The International Chamber of Shipping set out its views on three key issues
The International Chamber of Shipping set out its views on three key issues being debated at IMO this week. The Sub Committee on Bulk Liquids and Gases will be continuing its review of MARPOL Annex VI, implementation of the IMO Ballast Water Management Convention, and ship to ship transfer operations.
ICS proposes a new goal-based approach to emissions reduction and calls for a holistic consideration of emission reduction measures. It draws attention to the need to take account of the environmental justification for improvements proposed, and to consider fully the relationship between measures to reduce local air pollution, such as sulphur, and the subsequent implications for CO2/Green House Gas emissions. ICS believes that there should be choice with regard to compliance measures. In addition to discussing reductions in sulphur emissions, the ICS paper makes detailed suggestions about other aspects of the review, including the reduction of emissions of nitrous oxides, particulate matter and volatile organic compounds.
The prevailing view, following extensive debate within ICS Committees, is that IMO should focus on the environmental outcome required, but should encourage different ways of achieving the agreed emission reduction goals. Technical innovation certainly needs to be stimulated but, where regulation requires technical solutions, it should be established that proven and robust technology does in fact already exist. Above all, any new regulations should be aimed at delivering an overall net environmental benefit. ICS does not wish to solve one problem by creating another. Methods for reducing sulphur emissions should not inadvertently lead to an increase in greenhouse gas emissions, for example, by generating additional CO2 from oil refineries.
Meanwhile ICS says it is “trying to broker a solution to an impossible situation confronting shipowners currently placing orders for new tonnage”. Under the terms of the IMO Ballast Water Management (BWM) Convention, adopted in 2004, new ships delivered in 2009 will be required to be fitted with special treatment equipment to eliminate unwanted marine micro–organisms. This will be instead of deep sea ballast exchange at sea, which is currently the only management option available to most existing ships. The problem, however, is that there is still no technology that is officially proven to comply with the required IMO standards.
ICS notes that many governments are sympathetic to the position of ICS, which is that the date of introduction of the new treatment methods should be suspended until the technology has been approved. However, because of legal complexities, any decision about the date has been delayed until July. ICS says it has been trying to find a practical solution and has submitted text for a possible IMO resolution which would allow Parties to the Convention to defer enforcement of the new equipment requirements until the technology catches up. The ICS proposal will be considered by IMO in April.
Regarding ship-to-ship transfer, ICS and OCIMF are resisting proposals, being led by Spain at IMO, for large sections of the ICS/OCIMF Ship-to-Ship Transfer Guide (Petroleum) to be made mandatory through incorporation in the IMO SOLAS Convention. ICS says: “While the industry is very pleased for SOLAS to refer to such industry guidance, it is important that industry remains in control of the review and updating of its own best practices.”
ICS proposes a new goal-based approach to emissions reduction and calls for a holistic consideration of emission reduction measures. It draws attention to the need to take account of the environmental justification for improvements proposed, and to consider fully the relationship between measures to reduce local air pollution, such as sulphur, and the subsequent implications for CO2/Green House Gas emissions. ICS believes that there should be choice with regard to compliance measures. In addition to discussing reductions in sulphur emissions, the ICS paper makes detailed suggestions about other aspects of the review, including the reduction of emissions of nitrous oxides, particulate matter and volatile organic compounds.
The prevailing view, following extensive debate within ICS Committees, is that IMO should focus on the environmental outcome required, but should encourage different ways of achieving the agreed emission reduction goals. Technical innovation certainly needs to be stimulated but, where regulation requires technical solutions, it should be established that proven and robust technology does in fact already exist. Above all, any new regulations should be aimed at delivering an overall net environmental benefit. ICS does not wish to solve one problem by creating another. Methods for reducing sulphur emissions should not inadvertently lead to an increase in greenhouse gas emissions, for example, by generating additional CO2 from oil refineries.
Meanwhile ICS says it is “trying to broker a solution to an impossible situation confronting shipowners currently placing orders for new tonnage”. Under the terms of the IMO Ballast Water Management (BWM) Convention, adopted in 2004, new ships delivered in 2009 will be required to be fitted with special treatment equipment to eliminate unwanted marine micro–organisms. This will be instead of deep sea ballast exchange at sea, which is currently the only management option available to most existing ships. The problem, however, is that there is still no technology that is officially proven to comply with the required IMO standards.
ICS notes that many governments are sympathetic to the position of ICS, which is that the date of introduction of the new treatment methods should be suspended until the technology has been approved. However, because of legal complexities, any decision about the date has been delayed until July. ICS says it has been trying to find a practical solution and has submitted text for a possible IMO resolution which would allow Parties to the Convention to defer enforcement of the new equipment requirements until the technology catches up. The ICS proposal will be considered by IMO in April.
Regarding ship-to-ship transfer, ICS and OCIMF are resisting proposals, being led by Spain at IMO, for large sections of the ICS/OCIMF Ship-to-Ship Transfer Guide (Petroleum) to be made mandatory through incorporation in the IMO SOLAS Convention. ICS says: “While the industry is very pleased for SOLAS to refer to such industry guidance, it is important that industry remains in control of the review and updating of its own best practices.”
