E

MARINE ENVIRONMENT PROTECTION MEPC 75/3/3

COMMITTEE 24 January 2020
75th session Original: ENGLISH
Agenda item 3 Pre-session public release: ☒

CONSIDERATION AND ADOPTION OF AMENDMENTS TO

MANDATORY INSTRUMENTS

Comments on the draft amendments to the MARPOL Annex VI

Submitted by the Republic of Korea

SUMMARY

Executive summary: This document comments on the draft revised regulation 21 of

MARPOL Annex VI regarding the change of the EEDI Reference
Line of Bulk Carriers

Strategic direction, 3
if applicable:

Output: 3.6

Action to be taken: Paragraph 9

Related documents: MEPC 73/19; MEPC 74/5/22, MEPC 74/18, MEPC 74/WP.8 and
MEPC 75/3

Introduction

1 At MEPC 73, the Committee considered EEDI Phase 3 requirements for bulk carriers
and tankers and agreed to retain the starting year for EEDI Phase 3, including the required
reduction rate of 30% and the parameters for determination of reference values. Based on that
agreement, some observers and delegations raised concerns and suggested that further
consideration was needed at MEPC 74.

2 At MEPC 74, document MEPC 74/5/22 (Brazil et al.) proposing amendments to

regulation 21.3 of MARPOL Annex VI with regard to the EEDI reference line parameters for
very large bulk carrier ship types was considered, and the Committee instructed the Working
Group on Air Pollution and Energy Efficiency to review this document. At that time, due to the
urgency of the agenda item regarding the implementation of the sulphur cap, the Working
Group did not have sufficient time to discuss EEDI issues. Considering this, the Chair of the
Working Group noted that interested delegations could submit a document on the draft
amendment to MEPC 75, as referred to in paragraph 40 of MEPC 74/WP.8.

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Discussion

Development and reviews of EEDI Reference Line for Bulk Carriers

3 As mentioned in document MEPC 74/5/22 (Brazil et al.), the database used for
developing the reference line of bulk carriers was imbalanced, with limited data for large bulk
carriers. However, the amendment, which proposes the constant required EEDI value for bulk
carriers of more than 279,000 deadweight tonnage (DWT), did not settle the matter of the data
imbalance.

4 Also, taking account of the aforementioned issues, the Committee decided to go

through the review process based on the accumulated data following the entry into force of the
EEDI regulation. As a result of the discussion, the Committee agreed to retain the regulation
on bulk carriers, including the parameters for determination of reference values agreed at
MEPC 73.

EEDI as a technical approach to reduce GHG emissions

5 The EEDI regulation, as a technical approach to reduce GHG emissions, was

introduced to stimulate continuous innovation and the technical development of all the
components influencing the fuel efficiency of a ship from its design phase. Following
implementation of the regulation, relevant industries developed a number of technologies to
improve energy efficiency of ships, such as dual fuel systems, air lubrication systems and shaft
generators. The Republic of Korea is of a view that with these advanced technologies, large
bulk carriers can achieve current EEDI Phase 3 requirements, as shown in the case study
included in the annex.

6 In addition, the rates of EEDI improvement by technologies are similar, regardless of

the size of ship, as shown in the graph below. Taking this into account, the current EEDI
reference line, which was interpolated by the data for 180,000 DWT and 210,000 DWT bulk
carriers, are considered reasonable.

Table 1– Graphical representation for very large ships with additional ship data

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7 Additionally, the Republic of Korea would like to highlight that one of the levels of
ambition in the Initial IMO Strategy on reduction of GHG emissions from ships is to reduce the
carbon intensity of ships through the implementation of further phases of the energy efficiency
design index (EEDI) for new ships. The aim is to strengthen the energy efficiency design
requirements for ships, with the percentage improvement for each phase to be determined for
each ship type, as appropriate.

Proposal

8 It is proposed to retain the values for bulk carriers in row 2.25 of table 2 (Parameters
for determination of reference values for the different ship types), as set out in the current
MARPOL Annex VI.

