All Aboard a
Green
Future?
An analysis of the policy processes leading up to the climate
regulation in the aviation and shipping sectors
First and Second Readers Dr J. W. G. Blom
Dr P. Schleifer 16907 Words
Mat
Duco Ferwerda
Master Thesis Political Science
Political Economy
Duco Ferwerda Master Thesis University of Amsterdam Political Science Political Economy
Duco Ferwerda
16907 Words First and Second ReadersDr J. W. G. Blom Dr P. Schleifer
s Political Science
Political Economy
Table of Contents
Introduction 1
Case Selection 3
Relevance 5
Methodology & Data 6
Theoretical Framework 8
Interest group definition 8
Mobilization bias 9
Pluralism & Business Unity 9
Rent-seeking 10
Influence: an instrumentalist approach 12
Influence: A structural approach 13
The Socio-Institutional Context 14
Validity & Reliability 14
Results 16
Decision-making in the IMO and ICAO 16
Socio-institutional context 18 Shipping 20 Aviation 29 Comparison 35 Conclusion 40 Further Research 42 Discussion 42 List of Acronyms 44 Bibliography 45
Introduction
To tackle the increasingly urgent problem of man-made climate change, climate policies aimed at lowering emissions are required. However, tough action on climate change is more often than not at odds with short-term business interests. As a result, trade associations and individual firms tend to try to influence environmental policy, which can undermine action on environmental issues (Fagan-Watson, Elliot, & Watson, 2015). This makes lobbying an important component to understand the stringency of climate policies.
Two industries in particularly have long managed to dodge climate regulation: shipping and aviation. Due to their international character, both have been left out of national targets for emission reductions since the Kyoto Protocol. Instead UN bodies were tasked to curb their emissions, with little result in the last two decades (Bows-Larkin, 2015; EP, 2016, p. 40). This is deemed problematic because the emissions of the two sectors, which together form 7% of total CO2 emissions, threaten the ambition to keep global warming below 2 degrees Celsius
(Bows-Larkin, 2015). But recently policy progress seems to have accelerated, with the UN body for aviation, the International Civil Aviation Organization (ICAO), agreeing on a carbon offsetting scheme in 2016 and committing to Carbon Neutral Growth (CNG) starting in 2020. Similarly, in 2018 the UN body for shipping, the International Maritime Organization (IMO) has agreed to an Initial GHG (Greenhouse Gas) Strategy in which it aims to cut emissions from maritime transport with 50% by 2050. And although in their current form both resolutions still fall short of the Paris Climate Agreement targets, they open avenues for further improvement and signal a clear first step in the right direction.
This climate policy progress comes after decades with few developments. For long, the lack of progress in both these organizations was thought to reflect the preferences of industry, which opposed regulation due to the expected negative effects on profits. Business has traditionally been an important voice in both UN bodies, which rely heavily on its technical expertise and knowledge to gage the effects of proposed regulations. At the same time, civil society organizations pushing for action against global warming have been underrepresented at both the IMO and ICAO (EP, 2016, p. 7). This resulted in an impasse, with the environmental protection committees in either UN body unable or unwilling to address the emissions of each sector in any substantial way. As recent as October 2017, InfluenceMap (2017) even reported regulatory capture at the IMO, and ICAO has previously faced similar criticism.
The power of business in these UN bodies, combined with its presumed unwillingness to tackle its emissions, make the sudden change in pace of policy progress in both sectors surprising. This research therefore seeks to answer the following question: What explains the
recent developments in climate regulation of the aviation and shipping sector? By tracing the
policy process, this research seeks to explain how the recent policy progress came about and uncover which actors and factors were influential in shaping it.
Although in recent years both industries have seen climate regulation, the level of stringency between the two organizations differs. And while neither is in line with the 1.5-degree target, compared to the IMO’s goal of 50% absolute in-sector emission reduction, the ICAO’s aim of CNG through offsetting – which essentially allows the sector to emit as much as they can buy – is expected to be far less effective in slowing climate change. This research thus not only looks at why there is process despite the power of industry in both organizations, but also what factors have contributed in the perceived difference between the deal in these two organizations. Part of this comparative element of this research can be explained by sectoral differences; abatement opportunities differ significantly. However, part of the difference between the two sectors may also be the result of a difference in industry power. Several reports have shown that the level of ambition set by the ICAO through the adoption of Carbon Offsetting and Reduction System for International Aviation (CORSIA) is disappointing when compared to the IMO’s Initial GHG Strategy, even when keeping this difference in mind. (ICCT, 2018; T&E, 2018). From the perspective of interest group politics literature, it is the factors that lead to this difference not attributable to abatement opportunities that are of interest to us.
