Shipping Australia sent the following text to DCN in response to an article published on Tuesday concerning the International Fund for Animal Welfare’s call for regulation of vessel speeds.

The ocean shipping industry is keen to operate in a sustainable manner with a minimal burden on communities and eco-systems. Shipping Australia notes comments made by the IFAW: “Blue speeds: socioeconomic benefits of up to EUR4.5 billion a year from slowing down ships”. Shipping Australia is pleased to respond that many policy and operational actions have already been taken that will cut underwater noise, reduce whale strikes and produce less emissions.

Ocean shipping has long been aware of and has long taken action to reduce ship strikes on whales. In 2009, the International Maritime Organization issued a guidance document for minimising the risk of ship strikes with whales.

Another example is the Protecting Blue Whales and Blue Skies program that runs in the United States. In 2014, seven global shipping companies trialled slowing down ships in certain whale-sensitive areas. At the time, Chris Mobley, superintendent of Channel Islands National Marine Sanctuary, said: “the success of the vessel speed reduction trial is evident in the strong partnership and the shipping industry’s willingness to participate to advance our respective goals of endangered whale conservation, cleaner air and maintaining maritime commerce”.

In 2016, seven global shipping companies were acknowledged for reducing speeds to protect whales.  In 2017, ten global ocean shipping companies were recognised for their work in reducing speeds to cut emissions and to protect whales. Also in 2017, both Mediterranean Shipping Company and COSCO were recognised and honoured by the IFAW for their actions in slowing down to prevent strikes in areas inhabited by North Atlantic right whales. In 2018, eleven global ocean shipping companies were recognised for their work in cutting emissions and protecting whales. In 2019, twelve global ocean shipping companies were recognised for cutting emissions and protecting whales. In 2020, fifteen global ocean shipping companies were recognised for cutting emissions and protecting whales. It was noted that “MSC, Hapag-Lloyd, Yang Ming, and MOL ACE notably achieved the Sapphire tier in the large company category (greater than 30 transits) by slowing down more than 800 transits, combined”. In 2021, sixteen global shipping companies were publicly recognised for slow speed transits to cut air emissions and to protect whales. In 2022, 15 global shipping companies were recognised for their work in cutting speeds to protect whales and prevent emissions.

The program organised particularly highlighted and praised the work of Mediterranean Shipping Company. Of the nearly 280,000 nautical miles of ocean transited by all the ships in the 2021 program, nearly 180,000 nautical miles were at 10 knots or less, which is equivalent to traversing the circumference of the earth more than eight times.

Aeron Arlin Genet, Air Pollution Control Officer, Santa Barbara County Air Pollution Control District, commented: “We applaud the participating shipping companies, many of which have returned to this program year after year. Their voluntary efforts to reduce speeds have again translated to significant benefits for air quality and endangered whales”.

MSC has re-routed ships off the west coast of Greece to protect sperm whales and, in association with the IFAW, is working to study local populations. “We have a responsibility to ensure that our cargo operations make a positive impact, reflecting our longstanding commitment to conserving and protecting the ocean and marine wildlife”, said Stefania Lallai, vice president of sustainability at MSC Mediterranean Shipping Company. Meanwhile, MSC also began voluntarily re-routing around Sri Lanka to protect Blue Whales by passing approximately 15 nautical miles to the south of regular routes following scientific advice. The re-routing cuts the risk of ship strike on whales by 95%. The global trade body for liner shipping companies is advocated to create a new official marine traffic scheme fully separated from blue whale feeding areas.

Shipping is also taking major steps to address emissions of all kinds from shipping. The International Maritime Organization adopted rules for the prevention of air pollution from ships back in 1997 and these are updated over time. The last update was in 2020, a global rule that cuts sulphur in ship’s fuel oil to less than 0.5% mass-by-mass (that results in far less sulphur dioxide emissions) entered into force on a global basis. This will protect human, animal, and plant health while simultaneously protecting eco-systems on a planetary scale. There are several energy efficiency rules. In 2013, energy efficiency rules for new ships entered into force. New ships now are about 30% more efficient than ships from about 10 years ago. In a few months, progressively tightening rules on energy efficiency will require ships to become increasingly more energy efficient. These new rules will likely result in ships slowing down, which saves fuel, emissions and reduces the chances of ship-strike on whales. The new rules will likely spur a wave of investment in improvements to the hull and the propeller, the cumulative effect of which will be to cut noise from ships.

No doubt there is more that can – and should – be done to reduce the impact of ocean shipping on global environment. International shipping has recognised this fact, and has been working to address its impacts, for literally decades. Shipping will no doubt be keen to continue to work to reduce its impacts in the years to come.

Shipping is keen to see that regulation of the worldwide industry takes place on a global scale. Therefore, the best forum for regulatory reform is through the Marine Environment Protection Committee of the International Maritime Organization. It is the expert global regulator; all parties should be keen to see it produce expert, international, regulation.

We note the IFAW’s call for a global-slowdown of ships. While this policy suggestion could possibly, in due course, be a solution that is favoured and adopted by the global shipping industry, it is not the only way to reduce emissions from shipping, cut marine noise, or protect whales. Different fuels, hull-propeller optimisation, and re-routing are just three alternative solutions that could have highly beneficial effects. Adopting a global shipping speed limit could have a variety of adverse effects, the most obvious effects being a massive reduction in global shipping capacity along with a reduction in the number, frequency, and resilience of services offered to shippers as the industry transitioned into a slow speed. There’s always a trade-off in every policy prescription and it is vital to discuss the details, burdens and benefits before taking action.

We were therefore disappointed with the media statement from the IFAW. Firstly, it did not acknowledge the role played by shipping in helping to reduce its impact on whales, especially as a quick search on the IFAW’s own website reveals that the IFAW is well aware of the actions that shipping has been taking to reduce the impact. See Major shipping company helps save endangered sperm whales in the Mediterranean, IFAW, 26 January 2022. Not including that information in its media release is, at best, extremely misleading. Secondly, as noted above, slowing down is not the only solution and it could, perhaps, not be the optimal solution. A more thoughtful and measured approach would have been more welcome.