Among all the submissions on potential measures to reduce emissions and comply with the upcoming cap, the proposals from France and Greece for prescriptive speed reduction regulation and introduction of a ship fuel consumption cap could divide the industry.

The idea of regulating speed limits to slow down ships to cut fuel consumption and carbon intensity of the industry is not new in the IMO; however, so far it has been politically unacceptable due to the direct impact that it might have to trade

Anna Ziou, Policy Director, says.

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These proposals may have a positive intention, but they do not match the risk leaving gaps in the IMO’s decarbonisation plan, while their implementation and enforcement are also problematic, the UK Chamber of Shipping notes.

It explains that, should the IMO eventually relies on prescriptive speed regulation to meet its short-term target, it would lead to delays in the low-carbon transition and store up greater costs later on for the industry.

In addition, there is an argument that limiting ships speed further might deliver fuel savings for current ships. However, this is based on speed simulations studies where it is expected that ships will always drive at a certain speed, while the savings could be minimal or even negative. In fact, the actual fuel consumption benefits of low speed would be negated by the loss of capacity which would require more ships to be build and recycled at a later stage, Ms. Ziou says.

Moreover, reducing speed could lead to a modal shift and higher aggregate GHG emissions in case of time-sensitive cargos, especially in the short sea segment. Some cargos may even change to other modes, increasing overall emissions.

Furthermore, some vessels may call ports that are often tidally constrained where a delay of 1-2 hours could cause a delay of 12 hours to the vessel and thus economic damage. It could also create emissions during the waiting time for the next tide.

Another negative impact, the Chamber adds, is the fact that the speed limit will be counterproductive about other IMO regulations as low load engine operation increases emissions of NOx, PM and Black Carbon.

I am not saying that speed does not have a role to play. However, that should be speed optimisation and done through a goal-based approach. The IMO should offer shipowners both technical and operational options to give them control on what works best for their business model

Ms. Ziou highlighted.

Finally, another point of contention is the proposal to put a cap on how much fuel a ship will be allowed to consume during a given year. This  raises a number of questions regarding its implementation, such as:

  • Will all vessels be allocated the same fuel consumption?
  • What happens if a ship reaches its limit before the end of the year?
  • Will the vessel not be permitted to be available in the market?
  • What will be the impact on States, especially on island states if by the end of the year ships were not able to trade?

The core conclusion is that unless the IMO ensures that there is a level playing field and the right direction on the pathway going forward we might miss the boat. We have set ambitious targets, but we need the IMO to support these with appropriate policy for the industry to realise it. These issues require long-term perceptive and not just short-sighted quick fixes. We need measures to make the targets sets work in real business conditions

The UK Chamber of Shipping concluded.