IMO's MEPC 72 meeting (photo: IMO)
Tue 24 Apr 2018 – Member States of the International Maritime Organization (IMO), the sister UN agency of the International Civil Aviation Organization (ICAO), have adopted an initial strategy on the long-term reduction of greenhouse gas emissions from international shipping. Reaching a global consensus on climate action has proved as contentious for IMO as it has for ICAO since the two agencies were handed the responsibility for limiting or reducing international GHG emissions from their respective sectors in the Kyoto Protocol adopted in 1997. A dispute between countries on the level of ambition in reducing emissions was resolved at a meeting of IMO’s Marine Environment Protection Committee (MEPC 72) in London attended by over 100 countries. The strategy aims to reduce annual GHG emissions by at least 50% by 2050 compared to 2008 and pursue efforts towards phasing them out entirely. Some believe this now moves IMO ahead of ICAO on a path to fulfil the global climate ambitions of the Paris Agreement.
Both agencies have struggled since Kyoto’s Article 2.2 to achieve a consensus among their member states and reconcile their non-discrimination guiding principle with the UN climate principle of common but differentiated responsibilities by which developed nations are expected to take a bigger share of the burden to reduce GHG emissions. The successor climate treaty adopted in 2015, the Paris Agreement, makes no mention at all of the two sectors, a sign of the difficulties countries encountered in finding a common position.
The first action taken by ICAO States to limit the growth of emissions from international aviation was to agree at their Assembly in 2010 (Resolution A37-19, para 4) to set a global annual average fuel efficiency improvement of the civil aviation sector by an average 2% per year until 2020 and a similar aspirational goal from 2021 to 2050. The resolution qualifies this by noting the goals should take into account the different circumstances, respective capabilities and contribution of developed and developing States to determine how each should voluntarily contribute to the goal.
However, subsequent ICAO climate change Assembly resolutions have noted in their preamble that this “is unlikely to deliver the level of reduction necessary to stabilize and then reduce aviation’s absolute emissions contribution to climate change, and that goals of more ambition will need to be considered to deliver a sustainable path for aviation.”
This contrasts with a more ambitious approach taken previously in 2008 by the aviation industry itself, which set short, medium and long term targets that included improving fuel efficiency by an average of 1.5% per year from 2009 to 2020 (the 0.5% gap with ICAO’s 2.0% is seen as the responsibility of governments, such as air traffic control improvements); stabilising emissions from 2020 with carbon-neutral growth; and an aspirational goal to reduce net emissions from aviation by 50% by 2050 compared to 2005 levels.
In February 2016, ICAO’s environmental protection committee CAEP – which does not meet in open session, unlike IMO’s MEPC – agreed a binding CO2 emissions standard for new aircraft that was formally adopted by the governing 36-State governing Council a year later. The standard will apply to new aircraft type designs from 2020 and to aircraft type designs already in-production as of 2023. Those in-production aircraft which by 2028 do not meet the standard will no longer be able to be produced unless their designs are sufficiently modified.
Due to its complexity and the unknown market-driven responses to the regulation, the contribution of the standard to reducing CO2 emissions from international aviation is so far unclear, although Council President Dr Olumuyiwa Benard Aliu said the standard “guaranteed reductions.” An analysis by the International Council on Clean Transportation (ICCT) showed the standard will on average require a 4% reduction in the cruise fuel consumption of new aircraft starting in 2028 compared to 2015 deliveries, with actual reductions ranging from 0 to 11%, depending on the maximum take-off mass of the aircraft.
By contrast, IMO adopted two mandatory measures in 2011 to improve the efficiency of ships through an Energy Efficiency Design Index (EEDI), which entered into force in January 2013, and the Ship Energy Efficiency Management Plan (SEEMP). The EEDI requires a minimum energy efficiency level per capacity mile for different ship type and size segments, and new ship designs need to meet the reference level for their ship type. The CO2 reduction level (grams of CO2 per tonne mile) is set to 10% in the first phase and to be tightened every five years, which, says IMO, “is expected to stimulate continued innovation and technical development of all the components influencing the fuel efficiency of a ship from its design phase.” The SEEMP is an operational measure that establishes a mechanism to improve the energy efficiency of a ship “in a cost-effective manner.” It also provides an approach for shipping companies to manage ship and fleet efficiency performance over time using, for example, IMO’s Energy Efficiency Operational Indicator (EEOI) as a monitoring tool.
IMO says the measures will lead to significant emission reductions, with up to 200 million tonnes of annual CO2 reductions expected by 2020 from the introduction of the EEDI for new ships and the SEEMP for all ships in operation, with an increase to 420 million tonnes annually by 2030. This represents a reduction of between 10 and 17% in 2020, and between 19 and 26% by 2030, compared with business as usual.
However, an ICCT study released in January 2017 found that although the CO2 intensity of many major ship classes decreased, i.e. they became more efficient, total CO2 emissions from ships increased between 2013 and 2015 as distances travelled grew due to greater demand. “The disconnect between CO2 intensity and total emissions suggests that business as usual improvements in energy efficiency are unlikely to yield substantial reductions in CO2 emissions from ships,” warned the report.
The IMO decision in 2011 had nevertheless been greeted warmly by the then UN Secretary-General and UNFCCC Executive Director as an important outcome and a substantial contribution of the international shipping sector in addressing climate change.
No less heralded was the successful adoption of a market-based measure, after many years of disagreement, by States at the ICAO Assembly in late 2016 to implement the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) from 2020. Not only was this the first global commitment on climate change for an entire industrial sector but all States now have a responsibility for administering and overseeing the scheme, whereas accountability for achieving ICAO’s fuel efficiency improvements and reaching the aircraft CO2 emissions standard falls largely on industry.
