As part of its Greenhouse Gas Strategy, The International Maritime Organisation (IMO) is taking a firm stance on the reduction of carbon emissions in the shipping sector and it has set a target date of 2030 to achieve a reduction of 40%. This is just part of the decarbonisation strategy, but one that cannot be achieved overnight. The process of change must start immediately.

In fact, the next milestone will be in 2023, when IMO amendments to existing regulations for the reduction of greenhouse gas emissions from vessels – the Energy Efficiency Index for Existing Ships (EEXI) and Carbon Intensity Indicator (CII) – come into force.

The CII measures how efficiently ships transport goods or passengers. It is represented and is measured in grams of CO2 emitted per cargo-carrying capacity and nautical mile.

The EEXI is a comprehensive framework for determining the energy efficiency and CO2 emissions of in-service vessels over 400GT. Largely adapted from the Energy Efficiency Design Index (EEDI) for new-build vessels, it demands that ship owners assess and measure their ships’ CO2 emissions by design against specific emission reduction factors for each vessel type. Following this assessment, they are able to take any necessary technical measures to adjust emissions to the required level.

This sounds simple in principle, but it may prove tougher in practice. A key strategy will be the adoption of new fuels, as well as other innovative on-board technologies.

“The new IMO regulations on decarbonisation will be challenging, however, it is strongly believed that these regulations will push the development of alternative fuels and increase the need to optimise design and operation aimed at reducing energy consumption even more,” says Andreas Ullrich, global market leader for passenger ships and ferries at Bureau Veritas Marine & Offshore. “The industry is well under way to meet the goals of the regulations.

“The biggest challenges today are to decide on the alternative fuel of the future, whether those fuels will be available in relevant quantities, and at what cost,” he adds.

The tools for the task

Reducing the shipping sector’s environmental impact is a top priority for marine stakeholders and regulators, hence the existing regulations for NOx and SOx emissions that have already come into force. The next phase, however, will bring some difficult choices for cruise operators, who must decide which fuels will underpin their long-term strategy at a time when innovation is rife.

“The shipping industry generally, as well as the cruise industry specifically, have well understood the implications connected with the EEXI and are fully aware of the challenges and where they are,” believes Ullrich. “The goal behind EEXI is carbon reduction and not primarily fuel usage. However, emission factors have an impact on the fuel choice.”

In general, the challenges are the same for all players within the shipping industry, but cruise operators must address the fact that their vessels stay longer in ports and have to deal with the effects of the required hotel load.

“When it comes to the CII, the cruise industry had proposed a port time correction factor, considering the longer stays in ports, which was rejected at the IMO MEPC78 session,” Ullrich notes. “The industry and its partners, such as classification societies and yards, are now developing an alternative CII matrix specifically for cruise ships.”

The transition will not be easy for ship owners to make without expert help. It is fortunate, therefore, that Bureau Veritas and others have developed specific tools to help them through the compliance process.

Bureau Veritas’ VeriSTAR Green, for example, is a tool that guides ship owners through the regulatory requirements of energy efficiency management regulations – the IMO Data Collection System (DCS), the EU Monitoring Reporting and Verification (MRV), EEXI and CII.

“It is a self-assessment tool and not a guidance tool, even though it provides access to The Ship Energy Efficiency Management Plan (SEEMP) template part III,” says Ulrich. “IMO DCS and EU MRV are clearly reporting tools showing the actual status, and the same applies to EEXI and CII. If the results are not in compliance with the targets set by IMO, then measures have to be implemented to become compliant.”

“These measures can be a reduction of speed, optimisation of hull design, usage of an alternative fuel, and other technologies such as sails and fuel cells,” he adds. “It is planned to include CII development within VeriStarGreen by 2026, based on existing values.”

Accredited registrar and classification society DNV GL, based in Norway, has produced a Compliance Planner, which enables shipowners to find a complete list of their vessels and their individual status in connection with the EEXI. It has produced two tools – a digital self-service model and an interactive, expert-led alternative.

“The goal behind EEXI is carbon reduction and not primarily fuel usage. However, emission factors have an impact on the fuel choice.”

DNV notes that the requirements of EEXI for cruise ships are similar to ro-ro passenger, where the correction factor will depend on the ship’s dimensions and its speed. It points out that, specifically, the efficiency of the generators and electric motors will be considered, as well as the additional hotel load.

As clear recommendations, DNV proposes that if a ship does not comply with required EEXI parameters, it should consider limiting the power of its engines, invest in energy efficiency technologies and look at reductions in speed with limited power.

Time is of the essence

The new regulations will have long-term implications for the cruise industry – and for the shipping sector as a whole – and time is running out.

Vessels impacted by EEXI must demonstrate compliance by their next survey – annual, intermediate or renewal – for the International Air Pollution Prevention Certificate (IAPPC), or the initial survey before the ship enters service for the International Energy Efficiency Certificate (IEEC) to be issued, whichever is the first on or after 1 January 2023. Entry into force of the new regulations will come at the start of November 2022.

Although the industry is aware of the broader decarbonisation drive by regulators and understands the implications of incoming regulations, it seems that some shipowners are yet to commence the compliance process. Some operators may not, in fact, fully comprehend the implications for their fleet.

“Sustainability is more than decarbonisation or EEXI and CII compliance and, therefore, we need to rethink the way ships are designed, built, operated and disassembled.”

“Our clear advice is to start now to calculate EEXI and CII, as well as to prepare SEEMP III, which will become mandatory on 1 January 2023,” Ullrich states. “When calculating EEXI and CII it is very important to use correct and reliable values in line with the IMO regulations.”

Lloyds Register also urges prompt action. In its six-step guide to EEXI compliance, step one is ‘Don’t Wait’. Given the urgency, there is some uncertainty about whether the cruise industry as a whole will be ready in time.

“This depends on a few factors, such as availability of alternative fuels and shore power,” Ullrich remarks. “The primary focus is currently on calculating EEXI and CII and, of course, on measures to improve the value, such as speed reduction, hull and route optimisation. This has, however, been in the focus of the industry for quite some time.”

One thing is certain, the compliance process required for EEXI will not be an endpoint but rather the start of the next phase of decarbonisation regulations. Industry rules are a constantly moving target. Change is the only constant, but at least the direction of movement is clear for all to see.

“Sustainability is more than decarbonisation or EEXI and CII compliance and, therefore, we need to rethink the way ships are designed, built, operated and disassembled,” says Ullrich. “New alternative and carbon-free fuels will help, aside from technologies such as wind, fuel cells and batteries, or maybe even nuclear power will play an important role in this transition.”

Indeed, nuclear-powered propulsion has been seriously discussed by cruise industry experts as a possible answer to the need to diversify away from fossil fuels, though many obstacles stand in the way of its wide adoption. The reaction of the paying public to having a nuclear element on board is chief among them. Technological challenges are the least of their worries.

Going forward, EEXI will certainly have an impact on the choice of alternative fuels, even if the industry does not take the nuclear option, but the most immediate concern is compliance. While long-term strategic decisions will certainly have to be made, the chief targets are meeting the new criteria in the short term.