MEPC 80 – GHG moves dominate debate but outcome brings criticism

The headline discussion matter for MEPC 80 leading up to the early July 2023 meeting was the IMO’s emission targets for the shipping industry. An intersessional working group had spent the previous week debating the issue with the main meeting intended to be a rubber stamping exercise. In the event, the ISWG could not agree on imposing stricter targets and neither could MEPC 80 itself.  

by Gillian Lovering

Before MEPC 80 the targets were: 

  • To reduce CO2 emissions per transport work, as an average across international shipping, by at least 40% by 2030, pursuing efforts towards 70% by 2050, compared to 2008; and   
  • to peak GHG emissions from international shipping as soon as possible and to reduce the total annual GHG emissions by at least 50% by 2050 compared to 2008 whilst pursuing efforts towards phasing them out as called for in the Vision as a point on a pathway of CO2 emissions reduction consistent with the Paris Agreement temperature goals. 

The new agreement at MEPC 80 includes indicative checkpoints of a 20% reduction in emissions by 2030, a 70% reduction by 2040 (compared to 2008 levels) if national circumstances allow, and the ultimate goal of achieving net-zero emissions close to (but not by) 2050. 

The shipping industry and environmental groups have disagreed on whether this really increases ambition with the latter making the point these are ambitions only and are not mandatory and the inclusion of reference to national circumstances will likely mean that only some European states, the US and a handful of others will adopt them. 

With regard to the measures for reducing GHG emissions, it was agreed that a review of the short-term mandatory goal-based technical and operational measures shall be completed by 1 January 2026. While the basket of mid-term GHG reduction measures, which includes financial options such as levies and incentives, should be finalised  by 2025 with other candidate mid-term GHG reduction measures finalised and agreed between 2023 and 2030. Long-term measures could be agreed MEPC beyond 2030, to be developed as part of the 2028 review of the IMO GHG Strategy. 

MEPC 80 Adoption of the 2023 IMO Strategy on Reduction of GHG Emissions from Ships during the 80th Session of the Marine Environment Protection Committee (MEPC) at IMO HQ (07/07/2023)

Fuel lifecycle, carbon capture and EGCS developments 

On fuels, MEPC 80 adopted Resolution MEPC.376(80) containing the Marine Fuel life Cycle GHG Guidelines (LCA Guidelines) and agreed on a work program to further enhance guidelines on specific areas. The scope of these guidelines is to address Well-to-Tank, Tank-to Wake, and Well-to-Wake GHG intensity and sustainability themes. 

With onboard carbon capture and storage now becoming reality the IMO is being pressed to recognise the technology in its efficiency and CII regulations. It was agreed to instruct ISWG-GHG 16, if time permits, to consider the proposals related to onboard CO2 capture, using document MEPC 80/7/7 as a basis advise the Committee on a way forward.  

The meeting approved circular MEPC.1/Circ.905 relating to biofuels and carbon reduction suggesting that in the interim, pending development of policy instruments for the use of the Marine Fuel Life Cycle Assessment (LCA) guidelines, biofuels that have been certified by international certification scheme 0F 1 may be allowed a lesser emission rating under Regulations 26, 27, and 28 of MARPOL Annex VI. 

On other matters, amendments to the 2021 Guidelines for Exhaust Gas Cleaning Systems 2021 Guidelines for Exhaust Gas Cleaning Systems, MEPC.340(77) were amended to include also a footnote referring to Guidelines for the use of electronic record books. There were changes to the EEDI relating to tank loadings for LNG as a fuel and cargo and changes to the EEXI requirements in relation to shaft power limitation concepts. 

There was a discussion on the risks of EGCS Discharge Water. In particular recent developments from the PPR 10 sub-committee meeting (April 2023) regarding potential environmental risks associated with discharges from exhaust gas cleaning systems and several submissions were received proposing regulatory measures to limit such discharges. In discussion, some member States expressed views for limiting such discharges by means of amendments to MARPOL Annex VI, while others suggested that MARPOL Annex VI amendments would be premature at this stage and providing guidance on controls for these discharges would be sufficient. Related submissions to MEPC 80 will be sent to the PPR 11 sub-committee meeting (Feb. 2024) for further assessment and advice. 

