Memorandum submitted by the International
Maritime Organisation
IMO'S WORK TO LIMIT OR REDUCE CO2
EMISSIONS FROM INTERNATIONAL SHIPPING
IMO—A SPECIALIZED
SHIPPING AGENCY
OF THE
UNITED NATIONS
Shipping is one of, or perhaps the most, international
of all the world's industries, carrying more than 90% of global
trade by weight cost effectively, cleanly and safely around the
world. Today, we live in a society supported by an expanding global
economy, which simply could not function without international
shipping. IMO as UN's specialized shipping agency plays a key
role in ensuring that lives at sea are not put at risk and that
the marine environment is not polluted by international shipping—as
summed up in IMO's mission statement: Safe, Secure and Efficient
Shipping on Clean Oceans.
The Convention establishing the International
Maritime Organization (IMO) was adopted in Geneva in 1948 and
IMO first met in 1959 and embarked on the work on developing instruments
for international shipping. IMO's main task has been to develop
and maintain a comprehensive regulatory framework for shipping
and its remit today includes safety, environmental concerns, legal
matters, technical co-operation, maritime security and the efficiency
of shipping. With 167 Member States and three Associate Members,
IMO represents 97% of the world merchant tonnage. IMO has
also 51 IGOs (Inter-Governmental Organizations) and 66 NGOs (Non-Governmental
Organizations) with observer status representing all stakeholders
in the shipping and maritime industry covering the total chain
of value and the entire lifespan of a ship from the drawing board
to the recycling yard.
The purposes of IMO, as summarized by Article
1(a) of the Convention, are "to provide machinery for co-operation
among Governments in the field of governmental regulation and
practices relating to technical matters of all kinds affecting
shipping engaged in international trade; to encourage and facilitate
the general adoption of the highest practicable standards
in matters concerning maritime safety, efficiency of navigation
and prevention and control of marine pollution from ships".
The Organization is also empowered to deal with administrative
and legal matters related to these purposes.
IMO AT WORK
IMO's specialized committees and sub-committees
are the focus for the technical work to update existing legislation
or develop and adopt new regulations, with meetings attended by
maritime experts from Member Governments and observer organizations.
The result is a comprehensive body of about 50 international
mandatory instruments, supported by hundreds of codes, performance
standards, guidelines and recommendations governing every facet
of shipping:
— There are, firstly, measures aimed
at the prevention of accidents, including standards for ship design,
construction, equipment, operation and manning—key treaties
include SOLAS, the MARPOL convention for the prevention of pollution
by ships and the STCW convention on standards of training for
seafarers.
— Then there are measures which recognize
that accidents do happen, including rules concerning distress
and safety communications, the International Convention on Search
and Rescue and the International Convention on Oil Pollution Preparedness,
Response and Co-operation.
— Thirdly, there are conventions which
establish compensation and liability regimes—including the
International Convention on Civil Liability for Oil Pollution
Damage, the convention establishing the International Fund for
Compensation for Oil Pollution Damage and the Athens Convention
covering liability and compensation for passengers at sea.
RATIFICATION OF
IMO INSTRUMENTS
IMO has developed and adopted a wide range of
measures to prevent and control pollution caused by ships and
to mitigate the effects of any damage caused. Instruments such
as the MARPOL and OPRC Conventions; the compensation regimes in
the CLC, FUND, HNS and Bunkers Conventions; the newer standards
on ships' anti-fouling systems and ballast water management; the
emerging regulations on environmental sound ship recycling and
wreck removal, and the work on the reduction of ships' emissions,
are all positive proof of the determination of Governments and
the industry to reduce to the barest minimum the impact of
shipping on our fragile environment.
In achieving this goal, however, it is not sufficient
to just adopt high standards. The treaty or other instruments
that contain them have to be ratified and translated into national
legislation and they have to be implemented effectively and
uniformly throughout the world and, equally important, they
have to be enforced. Although the majority of the conventions
adopted by IMO are in force, some of the IMO instruments developed
to protect the marine and global environment have taken years
before entering into force due to the slow pace of ratification,
and some are still not yet in force, years after they were adopted.
IMO and the Secretary-General are very concerned
at the slow pace of ratification of conventions already in
place, the concern is threefold:
— one, by not bringing the relevant
instruments into force, we delay their implementation, thereby
depriving the environment of the service these instruments aim
at rendering to it;
— two, any further delay in
tackling the issues regulated by the instruments in question may
give rise to individual countries or groups of countries to move
to unilateral or regional measures, with all the negative repercussions
such measures entail; and
— three, any prolongation of
the situation may lead to ambiguities, which, in the final analysis,
may turn against seafarers and the industry.