To answer this question, the policy process at the UN bodies for shipping and aviation, the IMO and ICAO respectively, will be examined. Focus will be not only aviation and shipping lobby groups, in the form of industry associations, but also Civil Society Organizations (CSOs), which are expected to push for regulation and emission reduction. For this, Assembly reports will be examined and all submissions to these Assemblies, alongside interviews with policy-makers, CSO and industry officials. It will examine influence by aiming to answer the following sub-questions: (1) What are the policy preferences of the actors
engaged in the climate policy-making process at the UN and EU level? (2) What action did the actors undertake to attain their policy preferences? (3) To what degree did actors attain their preferred policy outcomes at the UN level? Together these three sub-questions help gain insight
into the influence of these two sectors.1
1 Further explanation of the chosen sub-questions, and how they help answer our research question will be
For this, first the case selection will be described in more detail, and the rationale for examining both UN bodies simultaneously. Next, the academic and societal relevance of this study will be outlined, followed by the methodology and data section, outlining the research methods and data used to answer the research question. In the theoretical framework, first relevant definitions will be given. The rest of the theoretical framework section aims to explain why business is expected to be more successful in influencing policy and the way in which influence manifests itself, along with propositions where relevant. Furthermore, it serves to gain insight in expected2 policy preferences of the aviation and shipping sector, and gives two
potential explanations for possible business support for climate regulation. Finally, attention will be paid to the possible effects of a socio-institutional context on the ability of different actor types to influence the policy process. At the end of the theoretical framework issues concerning the validity and reliability issues in this research will be addressed. Afterwards the results follow, with first an in-depth look into the decision-making process at both the IMO and ICAO. The socio-institutional context in which these decisions are made are examined next, linking back to concepts in the theoretical framework. After the functioning and setting of both organizations has been described, the policy process leading up to the most significant agreement in each UN body will be relayed chronologically per sector. The results end with a comparison between the IMO and ICAO decision-making process, highlighting the most important differences that have led to different levels of ambition in each sector and explaining the timing of the progress. In the conclusion, the research question will be answered in full along with its three sub-questions. The thesis will end with a discussion and recommendations for further research.
Case Selection
Although there are important differences between shipping and aviation, most notably in the number of abatement opportunities, which are far more promising and easier to accomplish in the shipping sector compared to aviation, there are several reasons to consider the two sectors simultaneously. First and foremost, the way in which emissions ought to be addressed in both sectors is similar and differs distinctly from other sectors. Both have been excluded from national targets in the Paris Climate Agreement, meaning they are not part of the Intended Nationally Determined Contributions (INDC) like other sectors. This is due to the international
2 Actual preferences will be uncovered during the research. Any deviation from the expected would however
nature of their emissions, which are hard to contribute to any one country. Instead of states, the IMO and ICAO were tasked by the Kyoto Protocol and again by the Paris Climate Agreement to tackle their emissions. In response, both UN bodies assigned committees to deal with the issue of the sectors’ environmental impact, which are the Maritime Environmental Protection Committee (MEPC) for shipping and the Committee on Aviation Environmental Protection (CAEP) for aviation. Although the UN bodies differ in several ways, like meeting frequency, levels of transparency and (to a lesser extent) organizational set-up, they both share characteristics typical for the UN. All member states are represented and have a vote, although the organizations work mostly on a consensus basis. Because of their focus on creating a regulatory framework that creates a level playing field, both organizations also have traditionally had strong ties to industry representation (EP, 2016).
A second reason to look at these two industries at the same time is that both aviation and shipping have similar emission growth trajectories. Their role for trade and travel has made these sectors some of the fastest growing emitters in recent decades. The emissions in these sectors have grown at twice the rate of the global economy and are currently estimated to be roughly 7% of the global CO2 emissions (Hemmings & Murphy, 2016). And with the rapid
globalization, demand is expected to continue to rise, meaning emissions are not yet at peak levels.
Thirdly, although both UN bodies were ordered to deal with their impact on global warming in 1997, in both sectors these rising emissions have gone virtually unaddressed for a long period of time. While over the years more toxic pollutants like sulphur and nitrogen oxides were reduced, the issue of Greenhouse Gasses (GHGs) and CO2 emissions in particular were
hardly confronted until recently.
Finally, the timing of progress might suggest a shared cause. After decades of inactivity in both organizations, within two years of the acceptance of CORSIA (the Carbon Offsetting and Reduction Scheme for International Aviation), the IMO agreed on their 50% emission reduction target. The quick succession of these resolutions – which are the most important legislative developments and the focus of this research – may mean that the roots of the sudden climate regulation progress in both sectors are linked.
The unique international nature of emissions from shipping and aviation and their similar governance, along with the similarity in emission trajectories, the long period of minimal climate governance, and the sudden progress in of both sectors in quick succession, make it logical to consider both simultaneously. As such, together these two sectors form a one-of-a-kind case as their international character and lacking regulatory process constitute a
unique context with significant impact. Through the design of a single case study the integrity of this context can be preserved, rather than disaggregating it into features (Fiss, 2009).
Relevance
As the theoretical framework will accentuate, the recent progress made in both UN bodies does create a theoretical puzzle from the perspective of interest group politics. The long lacking climate regulations in the aviation and shipping sector have been attributed to the power of business in both these sectors, with some seeing it as a signal for corporate capture. There is a general expectation that business – or more specifically narrow interests – have more access to and influence on policy-making processes due to their superior expertise and resources compared to CSOs – or diffuse interests. In the case of aviation and shipping there is a striking information asymmetry between policy-makers and environmental CSOs on the one hand and business on the other, which is exacerbated by a resource asymmetry. This has resulted in privileged access for industry at both UN bodies. Furthermore, both UN bodies have a socio-institutional character that strongly favours industry over environmental CSOs. These factors, all of which will be expanded on in the theoretical framework, make the policy-making process susceptible to regulatory capture – a situation in which the content of regulation is actively designed by, and in the interest of, the regulated industry itself (Young, 2012, p. 664). Answering why despite the power of business both sectors have now managed to advance their climate policy will help further our understanding of the causal mechanisms of influence, for which scholars call for more research (Dür, 2008, Lowery et al., 2008; Klüver, 2013; Fagan-Watson, Elliot, & Fagan-Watson, 2015). As pointed out, the level of ambition also differs between the two sectors. Though these can no doubt in part be attributed to technical differences, as a scholar of Political Economy it is the part that may be due to the power of business that interests us. Explaining the difference between the stringency of climate regulation and exposing the underlying causes may give insight into factors that benefit narrow over diffuse interests.
