“The HKSOA urges the European Parliament and the Council of the European Union to reconsider this proposed regulation, which would appear to have been developed prematurely without the proper consideration of all the factors and unintended consequences that may result,” the association said in a statement.
The HKSOA gave four reasons for its opposition to the regulation. First it said that as a global industry and as such regulations need to be global in nature and developed by the IMO.
Secondly it said the EU’s actions would not help the IMO discussions on the issue. “In fact, the EU’s actions could well result in some member States becoming strongly opposed to any such regulation,” it said. Last month the ICS cited potential for it to create problems with countries such as China and India.
Thirdly HKSOA objected to the descriptive text that said shipping was the only mans of transport not included in the Union’s commitment to reduce greenhouse gas emissions. “While this might be correct for the Union (which is not a member of the IMO), this is not correct for the member States,” it said noting the IMO’s Energy Efficiency Design Index (EEDI) and Ship Energy Efficiency Management Plan (SEEMP).
Fourthly it said time was required to develop a fair and consistent metric for measuring emissions. “A simple definition of ‘multiplying the distance travelled with the amount of cargo carried’ will clearly benefit unprofitable and uneconomic diversions to reduce ballast legs, so reducing the efficiency of maritime transport,” HKSOA said.