INTERCARGO Statement on IMO Decarbonisation Ambitions, Medium-Term Measures and Carbon Intensity Indicators

INTERCARGO continues to fully support the ambition to achieve net zero emission shipping by 2050. It is important to stress, however, that this goal can only be achieved by providing the shipping industry with alternative zero carbon fuels.

The responsibility for decarbonisation cannot be placed solely on the shoulders of the ship operator at the end of the line – it is a challenge that must be dealt with holistically by the entire shipping industry.

It is essential that appropriate policies are included in the Revision of the International Maritime Organization (IMO) GHG Strategy to ensure that green fuels are secured as well as the necessary infrastructure to ensure availability and bunkering in ports around the world. Unfortunately, these aspects are not sufficiently discussed and addressed despite their critical role.

INTERCARGO’s position is that a combination of core elements of previous proposals on medium-term measures is the best way forward, and therefore welcomes the ICS revised proposal (paper ISWG- GHG 13/4/9).

Specifically, INTERCARGO believes that a flat rate contribution per tonne of CO2 emitted on a Tank- to Wake (TtW) basis - and subject to the outcome of the ongoing discussions at IMO on fuel emissions’ Life-Cycle Assessment (LCA) - should be combined with an International Maritime Sustainability Funding and Reward (IMSF&R) mechanism where ships of 5,000 GT and above will make an annual contribution per tonne of CO2.

Under such a scheme only ships that use ‘eligible alternative fuels’ would receive a reward for CO2 emissions prevented.

A combination of technical and economic measures should be accompanied by appropriate policies and commitments from the Member States, in order for fuel suppliers to secure the required alternative fuels in ports around the world in sufficient quantities.

On CII (Carbon Intensity Indicators)

INTERCARGO believes that the current Carbon Intensity Indicator (CII) framework should not be used as a benchmark for IMO’s medium-term measures.

During the Association’s recent deliberations during its semi-annual meetings, INTERCARGO members expressed their belief that CII cannot be used to achieve the desired decarbonisation goals as under real life operating conditions it will not deliver equitable, transparent and non-distorting emissions' reductions.

A number of factors can have a significant adverse impact on a vessel's CII rating, most of which are outside the vessel’s control. Examples include adverse weather, voyage distance, port waiting times, port infrastructure, and charterers orders. Paradoxically when considering voyage distances and port waiting times, vessels with longer travel distances can produce more emissions but have a better CII rating when compared to vessels travelling shorter distances and producing less emissions.

INTERCARGO does not therefore believe that CII, in the current format, would achieve the desired de- carbonisation goals or targets. While generally supportive of the operational short-term measure, there are significant flaws that need to be addressed in order to make CII fit for purpose.

The opinions expressed herein are the author's and not necessarily those of The Xinde Marine News.