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IMO’s work on prevention of air pollution and control of GHG emissions from ships Adoption of mandatory Energy Efficiency measures for ships IMO’s work.

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Presentation on theme: "IMO’s work on prevention of air pollution and control of GHG emissions from ships Adoption of mandatory Energy Efficiency measures for ships IMO’s work."— Presentation transcript:

1 IMO’s work on prevention of air pollution and control of GHG emissions from ships Adoption of mandatory Energy Efficiency measures for ships IMO’s work on prevention of air pollution and control of GHG emissions from ships Adoption of mandatory Energy Efficiency measures for ships Eivind S. Vagslid Technical Adviser to the Secretary-General Secretary-General’s Office IMO Visit to IMO by Norwegian Shipping Forum London 18 October 2012

2 2 IMO – specialised UN agency 170 Member States IGOs and NGOs London headquarters Annual budget £30+ M Secretariat: 300+ staff 50+ Nationalities Secretary-General: Koji Sekimizu, Japan Safe, secure and efficient shipping on clean oceans! 53 treaties covering all aspects of international shipping Design – Construction - Equipment – Operation – Maintenance – Manning Prevention – Response – Liability – Compensation

3 3 Incident Proposal to IMO Committee Committee Discussion, refer to Sub-Committee, Working Group Development of draft Regulation, circular, Code or resolution Adoption of new regulation Idea, development Progress of measures at IMO - example

4 4 Safety and Security SOLAS, STCW, Load lines, COLREGS, SUA Pollution Prevention MARPOL Annexes I to VI, Dumping (LC/LP), Intervention, AFS, [Ballast Water Management,] [Recycling] Response and Reaction SAR, OPRC, HNS Protocol, [Wreck removal] Liability and Compensation CLC, IOPC Fund, Athens, Bunkers, HNS IMO’s Treaty Instruments

5 5 InstrumentDate of entry into force No. of Contracting States / Parties% world tonnage* IMO Convention17-Mar-5817097.16 SOLAS 197425-May-8016299.20 SOLAS Protocol 197801-May-8111796.86 SOLAS Protocol 198803-Feb-0010395.67 Stockholm Agreement 199601-Apr-97118.59 LL 196621-Jul-6816199.19 LL Protocol 198803-Feb-009895.96 TONNAGE 196918-Jul-8215299.06 COLREG 197215-Jul-7715598.71 CSC 197206-Sep-777860.95 1993 amendmentsNot yet in force96.18 SFV Protocol 1993Not yet in force1719.78 STCW 197828-Apr-8415699.22 STCW-F 199529-Sep-12154.75 SAR 197922-Jun-8510362.45 STP 197102-Jan-741723.98 SPACE STP 197302-Jun-771623.33 IMSO 1976 Convention16-Jul-799794.92 1998 amendments31-Jul-014026.91 2008 amendments** Not yet in force**103.65 FAL 1965 05-Mar-6711590.77

6 6

7 Ship emissions one of the last major ship pollutants to be regulated Work started at IMO in the late 1980’s Annex VI adopted in 1997, in force in May 2005, Substantially revised 2005 – 2008 Revised Annex VI in force 1 July 2010  Prohibits ODS in line with the Montreal Protocol  Regulates exhaust gas: NOx & SOx (PM), and cargo vapours from tankers (VOC)  Energy Efficiency covered in new chapter 4 in force 1 January 2013

8 Range of typical CO 2 efficiencies for various cargo carriers Road RoRo/Vehicle LPG Bulk Reefer LNG Crude Container General Cargo Chemical Product Rail 050100150200250300 g CO 2 / ton*km Data: Second IMO GHG Study 2009

9 Source: Fearnley's Review World seaborne trade 1968-2008 Efficiency improvements Fuel Consumption World Fleet

10 Second IMO GHG Study 2009 2007 shipping CO2 emissions 870 million tons Future CO2 emissions:  Significant increase predicted: 200 - 300% by 2050 in the absence of regulations  Demand is the primary driver  Technical and operational efficiency measures will provide significant improvements but will not be able to provide real reductions if demand continues

11 Potential reductions of CO2 emissions

12 12 Examples of efficiency measures: Technical: -Improved hull design and engine efficiency -More efficient propellers and rudders -Larger ships, combination carriers -Reduce installed power (speed) -Wind and solar power -Alternative fuels Operational: -Speed and energy management -Improved routeing & less waiting -Enhanced fleet management and better utilization

