Shipowners rush to calculate the attained CII Rating of the fleet to include in SEEMP Part 3 when it is not needed. Why?