Round Table associations recommend against the application of EEDI to existing ships
Thursday, 23 February 2012 | 00:00
The Round Table of international shipping associations (RT) supports the adoption of the new energy efficiency regulations for ships by the IMO in July 2011, which demonstrated the effective role of IMO in regulating worldwide shipping CO2 emissions. The measures include the Energy Efficiency Design Index (EEDI) for new ships and the Ship Energy Efficiency Management Plan (SEEMP) for all ships in service.
The EEDI formula in its present form is, however, not supposed to be applicable to all ships. Indeed, it is explicitly recognised that it is not suitable for all ship types (particularly those not designed to transport cargo) nor for all types of propulsion systems.
Parallel to the regulatory developments at IMO, a number of initiatives are seeking to apply the EEDI formula also to existing ships, using speculative data to establish the values. The RT strongly recommends against the application of EEDI to existing ships, as the values generated by such application can be misleading and can create unintended consequences. The focus for ships in service is - and should continue to be - on operational and commercial efficiencies.
The EEDI separates the technical and design-based measures from the operational and commercial ones. It was developed as a regulatory tool with the objective of mandating improvement in the energy efficiency of new designs by stimulating continued technical development of all the components influencing the fuel efficiency of a ship. Such a mandate cannot be applied to ships already in service, as their basic design is not changeable after construction.
The RT will continue to support the important work on energy efficiency for ships at IMO with a view to ensuring a rigid implementation of EEDI for new ships and SEEMP for all ships. Effective implementation of the measures already adopted globally will bring about considerable and tangible reduction of GHG emissions from ships.
Round Table associations believe the timing is not right for an MBM
As it issues its latest position paper on greenhouse gases from ships and market-based measures (attached below), the Round Table of international shipping associations (RT) is of the view that Market Based Measures (MBMs) are not justified at this particular time.
The RT fully supports the adoption at IMO of mandatory Energy Efficiency Design Index (EEDI) for new ships and the Ship Energy Efficiency Management Plan (SEEMP) for all ships. It is convinced that the SEEMP will allow shipowners to better gauge their energy consumption and thereby enhance existing operational efficiency, since fuel is the single highest operational cost factor and this fact alone has already induced ship-owners to become more energy efficient.
In the event that Market Based Measures (MBMs) are eventually introduced to shipping by IMO, these should apply globally and should completely address the nine principles adopted by IMO, it says.
If ultimately it is found that technical and operational measures cannot wholly meet the agreed reduction targets, then any funds generated by means of a globally applied MBM for shipping must be controlled by IMO, says the RT, and, in large part, be disbursed to support further technological development focused on energy efficiency in shipping. It further maintains that the collection and distribution of such funds should be based on a very simple, transparent, verifiable and auditable scheme which minimises any additional bureaucratic and financial burdens on shipping companies.
The RT does not believe that an Emissions Trading Scheme (ETS) can be practically and effectively applied to shipping, as the shipping industry in concept and functionality is global and relies on mobility, diversity, open access to markets and free trade. It stresses that the very complexity of international seaborne trade renders the concept of ETS unworkable for the shipping industry.
The RT strongly believes that the debate about any shipping MBM must be held at IMO where the nature of the industry is understood and the ultimate impact of a fiscal measure can be measured. Under no circumstances does the RT believe that shipping should be subject to a separate UNFCCC or regional MBM as well as an MBM under IMO.
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