13 2030 – abatement potential Average marginal CO 2 reduction cost per option - World shipping fleet in 2030 (existing and newbuilds) Note; abatement potential for individual ship types and size segments vary widely

14 IMO’s work on GHG control and Energy efficiency Work on air pollution prevention from late 1980s In 1991 IMO’s Assembly called for the development of MARPOL Annex VI The 1997 MARPOL Conference’s on Annex VI called for GHG action by IMO First IMO GHG Study published in 2000 (1.8% - rapid and massive growth) IMO’s GHG policy adopted by Assembly 23 in December 2003 (res.963(23)) Development of T&O measures, including EEOI, EEDI, SEEMP: 2000 – 2009 Voluntary application and testing by administrations and industry: (2005) 2009 ---- Basic principles adopted by MEPC 57 (April 2008) Regulatory text developed 2009 – 2011 2011: Adoption of new chapter 4 to MARPOL Annex VI: mandatory T&O measures Second IMO GHG Study 2009 published (2.7%, significant reduction potential) Development of an MBM from 2007, Expert Group reported in 2010 Technical - mainly applicable to new ships – EEDI Operational - applicable to all ships in operation – SEEMP and EEOI Market-based Measures (MBM) – carbon price for shipping, offsetting, incentive, may generate funds

15 Breakthrough at IMO MEPC 62 (11 – 14 July 2011) Mandatory technical and operational measures adopted Mandatory energy efficiency measures Adopted (EEDI and SEEMP) for all ships by inclusion of new chapter 4 in MARPOL Annex VI Further development of supporting guidelines on: Calculation of EEDI EEDI Reference Lines (average of ships built 1999 – 2009) EEDI Survey and Certification Development and implementation of SEEMP EEOI - Energy Efficiency Operational Indicator (MRV tool and benchmark) Work on EEDI formulas for ship types not yet covered Intersessional meeting in January 2012 prepared guidelines

16 New Chapter 4 to Annex VI Regulation 19 – Application -Ship types: bulk carriers, tankers, container ships, general cargo ships, gas carriers, reefers and combination carriers - Covers 71% of international shipping CO2 - 4 years waiver clause for Administrations in need of more time Regulation 20 Attained EEDI Regulation 21Required EEDI Regulation 22SEEMP for all ships (400 GT) Regulation 23Promotion of technical co-operation and transfer of technology relating to the improvement of energy efficiency of ships

17 g of CO 2 emitted cargo capacity x speed Attained EEDI ≦ Required EEDI values Energy Efficiency Design Index - EEDI -10% ships built between 2015 – 2020 -20% ships built between 2020 – 2025 -30% ships built between 2025 – [2030]

18 Required EEDI – Regulation 21 Ship TypeSize Phase 0 1 Jan 2013 – 31 Dec 2014 Phase 1 1 Jan 2015 – 31 Dec 2019 Phase 2 1 Jan 2020 – 31 Dec 2024 Phase 3 1 Jan 2025 and onwards Bulk Carrier 20,000 DWT and above 0102030 10,000 – 20,000 DWTn/a0-10*0-20*0-30* Gas carrier 10,000 DWT and above 0102030 2,000 – 10,000 DWTn/a0-10*0-20*0-30* Tanker 20,000 DWT and above 0102030 4,000 – 20,000 DWTn/a0-10*0-20*0-30* Container ship 15,000 DWT and above 0102030 10,000 – 15,000 DWTn/a0-10*0-20*0-30* General Cargo ships 15,000 DWT and above 0101530 3,000 – 15,000 DWTn/a0-10*0-15*0-30* Refrigerated cargo carrier 5,000 DWT and above0101530 3,000 – 5,000 DWTn/a0-10*0-15*0-30* Combination carrier 20,000 DWT and above 0102030 4,000 – 20,000 DWTn/a0-10*0-20*0-30* Reduction factors (in percentage) for the EEDI relative to the EEDI Reference line

