第76回IMO海洋環境保護委員会(MEPC76) 概要まとめ

2021年6月10日から17日にかけて、第76回IMO海洋環境保護委員会(MEPC76)がオンラインで開催されました。

The 76th session of the IMO’s Marine Environment Protection Committee (MEPC 76) was held remotely with a limited agenda from 10 to 17 June 2021. A summary of the main outcome from MEPC 76 is provided below.

1. Meeting the initial GHG Strategy Ambition

During MEPC 76, IMO adopted new mandatory measures into MARPOL Annex VI to cut the carbon intensity of international shipping, setting shipping on course to meet greenhouse gas reduction targets established in the 2018 Initial IMO Strategy on Reduction of GHG Emissions from Ships (MEPC.304(72)). The initial strategy sets out short- mid- and long-term measures. The combined technical and operational measures adopted into MARPOL Annex VI fall into the category of short-term measures.

Mandatory Measures – Adoption of Amendments to MARPOL Annex VI

MEPC 76 adopted amendments to MARPOL Annex VI to reflect the technical and operational measures to reduce the carbon intensity of international shipping. The revised Annex VI requires ships to calculate their Energy Efficiency Existing Ship Index (EEXI) and establish an annual operational carbon intensity indicator (CII) and rating. The amendments to MARPOL Annex VI are expected to enter into force on 1 November 2022, with the requirements for EEXI and CII certification coming into effect from 1 January 2023. This means that the first annual reporting will be completed in 2023, with the first rating given in 2024.

• Energy Efficiency Existing Ship Index (EEXI) - Revised regulations 23 (attained EEXI) and 25 (required EEXI) require existing ships to improve their technical efficiency to the extent they are comparable to that of an equivalent new ship of the same type and deadweight which would be required to comply with the applicable EEDI Phase.
  
  The attained EEXI is required to be calculated for ships of 400 gt and above and operating internationally, in accordance with the different values set for ship types and size categories , and indicates the energy efficiency of the ship compared to a baseline.
  
  Existing ships must meet a specific required EEXI based on a required reduction factor expressed as a percentage relative to the EEDI baseline.
  
  The introduction of the EEXI requires all applicable vessels to hold:

• An attained EEXI or EEDI equal to or below the required EEXI of the vessel;
• An Onboard Management Manual verified by a Recognised Organisation (RO), where Over-ridable Power Limitation (OPL) has been installed to improve the attained EEXI;
• A verified attained EEXI (or EEDI where applicable) based on an EEXI (or EEDI) Technical File;
• A Flag or RO issued International Energy Efficiency Certificate (IEEC) following verification of the attained EEXI.
  
  Alongside the MARPOL amendments, the associated EEXI guidance has been approved during MEPC 76 to support the implementation of the amendments.

• Carbon Intensity Indicator (CII) - Revised regulation 28 (operational carbon intensity) requires a linear reduction in the in-service carbon intensity of ships between 2023 and 2030, such that the global fleet achieves an average reduction of at least 40% by 2030 when compared with 2008.
  
  Revised regulation 26 requires aspects of a ship’s CII to be documented under the existing framework of the Ship Energy Efficiency Management Plan (SEEMP). On or before 1 January 2023, ships of 5,000 gross tonnage and above will need to revise their SEEMP to include:

(a) a description of the methodology to be used to calculate the ships Attained Annual Operational CII, and the process that will be used to report this value to the Administration;
(b) the Required Annual Operational CII for the next three years;
(c) an implementation plan documenting how the Required Annual Operational CII will be achieved during the next three years; and
(d) a procedure for self-evaluation and improvement.

Emissions data must be submitted through the IMO Data Collection System (DCS). As a minimum, the vessel’s relevant Carbon Intensity Indicator (CII), as attributed by the IMO, must be reported. This will be either the Annual Efficiency Ratio (AER) or the cgDIST in the case of cruise ships, ROPAX or vehicle carriers.

From 1 January 2024, vessels will be issued with a Statement of Compliance (SOC). The Confirmation of Compliance (CoC) and Statement of Compliance (SoC) which are associated with fuel oil consumption reporting (renumbered Regulation 27) will be modified to also address the Operational Carbon Intensity Rating, both of which must be reported annually to the Administration. This will require new issuance of CoC and SoC documents when these amendments enter into force.

Each year, the actual annual operational CII achieved (attained annual operational CII) shall be documented and verified against the required annual operational CII to determine the operational carbon intensity rating. The rating would be given on a scale, i.e. operational carbon intensity rating A, B, C, D or E, indicating a major superior, minor superior, moderate, minor inferior, or inferior performance level. A ship rated D for three consecutive years, or E, would have to submit a corrective action plan, to show how the required index (C or above) would be achieved. The corrective action plan is to be included in the SEEMP.

The associated CII guidelines supporting the new requirements has been adopted at MEPC 76.