In this respect, the IMO Secretariat would like
to remind the Treasury Committee that the United Kingdom has
not yet ratified the HNS Convention 1996 on Harmful Noxious
Substances, the OPRC/HNS 2000, the Anti-Fouling Systems Convention
and Ballast Water Management Convention. Furthermore, to encourage
the members of the Committee, to exert whatever influence you
have so all the environment-related IMO instruments are ratified
without further delay, so that the maritime community is not accused
of neglecting its duty towards the global environment and the
responsibility to preserve the Planet for future generations.
ENFORCEMENT OF
IMO INSTRUMENTS
Inspection and monitoring of compliance are
the responsibility of Member States, but the adoption of a Voluntary
IMO Member State Audit Scheme is expected to play a key role in
enhancing implementation of IMO standards. IMO has an extensive
technical co-operation programme, which identifies needs among
resource-shy Members and matches them to assistance, such as capacity
building and training. IMO has founded three advanced level maritime
educational institutes in Malmö, Malta and Trieste.
INTERNATIONAL INDUSTRY
The ownership and management chain surrounding
any ship can embrace many countries and ships spend their economic
life moving between different jurisdictions, often far
from the country of registry. There is, therefore, a need for
international standards to regulate shipping—which can be
adopted and accepted by all. The first maritime treaties date
back to the 19th century. Later, the Titanic disaster of 1912
spawned the first international safety of life at sea—SOLAS—convention,
still the most important treaty addressing maritime safety.
It has always been recognized that the best
way of improving safety and environment protection at sea is by
developing international regulations that are followed by all
shipping nations and from the mid-19th century onwards a number
of such treaties were adopted. Several countries proposed that
a permanent international body should be established to promote
maritime safety more effectively, but it was not until the establishment
of the United Nations itself that these hopes were realized. Establishment
of different regulations and requirements in different ports or
waters, through national or regional regulation, is potentially
problematic for the shipping industry and global regulation
should be pursued in all aspects of shipping rules.
ENERGY EFFICIENT
TRANSPORT MODE
Shipping is a clean, green, environmentally-friendly
and last but not least an energy efficient mode of transport.
Huge volumes of cargo are transported globally each year, and
shipping is only a small contributor to the total volume of atmospheric
emissions, when compared to other transport modes. Reduction of
harmful emissions from ships and an increase in fuel efficiency
have been achieved over the past decades through enhancements
in engine and propulsion systems efficiency and improved hull
design. Larger ships and better utilization of individual ships
have also contributed significantly to reducing the amount of
energy needed to transport the same unit over the same distance.
COMPARISONS OF
EMISSION FROM
DIFFERENT TRANSPORT
MODES
Table 1
PUBLISHED AIR EMISSION FACTOR RANGES FOR
TRUCK, RAIL, AND MARINE, IN GRAMS/TONNE-KM
|
| Pollutant | Truck
| Rail | Marine
|
|
| CO | 0.25-2.40
| 0.02-0.15 | 0.018-0.20
|
| CO2 | 127-451
| 41-102 | 30-40
|
| HC | 0.30-1.57
| 0.01-0.07 | 0.04-0.08
|
| NO x | 1.85-5.65
| 0.20-1.01 | 0.26-0.58
|
| SO2 | 0.10-0.43
| 0.07-0.18 | 0.02-0.05
|
| Particulate | 0.04-0.90
| 0.01-0.08 | 0.02-0.04
|
| VOC | 1.1 |
0.08 | 0.04-0.11
|
|
| From IMO GHG Study, published in June 2000 as MEPC 45/8.
|
CO2 EMISSION INDEXING
The fifty-third session of the Marine Environment Protection
Committee (MEPC 53), in July 2005, approved IMO's "Interim
Guidelines for Voluntary Ship CO2 Emission Indexing
for Use in Trials" (MEPC/Circ 471). The objective of the
interim Guidelines is to establish a common approach for trials
on voluntary CO2 emission indexing, which will enable
shipowners to evaluate the performance of their fleet with regard
to CO2 emissions. As the amount of CO2 emitted
from a ship is directly related to the consumption of bunker fuel
oil, the CO2 indexing will also provide useful information
on a ship's performance with regard to fuel efficiency.
