Maritime Safety and Protection of the Environment

Ongoing work at UN IMO primarily focuses on short-term GHG emissions reduction measures for early action. The UGS favours an approach which will ensure that charterers bear their fair share of responsibility for a ship’s carbon footprint. This is because, in tramp shipping, it is usually the charterer who controls the vessel’s itinerary, cargo type and quantity, service speed and fuel consumption. Therefore, the UGS supports the proposal made by Greece et al. for the limitation of main engine shaft power as a measure that will yield immediate results and will help bring about behavioural change without stifling innovation and without jeopardising the bulk / tramp shipping business model.

This approach is based on the EEDI regulation, an important ongoing mandatory measure that was adopted by the UN IMO in 2011 and implemented on new build ships since 2013. This measure already provides tangible carbon intensity reductions and its extension to ships built before 2013 qualifies as the best available short-term measure as it allows existing ships to conform to higher technical efficiency standards through shaft power limitations. It also provides a means for international shipping to achieve the UN IMO’s 2030 goals. The proposal includes a review in 2027. In addition, the establishment of a Ship Energy Efficiency Management Plan (super SEEMP), as an operational measure to complement technical measures, may safeguard the accomplishment of the UN IMO’s 2030 goals, if necessary.

As shipping is a genuinely global industry, global measures at UN IMO level are the most effective way forward. Regional measures contemplated by the European Commission in the framework of its recently announced Green Deal, such as the inclusion of shipping in the EU Emissions Trading System (ETS) would undermine the industry’s global regulatory framework, as well as the UN IMO’s efforts for a global level playing field. The ETS is not appropriate for shipping and would lead to a host of unintended consequences, including market distortion, carbon leakage and a modal shift from sea to road.

For shipping to truly decarbonise in the long- term, the substantial technological gap between the UN IMO’s 2050 objective and the current state of affairs must be bridged. Shipping will have to undergo a paradigm shift similar to the move from sail to steam in the late 19th century. Without innovation in alternative fuels, shipping will remain carbon captive. The best choice for the existing fleet would be “drop-in” fuels from renewable sources. Therefore, the International Maritime Research Fund (IMRF) proposed by the shipping industry, which includes core funding from shipping companies across the world of about $ 5 billion over a 10-year period, is more timely than ever. Once a technological long-term solution has been found, an appropriate and effective global Market-Based Measure (MBM) could facilitate in the medium-term the transition to a decarbonised future. For a change of this scale to materialise, however, shipowners alone cannot be held responsible.

In fact, shipowners order ships in the same way that individuals buy cars. The manufacturer of the vehicle (in this case the shipbuilder) is responsible for the environmental characteristics of the vessel but not for the fuels it will use. Therefore, all actors in the maritime value chain, from engine manufacturers and shipyards to ports and fuel suppliers, should actively participate from the outset, to ensure compatibility of solutions and improve vertical and horizontal efficiencies.

The UGS supports a short-term measure focusing on main engine power limitation that can lead to immediate carbon intensity gains while research must be prioritised as soon as possible to provide for longer-term solutions. A super SEEMP can be an effective complement.