The timing of the developments at the IMO adds to the relevance of this research. Since the IMO’s Initial GHG Strategy was only adopted on the 12th April 2018, this paper is among
the first, and may well be the very first, to examine the policy process that led to this decision, systematically assess the influence of actors involved in it, and compare this with the ICAO policy process. In this way, this research can add to the understanding of the recent deal, how it came about and the functioning of both organizations.
Moreover, in the field of interest group politics, plenty scholars have pointed to the importance of taking into consideration the institution in which interest groups are active
(Eising, 2007; Klüver, Braun, & Beyers, 2015). This research can shed light on how the battle for influence plays out in both these organizations, which have been understudied, and reveal how their structure and socio-institutional context have affected this.
Furthermore, given the importance of the issues of climate change, there is a need to scrutinize regulations that aim to address this issue. This is particularly the case when there is reason to believe that these regulations may prioritize the narrow interests of business over the diffuse interests of the global community. This research may be able to provide such scrutiny.
Methodology & Data
To uncover the causes of the recent developments in climate regulation in the aviation and shipping sectors and the causes of respective differences between the deals of the two UN bodies, a qualitative research approach is used. To gain insight in the policy process, a method of process tracing will be employed. This method aims to uncover step by step which parties influenced the process and is widely recommended for studying influence (Dür, 2008, Young, 2012). Focus is on the preference of each group, their attempts to influence outcome, their access to decision-makers and the subsequent responses of decision-makers to such attempts (Dür, 2008). As with most process tracing studies, this study relies on semi-structured interviews. This research method offers some freedom to probe which is essential to explore respondents’ opinions, clarify interesting and relevant issues, elicit complete information and explore sensitive topics within each interview (Barriball & While, 1994, p. 334). Alongside semi-structured interviews, a document analysis has been executed. Together, this will help us firstly to determine the policy preferences of each group (CSOs engaged in environmental issues, and business interest groups of both the aviation and shipping sector). Secondly, it will help us understand of each party what actions were undertaken, what information was sent, and what the intensity of contact (access) was to policy-makers. Thirdly, the combination of a document analysis and semi-structured interviews with policy-makers can illuminate possible influence from any interest groups. A comparison between both sectors can uncover which methods and factors were important in subsequent policy-outcomes and whether recent progress in each sector is linked by a shared cause.
For this, four types of officials were approached who were present during the negotiations within each sector. These are industry officials of the most important trade associations, CSO officials, state policy officials and members of the European Commission. Also, one person was interviewed who was present at both the ICAO and IMO negotiations. For aviation, an interview was conducted with the Environmental Manager from the
International Air Transport Association (IATA). Unfortunately, no one within the shipping industry agreed to participate in this research. The CSO that was approached was Transportation and Environment (T&E), specialized in transportation and the EU ETS and founder of the Clean Shipping Coalition (CSC) and co-founder of the International Coalition for Sustainable Aviaiton (ICSA), two coalitions of CSOs with observer status at the IMO and ICAO respectively. Interviews were conducted with the Aviation Officer, the Shipping Officer, and the Shipping and Aviation Officer, with insight on both policy processes. From the EC, interviews were conducted with both the Directorate-General on Climate Action as well as the Directorate-General on Mobility and Transport. This was done in part to examine the effect of and the strategy behind the threat of inclusion of both sectors into the EU ETS as well as gain another perspective on the policy process. On the state level, two members from the Dutch delegation were interviewed from Ministry of Infrastructure and Waterways. The choice for the Dutch delegation was made out of interest and because, as the findings will show, the Dutch delegation was part of a coalition of ambitious members within both ICAO, in the form of the European Community, and the IMO, in the form of the Shipping Higher Ambition Coalition. By choosing to analyse one state for both organizations, difference in approach between the two sectors can more reliably be compared. In the end a total of eight interviews were conducted with people which were present for most of the policy process in the IMO or ICAO or both.
The documents that were analysed are firstly Assembly reports from the ICAO and the MEPC, which is the Committee that deals with environmental issues within the IMO, and secondly the position papers and working papers submitted by member states and observers to these organizations. The analysis of submissions by states and observers, which include the EC, EP, CSOs and industry associations, helped get a sense of each actor’s regulatory preference and the argumentation thereof. This relates to our first sub-question on actor preferences.
A combination of a document analysis of submissions and interviews will also illuminate what information is being pushed and what frame is used, as well as give us a sense of when action was undertaken. This relates to our second sub-question on action undertaken to influence policy. This combination provided insight in the lobbying activity of all involved interest groups as well as the EU and member states, and see whether a difference in strategies or access can be observed.
