Reduction of Emissions of Greenhouse Gas (GHG) from Ships - Prevention of Pollution of the Marine Environment from Vessels - page 108

account guidelines developed by the IMO. The IMO has developed three guidelines
in this regard. 32
The EEDI is applicable only to ships of 400 gross tonnage and above. Moreover,
these ships have a leeway period. Regulation 19 allows the Administration to waive
compliance with the EEDI requirements until 4 years after the entry into force date
of the regulations. 33
The IMO is expecting significant emission reductions and cost savings for the
shipping industry by implementing these regulations. As observed in a document
published by the organization:

By 2020, between 100 and 200 million tonnes of annual CO 2 reductions are estimated from
the introduction of the EEDI for new ships and the SEEMP for all ships in operation, a
figure that, by 2030, will increase to between 230 and 420 million tonnes of CO 2 annually.
In other words, the reductions will in 2020 be approximately between 10 and 17 % and by
2030 between 19 and 26 % below business as usual. The reduction measures will also result
in a significant saving in fuel costs to the shipping industry, although these savings require
deeper investments in more efficient ships and more sophisticated technologies than the
business as usual scenario. The annual fuel cost saving estimate gives an average figure of
US $ 50 billion by 2020 and of US $ 200 billion by 2030. 34

However, the implementation of these regulations may involve some legal and
practical challenges, as unlike many other IMO environmental legal instruments,
these regulations have not been adopted unanimously. These regulations create
some serious challenges for developing countries, particularly those that voted
against them. Usually, an international legal instrument creates implementation
challenges for parties. The following section discusses how these regulations may
even create challenges for non-parties.

6.3 Legal and Implementation Challenges for Developing
Countries

IMO Member States have very divergent interests in respect of energy efficiency
measures including Annex-I countries, non-Annex-I countries, developing coun-
tries, least developed countries (LDCs), flag States, ship building nations, States

32

Guidelines for Calculation of Reference Lines for Use with the Energy Efficiency Design Index
(EEDI) , Res MEPC.215(63), Annex 11, IMO Doc MEPC 63/23/Add.1 (2 March 2012); Guide-
lines on the Method of Calculation of the Attained Energy Efficiency Design Index (EEDI) for New
Ships , Res MEPC.212(63), Annex 8, IMO Doc MEPC 63/23 (2 March 2012); 2012 Guidelines on
Survey and Certification of the Energy Efficiency Design Index (EEDI) , Res MEPC.214(63),
Annex 19, IMO Doc MEPC 62/24/Add.1 (2 March 2012).
33 MARPOL 73/78, Annex VI.
34 IMO, Main events in IMO

s work on limitation and reduction of greenhouse gas emissions from
international shipping, http://www.imo.org/MediaCentre/resources/Documents/Main%20events
%20IMO%20GHG%20work%20-%20October%202011%20final_1.pdf ,

'

last accessed on

6 September 2013.