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Home Associations Carbon Intensity Indicator (CII) for bunker vessels

Carbon Intensity Indicator (CII) for bunker vessels

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IBIA – The International Bunker Industry Association’s members, along with the wider shipping industry, are actively pursuing operational energy efficiency improvements as part of goals consistent with the International Maritime Organization’s (IMO) 2023 Strategy on Reduction of Greenhouse Gas (GHG) Emissions from Ships.

With the IMO’s initial Carbon Intensity Indicator (CII) ratings applied to ships, like others1 IBIA has noted the current inadequacies of CII methodology to appropriately reflect the service of bunker vessels which predominantly operate over short distances (duration) in port areas. IBIA seeks a CII methodology that is accurate, reliable, and implemented in a manner that fully reflects the intent of the IMO Strategy for its members’ bunker vessels that undertake a vital role in supporting international trading commercial ships.

IBIA agrees with other industry associations that to achieve the IMO’s intent, the CII must be appropriate for each shipping sector. A one-size-fits all instrument, as the CII is currently designed, has inherent flaws that has resulted in the introduction of goals that, because of the way CII is calculated, penalises vessels that undertake short voyages (duration).

The IMO’s Marine Environment Protection Committee (MEPC) at its 81st session in March 2024, publicly acknowledged significant concerns raised by IMO Member States and industry, recognising “shortcomings and unintended consequences of the CII mechanism and the general agreement that these concerns should be fully considered and addressed during the CII review process”.

IBIA supports the calls to amend the current CII mechanism, especially in view of the likely expected strengthening of the CII requirements after 2026, to avoid unintended consequences that are contradictory to IMO’s key principle of a maintaining a “level playing field” through the regulation of international shipping.

IBIA looks forward to the commencement of the CII “data analysis stage” at MEPC 82 in September following the “data gathering stage” and to that end has proposed through a submission to that meeting an amendment of the current CII methodology and formula to incorporate a short voyage (duration) correction factor that will go some way to address the service duty of bunker vessel when they support international shipping.

IBIA’s Representative to the IMO, Dr Edmund Hughes summarises that ‘IBIA as an organisation with consultative states at the IMO fully supports the effective and uniform implementation of the regulatory framework for international shipping. However, where anomalies are identified in those regulations IBIA will provide constructive input to their further development. IMO is undertaking a review of the Carbon Intensity Indicator (CII) and IBIA has submitted a document to MEPC 82 proposing a short voyage (duration) correction factor be applied to ensure bunker vessels, which perform an invaluable service to support international shipping, are not overly penalised due to the nature of their unique service duty.’

1 https://www.ics-shipping.org/wp-content/uploads/2024/07/Policy-Statement_CII_9-July-2024_final.pdf

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