'Reducing CO2 Emissions to Zero' sets out ICS’s firm opposition to the concept of mandatory operational efficiency indexing of individual ships as a possible candidate measure for CO2 reduction, because of 'the potential inaccuracies of such a metric and the significant danger of market distortion'.
The ultimate purpose of operational efficiency indexing...is to penalise individual vessels twice, on the basis of a theoretical and arbitrary operational rating that has little relation to the actual CO2 emissions of the ship in real life.
For example, ICS explains, the fuel consumed by two identical ships during two similar voyages will vary considerably due to factors such as currents, ocean conditions and weather. Similarly, fuel consumed by individual ships, particularly those in tramp sectors, may vary considerably from one year to the next, being dependent on changing trading patterns and the nature of charters over which the ship operator has little control.
As such, ICS expressed its frustration by the European Union’s decision to pre-empt these IMO discussions by proceeding with the implementation of its regional system for collecting data on individual ship emissions.
The EU Regulation on the Reporting, Monitoring and Verification (MRV) of CO2 emissions applies to all ships trading to Europe, with the apparent intention of eventually developing this into some kind of regional operational efficiency indexing system.
The EU MRV Regulation was adopted during 2015, and includes controversial provisions for the submission of data by ships on ‘transport work’ using different metrics to those now agreed by IMO in addition to data on fuel consumption. Moreover, ICS noted that the verification and certification method that has been developed by the EU will be overly complex:
It seems that EU climate officials wish to ignore the tried and tested processes for statutory certification used in international shipping, and instead propose an additional administrative burden for ship operators. But the greatest concern about the EU MRV Regulation is that commercially sensitive information will be published annually by the European Commission, along with ship name and company identifiers. This is with the intention of facilitating comparison of the supposed operational efficiency of individual ships – which is very likely to be inaccurate. In short, the EU Regulation contains many of the elements which most IMO Member States chose to reject when adopting the global CO2 Data Collection System.
Concluding, ICS underlined its intention to maintain its strong objection to the publication by the Commission of data about individual ships, an objection which is shared by a number of non-EU Member States.
ICS will also continue to oppose the development of any system of mandatory operational efficiency indexing that may be considered at IMO.
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