Fuel Consumption: IMCA and its Members to play key role

Published on 30 July 2021

As a result of a submission by the International Marine Contractors Association (IMCA) to the International Maritime Organization’s (IMO) Marine Environment Protection Committee (MEPC 76/5/3) in June 2021, the MEPC has granted IMCA authority to:

1 Collect fuel consumption data from IMCA members’ offshore vessels which fall within the scope of the mandatory requirement under Regulation 22A of MARPOL*, Annex VI and applies to all vessels of 5,000 gross tonnage and above.  

2 Use this data to calculate the two proxies IMCA proposed in its submission to MEPC 74 (MEPC 74/6), and

3 Submit the calculations to IMO on behalf of its members.

IMCA Contact

Margaret Fitzgerald
Head of Legal & Regulatory Affairs
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IMO’s review of the result will determine which, if either, of the two proxies IMCA proposed to them, will be used to assess the carbon intensity of the offshore and marine contracting sector. IMCA is immediately contacting all members impacted by this mandatory requirement in order to collect fuel consumption data for the 2019 and 2020 reporting periods, via an updated spreadsheet, to enable Proxies A and B to be calculated and the result then submitted to the IMO. Separate spreadsheets need to be completed for each vessel.

Margaret Fitzgerald, IMCA’s Head of Marine Policy & Regulatory Affairs explained:

“It is imperative that members engage with this process as soon as possible and have full oversight of what decision is taken.

“The IMO is pressing ahead with the development of mandatory short-term measures to reduce CO₂ emissions from international shipping as part of its greenhouse gases (GHG) strategy and commitment to the targets set by the Paris Agreement. Included in this process is the development of suitable Carbon Intensity Indicators (CII).

“Our members are well aware that IMCA successfully argued at the IMO that the ‘transport work proxy’, which has been developed as a CI Indicator for cargo ships, is not a suitable metric for assessing carbon intensity of the offshore and marine contracting sector since the measurement of fuel consumed/distance travelled does not reflect how the offshore sector operates. If you take DP vessels, much of the time their fuel consumption is expended on staying still in the interests of safety, during tasks (such as saturation diving) being undertaken on the seabed.

“In its’ paper MEPC 76/5/3, IMCA expressed concern to IMO Member States about the voluntary nature of submission of data for offshore and marine contracting vessels and cautioned that care is needed to ensure that the process is carefully managed to minimise the possibility of selection bias and inadequate quality control leading to a distorted impression when analysing the different proxies.

“Naturally, we are delighted that our submission to MEPC 76 last month was accepted.  In a supplementary paper (MEPC 74/INF.35) to its’ proxy paper, IMCA highlighted the fact that there are more than 20 different vessel types operating in the offshore and marine contracting sector and it is going to be a challenge to identify a single proxy which will be appropriate to suit all those vessels. It is imperative that sufficient data is collected for each of these vessel types and so it is a great outcome for IMCA members that IMCA has been authorised to oversee the process”.

She added:

“Because IMCA will be reporting to IMO, we need to be completely transparent with regard to the data collected in respect of the data elements for each of the two proxies as well as the final calculated Proxy A and Proxy B. For this reason, IMCA has amended the fuel consumption spreadsheet, which was circulated to members last year, with one version for 2019 data and one for 2020. Both can be accessed on the Marine Policy & Regulatory Affairs Committee page on our website – see links below

IMCA has held non-governmental observer status at the IMO since 1999. The association frequently attends IMO meetings to keep abreast of the latest developments and provide input based on members’ combined experience and expertise. IMCA’s Marine Policy & Regulatory Affairs Committee is actively involved in representing IMCA Members at the IMO.

Notes to Editors

Carbon intensity indictors and IMCA: The background

In 2019, IMCA’s Marine Policy & Regulatory Affairs (MPRA) Committee developed two potential proxies which could be used instead of ‘transport work’ to assess the carbon intensity of the marine and offshore contracting industry.

These proxies were submitted to IMO’s Marine Environment Protection Committee (MEPC) but due to the sheer volume of proposals on the agenda for that session, IMCA’s proposal was deferred for consideration in 2020 by IMO’s Intersessional Working Group on Green House Gases which called upon the offshore and marine contracting sector to submit data to IMO on a voluntary basis to enable a decision to be taken on which of the two proxies, if any, should be selected for incorporation into future carbon intensity reduction measures.

MARPOL

*The requirement for collection and reporting of fuel consumption data is mandatory under Regulation 22A of MARPOL, Annex VI and applies to all vessels of 5,000 gross tonnage and above.  

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