MEPC 82: China, Saudi Arabia and the UAE criticise comprehensive impact assessment

The IMO should not base its mid-term measures on the “unconvincing and misleading” conclusions of UNCTAD’s comprehensive impact assessment report, according to a joint proposal from China, Saudi Arabia and the UAE.

PHOTO: Aerial view of the Port of Shanghai in China. Getty Images

Classification society DNV used a well-to-wake (WtW) scope to model GHG trajectories for the comprehensive impact assessment. But the proposal argued that IMO's upcoming mid-term measures should not be based on a WtW framework.

Instead, GHG emission trajectories can be set based on tank-to-wake (TtW) emissions, as only these emissions fall under the purview of global shipping, the countries said.

The proposal contended that the emission reduction trajectories used in DNV’s modelling are “not guaranteed to be practical” in the real world.

According to the proposal, the DNV model assumes unlimited availability of e-fuels and onboard carbon capture and storage (OCCS) to ensure compliant solutions for all ships. However, projected demand for these technologies often far exceeds the estimated supply, particularly by 2030 and 2040.

China, Saudi Arabia and the UAE also called out the comprehensive impact assessment (CIA) report as being overly focused on scenarios involving carbon levies. They pointed out that the report did not model scenarios with a flexibility mechanism but no levy for revenue distribution, simply because it does not generate a large amount of revenue as the levy scenarios."

Instead, any potential revenue distribution mechanism should account for various revenue streams from all proposed measures, including those with a flexibility mechanism but without levies, they advocated. The proposal also recommended that after rewarding ships using low- and zero-emission fuels, a significant portion of the remaining revenue should be distributed primarily within the shipping sector.

This proposal may be discussed at the IMO’s 82nd Marine Environment Protection Committee (MEPC 82) at the end of the month.

By Konica Bhatt

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