All IMO meetings have now been cancelled until the end of July and work is ongoing to “reconstruct” the IMO schedule from September onwards. The reduction of GHG emissions is seen to be the most important issue on the agenda and MEPC 75 and the Intersessional working group on GHG emissions will accordingly be the first meetings to be resumed, with the aim of sticking to the original timetable for the imposition of technical and operational measures – i.e. to have them in force before 2023.
It is suggested that MEPC 75 could be rescheduled for autumn 2020, with the ISWG GHG the preceding week, to agree to the MARPOL amendments, then adoption at MEPC 76 rescheduled for spring 2021. This would mean that entry into force could still take place by the end of 2022. Nothing has been decided as yet, however.
At the last intersessional working group in October last year it was clear that there was very little support for prescriptive measures such as mandatory slow steaming, but no agreement was reached on whether the favoured goal-based approach should take the form of pre-certified technical measures (EEXI) as proposed by Japan or annual measurement of efficiency by a Carbon Intensity Indicator such as the EEOI or AER (or a mixture of both) as per a number of submissions. It seems clear now that we are likely to end up with some form of measurement of carbon intensity, possibly combined with EEXI.
There are still many issues to be hammered out, including how to calculate carbon intensity in 2008 (the base year) for various vessel types and sizes, whether the 40% reduction should apply to individual vessels or the fleet as a whole, and – importantly – how a ship’s carbon intensity would be measured. It remains to be seen whether it will be possible to thrash out all these issues and produce viable legislation within the timeline of the IMO’s Initial Strategy under the constraints imposed by Covid-19.