19 19 Ship Energy Efficiency Management Plan SEEMP - Ship Energy Efficiency Management Plan SEEMP - Onboard management tool  Monitoring of emissions and energy performance of individual ships and encouraging continues improvement, using the operational indicator (EEOI) as monitoring tool and benchmarking  Improved voyage planning (Weather routeing/Just in time)  Speed and power optimization (single most important issue)  Optimized ship handling (ballast/trim/use of rudder and autopilot)  Improved fleet and ship management - utilization  Improved cargo handling  Energy management

20 Energy Efficiency Operational Indicator - EEOI MRV tool and benchmark for individual ships  A ship specific efficiency indicator to be used by all ships in operation (new and existing) obtained from fuel consumption, voyage data (miles) and cargo data (tonnes) Cargo Onboard x (Distance traveled) Fuel Consumption in Operation = Actual Fuel Consumption Index Index

21 Guidelines adopted by MEPC 63 (March 2012)  2012 Guidelines on the method of calculation of the attained Energy Efficiency Design Index (EEDI) for new ships  2012 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP)  2012 Guidelines on survey and certification of the EEDI  Guidelines for calculation of reference lines for use with the EEDI MEPC 64 continued work in accordance with the work plan for technical and operational measures for ship types and propulsion systems not covered by the current EEDI formula

22 EEDI and SEEMP Effects Results of analytical study by Lloyds Register and DNV, commissioned by IMO. Document MEPC 63/INF.2 2020 - Combined effects 103 – 200 mill tonnes CO2 10 – 17% reduction over BAU $20 – 80 bill fuel savings

23 EEDI and SEEMP Effects 2030 - Combined effects 237 – 423 mill tonnes CO2 18 – 26% reduction over BAU $90 –310 bill fuel savings Results of analytical study by Lloyds Register and DNV. Doc MEPC 63/INF.2

24 EEDI and SEEMP Effects Results of analytical study by Lloyds Register DNV. Document MEPC 63/INF.2 Combined effects over BAU 2020: 10 - 17% 2030: 18 – 26% [2050: 35 – 41%]

25 Effects of amendments 2020 – combined effects of EEDI and SEEMP 103 - 200 million tonnes of CO2 10 – 17% reduction over BAU US$ 20 – 80 billion annual fuel cost savings 2030 237 - 423 million tonnes of CO2 18 – 26% over BAU US$ 90 – 310 fuel cost savings 2050 706 – 1320 million tonnes of CO2 35 – 41% reduction over BAU Following the adoption, IMO commissioned a study from LR/DNV to estimate the effects, document MEPC 63/INF.2

26 Breakthrough at IMO “This is a landmark for the Organization, which has now made a positive contribution to worldwide efforts to stem climate change and, indeed, a landmark for the international community since, for the first time in history, it has been possible to legislate GHG emission reductions for an entire industry sector” E.E. Mitropoulos IMO Secretary-General “…..this underscores the fact that IMO is best positioned to play a leadership role in addressing greenhouse gas emissions from international shipping.” Ban Ki-Moon UN Secretary-General “I would like to congratulate IMO on this outstanding result….The adoption of mandatory efficiency standards for international shipping is a major step and a substantial contribution….” Christiana Figueres UNFCCC Executive Secretary

27 Capacity building needs  Preliminary assessment presented to MEPC 61  Training of flag State and port State control officers  Training of seafarers in use of new technologies  Instil in the industry an energy efficiency culture  IMO’s Integrated Technical Co-operation Programme for the 2012-2013 biennium allocated funding for the first round of training activities to be undertaken before the entry into force of the amendments

28 Capacity building activities Workshops on CO 2 emissions from shipping  Regional and national workshops on awareness raising and knowledge sharing to enhance global implementation and to enable States to take appropriate actions  Regional and national workshops on energy efficient ship operation for ship and shore based personnel  Regional and national workshops on energy efficient ship design for administrations, academia and industry  Regional workshops on port State control procedures and regulations related to energy efficiency and air pollution regulations under MARPOL Annex VI

29 Technical Cooperation and Capacity Building activities planned for 2011 – 2013 related to EEDI and SEEMP Model course for energy efficient ship operation developed by WMU – Finalized and issued in 2011. To be used for officers training by education institutes and the industry, important for future training Capacity building: $650,000 for training activities (e.g. EEDI verifiers) $200,000 for fellowships and $200,000 for workshops First awareness raising workshop in Durban 24 – 25 November Agreement with KOICA for a South East Asian Climate Capacity Building Partnership in Maritime Transport - $700.000 for 2011 - 2013. First workshop held in Singapore 16 – 18 November 2011 A total of 12 workshops in the region 2012 – 2013 Dialog with donors for a global project: $10 – 40 millions

