In recent times, the idea of creating an emission control area for the Mediterranean Sea seems to have come back under the spotlight. The proposal was put forward by France, which, in the wake of the ECA models already seen in Northern Europe and in the United States, would deem it necessary to (re)try to introduce an area also in our seas.

Of course, the French proposal is grounded on the environmental benefits that the area could produce. However, before embracing the idea of a new ECA, we should also consider possible drawbacks.

Indeed, the Emission Control Area (ECA), is a sea area subject to minimization standards for airborne emissions from ships. More specifically, resolution MEPC 176(58) of the International Maritime Organization (IMO) defined ECAs as areas where the adoption of special mandatory measures for emissions from ships is required to prevent, reduce and control air pollution from NOx or SOx and particulate matter (PM).

ECAs introduction is the result of the enactment of ANNEX VI to the MARPOL protocol. To that extent, ANNEX VI was approved in 1997, introducing limitations to emissions of harmful gases such as Sulphur oxides (SOx) and Nitrogen oxides (NOx). The same protocol has also prohibited any voluntary emission of ozone depleting substances (ODS), as well as the emission of volatile organic compounds (VOC).

Those limitations have increased over the years, until resolution MEPC 58 of the International Maritime Organization (IMO), adopted in 2008 and in force since 2010.

The actual limit of sulphur content of fuel used by ships is 0.10% m/m, whilst outside the ECAs the same limit is 3.5% m/m, even though it is destined to further decrease to 0.50% by 1 January 2020.

As far as the European scenario is concerned, today we have ECA areas located in the Baltic Sea and in the North Sea. As mentioned, after the French Authorities submitted a report explaining the benefits of a possible ECA in the Mediterranean Sea, this idea seems to be back on the agenda.

The benefits that an emission control area could bring are attributable to:

  • reduction of Sulphur gas, Nitrogen oxides and PM10 emissions.
  • reduction of negative externalities and consequent socio-economic benefit: in practice, benefits would result in a saving on the national expenditure for healthcare (since the emission of harmful gases is directly proportional to the risk to human health) and above all in a significant reduction in the risk of environmental damage.
  • reduction of emissions into the sea, at a time when the fight against climate change has become a very topical issue.

But, on the other hand, we must not forget that, in addition to the need for environment protection, we must also take into account the differences between the Mediterranean Sea and the Baltic-North Sea (where ECAs are active).

In this regard, in particular, the feeling is that the introduction of an ECA area in the Mediterranean Sea might put the ship owning industry into crisis. Indeed, the costs of low-sulphur fuel are much higher than those currently used in the Mediterranean sea and here the sources of supply are much more limited than in the aforementioned northern European seas. By way of consequence, today the risk arising from the introduction of an ECA in the Mediterranean Sea could be to cause a serious damage to the shipping industry.

Hence, we would consider the possible extension of the emission control area to the Mediterranean Sea an ambitious goal that can hardly be accomplished without implementing measures aimed at enabling the maritime industry to encourage said virtuous processes, by way of example the availability of alternative fuels technologies (such LNG or the so-called cold ironing). Otherwise, there would be a risk to cause a serious harm to shipowners' companies and consequently to the whole shipping market. In other words, we would deem it necessary to strike a balance between the legitimate demand for environmental protection and the objective conditions of the reference market, in order to define a breakeven point.

To conclude, we would like to point out that in May 2018 Italy voted in favor of the ECA for the Mediterranean Sea. The then Italian Minister of the Environment (Ministero dell'Ambiente), following the G7 Environment Ministers summit in Metz, declared that he considered it necessary to introduce an ECA area in order to make a decisive contribution to the reduction of emissions into the atmosphere arising out of maritime traffic as well as to prevent the consequent harmful impact on the marine environment and on the health of populations of coastal areas.

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