CII’s impact on engines remains unclear

Uncertainty about the impact of IMO’s proposed Carbon Intensity Indicator (CII) on ship operations was voiced in The Motorship in December by Lars Robert Pedersen, deputy secretary general of the international shipowners organisation BIMCO. Now, engine builders and a leading organisation representing machinery manufacturers have added their voices to concerns about a lack of information about the new measure.

In his commentary, Mr Pedersen described the amendment to Marpol Annex VI that will bring in CII as “a novel piece of regulation” for which his members “are certainly not prepared”. CII, he said, “[has] not been clearly defined.”

Now a leading figure in the ship machinery sector, Peter Müller-Baum, secretary general of CIMAC, has told The Motorship that, with no details about how the CII will be calculated, “we do not yet know … what adjustments might be made to the engine.” He said that to make any comments on CII’s impact on ship’s machinery would be “like looking into a crystal ball” and it was impossible “to say if, or to what extent, existing engines will have to be modified.”

He pointed out that since CII is an operational index, it is more of a measure of how machinery is used, rather than the hardware itself and its “first targets will probably not involve machinery conversion,” although “mid- to long-term targets will likely require … onboard machinery modifications” in relation to fuel supply changes.

Zero-carbon fuels will certainly be necessary alongside “other technical and operational efficiency measures,” he explained, if shipping is to achieve the greenhouse gas (GHG) emission reductions in line with IMO’s GHG strategy and the Paris Agreement.

Dr Gunnar Stiesch, senior vice president and head of engineering engines at MAN Energy Solutions, also stressed the significance of new fuels on calculating CII, which he said “incorporates in its numerator fuel-related specifics” that are “influenced by the engine design and the fuel used on board.”

MAN Energy Solutions has a “standing development target” to lower OPEX while reducing CO₂ emissions, he said, stressing that its own engines and systems can operate on a variety of fuels to “pave the way for a use of low and zero carbon fuels.”

But implementing an operational measure such as CII “has to go hand in hand with a further development of design-related measures [EEDI and EEXI] to foster improvement of ship design and engine technology development,” he added. And he acknowledged that there are “pros and cons to several methodologies being considered for CII” and that “practicable implementation of CII is important to ship owners and operators.”

Nonetheless, he welcomed IMO’s decision to introduce CII, describing it as “an important step to assess operational performance of ships” and echoed Mr Müller-Baum by saying that this will help meet the goals of IMO’s Initial GHG Strategy.

Working group to report to MEPC 76

Behind the scenes, a correspondence group set up by the delayed Marine Environment Protection Committee’s 75^th meeting (MEPC 75) in November is working on a number of CII-related tasks, including drafting guidelines on operational carbon intensity indicators and their calculation methods, and will submit its report first to the next Intercessional Working Group on Greenhouse Gasses (ISWG-GHG 8), which is due to meet in May, before it goes to the delayed MEPC 76 in June.

The correspondence group’s full terms of reference can be found in IMO’s document management system, IMODOCS, where MEPC’s outcomes can be found in document MEPC 75/18. However, a separate addendum to that document, MEPC 75/18/Add.1, suggests that when the various proposals for CII reach MEPC 76, they may not simply be rubber-stamped for adoption.

That document includes some statements that delegations asked to be minuted, including one from the US delegation. This says that “the United States continues to have concerns over the rush to approve operational carbon intensity requirements before developing core aspects of the measure, including the basic metric to be used for measuring carbon intensity.”

It goes on to warn that, when the proposals reach MEPC 76, “our final view on the measure will depend upon these elements being developed to … reassure ourselves that they do not disproportionally impact ships in the US fleet.”

Assuming they are adopted in June, the amendments could come into force 16 months later, in October 2022. They include a review date of 1 January 2026 “at the latest” by when IMO must review “the effectiveness of the implementation of the CII and EEXI requirements … and, if necessary, develop and adopt further amendments,” an IMO summary of MEPC 75 notes.