Finally, a combination of interviews and an analysis of policy documents can illuminate if a push of information had any effect, by examining policy proposals with their final form,
and whether there is congruence between the information being pushed and subsequent changes in policy (Dür, 2008). This relates to our third sub-question on policy change. If congruence is found between actions uncovered by interest groups and subsequent changes in policy, this is a strong indicator of influence (Lowery, 2013).
The focus is on the two most important policy developments, the 50% in-sector reduction agreement in shipping, and the agreement on the offsetting MBM in aviation (CORSIA). Both policy processes leading up to these agreements were followed from beginning to end. For this, the policy documents from the ICAO that were analysed are from 35th Assembly in 2004 to the 39th in 2016. Within the IMO, these are the 68th Assembly 68 in
2015 to the 72nd Assembly in 2018.
Theoretical Framework
Interest group definition
One way in which policy is influenced is by collective action of a group of people with common interests, which we will refer to as an interest group. Interest groups are defined by Beyers, Eising and Maloney (2008, pp. 1106-1109) along two distinct features: Organization and
political interest. Firstly, to qualify as an interest group there must be some form of
membership and/or organizational structure present. Secondly, interest groups must seek to influence political decision-making and policy outcomes. Klüver (2013, pp. 5-6) adds to this a third: Private status, meaning that interest groups are not seeking public office and they are not public institutions which are funded by and subject to the state.
Traditionally, a distinction is made between narrow and diffuse interests. This refers to the degree to which the interests are shared by a selective group (narrow) or society as a whole (diffuse) (Richardson, 1993). Though never clear cut, in the case of environmental issues this distinction is more evident, with environmental CSOs representing diffuse interests by aiming to curb climate change and business interest groups representing their own narrower interests, aiming to reduce or avoid entirely the burden this could have for them. Whereas diffuse interests thus aim to represent the aggregate interest of society, business or narrow interests act on a shared interest within smaller groups that may be averse to this aggregate interest (Richardson, 1993).
Mobilization bias
The process through which interest groups mobilize has often been taken for granted, expecting that groups act on a shared interest the same way individuals act to serve their own self-interest (Richardson, 1993, p. 23). However, the goods that collective action seeks to attain (in the case of environmental issues, a curbing of manmade global warming) are of such a nature that once available to one member of the group, they are available to all members. Thus, since an individual could also reap the benefits without bearing the costs, participating in collective action is not necessarily in his self-interest (Olson, 1965). An individual will only partake if (1) the good will not likely be secured without his effort and (2) the possible gains are large enough to warrant action. This results in a dynamic where small groups are favoured over large groups and narrow over diffuse interests (Adelman & Engel, 2007; Rasmussen & Carroll, 2014; De Bruyker, Berkhout, & Hanegraaff, 2017, p. 5). This leads us to our first proposition:
Due to the mobilization bias, industry interests will be better mobilized than diffuse interests in the policy-making process.
Pluralism & Business Unity
The bias in the mobilization stage thus affects the interest group community make-up. The advantage of narrow over diffuse interest here can lead to a lacking pluralism of voices in the political arena. This might mean that business interests, though harmful for some, are not always countered by dissenting voices (Pagliari & Young, 2016). As such, a bias in mobilization could lead to a bias in representation. As such:
A difference in the number of business interest groups that mobilize relative to CSOs will lead to a difference in representation at the IMO and ICAO.
The pluralism of the interest group community, however, is not only determined by this diffuse-narrow interest group ratio. The relative unity of a business sector also plays a role (Klüver, 2013; Rasmussen, 2015). When business is divided it in a way creates a more pluralistic interest group community, offering policy-makers with competing frames that in turn result in a more nuanced image on a subject. In contrast, when business stands united and jointly frames an issue through a single narrative, it is more likely to successfully influence policy (Rasmussen, 2015, pp. 376-377).
The degree to which business interest groups represent a united front will affect their ability to influence the policy-making process.
Rent-seeking
The nature of most government interventions in market mechanisms is such that they create economic rents. An emission trading system is such an example, where clean air is monetized and allowances create new property rights which are then allocated. Since these interventions are intended to change relative prices, they create income effects as well (Krueger, 1974). As a result, the goal of business interest groups when influencing policy is to capture these income effects or avoid taking hits to existing asset values (Helm, 2010, p. 185). As such, the expectation is that the preferences of business interest groups will be the following:
Business interest groups will seek to minimize regulation to avoid financial and regulatory burden and seek regulation that would enhance their profits. The assumption is thus
that minimal regulation will be preferred over stringent regulation, that Market-Based Measures (MBM) as an ETS will be preferred over taxation since they create economic rents, and that the degree to which a sector is able to pass down additional costs from regulation to customers will impact their opposition to these costs.3
However, although business opposition to environmental regulation is common it is far from universal. Therefore, here attention will be paid to three situations where business is incentivized to lobby for stricter environmental policy that may be of relevance to our case. First, firms that have made investments in low emission technology will gain an edge over competitors if regulation is introduced or tightened. The creation of environmental rents and the opportunity to use regulation to gain a competitive advantage over a rival are both powerful reasons for profit maximizing firms to support environmental protection (Grey, 2017, p. 32). However, this only holds if the investment in emission abating technologies is lower than the cost of a potential carbon offsetting program.4
Secondly, and similarly, since operating under stringent regulation brings costs with it, firms exposed to environmental regulation in their main areas of operation might be incentivized to lobby governments outside that area to lobby for stricter environmental regulation to level the playing field. This so-called ‘trading up’ could give more firms operating
3 According to Anger & Köhler (2010), the aviation sector in particular is able to pass down such costs. 4 Although abatement costs for shipping are roughly three times lower than they are for aviation, the price
of emission allowances have in all cases been far too low to incentivize in-sector CO2 abatement (Anger &
mostly in strictly regulated areas a competitive advantage over firms operating mostly in more laxly regulated areas (Bernauer & Caduff, 2005, p. 122).5
These previous two circumstances could explain a part of the aviation or shipping sector lobbying for instead of against environmental regulation, resulting in a more pluralistic interest group community, and leading to the better representation of diffuse interests as a result. The third relates to a united attempt by business to lobby for global environmental regulations.
