MRV system should include specificities of the shipping sector, says ECSA
European shipowners welcome the Commission’sproposal for a Monitoring, Reporting and Verification (MRV) system of CO2 emissionsfrom maritime transport as a contribution towards finding an appropriate global solution for CO2 monitoringfrom international shipping. Any mandatory requirements onMRV for the international shipping sector however, must be agreed upon at IMO level, as this isthe only way of securing a globally harmonised system, according to an ECSA position paper.
ECSA considers that reporting of commercially sensitive cargo information per-shipis premature. Publication of such data would in any case be unwarranted. As apotential way ahead, the European Shipowners recommend an MRV system that solely includes theaggregated data from ships’ fuel consumption in combination with distance sailed.This combination will substantiate shipping’s advantages as the most energy efficientand environmentally friendly mode of transport and allows correlating the trends ofCO2 emissions with already available data on world trade.
Overall, ECSA believes that the proposed MRV system should ensure that the realitiesand practicalities of the shipping industry enables a CO2 monitoring system that isworkable both for the industry and for the authorities.
ECSA notes that its support in principle for an MRV system does not imply that ECSA would accept thatMRV were to be used to establish regional Market Based Measures, mandatory applicationof energy efficiency improvement measures or indexing for existing ships.
Whilstacknowledging the expressed long term intention of further improving the environmentalperformance of the existing fleet, ECSA considers it premature for the European Union to goalong this path. Detailed input values for operational efficiency vary to a degree where anyaveraging and aggregation would make the result useless. Calculating such gross averageindices for operational efficiency would expose the commercial viability of ships in a mannerthat is unjust and misleading.
ECSA says in the position paper: “A transport work value, expressed in CO2 emissions per distance travelled per amount ofcargo 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 environmentwhich produces many variables that can be under the control of different parties (whetherthe owner, the technical operator, the commercial operator or the charterer) and whichinfluence its performance.
ECSA adds “Each individual ship achieves its service and transportperformance within an individual transport environment subject to constant variation ofeconomical aspects (fuel price, freight rates), operational aspects (amount of cargo carried,speed, routeing, ballast legs) and environmental aspects (current, weather and seaconditions, winter and ice navigation). These factors would even make it difficult to comparesister ships in the same trades, or seemingly identical voyages of the same ship duringdifferent seasons. Any attempt to formulate emissions regulations that ignore theabovementioned facts is therefore bound to be ineffective.”
ECSA is furthermore concerned about the negative impact the publication of commerciallysensitive data would have on shipping companies. Rating of performance of existing shipsusing variable factors, will lead to unfair comparison of ship operators creating marketdistortions, as it happens today with the use of certain non-authorised industry ship ratingsystems. ECSA therefore believes that publication of individual ship’s commercial sensitivedata is unwarranted.
ECSA is also concerned that, even if the vessel operator possesses the operational data thatmight be required to be recorded or reported under the current version of the Commission’slegislative proposal, there are significant complexities and costs that would arise from amandatory third-party verification of such huge amount of data.
“Monitoring of ships data on aper-voyage basis might be easier for some markets (e.g. deepsea trading incl. bulkers,tankers, liner containerships) than others (e.g. short sea shipping incl. RoRos, RoPax,feeders). A monitoring on a per-voyage basis is not a practical approach for vesselsoperating in short sea trades, particularly for those vessels performing multi-voyages perday, as this would create a substantial administrative burden and impracticable verificationprocess. Therefore, these vessels should be allowed to average on a monthly basis forinstance.”
For all these reasons, ECSA recommends to focus on aggregated data from ships’ fuelconsumption in combination with distance sailed. The EU initiative should primarily encourage ways and means of collecting data on CO2emissions through the IMO. In sum, ECSA believes that the EU Regulation proposal has the potential to contributeto the development of a globally harmonised MRV system when taking into accountthe specificities of the shipping sector. The Commission’s proposal should thereforebe ‘simplified and focussed in order to achieve the overall goal to collect useful data inan efficient and flexible way.”
