EUROPEAN COMMISSION'S PROPOSED CO2 GHG MRV SCHEME FOR SHIPPING

The precise amount of CO and other greenhouse gas emissions of EU-related maritime transport is not known due to the lack of monitoring and reporting of such emissions. The impact assessment and stakeholder consultation (see section 2) identified that a robust system for monitoring, reporting and verification (MRV) of greenhouse gas emissions from maritime
transport is a prerequisite for any market-based measure or efficiency standard, whether applied at EU level or globally.
BIMCO's Position
BIMCO's believes that before governments can establish realistic targets for the reduction of CO2 as related to the shipping industry, governments must compile reliable data that supports such targets. In support of this undertaking, BIMCO will in principle support a scheme that strives to collect reliable data regarding CO2 emissions from ships engaged in international trade, provided that such a scheme does not place an unnecessary and additional administrative as well as operational burden on the ships and thus potentially impact the safe operation of ships.
In line with BIMCO's objective to facilitate international trade in a fair and non-discriminatory manner the MRV dataset should be as simple as possible to facilitate international implementation and preferably by use of data monitored and collected by means of existing procedures on board the ships.
BIMCO thus sees any possible MRV scheme of data collection as a vehicle by which the industry may contribute to deliver data for governments to facilitate their setting of realistic targets for the reduction of CO2 emissions from ships.
Discussion
In the autumn of 2012 the European Commission (EC) communicated its intentions with regard to actions towards GHG emissions from ships. Its initial approach is a MRV (Monitoring, Reporting and Verification) scheme. The EC will release its proposal during the first half of 2013 and the normal EU processes for translating an EC initiative into European law will take some years. Mandatory requirements on ships calling in Europe will thus likely become a reality some years later.
The USA has submitted a proposal to MEPC for a three phase scheme to ultimately result in a regulatory requirement for existing ships' energy efficiency. The first phase is proposing a data collection scheme to be used for subsequent analysis in a second phase – potentially leading to the development of an energy efficiency baseline for existing ships. The suggested third phase is implementation of some kind of mandatory requirement to efficiency and a potential trading scheme to allow for alternative compliance.
MEPC is working on an update of the IMO GHG Study. An expert working group met in February 2013 to discuss methodology. Some coherence is noticed between the US proposal to monitor and report GHG emissions from ships, the EU MRV option that is presently being worked on within the EC and several IMO member states clearly voicing their preference for a "bottom up" approach for the IMO GHG Study update.
The update of the IMO GHG study is however expected to be completed already by first half of 2014 to coincide with MEPC 66. The study will thus largely be based on a similar methodology as was used in the 2009 update – estimation of ship activity and developing a detailed model for fuel use by well-defined sub divisions of each segment of the world fleet.
It is already required by existing IMO rules to have a range of information on board of ships related to emissions, both relative and absolute, including the bunker delivery note, cargo among other elements. It appears therefore possible to establish a system that is based on existing information available on board probably used and gathered in a new way by either flag states or IMO.
MEPC 65 in early May 2013 will shed more light on the way ahead for data collection under the purview of IMO