Related to these two reasons, a third reason to lobby for environmental regulation is to create a level playing field. Regional regulation may result in market distortion by exposing some firms to additional costs but not others. Within both aviation and shipping the threat of such market distortion has been present due to promised actions of the EU. The main tool of the EU to address emissions is the European Union Emission Trading System (EU ETS), a cap-and-trade system of greenhouse gasses (GHGs), which aims to create economic incentives to abate emissions by making CO2 into a tradable good (Brouwers et al., 2017). During the policy
process in both the ICAO and the IMO, the EU has threatened to unilaterally act by including both sectors into the EU ETS. Furthermore, in its initial conception such measures would not only affect EU companies, but all planes and vessels arriving in or departing from the EU. The efforts to reduce emissions within the UN are thus part of an international regime of environmental policies. These regimes, parallel to one another, may affect the preferences of interest groups and should therefore be considered to see whether they caused a shift in preference. The literature suggests that the EU started considering inclusion of both sectors due to lacking ambition on the UN level. The pressure that this threat of inclusion created may have incentivized each sector to agree on a deal at the UN level, to avoid a patchwork of regional climate policy regimes and maintain a level playing field. The EU’s proposed unilateral actions will therefore also be taken into consideration to see if choices and behaviours of actors are shaped by larger chessboard politics.
Moreover, taking into account these EU actions may uncover whether the pressure put on each UN body by parallel regimes differs. Similarly, understanding the interplay between both levels will help uncover whether the timing or framing of an issue at the EU is shaped by politics occurring at the UN level.
5 This could incentivize particularly companies that operate mostly within the EU. Since this activity falls
or will fall under the EU ETS it puts them at a competitive disadvantage and incentivizes them to level the playing field by lobbying at the UN level for similar environmental regulations at the global level.
Influence: an instrumentalist approach
So far, we have examined what interest groups are, how they are created and what their expected preferences will be. Also, we have examined how diversity of an interest group community may affect the influence of individual interest groups. Next, we turn to how interest groups exert influence to attain their preferred policy outcomes. Here we will first look at the instrumentalist approach, and afterwards discuss the structural side that may be overlooked in this approach.
In political theory, the relationship between government and its constituents is often characterized as an exchange relationship. Governments introduce policies in exchange for resources they need, such as support in the form of votes or financial contributions, or information in the form of expertise necessary to form policies (Klüver, 2013, p. 3). One way in which corporations have the upper hand when influencing policy is their ability to mobilize these resources. Since campaign donations are assumed not to play a large role at the UN or EU level, and more explicit methods of buying influence are illegal, the direct influence of financial resources is assumed to be limited. However, money is also used to mobilize other resources, such as specialized information and access to policy-makers, through the employment of lobbyists.
Governments are inherently likely to have less information about specific technologies and markets than those who produce and trade (Helm, 2010, p. 187). This so-called information asymmetry makes governments dependent on corporations for decision-making and the implementation of policies. The art then of influencing policy is to provide information to government that will lead to the preferred outcome of the supplier (Helm, 2010). As such influence can be described as “the intentional sending of information, and subsequent action
because of it” (Betsil & Correll, 2001, p. 72). This sending of information is done directly,
through the producing of data, information and studies by firms or trade bodies for government use, and indirectly, by providing information to ‘opinion formers’ or sponsoring think tanks and discrediting studies that seem to contradict their interests (Helm, 2010, p. 187).
The information asymmetry between industry and policy-makers is exacerbated by the complexity of said industry. In our case, between shipping and aviation, the latter is far more complex than the former. Policy-makers thus likely have to rely on aviation industry expertise to a far greater extent. Moreover, not only the complexity of the regulated sector but also complexity of the legislative proposal itself affects influence. The degree to which a given policy problem is difficult to analyse, understand or solve determines in part the degree to which legislators must look for external expertise (Klüver, Braun, & Beyers, 2015, p. 451).
Apart from information supply, interest groups can also exert influence on policy-makers through mounting public pressure. This outside approach, trying to change public opinion, is characterized by diffuse interests or reframing issues as such (Bernauer & Caduff, 2004; Rietig, 2011). This approach includes strategies like campaigning, mass protests and media exposure, to build salience, increase public pressure and influence policy-makers as a result. However, highly complex issues also enjoy less salience in society. Limited attention to policy proposal from the general public, or a wider range of interest groups, undermines the pressure from below on policy-makers, which hinders the effectiveness of CSO (Bernauer & Caduff, 2004; Rasmussen & Carroll, 2014, p. 457). As such, a high degree of complexity makes it easier for the engaged narrow interest groups to align policy outcomes more closely with their preferences.
