Compliance Deficit: Tier 1 and Tier 2 Under the Draft IMO NZF
The compliance deficit in draft MARPOL Annex VI regulation 36.4: how Tier 1 and Tier 2 deficits are calculated against the two GFI targets and balanced.
A compliance deficit is defined in draft regulation 2.3.3 of MARPOL Annex VI Chapter 5 (MEPC/ES.2/2) as the amount of under-compliance by a ship with the target annual GFI, determined under regulation 36. Regulation 36.4 splits it into a Tier 1 deficit, for the band between the direct compliance target and the base target annual GFI , and a Tier 2 deficit, for any excess above the base target.
A Tier 1 deficit is balanced only with Tier 1 remedial units (regulation 36.5); a Tier 2 deficit with surplus units or Tier 2 remedial units (regulation 36.6). The full article will cover the arithmetic, the boundary cases and the relation to the GFI compliance balance . The draft has not been adopted.