Page 43 - ΝΑΥΤΙΚΑ ΧΡΟΝΙΚΑ - MARTIOS 2023
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CII: AN OPEN DISCUSSION
CHARTERERS SHOULD
ASSUME THEIR
RESPONSIBILITIES
I would like to begin by referring to As for now, does a good CII score neces-
the debate about the EEOI and AER. sarily mean an efficient ship? As a matter
In my eyes, EEOI is nothing more than of fact, it does not; it just shows if the
a random number generator. The stud- way the ship was operated during a spe-
ies submitted to the IMO show that it cific period was compliant with what is
is three times as random as AER, which currently being asked by the chosen CII
means if you are working with AER, you indicator. CII leads to slower speeds,
have a good chance to achieve the rating and slower speeds mean lower emis-
you want using your own actions, such sions. Speed reduction is the main tool
as reducing the speed of the ship. But an operator has in order to achieve the
EEOI is so random that you cannot reach desirable CII rating. But if it were up to
a rating based on your actions. So, I do me to improve the CII, I would take the
not agree with the calls to apply EEOI to unfairness out of the regulation instead
CII and think that if that happens, we will of changing the metric from AER to
regret it in the future. EEOI. For example, the CII is unfair to
As far as charterers are concerned, they bulk carriers. Bulk carriers have already
need to assume their responsibilities. If achieved a 40% reduction in their emis-
that were to happen, then it would be sions since 2019 compared to 2008
fair of them to demand better-rated levels, which means that they reached
ships. I was part of the BIMCO Carbon the 2030 CII target a decade earlier.
Clauses Drafting Subcommittee, which Therefore, the yearly CII reduction rates for
had been working on the CII clause bulk carriers should be amended to per-
for eight months, and we left no stone haps 0.5% per year instead of 2% per year.
unturned. The clause is very fair, and the On the other hand, containerships have
fact that several charterers do not like it achieved a relatively slight reduction in
tells me that perhaps their money is not emissions compared to 2008. For these
where their mouth is. We just followed ships, a higher than 2% annual reduction
decades of established time-charter- should be set, perhaps 4%, something
party practice, in line with the most used which for these high-speed ships is easily
pro-forma time charters that recognize doable since it may represent only a 1
that the party giving the orders has a -2 knot reduction in speed. Such speed
higher responsibility than the party reductions are unattainable, however, for
that must follow them. The IMO itself bulk carriers. That way, the overall annual
has indicated to whom the regulation CII reduction of shipping will remain at
applies. It says it is an operational mea- 2% but will be distributed based on
sure. Therefore, the CII is a regulation each sector’s capabilities and its already
Mr Panos Zachariadis’ views on the that is primarily addressed to whoever achieved performance toward the 40%
CII, as expressed in is the ship’s operator, who, in the case of reduction target. These kinds of ineffi-
13th Annual Capital Link Greek
Shipping Forum. a time charter, is the charterer. ciencies in the CII should be moderated.
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