Influence: A structural approach
However, some forms of power do not require the direct application of resources, such as the so-called second face of power, analysed through the structuralist approach to power. An example of structural power is the economic dependency of nations on certain sectors or individual firms, whose economic activity is so large that they are highly important for job creation or economic growth (Ruggie, 2017, p. 7). As such, the structural power of business may have enhanced concerns over the possibility that environmental policy could harm the economic activity of businesses with great economic importance6 (Anger & Kölher, 2010;
Oxfam, 2010).
However, such power often does not need to be voiced, since it relies on mutual economic dependencies (Woll, 2007). This view of power thus clashes with our definition of influence “the intentional sending of information”, which implies deliberate and observable action. Furthermore, without observable action, it is hard to trace whether structural power has actual impact on the policy-making process (Young, 2012). Yet, the role of structural power can none the less not be ignored. Therefore, this research will look at references made to this power by interviewees to get a sense of how structural dependencies might have enhanced the influence of some over others.7
6 The aviation industry employs roughly 20 million people worldwide and has great importance for the
tourism sector (aviationbenefits, 2014). However, due to its s enormous importance for trade – of all world trade, nearly 90% is transported by ship (ICS, 2017) – the structural power of shipping is assumed to be greater.
The Socio-Institutional Context
According to multiple studies, interest group influence is affected by the institutional context in which it operates. Part of this context is determined by the opportunities for interest groups to get in touch with decision-makers, or the degree of access that an institution offers (Eising, 2007, p. 332). Though access does not imply influence, the ability to send information is a prerequisite for determining influence, either through the submission of position papers, the ability to voice once opinion at assembly meetings, or informal contact with members or policy-makers of the organization. This also includes the level to which certain interest groups can be excluded from the process by the institution. This degree of access has both an organizational aspect and a sociohistorical one.
In sociohistorical terms, the context concerns the importance attributed to some stakeholders over others. As has previously been pointed out, both the ICAO and the IMO traditionally have strong ties with industry, which may result in a bias (EP, 2016). In institutional terms, this relates to which interest groups can be members and the level of access that is granted to these members. A sociohistorical bias may be carried over to an institutional one later, with organizations that value business input more highly set-up in such a way that grants them easier access and membership. This in turn may result in a lacking plurality of voices, giving industry more influence over the policy process.
Another factor in the institutional context is the level of transparency. The level of transparency impacts the ability to scrutinize policy processes. More transparency will likely lead to more scrutiny and more public pressure if bias occurs. Obscure policy processes on the other hand undermine the ability of outsiders to judge the policy process and inhibit the pressure environmental CSOs can produce.
Validity & Reliability
As March (1955) put it “Influence is to the study of decision-making what force is to the study of motion – a generic explanation for the basic observable phenomenon”. However, just as force or gravity itself is hard to observe (one merely observes its effects), so too is influence. Two problems in particular need to be addressed. Firstly, influence assumes a causal relationship between the actions of A and subsequent the actions of B, which could prove difficult to analyse. Therefore, the previously described methodology of process tracing is employed, which first uncovers preferences, then the actions undertaken to attain preferred outcomes, and finally congruence between action and policy changes and the timing thereof, guided by the three sub-questions of this research. To increase the validity and reliability, this
analysis employed the triangulation of research methods (document analysis and semi-structured interviews), the diversification of data source types (position papers, policy documents and interview), and data sources (from CSO and business interest groups, as well as state and EU officials). Because the case study research design seeks to maintain the configurational, holistic nature of the case, it is not limited to one particular data collection method and lends itself particularly well for triangulation (Fiss, 2009, pp. 417-418). Although the inclusion of semi-structured interviews reduces the reliability of this research, the combination with document analysis creates a research design that balances the trade-offs of reliability and validity. Also, transparency of findings, by clear reporting of interpretation in both the documents and interviews analysed will increase the reliability of this research.
Secondly, the degree to which structural power exerts influence on policy-makers is hard to assess. Instances of structural power have been operationalized here to the explicit mention of the effect of the economic importance of sectors or individual firms by interviewees in order to make their effects traceable. This operationalization has shortcomings, since it does not measure structural power itself. However, one should be aware of the distinction between power and influence. Whereas influence refers to “the modification of one actor’s behaviour by that of another”, power refers to ability – the aggregate of political resources available to an actor. As such, power may be converted into influence, but one should not assume that this is always the case, or to the full extent (Betsill & Corell, 2001, p. 73). As such, the operationalization used here does lend itself to examine the effects of structural power in influencing the policy process, rather than assume that power automatically translates into influence.
