ECSA concerns over EU MRV proposals

The European Community Shipowners’ Associations (ECSA) welcome the Commission's proposal for a Monitoring, Reporting and Verification (MRV) system of CO₂ emissions from maritime transport as a  step towards finding an appropriate global solution for CO₂ monitoring from international shipping.

However, it is ECSA’s position that any mandatory requirements on MRV for the international shipping sector, must be agreed at IMO level, as this is the only way of securing a globally harmonised system, according to an ECSA position paper.

ECSA considers that the reporting of commercially sensitive cargo information, per-ship, is premature. Publication of such data would, in any case, be unwarranted. As a potential way ahead, ECSA recommends an MRV system that solely includes the aggregated data from ships' fuel consumption in combination with distance sailed. This combination, ECSA suggests would substantiate shipping's advantages as the most energy efficient and environmentally friendly mode of transport and would allow correlating the trends of CO₂ emissions with   data on world trade which is already available. Overall, ECSA believes that any proposed MRV system should ensure that the realities and practicalities of the shipping industry provide a CO₂ monitoring system that is workable 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 that MRV were to be used to establish regional Market Based Measures (MBMs), mandatory application of energy efficiency improvement measures or indexing for existing ships.

Whilst acknowledging the expressed long term intention of further improving the environmental performance of the existing fleet, ECSA considers it premature for the European Union to go along this path. Detailed input values for operational efficiency vary to a degree where any averaging and aggregation would make the result useless. Calculating such gross average indices for operational efficiency would distort the commercial viability of ships in a manner that is unjust and misleading.

ECSA says in the position paper, "A transport work value, expressed in CO₂ emissions per distance travelled per amount of cargo 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 environment which produces many variables that can be under the control of different parties (whether the owner, the technical operator, the commercial operator or the charterer) and which influence its performance”.

ECSA adds, "Each individual ship achieves its service and transport performance within an individual transport environment subject to constant variation of economical aspects (fuel price, freight rates), operational aspects (amount of cargo carried, speed, routeing, ballast legs) and environmental aspects (current, weather and sea conditions, winter and ice navigation). These factors would even make it difficult to compare sister ships in the same trades, or seemingly identical voyages of the same ship during different seasons. Any attempt to formulate emissions regulations that ignore the above-mentioned facts is therefore bound to be ineffective."

Furthermore, ECSA is concerned about the negative impact the publication of commercially sensitive data would have on shipping companies. Rating the performance of existing ships using variable factors, would lead to unfair comparison of ship operators creating market distortions, as already happens today with the use of certain non-authorised ship rating systems in the industry. ECSA therefore believes that the publication of commercially sensitive data for individual ships is unwarranted.

ECSA is also concerned that, even if vessel operators possess the operational data that might be required to be recorded or reported under the current version of the Commission's legislative proposal, there are significant complexities and costs that would arise from a mandatory third-party verification of such a huge amount of data.

"Monitoring of ships data on a per-voyage basis might be easier for some markets (e.g. deep-sea trading including bulkers, tankers, liner containerships) than others (e.g. short-sea shipping including RoRos, RoPax, feeders). A monitoring on a per-voyage basis is not a practical approach for vessels operating in short-sea trades, particularly for those vessels performing multiple-voyages per day. This would create a substantial administrative burden and an impracticable verification process. Therefore, these vessels should be allowed to average on a monthly basis, for instance."

For all the aforementioned reasons, ECSA recommends that there should be a  focus on aggregated data from ships' fuel consumption in combination with distance sailed. The EU initiative should primarily encourage ways and means of collecting data on CO₂ emissions through the IMO. In conclusion, ECSA believes that the EU Regulation proposal has the potential to contribute to the development of a globally harmonised MRV system, when taking into account the specificities of the shipping sector. The Commission's proposal should therefore be 'simplified and focussed in order to achieve the overall goal to collect useful data in an efficient and flexible way.".