In a letter sent Wednesday to the European Parliament, the World Shipping Council claimed that the rationale for increased regulations regarding vessel emissions it proposed in draft legislation
, which would go into effect in July 2015, appears varied and unclear. The EU's current draft legislation, the council suggested, jumps into and ahead of a game plan that’s already in progress at the International Maritime Organization.
Attached to the letter, which was written by WSC President and Chief Executive Officer Christopher Koch on behalf of the council, is a list of comments the group recently submitted to the IMO concerning vessel emissions. The letter points out that measures to regulate vessel air emissions are already being discussed within the IMO and said that Parliament’s regulatory framework presents a “lack of clarity about what the specific objectives are for further regulatory efforts.” The council continued on to say that legislation requiring monitoring of emissions is “unnecessary” in order to make decisions about policy actions or regulations concerning emissions.
The council’s first recommendation to Parliament is that any EU legislation be deferred until the IMO has finished its work on an initiative for global monitoring. This request echoes the path of airline emissions regulations, which were imposed by the EU only to be put on hold while the International Civil Aviation Organization worked out a plan of its own.
In the letter, the council questioned the need for additional regulations and repeated its disapproval of unilateral regulation of issues by any nation or group of nations, stressing that action only be taken by the IMO.
“We note the strong interest and policy rationale for any such measures to be established through the International Maritime Organization, rather than a patchwork of national or regional regimes,” the letter said.
The council also said existing requirements need to be placed under consideration first, before additional ones are added.
“What is it about those existing requirements and their consequences for fuel cost and vessel efficiency that are insufficient to ensure very dramatic continued reductions of greenhouse gas emissions from the ships?” the council wrote. “What specifically would further regulatory measures seek to accomplish?”
Finally, the council said that if Parliament must consider legislation to require more recording and reporting of vessel fuel and operational data that it be for the full voyage rotation that falls in the jurisdiction of the regime. The legislation should be focused in its requirements for monitoring and reporting, excluding the reporting of NOx, SOx, PM, BC and methane, as this monitoring would “greatly increase the technical complexity of issues to be resolved in association with the proposed legislation.
“We understand that the Parliament is considering expanding the legislation to address NOx emissions, and perhaps other emissions such as sulphur, PM, BC and methane,” the letter said. “We recommend that the legislation not include such an expansion.”
The group stressed that work on these issues is being — and should be — handled by the IMO, and that Parliament should recognize the “relevant” regulations the IMO has already put into place, as well as the ongoing work it is doing.
And, because measures are already in place to address complications that stem from emissions, the council said, “we believe that the current MRV [monitoring, reporting and verification] discussion within the IMO and the European Parliament should retain a focus on carbon emissions and fuel efficiency.”