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11 November 2009
The Climate Effects of Transportation at Sea
An INTERTANKO Position
Climate Change
According to data presented by the United Nations Framework Convention on Climate
Change (UNFCCC), it is estimated that the surface temperature of the Earth has risen by
around 0.6°C over the past 100 years and that, unless action is taken, it may increase by
another 1.8°C to 4°C by the year 2100. There seems to be a broad political agreement that
measures need to be taken to contain the temperature rise below 2°C until 2100.
It is assumed that a major cause which triggered this climate change (also called global
warming) is the excess of greenhouse gas emissions (GHG) from human activities such as
manufacturing, agriculture, transportation, etc. Therefore, in order to contain the global
warming, it is agreed that man-made GHG emissions need to be significantly reduced.
1. INTERTANKO agrees that each sector of the industry, including transportation
should strive to deliver a significant contribution by reducing its Greenhouse
Gas (GHG) emissions, particularly CO2 emissions.
Greenhouse Gas Emissions from Shipping
Although shipping is the most efficient means of transportation, much more efficient than
rail, road and air transportation, it is of course accountable and responsible for the
emissions it produces and it has the obligation to find ways to reduce its emissions.
According to the Second IMO GHG Study (2009), the share of shipping accounts for 3.3%
of the global CO2 emissions, out of which 2.7% comes from the international shipping. Such
a modest contribution from shipping is not an excuse to limit the potential contribution to
reducing CO2 emissions. However, these statistics are significant when planning the targets
for emission reductions, particularly over a short term period.
Shipping is a service industry. Its activity very much depends on the society’s need for
transportation at sea. Achieving significant reductions in the international shipping trade will
be particularly challenging as the amount of goods transported by sea is steadily growing.
It is a fact that tankers have become extremely energy efficient - for every litre of fuel
burned in its main engine, today’s oil tanker transports its cargo twice as far as 20 years
ago. But achieving further large reductions in carbon emissions is challenging and
particularly hard at a time when the amount of oil transported in the international tanker
trade has, up to last year, been growing steadily – the tonne-mile oil trade has increased by
66% this decade compared to the 1980s.
2. INTERTANKO advocates measures that would result in CO2 and other GHG
emissions reductions from tankers. Some measures, such as ship operations,
are under direct control and thus the responsibility of tanker operators.
However, some other measures, such as improved ship design, improved
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technologies and improved logistics can only be obtained through a close and
coordinated cooperation with other stakeholders and with Governments.
3. INTERTANKO believes that energy efficiency will be gained through better
synergy, better coordination and systematic efforts towards optimising
shipping movements jointly with the other stakeholders involved in the
logistical chain.
Regulatory developments
The Maritime Industry has the best knowledge on efficient measures to reduce GHG
emissions from ships. Flag Administrations and the Maritime Industry are therefore best
placed to develop GHG emission reduction regulations through the International Maritime
Organisation (IMO). An international regulatory regime is by far, more efficient than a variety
of local regulations developed by authorities with potentially less knowledge and
understanding of the shipping industry.
4. INTERTANKO supports the IMO process to develop real and sustainable GHG
emission reduction regulations from ships that will not hinder international
commerce.
Regulating the reduction of GHG emissions from ships is however a political decision. There
are two distinct viewpoints among Governments with regard to the “scope of application” of
a new IMO regulatory framework. One view is that regulations should be “ship neutral”,
meaning they apply equally to all ships regardless of flag, consistent with the “no more
favourable treatment” principle that forms a fundamental and legally-binding element of IMO
Conventions. The second viewpoint holds that any GHG agreement should apply to Annex 1
countries only as defined in the Kyoto Protocol to the United Nations Framework Convention
on Climate Change (UNFCCC) based on the Kyoto principles of “common but differentiated
responsibilities”. These two perspectives represent fundamental differences on how various
governments view controlling GHG emissions, and this political issue remains an important
point of disagreement in the IMO debate.
5. INTERTANKO supports the idea that the GHG regulations should be “ship
neutral” as the only way to address a global environmental issue.
Differentiating vessels’ GHG obligations on the basis of a vessel’s flag would
fail to make a meaningful environmental improvement.
Measures for GHG emission reductions
IMO is striving to develop a regulatory package for reducing GHG emissions from ships that
will be presented at the UNFCCC meeting in Denmark in December 2009. These measures
to date include an Energy Efficiency Design Index (EEDI), Ship Energy Efficiency
Management Plan (SEEMP), Energy Efficiency Operational Indicator (EEOI) and potentially
additional Market-Based Instruments (e.g., a GHG Compensation Fund (tax/levy),
Emissions Trading Scheme or a combination of these).
Energy Efficiency Design Index (EEDI)
A ship Energy Efficiency Design Index (EEDI) will mandate a minimum acceptable fuel
efficiency of new buildings. The EEDI will assess the “environmental cost” (i.e. the amount
of CO2 emissions) a ship will have for the “benefit to the society” (i.e. amount of cargo
transported). The assessment is based on a variety of design features. The intention of the
EEDI is to promote more efficient designs and it is intended that the acceptable EEDI values
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will move towards better efficiency in time. Since the EEDI will have an influence on new
ships only, its impact will be noticeable some time in the future.
INTERTANKO members have tested the EEDI formula and, except for refinement needed
for some special tanker designs, consider that the formula has matured enough so ship
operators are encouraged to test it and provide early feedback with regard to its robustness.
