Proposal not enough to meet ship CO2 target

The EU must remove unreliable monitoring methods from the MRV, ensure transparency and agree on a market-based measure to meet its climate targets for the shipping sector.

In 2009, the EU committed to include shipping in its climate policy, but so far all the Commission has come up with is a proposal to monitor ships’ emissions of the main greenhouse gas carbon dioxide (CO₂).

While the Commission’s proposal for Monitoring, Reporting and Verification of emissions from maritime transport (MRV) is a step in the right direction, it lacks ambition and will have little impact if left unchanged. It can and should be strengthened to create a MRV system that covers not only CO₂, but also other harmful air pollutants, in particular sulphur dioxide (SO₂) and nitrogen oxides (NOx). Moreover, unreliable monitoring methods should be removed, and data transparency needs to be ensured. Finally, there should be a path for transition from minimum MRV requirements to real emissions-reduction measures.

Notwithstanding claims of being the most carbon-efficient mode of transport, CO₂ emissions from international shipping are rapidly growing – up 90 per cent since 1990, and now represent over three per cent of global CO₂ emissions. If emissions remain unabated, they could grow to represent almost one fifth of the allowable global 2°C carbon budget in 2050. In Europe, the Commission estimates that CO₂ emissions from maritime transport in EU seas in 2010 amounted to some 180 million tonnes. If these emissions were reported as a country, shipping would be the 8th largest emitter in Europe.

In its 2011 Transport White Paper, the Commission called for “EU CO2 emissions from maritime transport to be cut by 40% (if feasible 50%) by 2050 compared to 2005 levels”. The MRV proposal does not however require emissions cuts – merely the reporting of emissions from ships arriving at and leaving from EU ports.

The Commission claims the MRV proposal will stimulate fuel savings of around two per cent, but the methods proposed make this questionable. The Commission’s impact assessment shows that an EU market-based measure (MBM), such as emissions trading, could achieve significant emission cuts in a cost-effective manner.

Therefore the proposal should be amended to implement such a market-based measure and the MRV provisions strengthened to support such a measure.

Four reporting methods are specified in the MRV proposal. A recent study (see: http://transenv.eu/bunkerfuel) has confirmed that the first two of these are inaccurate and will add nothing new, while the last two are in fact capable of stimulating emissions reductions, potentially beyond the two per cent mentioned.

• Bunker Fuel Delivery Notes (BDN) and periodic stocktaking of fuel tanks relies on estimating the fuel consumed and hence the emissions by using fuel sales receipts (BDN) that ships are already required to retain onboard. Because these may be inaccurate and unreliable they are not considered to be a credible way to measure voyage fuel burnt.
• Ship fuel tank monitoring: Successive fuel level readings from tank soundings indicate the fuel consumed. The study suggests even higher uncertainty with this method than with BDNs due to human error, variations in fuel, inaccurate tables, etc.
• Flow meters: An accurate and reliable method already used in cars and trucks. It provides continuous readings of fuel flowing to the engines and thus fuel consumption. Low burden for ship’s crew and verifiers (except for regular calibration).
• Direct emissions measurement: Continuous measuring of the emissions in the exhaust funnel. Can also measure emissions other than CO₂ (such as air pollutants). Low burden for ship’s crew and verifiers (except for regular calibration). Requires new onboard equipment.

CO₂ is by no means the only emission from ship smokestacks worthy of monitoring. Other important pollutants include SO₂, NOx and particulate matter (PM). The EU recently implemented IMO’s fuel sulphur content regulations – when fully implemented by 2020 these will significantly cut ships’ SO2 and PM emissions.

However, at present only about 0.1 per cent of ships are controlled for fuel sulphur content. At this rate, it is clear that ensuring strict enforcement will be next to impossible.

It should be noted that projections on future emissions show that the emissions of NOx from shipping around Europe are expected to exceed NOx emissions from all EU land-based sources combined by 2020.

It is therefore important to introduce a single MRV requirement for continuous monitoring and reporting of all relevant emissions such as CO₂, SO₂ and NOx. The MRV instrument would then become a simple and powerful indicator of the overall air pollution performance of ships and allow for accurate and cost-effective enforcement of the EU’s Sulphur in Marine Fuels Directive.

Data transparency is essential if the information barriers preventing improved ship fuel efficiency at little or no cost are to be properly addressed. The required data should enable a full estimate of ship efficiency (including cargo data, etc.) and be made public to empower stakeholders such as charterers, who could then identify which ships operate in the most efficient manner. This would imply disclosure of more disaggregated data than the Commission’s proposal, most importantly allowing the publication of data on a route basis.

In summary, the policy recommendations from Transport & Environment are to:

• Remove unreliable monitoring methods.
• Require monitoring of CO₂, SO₂ and NOx emissions to create an integrated MRV.
• Mandate data transparency to help remove market barriers.
• Agree now on a market-based measure for CO₂ emissions to ensure the EU emission reduction target will be met in a cost-effective manner.

Aoife O’Leary
T&E Transport Policy Officer

Transport & Environment
European Commission