No e
e
7
Da ish No
-Pape
o the o sultatio o the e isio of
the poli y o
o ito i g, epo ti g a d e ifi atio of
CO e issio s f o
a iti e t a spo t
Denmark appreciates the effort to align the two sets of international rules on monitoring, reporting and
verification of CO2 emissions from maritime transport, and the Danish Government welcomes the
oppo tu ity to o
e t o the Co
issio ’s pu li o sultation
on this matter.
The Danish Government finds it positive and relevant that the Commission has initiated a process to align
the MRV-regulation with the IMO DCS-regulation.
As the maritime transport is responsible for approximately 2.5 % of global GHG emissions, Denmark finds it
important to monitor and report the GHG emissions from the sector in order to establish relevant and
ade uate easu es to edu e the se to ’s GHG e issio s i the lo g u a d to e su e that the se to
contributes to achieving the long-term goals of the Paris Agreement. The measures should contribute to
the global goal of GHG reductions and should be applied in a non-discriminatory manner to all ships,
regardless of their flag.
To ensure a reasonable administrative burden, Denmark is in favour of aligning the one system rather than
two (as is currently the case with MRV and IMO DCS) and appreciates the good work that has been carried
out in this regard.
Denmark supports a system that will drive forward the development of a green maritime sector, which
should also focus on energy efficiency in the maritime transport sector. In that context, Denmark finds it
ele a t that p o isio s fo t a spo t o k also i ludes al ulatio s ased o the a tual a go a ied,
which implies that the current definition in MRV annex II, A, 1., (c) should be maintained. Maintaining this
definition assures that the energy efficiency of ships will also be part of the data that will be collected and
will form the base for the future regulation of the sector. Denmark considers this issue very important and
would consequently encourage that it is considered to maintain the MRV-regulation with its adequate
definition of transport work, if it is not possible to negotiate a common definition of transport work that
includes cargo carried.
Denmark emphasises the need for transparency but could fear that the MRV rules, which favour
transparency on single ship level, could interfere with the trade secrets of ship owners, whereas the
transparency rules of the IMO DCS do not seem to pose this risk.
Denmark can therefore support the ongoing work to align the rules that regulate and reduce GHG-
emissions from the maritime transport sector. At the same time, Denmark is of the opinion that the
regulation should include measures on cargo carried by ships in order to reflect the energy efficiency of
ships.
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