May 9, 2019
The Coalition for Responsible Transportation (CRT) https://responsibletrans.org/fully supports the development of Green House Gas (GHG) reduction goals being developed for international shipping by the International Maritime Organization. CRT, though, expresses its opposition to the proposal advocating for mandated speed restrictions for all types of vessels put forward to the next IMO MEPC 74 meeting. Any use of slow steaming should be done on a voluntary basis through the marketplace between the business interests involved.
GHG reduction regulatory policy should be developed in a balanced manner based on factual analysis that takes into consideration the full end to end supply chain. Without a recognition of the complete supply chain, mandated speed restrictions for all vessels at sea will be counterproductive.
Commenting on the mandated slow steaming proposal, CRT’s Executive Director Stephen Cadden stated: “Global supply chain adjustments to compensate for reduced productivity at sea due to mandated slow steaming could be substantial. Additional vessels, increased inventory carrying costs and changes to land based distribution networks and transport modes to offset lost time are likely. Any speed regulation must look at the supply chain as a whole to avoid moving the challenge from sea to land.”
Policy and regulation should encourage and advance shipping’s pursuit of cleaner technologies and a low carbon future. Mandated slow steaming will have the opposite effect encouraging the continued use of technology and fuels that do not address air quality issues and offer no reduction in GHG emissions.
CRT strongly encourages the development of more efficient vessel technology, alternative fuels (LNG, Biofuels, Others), operational process efficiency and advanced logistics systems capable of reducing the GHG footprint of global supply chains. In CRT’s view, greater focus by the shipping industry on these areas in the immediate term will yield significant, permanent reductions in GHG emissions and local air pollutants.
The Coalition for Responsible Transportation(CRT) https://responsibletrans.org/is a US based a strategic coalition dedicated to enhancing freight flows through US ports and intermodal gateways. CRT has been an advocate for beneficial cargo owners and all sectors of the shipping industry since 2007. Our efforts have resulted in optimizations in cargo transport efficiency, responsible and voluntary environmental standards throughout the supply chain and the support of legislation, where appropriate, that improves economic and environmental competitiveness within partner industries. CRT members represent a wide-range of the US supply chain and include: Amazon, Best Buy, BigLots, BNSF Railway, BTM Holdings, Evans Delivery, GSC Logistics, The Home Depot, HP, Lowe’s, Majestic Realty Co., Marine Repair Services Corp., NFI, Port of Long Beach, Port of Los Angeles, The Port Authority of New York and New Jersey, Profit Tools, Retail Industry Leaders Association, RoadOne, South Carolina State Ports Authority, Southeast Streamline, Target, TOTE, Total Transportation Services, Inc.
Stephen P. Cadden
Telephone: +1 443 791 1948