According to a number of environmental NGOs that lobby both the shipping and aviation sectors, the new agreement by IMO’s MEPC could be argued to have leapfrogged ICAO in terms of ambition level, principally because it sets a long-term vision to reduce international shipping emissions for the period up to 2050. CORSIA, on the other hand, is a medium-term initiative designed to end in 2035 and despite the word “reduction” in its name, the scheme is intended to neutralise the growth of emissions from the sector rather than reduce them. However, ICAO and industry are keen to emphasise that it is one of a number of measures in place to tackle the issue.
With all efforts having gone into developing and implementing the CORSIA medium-term goal, ICAO has yet to focus seriously on a long-term 2050 target. The only sign that ICAO is working on a plan is a mention in Assembly Resolution A39-2 (para 9) that “Requests the Council to continue to explore the feasibility of a long term global aspirational goal for international aviation, through conducting detailed studies assessing the attainability and impacts of any goals proposed, including the impact on growth as well as costs in all countries, especially developing countries, for the progress of the work to be presented to the 40th Session of the ICAO Assembly [in 2019]. Assessment of long term goals should include information from member States on their experiences working towards the medium term goal.”
There are some, including in industry, who recognise that mapping out a route to achieving a 50% reduction target by 2050 cannot wait until CORSIA is well underway.
The ‘Initial GHG Strategy’ adopted by IMO’s MEPC – after much wrangling between States on levels of ambition – says emissions from international shipping should peak as soon as possible and should reduce by at least 50% by 2050 compared to 2008, “while at the same time pursuing efforts towards phasing them out entirely.” It includes a specific reference to “a pathway of CO2 emissions reduction consistent with the Paris Agreement temperature goals.”
The strategy also envisions at least a 40% reduction in carbon intensity by 2030, while pursuing efforts towards a 70% reduction by 2050, both compared to 2008 levels. It also includes a review of new phases of the EEDI.
As well as setting out a future vision and levels of ambition to reduce GHG emissions, the strategy includes guiding principles and candidate short, medium and long term further measures with possible timelines and their impacts on States. It also identifies barriers and supportive measures including capacity building, technical cooperation and research and development.
Mid-term candidate measures (2023-2030) include an alternative low-carbon and zero-carbon fuels implementation programme that would lead to the long-term (2030+) development and provision of zero-carbon or fossil-free fuels. The mid-term strategy also includes further operational efficiency measures and, significantly in the ICAO context, consideration of market-based measures (MBMs).
MBMs have been considered in-depth by MEPC since 2006 and in 2009 it was agreed overwhelmingly that a MBM was needed as part of a comprehensive package of measures for effectively regulating GHG emissions from international shipping. In 2010, 10 different MBMs were proposed by States and observer organisations. Despite the formation of expert and working groups, studies and impact assessments, little progress has been made since then and no consensus reached.
“IMO did a lot of work on potential MBMs around 2011 but that discussion was shut down after IMO agreed to the Energy Efficiency Design Index,” said Dan Rutherford, Program Director for Marine and Aviation at ICCT, who attended the MEPC 72 meeting and has since published an analysis of the MEPC resolution. “Very little was said at the meeting about what type of MBM might be applied since those are indicated for potential mid-term decisions taking effect sometime between 2023 and 2030. But it's safe to say that most IMO stakeholders are against offsetting in general. CORSIA is often referenced as the type of approach that IMO shouldn’t take.
“IMO’s strategy will require the proverbial policy kitchen sink – tighter design and operational efficiency standards in the near-term; low and zero carbon fuels and propulsion concepts in the longer-term; and legitimate carbon pricing in between – to meet the implied 60 to 70% reductions in GHG emissions this century. There’s no indication at this point that offsetting will be part of the mix.”
According to IMO’s last study of GHG emissions published in 2014, international shipping emitted 796 million tonnes of CO2 in 2012, accounting for around 2.2% of global total CO2 emissions. This is down from a peak in 2008 (the base year for the long-term goals) of 921 million tonnes that represented a 2.9% share of the global total.
ICAO does not issue similar statistics but a CAEP study estimated CO2 emissions from international aviation in 2010 at 448 million tonnes, or around 1.3% of the global total. Forecasts suggest this could rise to between 682 and 755 million tonnes by 2020. CAEP analysis published in the ICAO Environmental Report 2016 (page 17) suggests that even with a contribution from technology improvements and improved air traffic management and infrastructure use, there could be an additional 1,039 million tonnes of CO2 per year by 2050 without a significant replacement of fossil jet fuel with alternative fuels.
IMO mid-range forecasted scenarios suggest that by 2050, CO2 emissions from international shipping could grow by between 50% and 250%, depending on future economic growth and energy developments.
Commenting on IMO’s new commitment to a long-term CO2 reduction strategy, a statement by Kelsey Perlman of Carbon Market Watch on behalf of the International Coalition for Sustainable Aviation, which represents NGOs at ICAO, most of which cover both aviation and shipping sectors, said: “The outcome puts international shipping ahead of aviation – short of the type of ambition required by the Paris Agreement but with a clear, long-term commitment to decarbonise in-sector and peak emissions as soon as possible.
“This decision should light a fire under ICAO, which has been dragging its feet for over a decade on a vision for long-term decarbonisation, arriving only at the mid-term emissions target of carbon-neutral growth from 2020 levels. The agreement on shipping emissions should make people question whether aviation’s emissions should be allowed to grow with no concrete plan to decarbonise.”
Over 100 countries attended IMO’s MEPC 72 meeting in London (photo IMO):
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