Another matter from PPR 10 involved black carbon control measures in Arctic regions with some wanting the definition of the Arctic to be expanded. Interested parties were urged to submit concrete proposals to PPR 11 (Feb. 2024) for mandating reductions in Black Carbon emissions from international shipping. 

Ballast and biofouling  

Ballast water matters were also on the agenda with several matters discussed. MEPC 80 approved circular BWM.2/Circ.79 containing the Convention Review Plan under the experience building phase which will guide member States and others on the holistic review of the BWM Convention as part of the Experience Building Phase. In addition, the Committee decided to re-establish the Correspondence Group on Review of the BWM Convention which is instructed to define objectives for changes to specific Convention provisions and/or instruments, to address the issues in the annex of the Convention Review Plan and to submit a report to MEPC 81 

The meeting continued the development of the Guidance on the temporary storage of treated sewage and grey water in ballast tanks but due to the complexities of the discussion and the time constraints, the Committee agreed that further intersessional work would be needed and proposal should be submitted to MEPC81. Also held over to the next meeting was the question of guidance around challenging water quality. The delegations expressed their consent to work further with a view to finalizing the Guidance at MEPC 81, stating that any further delay might force them to take relevant action at the national level.    

BWM.2/Circ.80 containing the Guidance On Matters Relating to Ballast Water Record-Keeping and Reporting was approved by the meeting. It offers clarity and guidance around record keeping and reporting progress under the BWM Convention and includes an updated example ballast water reporting form and an example form for voluntary tank-by-tank logging of ballast water operations. Resolution MEPC.372(80) containing the Guidance for the use of electronic record books under the BWM Convention was also adopted and the Committee finalised the necessary amendments to Regulations A-1 and B-2 of the BWM Convention concerning the use of electronic record books under the Convention, with a view to adoption by MEPC 81.  There was also discussion around type approval of modified ballast water treatment systems. 

Three ballast treatment systems received IMO final approval – ERMA FIRST BWTS model FIT 75-3000 (electrolysis), BalClor Smart BWMS and EcoGuardian NFT (electrochlorination) and one HiBallast 2.0 (Active substance – sodium hypochlorite) was granted Basic Approval.  

Updated guidance on biofouling is to be circulated following adoption of Resolution MEPC.378(80).  The 2023 Guidelines for the Control and Management of Ships’ Biofouling to Minimize the Transfer of Invasive Aquatic Species.  

This replaces the former 2011 Biofouling Guidelines in Resolution MEPC.207(62). The updated guidelines provide revisions to the 2011 edition, removing Chapter 7 (Biofouling Risk Profile and Monitoring of Risk Parameters) and including a new chapter of Contingency-Action Plans (Chapter 7) that will be followed if the monitoring of biofouling risk parameters during ship operation identify an increased risk of biofouling accumulation. Example forms for the Biofouling Management plan and Record Book are also included. For Chapter 9 (Cleaning and Maintenance), guidance on in-water cleaning is to be addressed separately at a future session, with a target year of completion in 2025. 

Noise control 

Noise from ships has been criticised as causing problems for several marine species. MEPC 80 approved circular MEPC.1/Circ.906 and its Revised Guidelines for the Reduction of Underwater Radiated Noise from Shipping to Address Adverse Impacts on Marine Life. The guidelines come into effect on 1 August 2023, revoking the previous circular MEPC.1/Circ.833.   

Special Areas and ECAs 

Developments for regional measures adopted at the meeting include designating the North west Mediterranean as a Particularly Sensitive Sea Area for the protection of marine mammals. The area is approximately bounded by a line from the Spanish coast North of the Balearics and encompassing the Northern coast of Sardinia then to Italy. 

There were also proposals for a Canadian Arctic ECA covering NOx, SOx and OM and for a North Eastern Atlantic Ocean ECA which would effectively link the Baltic, North Sea and English Channel zones with the recently adopted Mediterranean SECA.