REDUCTION OF
GREENHOUSE GASES
FROM SHIPPING
Although no mandatory instrument has been adopted by IMO
to cover the emission of greenhouse gases (GHG) from ships, IMO
has given considerable consideration to the matter, leading to
the adoption of Assembly resolution A.963(23)—IMO Policies
and Practices related to the Reduction of Greenhouse Gas Emissions
from Ships (GHG) (see attachment). The GHG issue was agreed
after discussions at a number of sessions of the Marine Environment
Protection Committee (MEPC) as a view was expressed that any reduction
of GHG agreed to in IMO should only apply to Annex 1 countries
(the developed countries) under the United Nations Framework Convention
on Climate Change (UNFCCC) and its Kyoto Protocol, 1997.
The most comprehensive assessment to date of the contribution
made by international shipping to climate change is contained
in the IMO Study on Greenhouse Gas Emissions from Ships published
in June 2000 (MEPC 45/8). This study estimated that ships contributed
about 1.8% of the world's total CO2 emissions and also
states that there is no other mode of transport that has a better
record according to the transport work carried out.
As CO2 emissions are directly linked to the consumption
of fossil fuel, reduction is only possible by reduced consumption
of such fuels. Possible reduction measures identified by the 2000
IMO GHG study:
| — Speed reduction |
| — feasible for all ships |
| — Improved utilization of ships
| | — feasible for all ships
|
| — Reduced port congestion |
| — feasible for all ships
|
| — Improved hull design |
| — feasible for new ships
|
| — Reduced hull friction |
| — feasible for new ships
|
| — Improved propulsion systems
| | — feasible for new ships
|
| — Use of LNG fuel |
| — feasible for new ships |
| — Introduction of alternative power or fuels
| | — feasible for new ships
|
THE KYOTO
PROTOCOL AND
INTERNATIONAL SHIPPING
Article 2.2 of the Kyoto Protocol states that:
"The Parties included in Annex I shall pursue limitation
or reduction of emissions of greenhouse gases not controlled by
the Montreal Protocol from aviation and marine bunker fuels, working
through the International Civil Aviation Organization and the
International Maritime Organization, respectively."
Annex I Parties are those countries listed in Annex I to
the UNFCCC and represent the developed or industrialized countries
of the world.
UNFCCC and its Subsidiary Body for Scientific and Technological
Advice (SBSTA) have since 2002 debated shipping and aviation emissions
under a dedicated agenda item? "Emissions from fuel used
for international aviation and maritime transport", but as
the UNFCCC requires consensus it has been unable to reach any
conclusions. There are no incentives in the Kyoto Protocol for
OECD flag States to encourage their fleets to limit CO2
emission, eg, by switching to natural gas as fuel, as it cannot
be taken as credits in their national inventories.
One of the main elements in the UNFCCC and its Kyoto Protocol
is the "common but differentiated approach" (Annex 1
countries—non-Annex 1 countries). This approach and the
wording in Article 2.2 of the Kyoto Protocol have caused a lot
of discussions at MEPC sessions where non-Annex 1 countries have
argued that it is only Annex 1 countries that are obligated to
pursue limitation or reduction of greenhouse gases from international
shipping. Resolution A.963(23) was adopted in line with IMO's
objectives to find global solutions to all ships engaged in international
shipping. This view was expressed by the Working Group on Air
Pollution at MEPC 49 (MEPC 49/22, paragraph 4.7), namely that
international shipping should operate under a single regime and
that the concept of "no more favourable treatment of ships",
embodied in MARPOL (Article 5(4)) and other IMO Conventions and
instruments should be applied also in the case of climate change.
POTENTIAL OF
EMISSION TRADING
The United Kingdom has submitted documents MEPC 54/4/2 and
MEPC 55/INF.7 on the background for emission trading and the different
possible approaches to introduce such a mechanism for shipping.
MEPC 55 noted that emission trading was one possible operational
and market-based solution, as called for by resolution A.963(23)
when identifying and developing mechanisms needed to achieve limitation
and reduction of GHG emissions from international shipping. According
to the adopted work plan, technical, operational and market-based
methods for dealing with GHG emissions should be considered by
MEPC 56 (July 2007).
UPDATE OF
THE GHG STUDY
The latest GHG debate within IMO was at MEPC 55 (October
2006) where further follow-up to resolution A.963(23) was considered.
