Anti-Trust/Competition Law
Compliance Statement
INTERTANKO’s policy is to be firmly committed to maintaining a fair and
competitive environment in the world tanker trade, and to adhering to all
applicable laws which regulate INTERTANKO’s and its members’ activities in
these markets. These laws include the anti-trust/competition laws which the
United States, the European Union and many nations of the world have
adopted to preserve the free enterprise system, promote competition and
protect the public from monopolistic and other restrictive trade practices.
INTERTANKO’s activities will be conducted in compliance with its Antitrust/Competition Law Guidelines.
IMO GHG REGULATIONS
COUNCIL Meeting
London
5. October 2011
GHG – EEDI/SEEMP Regulation
• Part of the MARPOL Convention
• EEDI applies to new: Tankers, Bulk Carriers, Gas
Tankers, Container Ships, General Cargo Ships,
Refrigerated Cargo Carriers
• EEDI does not apply to: ships with diesel-electric
propulsion, turbine propulsion or hybrid propulsion
systems
• New tankers (> 400 GT):
– building contract from 1 January 2013 and
– delivery not later than 30 June 2015
• SEEMP required for ALL ships
20.0
EEDI IMPLEMENTATION
18.0
Attained EEDI < Required EEDI value
16.0
14.0
EEDI
12.0
PHASE 0 (2013 – 2014) – IMO Reference Line
PHASE 1 (2015 – 2019) – 10% lower than IMO Ref Line
PHASE 2 (2020 – 2024) – 20% lower than IMO Ref Line
PHASE 3 (2025 & after) - 30% lower than IMO Ref Line
10.0
8.0
6.0
Required EEDI = IMO Reference Line x Y%
4.0
2.0
attained EEDI
X
0.0
DWT
GHG – EEDI/SEEMP Regulation
• Administrations may delay the
enforcement of EEDI application with up
to 4 years. (i.e. building contract before 1
January 2017)
• Parties to MARPOL Annex VI have
agreed to allow ships with such waivers
to call at their ports
IMO Guidelines
• Method for EEDI calculation
• Survey and Certification of the EEDI
• Interim Guidelines for determining
minimum propulsion power and speed to
enable safe manoeuvring in adverse
weather conditions
• EEDI for larger size segments of tankers
and bulk carriers
• Cubic capacity correction factor for
chemical tankers
CONCLUSIONS
• INTERTANKO policy achieved
• Phase 0: many designs are compliant
• Phase 1: first 2 years possible waiver at
owner’s request & Flag agreement
• No waivers from 1 January 2017
• Lower speed design – easiest “solution”
• Intent of EEDI: better designs ~ less fuel
necessary to transport same amount of
cargo at the same speed as today
COUNCIL INVITED TO
• Consider INTERTANKO’s views on options to
waive the application of EEDI up to 4 years
• If not in favour of such waivers – membership
criterion? (e.g. all tankers contracted from 1 Jan
2013 EEDI compliant)
• Whether INTERTANKO may express any view with
regard to use of lower design speed as means of
compliance
RECOMMENDED INTERTANKO POSITION:
1. INTERTANKO welcomes the adoption by IMO of
amendments to the MARPOL Convention mandating
energy efficiency measures (EEDI/SEEMP regulations)
on ships.
2. INTERTANKO believes that:
a) In the implementation of the EEDI requirements, there should
be a “level playing field” and that the EEDI requirements
should apply equally to all applicable ships on the same
effective date
b) Compliance with EEDI should focus on improved hull design,
propulsion efficiency and energy optimisation, rather than
predominantly on reduced speed designs
c) Any measures taken to comply with EEDI shall not jeopardise
nor have an adverse effect on the safety of the ship
MARKET BASED MEASURES
COUNCIL MEETING
London
5. October 2011
QUESTIONS TO COUNCIL
• Would INTERTANKO see any justification
for a MBM?
• No matter justified or not, should
INTERTANKO support/be involved in
development of the MBM legislation?
• If involved in IMO MBMs, which model
should be supported?
• Alternatively, should a “fund free”
alternative be supported? i.e. direct
targeted emissions reduction from ships
in operation
MARKET BASED MEASURES &
ONE ALTERNATIVE
• Nine MBM proposals + one alternative
• The possible runners up:
– International GHG FUND (Denmark)
– Emissions Trading Scheme (Norway; UK;
Germany and France) – EU ETS !!