The key decision was the establishment of reduction factors for the CII. G3 indicate that, with 2019 as the base year for the reference lines, the reduction factor defines the mid-point of the C-rating band for each year. The CII reduction rates were set to increase by 1 percentage point (pp) per year for 2020–2022, followed by 2 pp per year for 2023–2026. The rates for 2027–2030 will be decided as part of the review to be concluded by 1 January 2026. See below:

Mandatory Measures - Amendments to MARPOL Annex I

The IMO approved a new Regulation 43A to MARPOL Annex I to incorporate a prohibition on the use and carriage for use of heavy fuel oil (HFO) as fuel by ships in the Arctic waters on and after 1 July 2024. For ships to which Regulation 12A of MARPOL Annex I (Oil fuel tank protection) is applicable, this prohibition would be effective on and after 1 July 2029.

The new Regulation 43A also contains provisions which allow for the following:

• A waiver from the HFO ban until 1 July 2029 for ships with oil fuel tanks within their double hull that comply with Regulation 12A of MARPOL Annex I or Regulation 1.2.1 of Chapter 1, Part II-A of the Polar Code.
• Arctic coastal countries may waive the requirements of this new regulation until 1 July 2029 for vessels flying their respective flags and operating in their respective waters.

These amendments will enter into force on 1 November 2022.

Exemption of UNSP barges from survey and certification requirements

MEPC 76 adopted draft amendment to MARPOL Annexes I, IV and VI concerning the exemption of unmanned non-self-propelled (UNSP) barges from survey and certification requirements. The exemptions under Annex I are based on the barge not carrying oil or fitted with any oil tanks or machinery that generates oil residues, and for Annex IV, also on the barge not being used for holding sewage or having any arrangement that could produce sewage.

Guidelines for exemption of UNSP barges from the survey and certification requirements were also approved during MEPC 76. UNSP barges being exempted will be issued with an exemption certificate valid for 5 years instead of the relevant MARPOL certificate.

The amendments will enter into force on 1 November 2022.

2. Mandatory Measures – Amendments to the International Convention on the Control of Harmful Anti-fouling Systems on Ships (AFS Convention)

MEPC 76 adopted draft amendments to Annexes 1 and 4 to the AFS Convention and the form of the International Anti-fouling System Certificate (IAFSC) to include controls on cybutryne. 
The amendments require ships to stop using anti-fouling systems containing cybutryne from 1 January 2023, and to remove from existing ships, or seal such anti-fouling systems on existing ships with an appropriate barrier, at the next scheduled renewal of the anti-fouling system after 1 January 2023, but no later than 60 months following the last application. 

The requirement to remove or seal does not apply to fixed and floating platforms, FSUs and FPSOs constructed prior to 1 January 2023 and not dry-docked on or after that date; ships not engaged in international voyages; and ships of less than 400 GT engaged in international voyages, if accepted by the coastal state.

The adopted amendments also includes a new proposal to amend the table within the draft form of IAFSC to include ships that had applied an anti-fouling system containing cybutryne previously, but not currently contained in the external coating layer of their hull.

3. Air Pollution and Energy Efficiency

• MEPC 76 approved draft amendments to the Guidance for best practice for member State/coastal State (MEPC.1/Circ.884), which contains the indicative example of a licence for fuel oil supply.
• MEPC 76 approved a draft work plan to develop the guidelines on the shaft/engine power limitation (S/EPL) system to comply with the EEDI or EEXI requirements and use of a power reserve to maintain consistency between the two requirements, with a view to finalization at MEPC 77 in November 2021.
• MEPC 76 approved the draft amendments to the guidelines for determining minimum propulsion power to maintain the manoeuvrability of ships in adverse conditions (MEPC.1/Circ.850/Rev.2). The amendments include changes to the definition of adverse weather conditions and a new minimum power assessment method.
• MEPC 76 reviewed carbon intensity proxies for offshore and marine contracting vessels and cruise passenger ships.
• MEPC 76 approved Unified Interpretations to the NOx Technical Code (MEPC.1/Circ.895), clarifying requirements for testing and certification of engines with Selective Catalytic Reduction (SCR) systems.

4. Marine Plastic Litter

MEPC approved two circulars regarding marine plastic litter:

• Circular MEPC.1/Circ.893 on the provision of adequate facilities at port and terminals for the reception of plastic waste from ships.
• Circular MEPC.1/Circ.894 on the sharing of results from research on marine litter and encouraging studies to better understand micro-plastics from ships.

An Action Plan to address marine plastic litter from ships was deferred to MEPC 77.

5. Other Matters

Due to time constraints at this session, the following work was deferred to MEPC 77:

• Ballast water management
• Pollution prevention and response including safety and pollution hazards of chemicals, exhaust gas cleaning systems and black carbon

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If Members have any queries regarding the above, please feel free to get in touch with the author, Meredith Yang, or their usual Club contact.