MEPC 55 decided to update the IMO GHG Study and agreed that an
update of the study was necessary to give a better foundation
for future decisions and could help to make progress in the follow
up to resolution A.963(23). MEPC 55 further agreed to revisit
the issue of the terms of reference for the update of the IMO
Study at the next session and invited Member States and observers
to submit input to the scope of the update and its terms of reference.
MEPC 55 noted that climate change caused by greenhouse gas
emissions from burning of fossil fuel was a steadily growing concern
for most countries, and that scientists had found more and more
proof of connections. The threat from global warming was far too
serious to be ignored and the shipping industry, although an environmentally
friendly and fuel efficient mode of transport, must take action.
IMO recognized in resolution A.963(23), that the projected adverse
effects of climate change and acidification of the world's oceans
called for the implementation of measures to limit or reduce the
emissions from international shipping which constituted one of
the sources of GHG emissions . MEPC 55 agreed that it should follow-up
all the action items to the Assembly resolution and IMO should
maintain its leading position, to avoid unilateral action either
on a global, regional or national level. MEPC 55 adopted a work
plan with timetable for IMO's future work on reduction of GHG
from ships (see attachment). MEPC should continue to take the
lead in developing GHG strategies and mechanisms for international
shipping and co-operate closely with other relevant UN bodies.
MITIGATION OF
THE IMPACT
OF CO2 EMISSIONS
FROM SHIPS
An option to mitigate the impact of CO2 emissions
from ships is by "offsetting", either through a post-Kyoto
mechanism, through IMO, the bunker industry or another organization
or scheme. A post-Kyoto mechanism could give Annex 1 countries
(industrialized countries) the possibility to offset reduction
of CO2 from ships flying their flag in the same way
as the reduction from land-based sources. A mandatory offsetting
scheme through IMO could, if agreed and adopted by the Member
States, be based on fuel consumption, so all ships would pay a
CO2 "toll" according to their fuel consumption,
and the money collected would be used for CO2 reduction
measures, such as wind farms and planting of forests.
OPERATIONAL AND
MARKET-BASED
METHODS
The next GHG discussion within IMO will take place at MEPC
56 to be held in July 2007. In accordance to the abovementioned
work plan, the main issues during that session will be to consider;
methodology for CO2 emission baseline(s) in terms of
efficiency and the establishment of CO2 baseline(s),
technical, operational and market-based methods for dealing with
GHG emissions and terms of reference for an update of the IMO
GHG Study. IMO continues to work on reducing harmful emissions
from shipping, a transport industry which is vital to world trade
and development. In the pursuit of environmentally sustainable
transport, seaborne trade must be promoted as part of the inter-modal
transportation chain.
CO2 CAPTURE AND
STORAGE (SEQUESTRATION)
The first Meeting of Contracting Parties to the 1996 Protocol
to the London Convention was convened in London (30 October-3
November 2006) and agreed to regulate CO2 sequestration
in sub-seabed geological formations by adopting an amendment to
Annex 1 to the London Protocol (Resolution LP.1(1)). This amendment
entered into force on 10 February 2007 for all Contracting Parties.
This means that a basis has been created in international environmental
law to regulate carbon capture and storage (CCS) in sub-seabed
geological formations for permanent isolation, as part of a suite
of measures to tackle the challenge of climate change and ocean
acidification.
Parties also agreed that guidance informing Parties on the
means by which sub-seabed geological sequestration of carbon dioxide
can be conducted, in accordance with Annex 2 to the Protocol,
and in a manner that is safe for the marine environment, over
the long and short term, should be developed as soon as possible
and will, when finalized, form an important part of the regulation
of sub-seabed geological sequestration of carbon dioxide. Arrangements
have been made to ensure that this guidance will be reviewed for
adoption at the second Meeting of Contracting Parties in November
2007.
CHRONOLOGICAL ORDER
OF SOME
MAIN EVENTS
IN IMO'S
GHG WORK
1. With a view to addressing the issue of greenhouse
gas (GHG) emissions from international shipping, the 1997 MARPOL
Conference convened by the International Maritime Organization
(IMO) adopted Resolution 8 on "CO2 emissions
from ships", inviting:
1. the IMO Secretary-General to co-operate with the Executive
Secretary of UNFCCC in the exchange of information on the issue
of GHG emissions;
2. the IMO to undertake a study of GHG emissions from
ships for the purpose of establishing the amount and relative
percentage of GHG emissions from ships as part of the global inventory
of GHG emissions; and
3. the Marine Environment Protection Committee (MEPC)
of IMO to consider feasible GHG emissions reduction strategies.
