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 Gr