Guido Harling, Executive Director and Founder of ETSverification GmbH, says the reporting of shipping emissions under MRV Regulation is a ‘daunting task’ and advises how companies shall get prepared for the monitoring plan up to the Aug 31st deadline. Mr Harling finds only advantages in the introduction of a global MRV and anticipates for the future IMO to introduce sooner rather than later such a world-wild solution.
Q1: How IMO’s decisions at MEPC70 on CO2 shipping emissions have affected the current legislative landscape? How do IMO’s plans differ from the EU MRV system?
Last year in October IMO through its body MEPC adopted changes to the MARPOL convention at the 70 annual meeting. IMO’s plan is to establish an emissions data collection system for ships greater than 5.000 GT. Voyages around the globe have to be reported on an annual basis by 2019. The difference to the EU’s MRV system is that under MRV ship-owners have to report on a per voyage basis (as shipping MRV only covers European ports) versus under IMO ship-owner have to report a total sum of emissions from worldwide maritime travel. The second difference is that the EU’s MRV system starts in the year 2018 with the submission deadline for the first verified full year emission report of 2018 being April 30th 2019 and IMO MRV starts about one year later.
Q2: Do you think that there will be any drawback associated with the decision to introduce IMO global MRV with respect to EU MRV and possible EU ETS?
It is my personal opinion that there are only advantage to the introduction of a global MRV. EU-ETS and shipping MRV by the EU are only small patches in a world-wide problem, that is the increase of CO2 in the atmosphere. So, IMO introduces a world-wild solution (a global MRV) than it is my option to introduce it sooner rather than later. Whether or not, the EU will modify or transition its Shipping MRV into the IMO’s global MRV is up for debate.
Q3: What should be the key priorities for the shipping industry in relation to EU MRV Regulation? How your organization may be of assistance towards that end?
Recording shipping emissions as a multiple of consumed fuel to satisfy shipping MRV reporting requirements is not small feast. Not at all. Or to be more precise it’s a daunting task. Considering that various fuel source streams have to be recorded on a pre voyage basis will require sophisticated measuring and recording processes. And since the majority of ship-owner still have shied away from that task – a lot of red flag should be raised. My organization ETSverification GmbH in Partnership with Bureau Veritas/Tecnitas offers MRV readiness assessments and verification services. Here we help companies to understand the requirements of shipping MRV, and prepare the monitoring plan for the Aug 31st deadline, as well as audit those monitoring plans we did not create.
Q4: Why is important for the ship-owners to plan early in order to lower shipping emissions? What are the benefits?
As stressed before – monitoring and reporting shipping emissions is a complex task. The first milestone of the EU’s shipping MRV is just a few month away (Aug 31st to present a monitoring plan to a verification body). Even if a shipping company will start today to create the monitoring plan and organize data collection processes on each ship and in the HQ accordingly – we can no longer speak of starting early.
My personal opinion is that these companies are already starting late – especially if they will be in need of 3rd party support. Verifiers, software company and equipment manufactures for measuring technology (such as combustion flow meters etc.) will provide services on a first come first served basis. Starting now is the only option to avoid a shortage or stark time pressures when it comes to the Aug 31st deadline.
Q5: What do you think may be the immediate and long term consequences of a possible introduction of an EU ETS for shipping? Are there any lessons to be learned from the aviation industry?
ETSverification GmbH has experienced firsthand how the introduction of an EU regulation to a global industry like shipping or aviation can create great turmoil. Aviation ETS was introduced in 2010 with the first deadline for the submission of a verified annual emissions report for flights into and intra Europe by March 31st 2011. Just like in shipping today airlines waited until the last minute to act and prepare for the regulation. Airlines looked at ICAO, the UN body for aviation, to help to make the EU regulation disappear. That did not happen so demand for 3rd party support and for verification services spiked and airlines found themselves scrambling for help as the 1st deadline came closer. This is a lesson for shipping (not to wait until the last minute) but to act now.
Q6: What would be your key message to the industry in general with respect to CO2 reduction from shipping emissions?
Shipping has enjoyed loose CO2 regulations for too long and we all know that global warming is a true global problem. The technology exist today to reduce emissions and to make our ships more efficient when it comes to fuel consumption. My message is that the early movers or early adopters will benefit and the laggards will face dire consequences of being no longer competitive.
The views presented hereabove are only those of the author and not necessarily those of GREEN4SEA and are for information sharing and discussion purposes only.
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About Guido Harling, Executive Director and Founder, ETSverification GmbH
Guido Harling is founder and executive director of ETSverification GmbH, the verification body for GHG emissions from the transport sector. He holds a bachelor of science (Dipl. Chem. Ing.) and a master of business (Dipl. Wirt. Ing.) degree. Furthermore he is IRCA accredited ISO 9001, 50001 auditor and an EU aviation security process validator. Guido started his career in North America where he worked for KPMG US specializing in ERP systems for airlines and airports. Since 2005 he has been Business Development Manager and managed projects in the aviation and transportation area. In 2009, with the emerge of EU-ETS he first helped operators to design and implement ETS conform monitoring concepts. In 2010 Guido founded ETSverification GmbH and his company became a DAkkS (Germany’s National Accreditation Board) accredited verification body under DIN EN ISO 14065. ETSverification GmbH offers verification services for airlines and shipping companies within the framework of the EU Emissions Trading Scheme. ETSverification GmbH is accredited to audit in all EU member states. Currently his company is offering Compliance Readiness Assessments to ship owners to prepare for MRV and to prepare for the verification of ship specific monitoring plans by Aug 31st 2017.
