The European Community Shipowners’ Associations (ECSA), formed in 1965, comprises the national shipowners’ associations of the EU and Norway. ECSA aims at promoting the interests of European shipping so that industry can best serve European and international trade and commerce in a competitive and free business environment, to the benefit of both shippers and consumers. The European Economic Area maintains its very prominent position with a controlled fleet of 40% of the global commercial fleet.
ECSA can see value in the EU initiative for a Monitoring, Reporting and Verification system (MRV) of CO2 emissions, as a contribution towards finding the most appropriate global solution for CO2 monitoring from international shipping. It then follows 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 harmonized system.
ECSA is prepared to play a constructive role in the up-coming discussions on the specifics of a MRV system for international shipping. However, once the purpose for and the methodology of collecting data have been clarified, it must be ensured that the realities and practicalities of the shipping industry are taken into account and that the system is workable both for the industry and for the authorities.
Any MRV system must be accurate, simple, cost-effective and exclusively based on the vessels fuel consumption. ECSA believes that the Bunker Delivery Notes (BDN), already available onboard all ships and the entries in the oil record book, constitute the appropriate legal, certified and verifiable input to a MRV system. BDN and oil record book are mandatory according to the MARPOL convention and subject to verification during Flag State and Port State inspections. Furthermore, ECSA is of the opinion that the relevant authority for CO2 data collection should be the Flag State.
The acceptance in principle of an MRV mechanism does not imply acceptance by ECSA of MRV being used for the eventual development of any specific Market Based Measures, or the mandatory application of energy efficiency improvement measures or indexing for existing ships. The collection of operational and commercial sensitive information is not supported as it would be irrelevant to a pure CO2 MRV system. However, collection of fuel consumption data including ‘cargo carried’ and distance travelled is a very useful tool for internal purpose of individual shipping companies in order to improve the individual performance of their vessels. This contributes to the exemplary environmental performance of maritime transport towards future sustainable transport worldwide. Hence, ECSA believes that averaging operational and commercial figures from an individual ship as input in a plain MRV system will inevitably contain a large degree of incorrectness as the ship may deliberately adjust speed and cargo under constantly moving market conditions.
ECSA calls on the European Commission to carry out an impact assessment study investigating the MRV process, as the current EU initiative only should have the intention of providing a constructive input to assist the IMO work in the same area.
Source: ECSA