Results
The results rely on a document analysis and interviews. Interviews were conducted with two policy officials from the EC, from both DG MOVE and DG CLIMA, two policy officials from the Dutch Government, responsible for sustainable aviation and shipping, three policy officers from Transport & Environment (T&E), the founder of both NGO coalitions most active in the policy processes, and one industry official from IATA. Industry officials from ICS, ECSA, and WSC were also contacted, as well as other representatives of the European Commission and Members of the European Parliament, but these didn’t respond to interview requests. For the document analysis, the official Assembly reports from the ICAO (Assembly 35 to 39) and MEPC (Assembly 68 to 72), the environmental committee within the IMO, were analysed as well as all submissions to these Assemblies from states, and observers (which include industry associations, CSOs and the European Commission and Parliament). These submissions offer insight into the preferences of the different actors, and the information they send to influence the policy outcome, related to the first and second sub-question. The Assembly reports offer insight into the policy process and the response to these submissions, relating to our third sub-question.
The results are structured as follows: first, a background describes the structure and decision-making process of both organizations. Next, the socio-institutional context in which this policy-making process takes place will be discussed, as they were relayed by interviewees and a study for the ENVI committee, commissioned by the European Parliament. After the functioning of both organizations is described, this chapter will examine both policy processes leading up to the most important emission reduction deal in each organization, shipping’s Initial IMO GHG strategy and aviation’s CORSIA. Finally, the chapter will conclude with a comparison between the two organizations, highlighting the differences in deals and the causes thereof.
Decision-making in the IMO and ICAO
Both the IMO and the ICAO were founded in the ’40s, shortly after the creation of the United Nations. Initially these organizations were concerned mostly with safety and technical issues, and to ensure that vehicles had access regardless of their origin. However, with the Kyoto Protocol both organizations were tasked in 1997 to address the environmental impact of their sector as well through Article 2.2 For this, the ICAO and IMO created separate committees, the CAEP and the MEPC respectively.
Both the IMO and ICAO have a similar organizational structure, which consists of an Assembly, a Council and a specialized Committee dealing with environmental issues. The IMO’s Assembly consists of 173 member states and meets every two years, the ICAO’s Assembly consists of 191 member states and meets every three years. In both organizations, the Assembly elects the Council compromised of 40 states in the IMO and 36 in the ICAO. Because the Council decides on the budget and sets the agenda, membership is highly sought after (EP, 2016).
Within the IMO, to address the emissions from shipping MARPOL ANNEX VI was drafted, limiting the air pollutants from ship exhausts. However, it took 7 years for this to enter into force, since for the adoption of an ANNEX in the IMO a two-third majority is needed at the Assembly, and a subsequent ratification of two-thirds of the members, totalling at least 50% of the total shipping tonnage. MARPOL ANNEX VI put the authority of environmental protection with the MEPC, which meets annually. All 173 member states can attend, as well as the accredited observers. These include both environmental CSOs, such as Greenpeace and WWF and coalitions of CSOs such as the Clean Shipping Coalition (CSC) as well as industry associations such as ICS, INTERTANKO and BIMCO. The European Parliament and the European Commission also hold an observer status. Resolutions are adopted through voting at the MEPC with a two-thirds majority rule, though the Committee strives for consensus. Only member states can cast a vote, but both member states and observers are allowed to submit working papers to be discussed during the session. All resolutions adopted here are final, and not up for review by the IMO General Assembly. Once resolutions are adopted they apply equally to all ships regardless of the flag they fly, reflecting the IMO principle of No More Favourable Treatment (NMFT) (IMO, 2018). Below the MEPC are several subcommittees and Working Groups, consisting of both states and observers which are created at the Councils request and are of a temporary nature, assisting the MEPC in identifying possible regulations and shaping draft texts.
In the ICAO, CAEP is the committee dealing with environmental issues, which consists of 24 member states and another 15 observers, of which 5 are states and 10 organizations. Only one environmental CSO currently holds observer status in this commission, which is the International Coalition for Sustainable Aviation (ICSA). Unlike the MEPC, work of the CAEP is made available only to ICAO member states and observers through a web portal and leaking of these documents may result in legal action and loss of membership. Similarly, unlike in MEPC, the decisions that the CAEP makes are not final. The CAEP is more a body of experts that meets annually and that makes recommendations and assist in studies, which are then
reports to the Assembly (ICAO, 2018). Instead, decisions are made at the Assembly level, which strives for consensus like the IMO, although voting does occasionally occur. However, according to several interviewees, the Council at the ICAO does have more power in the decision-making process compared to the IMO Council, for example by adopting and amending the SARPS (Standards and Recommended Practices).
Socio-institutional context
To understand the functioning of the IMO and ICAO it is important not only to understand their structure and decision-making process, but also the socio-institutional context in which this takes place.
A first characteristic of both organizations is the balance of industry and environmental CSOs. Within both the ICAO and the IMO industry is far better represented than the environmental CSOs. An example of the industry-leaning socio-institutional context is the delegation composition at the IMO. Though uncommon for most UN bodies, at the IMO states often send delegations that include industry officials as formal state representatives (InfluneceMap, 2017). Another example is the imbalance in representation in the make-up of the environmental committees, such as in the previously mentioned CAEP, where of the seven non-governmental expert observers8, only one environmental NGO was invited to participate,
with the rest consisting of industry officials (icao.int). Similarly, in a CAEP working group on the development on a global MBM, unlike trade associations, no environmental NGOs were invited, even though valuable expertise of MBMs is located at CSOs (EP, 2016, pp. 29-33). The imbalance in representation in the IMO and ICAO can be the result of a mobilization bias, which favours the organization of the narrow interest of business in industry associations over the diffuse interests of a global community affected by climate change.
