8 9 efficiency metric, which is the amount of GHG emitted per gross ton of the ship, per nautical mile sailed. Fully laden and completely empty ships of the same size would get the same ‘miles sailed’ performance score if they covered the same distance, but by default, the empty and lighter vessels will consume less fuel and thus rank better on the CII. Secondly, as per the original EEDI proposition, the CII has been developed without proper reference to different ship types. The EEDI has its merits for tankers and container ships, where smaller and larger vessels have broadly similar designs and service patterns. But applying statistical average methodology to a diverse design and operational population like the ferry sector will not produce a true basis on which to justify requirements costing multibillions of dollars. Interferry made this very point when successfully lobbying for sector-specific ‘fair and robust’ EEDI amendments. Thirdly, operators could inherit the sins of their forbearers. They might buy or bareboat a beautiful vessel that now requires them to find 50 per cent fuel savings because the former operator was less than careful; or they might outcharter a very efficient ship that returns to their fleet needing rectification due to a client’s over-ambitious itinerary. Within the ro-pax fleet, the ‘CII scatter’ – non-conformity to the imagined true average – is immense, with a worrying number of ships falling below the tentative 2030 targets. We deem the consequent corrective requirements to be highly unrealistic for such vessels. The IMO’s Marine Environment Protection Committee rubber-stamped the CII in June 2022 (MEPC 78). There was palpable apprehension about a regulation that blindly stipulates how much fuel a given ship should consume and retroactively penalises non-conformity to this narrow template. Many Member States indicated that they would adopt a soft approach and try their reasonable best, allowing more time to comply ahead of a review of the system due in 2026. Meanwhile, Interferry is advising its members to establish the expectations of their classification societies and flag states during the CII’s initial three-year stint. We will also rally our membership to provide the data and insights indicating how poorly this instrument reflects the true performance of ferries. Our sincere aim is to help the IMO towards regulatory adjustments that enable the ferry sector’s optimum contribution in reducing GHG emissions. CFR “ We aim to help the IMO enable the ferry sector’s optimum contribution in reducing GHG emissions” Is the Carbon Intensity Indicator a good measure of ro-pax efficiency? CO2 emissions relative to size (log scale) Size in GT (log scale) 2.2 2 1.8 1.6 1.4 1.2 1 0.8 3.5 3.7 3.9 4.1 4.3 4.5 4.7 4.9 5.1 Efficiency rating from A/B (light blue line) to D/E (green line), with the dotted yellow line representing the required CII efficiency rating CII efficiency ratings for 358 ro-pax ships show a large scatter of data that Interferry believes does not accurately reflect the real-world situation
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