INTERCARGO Proposals Call on IMO to Review CII at MEPC 82

[By: INTERCARGO]

The International Association of Dry Cargo Shipowners (INTERCARGO) has submitted proposals to the International Maritime Organization (IMO) calling for a review of the Carbon Intensity Indicator (CII) at the 82nd session of the Marine Environment Protection Committee (MEPC 82), being held between 30th September and 4th October at the IMO Headquarters in London.

Drawing on extensive studies that analysed data from over 5,600 bulk carriers, INTERCARGO has highlighted several key issues with the current CII system:

1. Impact of idle time: The studies show a clear correlation between increased idle time and poorer CII ratings, particularly for smaller vessel sizes. This idle time, which includes periods in port or at anchorage, is often beyond the vessel's control.
2. Perverse incentives: The current CII framework may inadvertently encourage ships to run their main engines unnecessarily, for example when waiting at anchorage, potentially increasing overall emissions while improving their CII rating.
3. Inconsistent efficiency indicators: Vessels with E ratings often have lower average CO2 emissions compared to those rated A to D, suggesting the CII does not accurately reflect a vessel's true efficiency.
4. Size-based disparities: Smaller bulk carriers, especially in the Handysize and Supramax/Ultramax segments, show a higher percentage of D and E ratings compared to larger vessels.

In light of these findings, INTERCARGO has proposed that the IMO:

• Review and adjust the CII to better reflect a vessel's true energy efficiency, rather than, by implication, reflecting the efficiency of a port or other factors outside the control of a ship.
• Implement a system that further incentivises overall GHG emission reduction, rather than potentially resulting in encouraging behaviour that improves ratings but increases total emissions.
• Consider a multi-phased approach to refining the CII, starting with solutions based on current data and progressing to more refined measures as additional data becomes available.

Mr Dimitris Monioudis, Vice-Chair of INTERCARGO’s Technical Committee, emphasised the rigour of the analysis underlying these recommendations: "Our proposals are grounded in a comprehensive examination of verified IMO Data Collection System data from 2022. This wasn't just a cursory review – it involved meticulous analysis of over 5,600 bulk carriers, conducted in collaboration with three major classification societies: ABS, Bureau Veritas, and DNV. This level of scrutiny provides a robust foundation for our recommendations and underscores the urgent need for a review of the current CII system."

INTERCARGO Chairman, Mr Dimitris Fafalios, added: "The current CII framework, while well-intentioned, may be leading us down a path which contradicts our ultimate goal of reducing overall emissions. We're seeing situations where ships might actually increase their total emissions to improve their CII rating. This is clearly not the outcome we're aiming for so it is crucial that we refine this system to ensure it truly incentivises energy efficiency and emissions reduction across our industry."

INTERCARGO has urged the MEPC's Working Group on Air Pollution and Energy Efficiency to examine how the CII can be adjusted to better align with the IMO's decarbonisation goals for global shipping.