FTA / Submission - Maritime Emissions Reduction National Action Plan (MERNAP) Issues Paper: Regulation & Standards

Friday, October 6, 2023

Freight & Trade Alliance (FTA) and the Australian Peak Shippers Association (APSA) incorporated extensive member feedback in a formal submission to the Department of Infrastructure, Transport, Regional Development, Communications and the Arts (department) in response to the Maritime Emissions Reduction National Action Plan (MERNAP) Issues Paper: Regulation & Standards.

Maritime Emissions Reduction National Action Plan (MERNAP) initiative. It serves as a proactive response to the industry's call for clear guidance and support in the face of a globally recognised imperative: the need to reduce maritime emissions and transition to a more sustainable, greener future.

By addressing the mosaic of regulatory challenges and providing a clear roadmap for transition, MERNAP lays the foundation for both a greener maritime sector and a resilient Australian economy.

Supporting this position, FTA / APSA have prepared the following submission with five (5) recommendations in response to the specific questions as outlined in the MERNAP Issues Paper on Regulations & Standards : 

RECOMMENDATION 1 - MERNAP needs to take a holistic approach to decarbonisation, ensuring compliance with IMO standards set, and crucially ensuring stakeholder engagement, particularly with ship owners & port operators.

RECOMMENDATION 2 – To best serve the maritime industry's evolving needs, it is recommended that the government adopt a dynamic, sustainable, and inclusive regulatory framework that prioritises adaptability, global harmonisation, stakeholder transparency, and uncompromised safety.

RECOMMENDATION 3 – MERNAP should consider the impacts and regulation of shore-side electricity in maritime ports, thereby reducing emissions and enhancing air quality.

RECOMMENDATION 4 – As a priority, targeted national actions need to specifically address shipping competition law (including repeal of Part X CCA, exclusive dealings via vertical integration, quayside cost recovery), Terminal Access Charges (stevedores & empty container parks), container detention (import & export). By doing so, holistically it would offset the cost impost of any carbon pricing mechanisms.

RECOMMENDATION 5 – MERNAP should ensure stakeholder engagement with ship owners and port operators to discuss and map the way forward in preparation of next generation fuel transitioning.

The FTA / APSA submission is available HERE

Tom Jensen - Head of International Freight & Logistics -  FTA / APSA

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