Action requested of the Committee

9 The Committee is invited to consider the proposal set out in paragraph 8 related to
the proposed amendments to regulation 21.3 of MARPOL Annex VI (Required EEDI for Bulk
Carriers), with regard to the EEDI reference line parameters for bulk carriers, and to take action
as appropriate.

***

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Annex, page 1

ANNEX

CASE STUDY OFTHE EEDI CALCULATION OF 325,000 DWT BULK CARRIERS

COMPATIBLE WITH EEDI PHASE 3

1 Case 1: Delivered bulk carrier, one main engine (MDO), standard auxiliary engines
(MDO), no shaft generator
S/N Parameter Formula or Source Unit Value
1 MCRME MCR rating of main engine kW 21,000

2 Capacity Deadweight of the ship at summer load draft DWT 324,690

3 Vref Ships speed as defined in EEDI regulation kn 15.05

4 PME 0.75 x MCRME kW 15,750

5 PAE 0.025 x MCRME + 250 kW 775

6 CF ME CF factor of Main engine using MDO - 3.206

7 CF AE CF factor of Auxiliary engine using MDO - 3.206

8 SFCME Specific fuel consumption of at PME g/kWh 163.2

9 SFCAE Specific fuel consumption of at PAE g/kWh 195.17

((PMEx CF MEx SFCME)+(PAEx CF AEx SFCAE)) /
10 EEDIAtt. gCO2/tnm 1.785
(Vrefx Capacity)
11 EEDIReq. Phase 2 gCO2/tnm 1.808

2 Case 2: Bulk carrier with slow steaming (optimized speed by model test analysis),
one main engine (MDO), standard auxiliary engines (MDO), no shaft generator

S/N Parameter Formula or Source Unit Value

1 MCRME MCR rating of main engine kW 17,500

2 Capacity Deadweight of the ship at summer load draft DWT 324,690

3 Vref Ships speed as defined in EEDI regulation kn 14.11

4 PME 0.75 x MCRME kW 12,975

5 PAE 0.025 x MCRME + 250 kW 682.5

6 CF ME CF factor of Main engine using MDO - 3.206

7 CF AE CF factor of Auxiliary engine using MDO - 3.206

8 SFCME Specific fuel consumption of at PME g/kWh 161.2

9 SFCAE Specific fuel consumption of at PAE g/kWh 210

((PMEx CF MEx SFCME)+(PAEx CF AEx SFCAE)) /
10 EEDIAtt. gCO2/tnm 1.580
(Vrefx Capacity)
11 EEDIReq. Phase 3 gCO2/tnm 1.582

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3 Case 3. Bulk carrier, Dual-fuel main engines (LNG, pilot fuel MDO) and standard
auxiliary engines which LNG could be regarded as "primary fuel" only for the dual-fuel main
engine
S/N Parameter Formula or Source Unit Value
1 MCRME LNG MCR rating of main engine using LNG kW 21,500
2 Capacity Deadweight of the ship at summer load draft DWT 325,000
3 Vref Ships speed kn 14.67

4 PME LNG 0.75 x MCRME LNG kW 16,125

5 PAE 0.05 x (MCRME MDO + MCRME LNG) kW 787.5

6 CF Pilot fuel CF factor of pilot fuel for dual fuel ME using - 3.206
MDO
7 CF AE CF factor of pilot fuel for Auxiliary engine using - 3.206
MDO
8 CF LNG CF factor of dual fuel engine using LNG - 2.75

9 CF MDO CF factor of dual fuel AE engine using MDO - 3.206

10 SFCME Pilot fuel Specific fuel consumption of pilot fuel for dual g/kWh 0.8
fuel ME at PME
11 SFCDF LNG Specific fuel consumption of dual fuel ME using g/kWh 147.6
LNG at PME
12 SFCAE Specific fuel consumption of at PAE g/kWh 210
13 EEDIAtt. (PMEx (CF Pilot fuelx SFCME Pilot fuel + CF LNGx SFCME gCO2/tnm 1.493
LNG) + (PAEx CFAEx SFCAE)) / (Vrefx Capacity)

14 EEDIReq. Phase 3 gCO2/tnm 1.582

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