– Vessel Efficiency Incentive Scheme (EIS)
(Japan/WSC)
– Mandatory CO2 emission cut targets through
technical and operational measures
(Bahamas)
GHG FUND
ETS
MARKET
SE LLING
IMO GHG
FUND
BUYING CREDITS
UNFCCC
SHIP
SHIP
IMO/ETS
GHG FUND
•
•
•
•
•
centralised system
CO2 credit vs. Levy
sets a target
ship not trading CO2
better predictability
of costs
• no guarantee against
increase levy levels
• Charterers involved
• World Scale
ETS
• sets a target
• credits up to the cap
– free or auctioning
• additional credits –
open market ( cap)
• ships trade
• “good ships” can sell
• no international
market
• EU market very small
• cruise lines like ETS
VESSEL EFFICIENCY INCENTIVE SCHEME (EIS)
No fee for ships meeting or
exceeding applicable standard
Fee applied if not meeting standard =
($Y/t fuel) x total tons of fuel
Y = f (Δ) from the standard
CO2 emissions cut targets
• Technical and operational measures only
• No penalties to pay, no rewards to be
given, no funds to be collected
• New ships (EEDI compliant)
Delivered
Cut
< 2 years from
rule enforcement
> 2 years from rule
enforcement
20%
25%
• Existing ships – targeted reductions
Age (years)
Cut
Up to 15
15 – 20
20 - 25
25+
20%
15%
10%
5%
• No compliance – no trade
EIS
• direct reductions
• rewards efficiency
• EEDI relevant for
operational efficiency?
• VA not accounted for
• slow steaming only if ME
derated
• difficult to establish
target cut levels
• limitation in using EEOI
• fee level (improve or
pay?)
• monitoring/reporting
TARGETING
• measures actual GHG
emissions
• targets each ship
• no fund collection
• Virtual Arrival & slow
steaming will count
• caps ship’s activity
• ships stop trading?
• difficult to establish
target cut levels
• monitoring/reporting
Trade
CO2 EMISSIONS PREDICTIONS
1800
1,836 MT
+ 111%??
1600
1,425 MT
+ 64%?
979 MT
+25%
1400
1200
Reference point
1000
800
870MT
600
400
200
CO2 mt (increase 3.3%/ year)
CO2 mt (increase 2%/ year)
CO2 mt (actual)*
0
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023
2024
2025
2026
2027
2028
2029
2030
CO2 EMISSIONS (MT)
2000
YEAR
IMPACT ON SHIPPING
•
•
•
•
•
GHG FUND: 5% increased voyage costs*
ETS: 11% increased voyage costs*
MBMs high admin costs –who benefits?
Shipping cannot absorb all cost increase
MBM targets set just to collect funds?
• If the MBM scope is
, limit the cost!
* PwC Study – An analysis of the future impact of carbon regulations
on environment and industry
CONCLUSIONS
• IMO will continue to discuss MBMs
• Choices: (a) collecting funds; (b) direct
measures on ships in operations; or both
• Monitoring/verification of CO2 emissions
from each ship would be necessary
• Shipping fuel consumption: not known!
• Shipping lacks mechanism for proper
recording of performance in operations
• Lack of such allows other parties to
initiate ship indexing
CONCLUSIONS
• Class Societies developing models to
assess/measure environmental efficiency
• Ports’ and charterers’ various Indexes
• Others (e.g. CWR) ship index calculators
• Shipowners may consider action
• Ships in operations (pre- & post-EEDI)
would need to evaluate, demonstrate and
report their energy efficiency
• Ships have necessary data (from
SEEMP/EEOI, SOx, NOx and VOC)
QUESTIONS TO COUNCIL
• Is there justification for MBMs?
• If so, which MBM scheme? . . . . . or
• “in operation” indexing?
• Industry indexing model?
• Industry to measure and
report its
?
• If so, what and where to report?
• Please, discuss and decide !
RECOMMENDED INTERTANKO POSITION:
• An MBM is not justified at this time. The
industry is already incentivised by high fuel
prices
• If an MBM should be required, then this
should:
–
–
–
–
be implemented through an international regime
be simple to enforce and to monitor
drive the right behaviour
provide sufficient transparency to maintain the
current level playing filed
– not be an unnecessary financial and operational
burden on the industry
RECOMMENDED INTERTANKO POSITION
• Out the current proposals, the GHG FUND
seems to be by far the simplest and most
transparent from a ship owner point of view.
INTERTANKO is not in favour of a trading
scheme to reduce GHG emissions.