Who should be responsible for the worsening of CII rate during high Anchorage and port times not caused by Shipowners?

After the IMO MEPC 80 meeting,it is understood that the ship types that will be most affected by this strategy will be the Bulk Carrier type ships.

The 80th session of the IMO’s Marine Environment Protection Committee (MEPC 80) adopted a revised GHG Strategy. The revised strategy targets to significantly decrease GHG emissions from international shipping. The new targets include a 20% reduction in emissions by 2030, a 70% reduction by 2040 (compared to 2008 levels), and the ultimate goal of achieving net-zero emissions by 2050. New regulations are expected to enter into force around mid-2027.

After the IMO MEPC 80 meeting,it is understood that the ship types that will be most affected by this strategy will be the Bulk Carrier type ships.

The main reason for the low CII rate of Bulk Carrier type ships is the long port and anchoring times. This problem is due to the fact that the loading and unloading times of the ships are very long due to the inadequacy of the port infrastructure and the cargo handling times, rather than the direct misoperation of the ships.

For this reason, IMO should determine reasonable times for the waiting times at the port and anchorage for the ships, the extra delays caused by the port should be deducted from the CO2 consumption of the ships and the extra time, should be charged to the relevant port authority.

Shipowner's Chartering departments should strive for more convenient cargo connection, but they do not have to bear the bill of infrastructure and lack of organization in which they are not directly involved.

In my opinion, the shipowner or the charterer should not be billed for the high CO2 emissions caused by the poor port infrastructure and inefficient cargo handling operations that are not caused by the ship operator and the ship owner.

On the one hand, when we make Life Cycle Assesment Analysis and root cause analysis, the invoice for the increase of CO2 emissions that do not originate from the companies operating the ships, it does not seem fair to me that the shipowners are charged for the excessive CO2 emission caused by the ship's high fuel consumption due to the delays I mentioned above.

When we focus on the the CII Leg Summary of a real ship below, it appears that ships are not responsible for a significant portion of carbon emissions. The "Ship CII Leg Summary" in Figure 1 clearly shows what I mean.

Figure 1. CII Leg Summary of a Bulk Carrier Type Ship

In the figure, BOSP-EOSP states duration Beginning of Sea Passage to End of Sea Passage, Dep.-Arr. states the duration Depature from Port to Arrival to Port and Dep.-Dep. states Departure from port to Departure from Port.

When we look CII rates average in selected period, Ship CII rate at the BOSP-EOSP" segment is "C", in Dep.-Arr. segment is "D" and Dept.-Dept segment is "E".

When we examine the these segments carefully, while the CII rate of ship was in the "C" efficiency rate in the course of the ship at the BOSP-EOSP segment, it consumed extra fuel due to anchoring and maneuvering time in the Dep.-Arr. segment. Due to the long stay of the ship in the port, this time the "D" efficiency rating has fallen to the "E" efficiency rating in the Dep.-Dept segment.

From this, we understand that although the ship is not responsible for the port and anchoring times that are longer than normal, the lack of infrastructure and inadequacy of port cargo handling operations are intended to be billed to the shipowners.

To summarize:

• IMO should be exempted from the CO2 emissions they consume for additional periods when they exceed the acceptable anchorage and stay in port for each port for reasons not caused by them.
• Each port should be equipped with a port electricity infrastructure powered by renewable energy sources and flag states should be held responsible for this infrastructure.
• Although the above example is specified for Bulk Carrier type ships, all ship types that are in case of exceeding the reasonable waiting period should be considered within this scope.
• If we are talking about LCA, the main responsible persons in the segments that negatively affect the CII rate value should be determined correctly and the invoice should be recourse to the main responsible parties.