Interferry understands the importance of making progress on the reduction of greenhouse gases.  However, it is critical to develop policies and procedures very carefully to avoid unintended consequences.  

An example was the recent action of IMO to reduce the limit on the sulphur content of fuel used in Environmental Control Areas (ECAs) to 0.10% by 2015.  

The result of this hasty action will be a dramatic rise in fuel costs for ferries and short-sea operators in the Baltic and North Seas, resulting in higher rates for freight, thus shifting a significant number of trucks back to the roads, and ultimately having a negative overall environmental impact.  

Based on this experience it is critical to have thorough analysis before implementing dramatic changes.

In the case of the sulphur rules only northern Europe will be impacted. In the case of carbon rules the whole world will be impacted since shipping carries over 80% of world trade.  

Despite our disagreement with IMO over sulphur, Interferry firmly believes that the best place to develop new environmental regulations for shipping is with IMO where the technical expertise lies and where organisations such as ours have consultative status.  

Let the UN develop broad goals in Copenhagen but leave it to the IMO in London to construct intelligent regulations with the full participation of the shipping industry.