30 Transfer of technology, technical assistance and capacity building on energy efficiency Transfer of technology covered in many IMO instruments, regulation 23 of new Chapter 4 goes beyond similar obligations in other treaties as it encourages cooperation bilaterally, through IMO or other organizations Transfer of technology outside IMO’s ITCP Work on draft resolution together with the regulatory text with the intention to adopt them as a package, not possible to reach consensus, still pending, needs to be resolved urgently

31 MARPOL Annex VI coverage Number of flag States Gross tonnageTotal World total162957,981,010100% Annex VI countries 64861,474,10189.96%

32 Breakthrough at IMO Adopted by majority as full consensus could not be reached despite strenuous efforts, however no division between developing and developed countries (Non-Annex I/Annex I). The majority of developing countries eligible to vote supported the adoption, including all LDC and SIDS Number of countries Gross tonnageTotal Yes49757,412,53379.06% No597,083,48210.13% Abstain24,877,3960.51% Not present84,448,0760.46% Non-Annex VI countries 9896,506,90910.04% World total162957,981,010100%

33 33 Will the EEDI and SEEMP be enough? They probably would if demand for shipping stopped growing. BUT… -World trade is likely to keep increasing -Emerging economies generate need for shipping -Developing countries depend on sea transport for development So, the reductions achieved by EEDI and SEEMP may be offset by increase in world trade and need for sea transport That’s why we need a market-based measures

34 Market-based reduction measures – MBM An MBM under IMO would serve two main purposes An economic incentive for enhanced energy-efficient both trough design and operation (in-sector reductions) Off-setting in other sectors (out-of-sector reduction) 10 MBM proposals by governments and NGOs under review Charges, ETS, Efficiency based, Incentive Schemes, Rebate Mechanism Three main streams: GHG Fund: Offsetting above a target line ETS: 100% auctioning (global/national) - remaining proceeds: R&D, TC, improve port/maritime infrastructure in developing countries, Climate Finance Efficiency based (EEDI): Closed trading of credits

35 MBM Expert Group established by MEPC 60  The analysis of the proposed MBM addressed, inter alia: Environmental effectiveness, cost-effectiveness and potential impact on trade and sustainable development Incentives to technological change and innovation Practical feasibility and the need for technology transfer to and capacity building within developing countries, mobilizing climate financing Relation with other conventions (UNFCCC, Kyoto Protocol and WTO) and compatibility with international law and IMO’s regulatory framework Additional administrative burden and legal aspects for National Administrations The potential additional workload, economic burden and operational impact for individual ships, the shipping industry and the maritime sector

36 MBM Expert Group established by MEPC 60 Developed methodology to asses, inter alia, possible impacts on end consumers and selected industries, in particular in developing countries, and analyzed 10 MBMs proposed by Governments/ NGOs Selected commodities and trades: Iron ore (Dirty Bulk) – Crude oil ( Tankers) – Grains (Clean Bulk) – Clothing and furniture (Container) Assumptions and growth scenarios: Size and composition of world fleet – growth scenarios (IPCC A1B: 1.65% and B2: 2.8%) – fuel and carbon prices – uptake of technology – etc. Elasticity estimates of freight rate to fuel price increase: SourceClean BulkDirty BulkTankerContainer IMO (MBM-EG)0.250.9590.3240.116 UNCTAD- – 0.36 OECD0.28---

37 Nautical distance weighted by bilateral trade MBM-EG concluded that those countries most affected would be those furthest away from their trading partners CerealsOresCrude OilManufacturedImpact 0.16% 11%20%13%5% Ad valorem maritime transport cost Australia Ad valorem maritime transport costs for Chile CerealsOresCrude OilManufacturedImpact 0.26% 27%20%6%5% Average global increase in freight costs equal to a 10% fuel price increase by introducing MBM Clean BulkDirty BulkTankerContainer 2.7%9.8%3.0%2.0%

