MEPC 82/6/42: Comments on document MEPC 82/6/1 – Energy Efficiency of Ships
This document provides comments on document MEPC 82/6/1 (Austria et al.) concerning GHG emissions data quality and integrity as a basis for current and future IMO GHG regulatory measures, as well as document MEPC 82/6/17 (Austria et al.) on the possible two-step approach for the review and revision of the short-term measures. CSC strongly supports the ambition to improve data quality, transparency and accessibility of the IMO Data Collection System (DCS). While cognisant of the need for further data collection and assessment of some aspects of the carbon intensity indicator (CII) calculation, CSC argues that existing IMO DCS data is sufficient to already transform the CII from a carbon intensity metric to a truly energy efficiency metric, as well as increase the required reduction factors for the post-2026 period already in the first step of the two-step approach.
