Oil Companies International Marine Forum
OCIMF
The Oil Companies International Marine Forum (OCIMF) is a voluntary association of oil companies having an interest in the shipment and terminalling of crude oil and oil products.
ID: 105222814108-05
Lobbying Activity
Response to Revision of the Shipping MRV Regulation
18 Jul 2017
Oil Companies International Marine Forum (OCIMF) would like to thank the Commission for the opportunity to comment on the ‘Revision of the Shipping MRV Regulation’. OCIMF supports and welcomes this step to fully align the EU scheme with the IMO. OCIMF was a member of the ESSF MRV working group and in this forum highlighted key concerns regarding the lack of alignment between the EU and IMO system.
OCIMF represents the maritime interests of oil companies, both charterers and owners, and we recognise that this sector is responsible for about 20% of CO2 emissions from international shipping. OCIMF supports the need to reduce greenhouse gas (GHG) emissions; however, OCIMF does not believe that the EU MRV system will result in the expected fuel reduction of 2%:
-Tankers and gas carriers are generally globally traded and thus under the EU system, only a subset of data will be reported. This means that the data will not reflect the annual performance, and indeed could be limited to one voyage thus making the data unreliable and unsuitable as a basis for operating decisions.
-Performance data gaps, should they exist, can already be addressed via third party websites.
-OCIMF’s mission prevents it from taking a commercial position on issues. OCIMF notes however that a significant barrier to improving energy efficiency in the tanker sector is the “split incentive” which is not addressed via an MRV system. The EU Commission recognized the importance of the split incentive as a barrier to reducing GHG emissions in shipping (reference COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS, Integrating maritime transport emissions in the EU's greenhouse gas reduction policies, Brussels, 28.6.2013, COM(2013) 479 final). https://ec.europa.eu/clima/sites/clima/files/transport/shipping/docs/com_2013_479_en.pdf
OCIMF is committed to a global system to monitor CO2 emissions and fleet efficiency as a function of transport work. This will be a key component of a shipping GHG reduction strategy: to understand the size of the problem and monitor changes. OCIMF is strongly in favour of one common global system for several reasons:
•Recognising international shipping is a global industry governed by the IMO
•Reduce the administrative burden and confusion for all parties involved
•Equal comparison / platform for all vessels trading within EU or globally (outside EU)
•Only have one data set as a basis for policy/regulatory decisions. Looking ahead the focus should be on how to reduce emissions, not arguing which data set is a more accurate reflection of shipping emissions.
For one common system, several changes are needed:
•OCIMF recognise the disadvantages of using a proxy (design DWT) instead of actual cargo when analysing data; however, OCIMF does question the usefulness of collecting EU MRV data on cargo carried when this data is not available globally.
•The EU MRV system treatment of “in-port” use is very complex and very difficult to implement and in some cases requiring operational changes. Alignment with a global system hopefully will reduce this burden.
•Regarding publication of performance data, OCIMF would prefer to only publish annual data covering all operations and not to also report a subset of EU data. This means it would not be necessary to identify cargo ports relative to EU voyages thus reducing the overhead. OCIMF suggests an option to provide either global or EU data (and not global and EU data) for publication.
With the global data collection system approaching finalisation OCIMF hopes that the EU will follow through with the review to ensure alignment between the two systems.
Read full responseMeeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)
21 Apr 2015 · Meeting with Oil Companies International Marine Forum (OCIMF)