Revision of the EU system for monitoring, reporting and verifying CO2 emissions from ships

18-10-2019

This initial appraisal assesses the strengths and weaknesses of the European Commission's impact assessment accompanying its proposals to revise the EU system to monitor, report, and verify CO2 emissions from ships, established by Regulation (EU) 2015/757. The proposal envisages aligning partially the EU system with the system adopted by the International Maritime Organization to monitor and report ship's fuel oil consumption. While the IA clearly identifies the problem – to facilitate the simultaneous application of the EU and IMO systems – its evolution could have been substantiated further. The general objectives identified by the IA are not entirely consistent with the manner in which the problem was defined; furthermore, there are no specific objectives, contrary to the requirements of the Better Regulation guidelines. The operational objective identified is not defined in operational terms. The only two options considered for further assessment, in addition to the baseline, do not appear to be substantially very different from each other, with the third option even being judged artificial by the Commission’s Regulatory Scrutiny Board. Moreover, the IA does not appear to have succeeded in structuring these two options convincingly. The analysis regarding the impacts of the identified options is very succinct. The Commission consulted a wide range of stakeholders, whose views were satisfactorily reported in the IA and were taken into account when considering the policy options. Overall, the IA appears to have taken on board most of the RSB's recommendations. However, the final revision of the IA report does not appear to have quantified the cost savings of the preferred option, as demanded by the RSB, and still contains Option 3, which the RSB had recommended to discard. As the IA does not explain how it has addressed the Board's suggestion regarding Option 3, it is unclear whether any changes were made to it or it was left untouched. Finally, the legislative proposal seems to be substantially consistent with the analysis carried out in the IA.

This initial appraisal assesses the strengths and weaknesses of the European Commission's impact assessment accompanying its proposals to revise the EU system to monitor, report, and verify CO2 emissions from ships, established by Regulation (EU) 2015/757. The proposal envisages aligning partially the EU system with the system adopted by the International Maritime Organization to monitor and report ship's fuel oil consumption. While the IA clearly identifies the problem – to facilitate the simultaneous application of the EU and IMO systems – its evolution could have been substantiated further. The general objectives identified by the IA are not entirely consistent with the manner in which the problem was defined; furthermore, there are no specific objectives, contrary to the requirements of the Better Regulation guidelines. The operational objective identified is not defined in operational terms. The only two options considered for further assessment, in addition to the baseline, do not appear to be substantially very different from each other, with the third option even being judged artificial by the Commission’s Regulatory Scrutiny Board. Moreover, the IA does not appear to have succeeded in structuring these two options convincingly. The analysis regarding the impacts of the identified options is very succinct. The Commission consulted a wide range of stakeholders, whose views were satisfactorily reported in the IA and were taken into account when considering the policy options. Overall, the IA appears to have taken on board most of the RSB's recommendations. However, the final revision of the IA report does not appear to have quantified the cost savings of the preferred option, as demanded by the RSB, and still contains Option 3, which the RSB had recommended to discard. As the IA does not explain how it has addressed the Board's suggestion regarding Option 3, it is unclear whether any changes were made to it or it was left untouched. Finally, the legislative proposal seems to be substantially consistent with the analysis carried out in the IA.