A mandatory global system for monitoring, reporting and verification of carbon dioxide emissions from the EU and IMO

摘要

As a contribution towards finding an appropriate global solution for C0_2 monitoring from international shipping European shipowners welcome the Commission's proposal for a Monitoring, Reporting and Verification (MRV) system of C0_2 emissions from maritime transport. ECSA however believes that any mandatory requirements on MRV for the international shipping sector must be agreed upon at IMO level, as this is the only way of securing a globally harmonised system.ECSA considers that reporting of commercially sensitive cargo information per-ship is premature. Publication of such data would in any case be unwarranted. As a potential way ahead, ECSA recommends an MRV system that solely includes the aggregated data from ships' fuel consumption in combination with distance sailed. This combination will substantiate shipping's advantages as the most energy efficient and environmentally friendly mode of transport and allows correlating the trends of C02 emissions with already available data on world trade.0verall, ECSA believes that the proposed MRV system should ensure that the realities and practicalities of the shipping industry enables a C0_2 monitoring system that is workable both for the industry and for the authorities.The support in principle for an MRV system does not imply that ECSA would accept that MRV were to be used to establish regional Market Based Measures, mandatory application of energy efficiency improvement measures or indexing for existing ships. Whilst acknowledging the expressed long term intention of further improving the environmental performance of theexisting fleet, ECSA considers it premature for the European Union to go along this path. Detailed input values for operational efficiency vary to a degree where any averaging and aggregation would make the result useless. Calculating such gross average indices for operational efficiency would expose the commercial viability of ships in a manner that is unjust and misleading.A transport work value, expressed in CO2 emissions per distance travelled per amount of cargo carried, suggests comparability over a large range of ship types and transport routes. ECSA doubts the validity and feasibility of such a system. Ships operate in an environment which produces many variables that can be under the control of different parties (whether the owner, the technical operator, the commercial operator or the charterer) and which influence its performance. Each individual ship achieves its service and transport performance within an individual transport environment subject to constant variation of economical aspects (fuel price, freight rates), operational aspects (amount of cargo carried, speed, routeing, ballast legs) and environmental aspects (current, weather and sea conditions, winter and ice navigation). These factors would even make it difficult to compare sister ships in the same trades, or seemingly identical voyages of the same ship during different seasons. Any attempt to formulate emissions regulations that ignore the abovementioned facts is therefore bound to be ineffective.ECSA is furthermore concerned about the negative impact the publication of commercially sensitive data would have on shipping companies. Rating of performance of existing ships using variable factors, will lead to unfair comparison of ship operators creating market distortions, as it happens today with the use of certain non-authorised industry ship rating systems. ECSA therefore believes that publication of individual ship's commercial sensitive data is unwarranted.ECSA is also concerned that, even if the vessel operator possesses the operational data that might be required to be recorded or reported under the current version of the Commission's legislative proposal, there are significant complexities and costs that would arise from a mandatory third-party verification of such huge amount of data.Furthermore, ECSA believes that an MRV regulation should apply to ships above a Gross Tonnage (GT) limit set at a level that excludes small emitters and consequently avoids an unacceptable burden on small ships - which proportionally represents a very limited fraction of the total CO_2 emissions. Hence, ECSA believes that ships above the 5000GT threshold -whilst covering 90% of the CO_2 emissions and accounting for around 55% of the number of ships calling at EU ports - will determine an acceptable 'administrative burden'-'environmental effectiveness' ratio. ECSA does support the monitoring and reporting of data from fuel consumption for the limited purpose of establishing the CO_2 emissions from maritime transport. CO_2 is by far the most important GHG emitted by ships - both in terms of quantity and of global warming potential (GWP), and the potential benefits from reducing emissions of other greenhouse gases are small in comparison. Obviously, emissions of other relevant substances as exhaust gas GWP or pollutants will be reducing as the energy efficiency of individual ships improves. This is linked to the reductions in emissions that are mandated from the implementation of the revised MARPOL Annex VI.The EU initiative should primarily encourage ways and means of collecting data on CO_2 emissions through the IMO. ECSA therefore believes that a stepwise approach needs to be taken, which first focuses on data collection and data collection only. In a second phase, the IMO can address to what extent the existing global fleet can reduce its CO_2 emissions and consider whether a compulsory instrument for the existing fleet is the appropriate tool.In sum, ECSA believes that the EU Regulation proposal has the potential to contribute to the development of a globally harmonised MRV system when taking into account the specificities of the shipping sector.The Commission's proposal should therefore be simplified and focussed in order to achieve the overall goal to collect useful data in an efficient and flexible way. Furthermore, the inclusion of parameters going at this stage beyond the current and expected discussions in IMO will be detrimental to a swift international solution in the IMO. Consistency with IMO efforts addressing CO_2 monitoring and shipping energy efficiency must be ensured.