The critical need for an adverse weather voyage adjustment to the CII mechanism (ISWG-GHG 12-2-4)

Submitted by Malaysia, Panama, United Arab Emirates, ICS, INTERTANKO, INTERCARGO and WSC.

This document comments on the work and final report of the Correspondence Group on Carbon Intensity Reduction as set out in document MEPC 78/7/11 (China et al.), highlighting and restating the specific need for the previously proposed adverse weather voyage adjustment for use in the CII calculation mechanism. This adjustment is considered critical to minimise negative impacts on Member States. Without adoption of the currently rejected adverse weather voyage adjustment, the CII rating mechanism will not be fit for purpose, which would unjustly and unreasonably impact the ratings of efficient and well operated ships because of a fundamental flaw in the mechanism. Ships operating predominantly throughout the year in a harsh ocean region, cannot, and should not be graded on the same basis as those operating in a benign ocean region, without an appropriate weather adjustment being applied. The cosponsors fully support the development and implementation of the CII system without delay, however, the CII rating mechanism must be fit for purpose and it would be an error to go forward with an incomplete system that unfairly penalizes well designed and efficiently operated ships. Such an outcome would provide perverse incentives and be inconsistent with the objective of decarbonization.

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