Memorandum submitted by WWF-UK (EFS10)
WWF-UK welcomes the opportunity to contribute to this timely inquiry into an important but little-discussed source of CO2 emissions. Our responses to the questions are set out below.
• How significant is global shipping's contribution to climate change? How is this projected to change in the future?
WWF understands that the provisional figure
of 1,200 MtCO2 for the global shipping industry is likely to be an
overestimate, and that at the 58th Marine Environment Protection
Committee meeting (MEPC 58, taking place in
Shipping emissions have roughly doubled since 1990 and the IMO forecasts continued growth as demand increases, even allowing for potential gains in efficiency. Furthermore, the sulphur particles in ship emissions, which exert a cooling effect in the short term, are likely to diminish substantially as tough new standards (that have already been agreed) come into force over the next two decades.
How should the
WWF-UK advocates a global sectoral approach to tackling shipping emissions (see further under Q3). In such a scheme the responsible entity is not the country but the shipowner (just as airlines, not Member States, will have to surrender allowances when aviation enters the EU ETS). Contrary to the impression given by the Government, this does not mean that the UK should exclude these emissions from its national totals; such an argument could equally apply to all traded sectors in the ETS from 2013 and our national totals would then cover less than half of our overall emissions.
Even if a global scheme can be negotiated
(which is far from certain), it would be prudent to include shipping in the
Unlike for aviation, calculating shipping
emissions from fuel sold in the
WWF-UK, therefore, advocates a route-based
system of accounting: emissions of ships on routes that end at a
• What are the prospects of international agreements to control and reduce carbon emissions from global shipping, or to bring it within wider emissions trading schemes?
Bunker fuel emissions occupy a precarious niche at UNFCCC negotiations. Aviation is barely discussed, and shipping has only recently begun to get a hearing, but some Parties wish to see both sectors left exclusively to ICAO and IMO and therefore struck off the UNFCCC agenda.
These Parties (OPEC, US and others) point to Article 2.2 of the Kyoto Protocol, which states that Annex I parties should 'pursue limitation and reduction' of GHGs from these sectors working through IMO and ICAO. Article 2.2 contains a paradox that has blocked progress on bunker emissions for the past decade: IMO and ICAO are charged with tackling Annex I emissions, but IMO and ICAO do not recognise UNFCCC Annexes or operate on the UNFCCC principle of Common But Differentiated Responsibilities; rather they have apparently contradictory principles of treating all ships (or airlines) the same, regardless of nationality.
Over the last 18 months or so, IMO has suddenly begun to play a very pro-active role in seeking to limit GHG emissions from shipping (providing a welcome contrast to the ICAO). Work is underway on a range of measures: a design index for new ships, an operational index for existing ships, a menu of best practice options, but most importantly in WWF's view, and certainly most controversially, a 'market-based instrument', of which there are two basic variants: a cap-and-trade scheme, or a levy on emissions / fuel use.
Schemes of this nature have been proposed
Opponents of a global scheme (chiefly the
BRICS countries -
The alternative to a truly global scheme is one that applies to 'Annex I' emissions only, but this requires a definition of what emissions can be attributed to Annex I Parties.
It is widely recognised that differentiation by flag is unfair (77% of ships are flagged in developing countries), contrary to IMO principles, and easy to evade; a ship can be re-registered under a new flag in a matter of hours.
A variant would be to differentiate according to the nationality of the ship owner, as many Panamanian-flagged ships (for instance) are controlled by companies registered in Annex I countries. The UN Convention on Trade and Development (UNCTAD) publishes statistics based on 'state of effective control', and the majority of ships by this definition belong to Annex I countries. But the problem still applies, if there were climate policy that imposed a cost only on ships owned by Annex I countries, there would be an exodus of ship-owning companies from Annex I to non-Annex I, much in the same way as some companies currently register in offshore tax havens where it suits them.
A more interesting possibility is a
route-based approach (see answer to previous question). Emissions on all routes
to Annex I ports would be subject to a cap-and-trade scheme or levy, regardless
of who owned the ships or where they were flagged. This would impose the cost
on consumers (importers) in the developed countries, as ship owners passed
through costs, and it would respect IMO principles as all ships on a given
route would be treated the same. The question is whether such a policy would
lead to evasion, for instance by ships making an extra port call at a country
on the edge of the Annex I zone (eg a ship from
Our analysis of the political situation is,
that many individuals within the delegations of BRIC countries accept privately
that any maritime emissions scheme that was less than global in scope would
lead to evasion and distortion. Notwithstanding that, the principle of CBDR is
absolutely critical to their negotiating strategies in the context of the wider
climate negotiations, and they fear that by granting this concession in the
shipping sector they risk conceding the principle more widely. Given the stance
So for example:
How well is the
At IMO, the
At UNFCCC, where the EU speaks as a bloc
through the Presidency, it is a little harder to pinpoint the exact
contribution of the
Overall, the UK Government must develop a strategy for achieving its objectives in maritime emissions that is more pro-active and more co-ordinated across the different Departments and agencies that share the responsibility.
• What are the prospects for developing new engine technologies and fuels, as well as more fuel-efficient operations?
Unlike the aviation sector, the shipping industry has a number of unrealised technological options to make substantial reductions in its emissions intensity, so that increasing the cost of burning fuel is more likely to drive efficiency within the sector than to limit demand.
For instance, the new generation of 'sky-sails', essentially huge kites harnessing the wind to power ships, could reduce fuel burn by 10-15%. Cruising at slower speeds in order to do 'just in time' deliveries of cargo can reduce fuel burn by up to 40% on some routes (figures from personal correspondence with IMO).
Several more detailed assessments of the mitigation options within the sector are available and we do not attempt to summarise these here. See for instance: http://www.regulations.gov/search/redirect.jsp?objectId=090000648063a431&disposition=attachment&contentType=pdf
What are the effects of shipping on
There is significant harm to public health
For further information, please contact Russell Cooper, Senior Public Affairs Officer, on 01483 412382 or at email@example.com
 Technical workshop
on GHG emissions from aviation and maritime transport in