6. INTERTANKO supports the adoption of the Energy Efficiency Design Index
(EEDI) as soon as possible. INTERTANKO also encourages IMO to use the
EEDI formulae for an early establishment of target levels for CO 2 emission
reductions for new ships.
Ship Energy Efficiency Management Plan (SEEMP)
Ships would be required to develop and maintain a Ship Energy Efficiency Management
Plan (SEEMP), through which it explains the measures taken and the results obtained by
using measures aimed at improving the energy efficiency of operations. It broadly covers
the implementation plan, record-keeping, monitoring and self-evaluation. SEEMP should be
individual for each ship and will include a list of best practices used to improve the ship’s
energy efficiency. There would be a record-keeping on the implementation of best practices
used to monitor/verify progress in reducing emissions possibly through use of the EEOI
(Energy Efficiency Operational Indicator). The EEOI is however only useful as an aggregate
internal KPI for monitoring ship’s progress in reducing GHG emissions but .it is not suitable
as the basis for regulation as its values for any ship are considerably affected by many
factors beyond the operator’s control. A significant issue regarding the energy efficiency
performance of ships in operations is that some factors in planning a ship’s voyage (i.e.,
optimal voyage speed and schedules, minimizing ballast condition, etc.) which can improve
the EEOI of a vessel are beyond the control of the vessel. It is essential that charterers
should also be involved in the chain of responsibility to minimize CO2 emissions during a
ship’s voyage.
INTERTANKO has noted and welcomed the release by OCIMF of their Energy Efficiency
and Fuel Management booklet. This contribution from OCIMF is recognized by
INTERTANKO as providing, at least in the tanker sector, the basis for a voluntary approach
between tanker operators and charterers for a joint planning of a ship’s voyage with a view
to limiting CO2 emissions. This would involve the practical application of the EEOI and, in
time, may also provide the basis on which emissions reduction targets may be set.
7. INTERTANKO supports the adoption of Ship Energy Efficiency Management
Plan (SEEMP) by IMO. A growing number of INTERTANKO members apply
operational measures aimed at improving ships’ fuel efficiency.
8. INTERTANKO has developed a SEEMP model specific for tankers which will be
made available to its members before end of 2009. The guide for tankers will
facilitate a harmonized and comprehensive recording, monitoring and
reporting of the results. It will also provide a much better assessment of the
usage of the Energy Efficiency Operational Indicator (EEOI).
9. INTERTANKO is actively involved in developing best industry practice
together with other stakeholders, particularly charterers, for a better planning
of the voyage with the view of reducing CO2 emissions.
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Market-Based Instruments: (MBI)
Market-based instruments proposals to IMO still need further development. It is too early to
know which (if any) will be successful or be implemented. If the IMO decides to include MBIs
as part of any regulatory package for the reduction of GHG emissions from ships,
INTERTANKO will strongly request that the selection of any MBI should be based upon
whether the specific proposals meet the IMO nine principles.
10. INTERTANKO is making an in-depth analysis of any concrete Market Based
Instruments (MBI) proposal against a set of principles the Association has
adopted and which embody the IMO nine principles.
INTERTANKO believes that a MBI scheme should be:
1 Governed by the IMO and be specific for the shipping industry;
2 Effective in contributing to the reduction of total GHG emissions:
 any funds collected should be used as “offsets”, e.g. to stimulate JI (Joint
Implementation) & CDM (Clean Development Mechanisms);
 should stimulate leading energy efficiency technologies;
 should provide incentives for improvement of ship’s energy efficiency through
innovation and R&D;
 should stimulate stakeholders, such as charterers and ports, to employ ships in the
most effective manner to reduce GHG emissions (e.g. by selection of voyage speed,
minimizing ballast legs, minimizing waiting times and adopting larger average
cargo/tonne miles ratios);
3 Environmentally sustainable without negative impact on global trade and growth
 should be cost effective;
 should not lead to competitive distortion;
 should not disadvantage operators or ships which have already taken actions
resulting in GHG reductions;
4 Efficient and credible enforcement and monitoring
 should be binding and equally applicable to all ships;
 should be practical, transparent, fraud-free and easy to administer by the governing
authority;
 should enable compliance to be demonstrated through proper monitoring (with the
scheme based on actual fuel burned); and
 should ensure certainty and predictability.”
11. INTERTANKO will report the result of its evaluations and a comparison
between various concrete alternative proposals as soon as more detailed
presentations of these are provided.
Targets for GHG Emissions Reductions
INTERTANKO believes that, despite the complexity of the issues that need to be addressed
in developing provisions to reduce CO2 emissions from both new and existing ships, IMO
has achieved a great deal of progress. When enforced, the IMO forthcoming regulations
could result in measurable reductions of GHG emissions from all ships.
Without ignoring the political connotations and the links to the more general debate with
regard to climate change negotiations in UNFCCC, INTERTANKO believes that IMO will
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maintain its momentum and will shortly reach agreements in setting short term and long
term targets on emission reductions from all ships.
12. Shipping is a service industry whose activity increase or contracts with the
demand of the society. Therefore, INTERTANKO believes that GHG emission
reduction targets should give due regard to optimising the supply chain.
13. INTERTANKO believes it is essential that stakeholders and regulators discuss
and assess targeting levels for GHG emission reductions from shipping, on a
short and long term basis. The target levels should be ambitious, but, they
should also give realistic predictions and thus provide incentive for
sustainable efforts to achieve them.
14. INTERTANKO believes it is more important to initiate the process of CO2
emission reduction from shipping as soon as possible and accept that the
initial agreed target levels could be adjusted as experience is gained.
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