The Port of Rotterdam has responded to a public consultation of the European Commission (DG CLIMA) on the revision of the policy on monitoring, reporting and verification of CO2 emissions (EU MRV). The European Commission is in the process of reviewing the existing EU MRV in view of alignment with the global data collection system of the International Maritime Organisation (IMO DCS) and has asked for the feedback of stakeholders on several elements of the EU MRV.
In order to decarbonize maritime transport, the Port of Rotterdam stresses that the European Commission should uphold the transparency requirement of the EU MRV when aligning the system with the IMO system.
Full disclosure of carbon dioxide emissions of ships is an essential first step in any effective GHG reduction measure. Public disclosure of emissions on a “per ship” basis would expose their relative carbon efficiencies as well as their total contributions to such emissions and this could help trigger the necessary improvements in fuel efficiency of ships. Moreover, transparent and accurate information about GHG emissions from ships can be used by shippers, freight forwarders, consumers and other players in the logistics chain to compare information and make choices not only based on costs but also on climate impact. Accurate and reliable data on GHG-emissions is also instrumental for properly assessing energy-efficiency measures and stimulating the uptake of low-carbon fuels and propulsion systems.
Publicly accessible information on the reported data emissions of individual ships under EU MRV could potentially also be used as a trusted metric in environmental incentive schemes used by European seaports. Ports that make use of environmental incentive schemes can use the reported information to award ships that become more sustainable and - on a more detailed level than currently available - determine the level of rebates for ships that call at EU ports. A prerequisite is that the information reported is accessible for port authorities and the data is of high quality and reliable.
Alignment of the two systems in terms of reporting formats and verification methods is the most optimal solution in our view, with the transparency requirement of the EU MRV maintained. With regard to potential market distortions due to the disclosure of commercially sensitive information, the operational efficiency metric of EU MRV should be aligned with the parameters of the IMO data collection system.