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The International Association of Independent Tanker Owners

INTERTANKO

INTERTANKO has been the voice of independent tanker owners since 1970.

Lobbying Activity

Response to Revision of the Energy Tax Directive

30 Mar 2020

General comments - In recognising the challenges posed by the climate change, INTERTANKO Members are engaged as individual companies as well as Members of INTERTANKO in initiatives to find solutions for reducing and eventually for phasing out the GHG emissions from shipping. Since this is a global climate challenge, it has to be addressed at a global level. Therefore, INTERTANKO strongly advocates that policy and actions are taken and agreed by IMO. The IMO Initial Strategy for Reduction of GHG emissions is ambitious and imposes concrete and challenging targets. We believe it will be contra productive to develop now local and regional regulations for the international shipping. In order to achieve the IMO targets, the shipping industry, particularly ship owners and operators need to invest large resources and efforts for solutions that result in actual GHG emissions reductions. When such solutions are available, one may consider the need for additional measures to incentives/accelerate adopting/phasing-in of such solutions. A local/regional tax imposed now, when shipping has no alternatives available, would only increase operational costs and may interfere with the general efforts for constructive and efficient measures. A – Context - It is stated in #1 under “Problem the initiative aims to tackle” that tax exemptions on fuels used by the maritime transport "increases the fragmentation of the internal market and in particular distorts the level playing field across the involved sectors of the economy" (distortion is related to land transportation). We will question this line of argument. Transportation of goods at sea is by far more climate friendly. The fuel consumption per transport work by ships is a fraction compared with the fuel used by the road transportation. To our recollection, the Commission stated several times the need to encourage moving more goods by ships rather than by road. The statement quoted seems to indicate the contrary. B – Objective and Policy Options. #2 – Sectoral tax differentiation – The intent of the policy described is not very clear, particularly with the intent of the harmonisation between ETS and the two Directives mentioned. Is it the intend to have a common taxation level across all EU MS borders on all fossil fuels? If exemptions and reductions apply, should these also be the same in all MS? These might be challenging tasks as financial measures have to be mandated to all MS C – Preliminary Assessment of Expected Impacts – A local/regional measure imposed on an international trade activity will always generate impacts. Taxation will make maritime fuels more expensive at EU ports. This can generate two type of consequences. (A) Ships will plan to avoid purchasing fuels in EU ports. The economic impact would result from a decrease of revenues for local EU based fuel suppliers. This might also generate social impacts. (B) Ships will purchase fuels at the EU ports but the price of doing this service will go up. This scenario would generate a mixed economic and social impact on the local communities. It is difficult to predict the level of such impacts with no more concrete data but it is no doubt that the mentioned impacts need to be considered. It is also difficult to appreciate the environmental impact. This would be a function of the amount of fossil fuel still purchased at the EU ports. Since there are no concrete good alternatives for sea going ships at this point in time, it is questionable that a taxation would bring an environmental benefit in terms of actual GHG emissions reductions. D – Evidence Base and Data Collection – we will encourage EC to consider the MRV data and the actual share of shipping as compared with the total land based GHG emissions in the EU MS. Taking into account scenarios (A) and (B) above, one should be able to make an assessment of right choice of priorities for regulatory developments addressing the EU MS related GHG emissions reductions.
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Response to Shipping Emissions Verification and Accreditation

26 Aug 2016

AA) Article 12 of the draft delegated regulation on the verification and accreditation of verifiers pursuant to Regulation (EU) 2015/757 suggest to mandate that the verifier develops a "verification plan" and a "data sampling plan". As member of the ESSF sub-group on Verification and Accreditation, I remember the group concluded that there should be no provisions to require a Verification Plan. I do not recall any discussion about a "data sampling plan". It was agreed that these should not be mandated but left with the Verifier's own procedures. The reasons: (1) Accreditation of the Verifiers will be done in accordance with EN ISO 14065 which already stipulates internal processes which auditors should follow conducting audits and verifications. (2) If the Regulation mandates the existence of such plans, the question is who will check / control whether these plans exist? According to the MRV Regulation, the Verifier will not submit to the Commission their verification plans but the results of the verification process. Concluding, we suggest to remove the provisions of the proposed Article 12 as not justified. They reflect the normal procedures carried out by accredited auditors. If such plans are mandated by regulations, it means lack of confidence on accredited auditors but also imply the need of some sort of validation/check which add unnecessary bureaucracy and costs. BB) "Independent Reviewer" - It is within the norm of a verification/auditing company to conduct an internal review of their activity reports. We find totally unnecessary that the Regulation needs to mandate and introduce a provision on what is part of the professional activity of a Verification company. The Verification company's internal procedures, including an internal review should be acknowledged during the accreditation process. If mandated by the Regulation, an "independent review", even if it is an "internal review" it comes out as a separate activity which increases the cost to the customer. To be more explicit, it will mean that each final report on each ship (including each report on sister ships and each report on ships of similar type and same size) of the same company needs an "independent review". We cannot understand the logic of such a provision and suggest to be removed it as unnecessary.
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Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc) and ADS Insight

10 Feb 2015 · Meeting Ship Safety needs