38 Impact Study by MBM-EG Cost pass-through range from 10% cent to over 100% - Great variations between different trades, e.g., ore/containers Product market Cost pass- through (%) Product market Cost pass- through (%) Wheat South Africa 10–40 Iron ore China* 52 Wheat Kenya50–75Furniture EU60–90 Wheat Algeria 50–75Apparel EU10–40 Barley China10–25 Crude oil South Korea* 111 Rice Philippines 5–20 Crude Oil US* 73 Maize Saudi Arabia 90–100 Shipping market Vivid Economics estimates (average for all routes) UNCTAD estimates Panamax grain0.19N/A Capesize ore0.961.00 Containers0.120.19-0.36 VLCC0.370.28

39 Emission reductions in 2030 Emission reductions in 2030 Modelled emission reductions across various scenarios SECTVESBahamasGHG Fund LISPSLETS (Norway France) ETS (UK) RM Mandatory EEDI (Mt) 123 - 299 123 - 299 123 - 299* MBM In sector (Mt) 106 - 142 14 - 45 1 - 31 32 - 153 29 - 119 27 - 114 27 - 114 29 - 68 MBM Out of Sector (Mt) 152 - 584 190 - 539 190 - 539 124 - 345 Total reductions (% BAU) 19 - 31% 13 - 23% 10 - 20% 13 - 40% 3 - 10% 2 - 8% 13 - 40% 13 - 40% 13 - 28% Potential supplementary reductions (Mt) 45 - 454 104 - 143 232 - 919 917 - 1232 696 - 870 187 - 517 * Included if the mandatory EEDI is adopted by the committee

40 Potential climate change financing* Potential climate change financing* Modelled “remaining proceeds” across various scenarios MBM2020 ($ billion)2030 ($ billion) GHG Fund2- 54-14 LIS6-3210-87 PSL24-4340-118 SECT00 VES8-415-18 ETS (Norway, France)17-3528-87 ETS (UK)00 Bahamas00 RM10-1317-23 * Excludes financing of out-of-sector emission reductions

41 Impacts on consumers depend on stringency of MBM, e.g. the carbon price, if it is equal to a 10% increase in fuel price, it means a 2 – 10% increase in transport costs and an increase of 0.0 – 0.2% on end prices Trading distances - Market share Domestic Domestic production - Value-to-weight ratio Impacts on developing countries w Impacts on developing countries will vary by country independent of level of economic development. As a result, developing countries, especially SIDS and LDCs, should not be treated as a collective bloc in assessing impacts MEPC (65) will continue work on MBMs and on further impact studies with a view to select a suitable instrument in 2015 Impacts of an MBM – Conclusions:

42 The needs and circumstances of developing countries in the context of climate finance The needs and circumstances of developing countries in the context of climate finance There will be impacts from introducing and MBM, but they will be dwarfed by increases in energy and food prices Compensating affected consumers and industries cent by cent is not possible, a workable proxy is needed An MBM is intended to drive behavioural change – any compensation will undermine this purpose To use 25 – 40% of revenues to compensate all developing countries by the same key will deprive the most vulnerable countries/peoples for large climate finance opportunities A targeted approach needed where only those most affected will be compensated (threshold/GDP per capita)

43 IMO’s MBM impact study to continue Emissions (Mt) Costs ($billion) Seaborne Imports ($billion) Costs/Imports (%) 87017.49.3930.19% MEPC 65 (May 2013) will continue work on MBMs and on further impact studies, selection of instrument 2015 AustraliaChile 0.16%0.26% Impact on import costs = 10% fuel price MBM cost in relation to world imports

44 44 IPCC Fourth Assessment Report (FAR) - A 1ºC to 2  C increase in temperature above 1990 levels will place many unique and threatened systems, including many biodiversity hotspots, at significant risk. - A global mean temperature increase of more that 2  C will lead to increasing risk of species extinction and climate havoc -The CO2 concentration must not exceed 450 ppm to keep the global warming within 2  C above 1990 level by 2100 To avoid this, CO 2 emissions must peak within 10 – maximum 15 years What is the consensus view of the world’s most eminent scientists?