2. As a follow-up to the above resolution, the IMO
Study on Greenhouse Gas Emissions from Ships was completed
and presented to MEPC 45 in June 2000 as document MEPC 45/8. This
Study estimated that ships contributed about 1.8% of the world's
total CO2 emissions.
3. In an effort to further address the issue of GHG emissions
from ships, the IMO Assembly adopted, in December 2003, resolution
A.963(23) on "IMO Policies and Practices related to the Reduction
of Greenhouse Gas Emissions from Ships", which:
1. URGES the MEPC to identify and develop the mechanism
or mechanisms needed to achieve the limitation or reduction of
GHG emissions from international shipping and, in doing so, to
give priority to:
(a) the establishment of a GHG emission baseline;
(b) the development of a methodology to describe the GHG
efficiency of a ship in terms of a GHG emission index for that
ship. In developing the methodology for the GHG emission indexing
scheme, the MEPC should recognize that CO2 is the main
greenhouse gas emitted by ships;
(c) the development of Guidelines by which the GHG emission
indexing scheme may be applied in practice. The Guidelines are
to address issues such as verification; and
(d) the evaluation of technical, operational and market-based
solutions.
(a) to consider the methodological aspects related to
the reporting of GHG emissions from ships engaged in international
transport;
(b) to develop a work plan with a timetable; and
(c) to keep this matter under review and to prepare consolidated
statements on the continuing IMO policies and practices related
to the limitation or reduction of GHG emissions from international
shipping.
3. REQUESTS the IMO Secretariat to continue co-operating
with the Secretariat of UNFCCC and the Secretariat of the International
Civil Aviation Organization.
4. Following an invitation by UNFCCC, and as requested
by the MEPC, there has been ongoing co-operation between the Secretariats
of IMO and UNFCCC on the work of GHG emissions from ships concerning
the use of bunker fuel oils in recognition of the Kyoto Protocol
requirements.
5. A report about IMO's work on GHG emissions from ships
was brought to the attention of SBSTA 21 in 2004. Since then the
issue of GHG emission has been considered by each session of the
MEPC.
6. MEPC 53 (July 2005) approved IMO's "Interim
Guidelines for Voluntary Ship CO2 Emission Indexing
for Use in Trials" (MEPC/Circ.471). The objective of
the Interim Guidelines is to establish a common approach for trials
on voluntary CO2 emission indexing, which will enable
shipowners to evaluate the performance of their fleet with regard
to CO2 emissions. As the amount of CO2 emitted
from a ship is directly related to the consumption of bunker fuel
oil, the CO2 indexing will also provide useful information
on a ship's performance with regard to fuel efficiency.
7. The Administrations and the shipping industry are
invited to promote the use of the Interim Guidelines in trials
and report the outcome to the MEPC for consideration, taking into
account:
1. operational experiences from trials of the index for
different ship types, as reported to MEPC by the industry, organizations
and Administrations;
2. progress in ISO regarding ship's CO2 performance;
and
3. any other relevant developments.
8. MEPC 54 (March 2006) received the first results from
trials in accordance with the "Interim Guidelines for Voluntary
Ship CO2 Emission Indexing for Use in Trials"
(MEPC/Circ.471) from India. In the meantime, the MEPC noted that
a number of other Member States were also undertaking such trials.
9. MEPC 55 (October 2006) received further information
on trials in accordance with the Interim Guidelines from Germany,
India, Japan, Norway, and the Republic of Korea. MEPC 55 thanked
all those countries for submitting the valuable information, and
invited other countries to take the information into account when
using the Interim Guidelines in their trials.
10. MEPC 55 approved a "Work plan to identify
and develop the mechanisms needed to achieve the limitation or
reduction of CO2 emissions from international
shipping", inviting Member Governments to participate
actively in the work.
11. MEPC 55 considered issuing an update of the "IMO
Study on Greenhouse Gas Emissions from Ships, 2000" and agreed
to consider the Terms of Reference for such an update at its next
session in July 2007.
12. MEPC 55 also agreed to continue and strengthen co-operation
with UNFCCC and ICAO on the work to reduce or limit GHG emissions.
13. The First Meeting of the Contracting Parties to the
1996 Protocol to the 1972 London Convention adopted, on 2 November
2006, resolution LP 1(1) on "Amendments to include CO2
sequestration in sub-seabed geological formations in Annex 1 to
the London Protocol".
February 2007
| 
