Page 45 - ΝΑΥΤΙΚΑ ΧΡΟΝΙΚΑ - MARTIOS 2023

CII: AN OPEN DISCUSSION

WE NEED REGULATIONS

TO BE CLEAR AND SIMPLE

FOR EVERYONE

We welcome the healthy debate regard- It’s too early to tell, but so far, regulation
ing clauses to help the shipping industry has not created multiple tiers in the spot
decarbonise. As an owner and charterer, market, only in the time charter market
we have an interest in helping set the most where charterers will happily pay more
balanced clauses possible in any new reg- for a competitive advantage such as an
ulation. Owning vessels is becoming an eco-vessel or a ship fitted with a scrubber.
increasingly complicated business, and Under the current format, we do not think
we want to support ship owners as much charterers will penalise vessels with lower
as possible through the energy transition. scores (D or E, for example) as most of
A fair and efficient market requires negoti- them recognise that as long as CII uses
ation periods to test clauses. Having com- AER, it will be a metric that is not fit for
pleted an average of over 4,500 shipping purpose.
fixtures per year over the past two years, We believe the metric should be changed
we believe we have established a fair and to differentiate between laden and ballast
balanced set of terms with most of our legs instead of total steaming. At the same
counterparties by now. time, we suggest adding a provision to
The BIMCO clause is a good attempt at ensure that vessels waiting for discharge
sharing the burden of upcoming carbon because of payment delays from suppli-
intensity or CII regulations. Conceptually ers, for example, are not overly penalised.
it makes sense for charterers to have some We also need to reward market players
minimum redelivery requirement regarding that run vessels efficiently by minimis-
carbon intensity as they have commercial ing ballasts and increasing laden ratios.
management of the vessel. But, due to the This is the only solution to transform CII
metric chosen by the International Mari- into a metric that can really promote and
time Organisation for its carbon intensity drive good behaviour and help compa-
assessment, charterers with high utili- nies reduce their carbon footprint. By
sation rates will be penalised under the tweaking CII -- so that it focuses on EEOI
regulation. This metric is problematic as rather than AER -- we can easily achieve a
it prevents charterers from taking on the better result. In addition, we recommend
burden of high CII scores upon redelivery. the introduction of a clearly defined pen- Heading towards new business frontiers and innovations while staying true to
We are big supporters of the Energy Effi- alty mechanism to reward vessels that
ciency Operational Indicator (EEOI) as have achieved higher scores and penalise our family tradition for excellence, continuous improvement and dedication
a metric for CII calculations, as it takes low scores. This is needed to ensure we to environmental sustainability and respect for our people
into account laden and ballast states of maintain a level playing field across the
operation, and we disagree with critics industry.
who claim it is excessively volatile as a We also realise that we need regulations
benchmark. There is a clear logic behind to be clear and simple for everyone; it is
this metric. It promotes ‘good behaviour’ vital that we create an industry where it
and avoids vessels having to take long is not too complicated, cumbersome, and
ballast legs to reduce their score, which administratively burdensome for ship-
is the big issue with using the Annual Effi- owners to invest and operate vessels. The
ciency Ratio (AER) as a metric. We have most dangerous thing we can do is intro-
been focusing on EEOI for a number of duce more and more complex regulations,
years now through our work with the Sea as this will drive small and medium-sized
Cargo Charter. And together with peers owners away from shipping at a time when
including Cargill, Equinor, Shell, and we need to attract more investment, given
by Andrea Olivi, TOTAL, we have been focusing on EEOI that an increasing number of vessels are 9, Fragoklissias str, 151 25 Maroussi, Greece
Global Head of Wet Freight, to reduce the carbon footprint of our char- moving into the so-called shadow fleet
Trafigura Tel: 2106152300
tering operations. and leaving the international market.
www.andriaki.gr
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