45 The World’s challenge: Increasing CO 2 concentrations Today 2005 Expected in 2100 Source: IPCC FAR 2007

46 46 What is the world community doing? First step: Adoption of the United Nations Framework Convention on Climate Change (UNFCCC) in 1992. - Aimed at stabilizing atmospheric concentrations of greenhouse gases to avoid “ dangerous anthropogenic interference ” with the climate system. Second step: Adoption of the Kyoto Protocol in 1997 - Commits developed countries (Annex I Parties) to reduce their overall emissions by an average of 5.2% below 1990 levels between 2008-2012. Third step: Bali Action Plan – Copenhagen Accord – Cancun Agreements – Durban Platform (2011) - Universal legal treaty covering all parties, to be adopted by 2015 and in force by 2020

47 47 UNFCCC debate on allocation of emissions from international shipping 1992 - 1997 1No allocation 2Proportional to national emissions 3Fuel sales 4Nationality of company 5Flag 6Route of vessel 7Route of cargo 8Country of origin of cargo 9Emissions in territorial waters Kyoto Protocol Article 2.2 “The Parties included in Annex I shall pursue limitation or reduction of emissions of greenhouse gases not controlled by the Montreal Protocol from … marine bunker fuels, working through … the International Maritime Organization, …”

48 Flag StatesNumber of shipsGTDW Annex I33.4%26.1%22.82% Non-Annex I66.6%)73.9%77.18% Distribution of the world fleet March 2008 ships above 400 GT Article 1(b) of the IMO Convention Encourage removal of discriminatory actions … promote the availability of shipping without discrimination … not be based on measures designed to restrict the freedom of shipping of all flags..;

49 Shipping under UNFCCC How should the balance between the basics principles under the two conventions be expressed in the new treaty text (UNFCCC and its fundamental CBDR principle, and on the other hand, the IMO constitutive Convention with its non discriminatory approach)? Should the new UNFCCC treaty state how revenues from a market-based instrument for international shipping under IMO should be distributed and used (climate change purposes in developing countries)? Should a reduction target be set for international shipping, and if so, what should the target be and should it be set by UNFCCC or IMO? No text on international shipping in the Durban outcome other than to continue address the issue Consultations in UNFCCC is slow and has not lead to an agreed text as there are three challenging obstacles:

50 Links with and effects on UNFCCC negotiations As the regulations address ships and not States, and as they do not impose any reduction obligations, quantified or otherwise, on States, as well as the fact that the cost of introducing EEDI/SEEMP will be borne by the industry, there are no incompatibility issues with UNFCCC Kyoto Protocol’s Article 2.2 is still interpreted differently by Parties Did adoption of mandatory T&O by MEPC 62 settle the issue? Disbursement of revenues from an MBM for international shipping under IMO is seen by many as a way to accommodate both sets of principles under the two conventions: - CBDR under UNFCCC and non-discrimination under IMO An MBM for international shipping could be a predictable source to the Green Climate Fund and thereby facilitate the UNFCCC negotiations

51 Climate Finance under UNFCCC The Copenhagen Accord noted the need for climate finance $30 billions annually 2010 – 2019 and $100 billions annually from 2020 The AGF report highlighted international shipping as a suitable and predictable source for climate change funding. $ 3 – 8 billions from international shipping – work should continue in IMO The Cancun Agreements agreed a process to establish the Green Climate Fund which was formally established in Durban and made operational by 2012 under the World Bank, process to identify funding sources in 2012 G-20 requested WB/IMF to explore potential sources Report to be considered by Ministers of Finance early November for submission to Durban. Elaborates on possible approaches but focuses on taxation not on the combined effect of an MBM: reduction and finance

52 Durban outcome affecting IMO’s work Reported in MEPC 63/5/5 The mandate of AWG-LCA extended by another year International transport part of mitigation under Sectoral Approaches Seven options for text on international transport in new treaty or COP decision Establishment of the Green Climate Fund Work programme under LCA to identify sources (public and private) Several proposals to use international shipping as source (AGF and G20) Direct links with IMO’s MBM work – proposed text on “no net incidence” Agreement on Carbon Capture and Storage as CDM Sub-seabed carbon storage regulated by the London Protocol

53 Summary - IMO’s GHG Work Mandatory technical and operational measures adopted in July 2011 – in force 1 January 2013 Important step - Energy efficiency standard for new ships, operational measures for all ships - Significant reductions MBM for international shipping under IMO Continued development - Possible adoption of treaty in 2015 Climate Finance and the Green Climate Fund may be the key to unlock the UNFCCC/IMO deadlock Application to all ships via IMO is the only way to raise revenues from international maritime transport (precedence in IOPC)

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