However, this imbalance also has a socio-institutional origin. Both the ICAO and IMO have traditionally had strong ties with industry, originating from the historical role of both organizations as standard-setting agencies for safety and security while maintaining a level-playing field. To achieve this, both organizations work closely together with industry associations, and rely heavily on their knowledge and expertise in the formulation of regulation. Since industry has most of the data and more resources to commission studies, their insights are highly valued. As such, an imbalance in representation of narrow versus diffuse
8 The three other observers are the EU, UNFCCC, and ACAC, a regional organization for coordination and
interests that is partly the result of the mobilization bias leading to a resource asymmetry, is further exacerbated by an information asymmetry.
Thus, though industry associations only function as observers themselves, they are actively engaged in the formulation and vetting of proposals. This is done either directly, through the submission of working papers, or indirectly, through state delegations. Most states see business as one of the most important stakeholders and take their preferences into consideration when positioning themselves. In the IMO, the states that most strongly represent industry interests are developing countries, that do not want regulation to increase the prices of trade or otherwise stifle economic growth, such as the BRICS, and the countries with strong shipping registries such as Liberia, Panama, Japan and China. The notable exception here is the Marshall Islands, which has one of the largest shipping registries in the world but who’s existence as a small island state is threatened by rising sea levels. In the ICAO, industry plays an important role in the position of a larger amount of states. This is because roughly half of the countries own their own national airlines, which leads to strong ties of the national aircraft operators with their transport ministers. Indeed, all interviewees signal the importance of industry associations in the policy-making process of both the IMO and ICAO.
Although an information asymmetry and an imbalance in representation have caused a difference in both access and representation of narrow versus diffuse interests, this in itself does not necessarily result in a difference in the influence. However, together with the structural power of both sectors described above, this creates a socio-institutional context that allows industry to be very impactful in the policy process. According to interviewees, if industry does not agree with regulatory proposals, getting them through becomes near impossible. This is evidenced by the statement of one Policy Officer from the European Commission who said they could not recall a single instance within the IMO when industry was not supportive of regulation but it was still adopted. Within the ICAO, the power of industry is said to be even greater.
Part of the socio-institutional context that explains this greater power of the aviation industry is the limited level of transparency in the ICAO compared to the IMO, as the previous chapter has already highlighted. While the IMO publishes all the minutes and reports of all its meetings, not all reports from ICAO meetings are made public, particularly from sub-committees like the CAEP and the Council. Similarly, not all working papers are made public. Furthermore, as the chronology will show, many important decisions were made in informal meetings behind closed doors. Though such informal meetings also take place within the IMO, they are far more prominent within the ICAO. This lack of transparency may affect the degree
to which it is possible scrutinize the policy process within the ICAO. And with less scrutiny it could become easier for business actors to get their way.
At the same time, there is said to be an “institutional tendency not to take environmental NGOs seriously”, particularly within the ICAO (EP, 2016, p. 35). An example of this is the fact that invitations to workgroup meetings are often treated as an afterthought, according to CSO officials. And CSOs are rarely invited to prepare presentations in front of the council. Similarly, there is a lack of willingness by the organization (as opposed to member states) to meet with environmental groups. But member states too tend to neglect the input of environmental CSOs (in both organizations) and often treat them with suspicion, especially states from outside the EU (EP, 2016).
Before analysing what other factors besides the socio-institutional context can be attributed to the greater influence of narrow over diffuse interests, and explain possible difference between the ICAO and the IMO climate policies, we will examine the policy process of each UN body leading up to the acceptance of first shipping’s Initial GHG Strategy and then aviation’s CORSIA.
Shipping
The policy process leading up to the IMO’s Intitial GHG Strategy, which includes its long-term reduction target, was characterized by several discussions. Firstly, there is a clash between the Paris Climate Agreement’s Common But Differentiated Responsibilities (CBDR) principle, which acknowledges that all states have a shared obligation but not all states have equally contributed to climate change on the one hand, and the IMO principle of non-discrimination, No More Favourable Treatment (NMFT), which dictates that all ships are treated equally, regardless of the flag they fly. With talks on universal design and operational standards, the friction between these principles is visible in the discussions. A second returning point of discussion concerns the speed at which the IMO moves to policy considerations, which usually follows the so-called three-step approach: first data collection, then data analysis, and finally decision-making on what further measures, if any, are required. Objections are often made to the discussion of possible measures, which are framed as premature through emphasizing this approach. The talks on MBMs from 2008 to 2010 exemplify these frictions. These talks constantly return to the problem of how to unify CBDR and no more favourable treatment, but are similarly complicated by the three-step approach, with states and observers pointing to a lack of data. Mr Abbasov, Shipping Officer for Transport & Environment, founder of the CSC, in an interview stated that a lack of data is used as an excuse to delay the process,
since the GHG studies conducted by the IMO and other organizations have, through GPS tracing, managed to give good estimates of energy efficiency and how much shipping contributes to global warming. Talks on data collection in turn are hindered by an unwillingness of states and industry associations to share sensitive data that could benefit competitors.
The talks on a reduction target face similar friction. The first mention of a long-term GHG reduction goal appears in 2003, but no decisions were made and it subsequently disappeared from the agenda. At MEPC 68, several months before the Paris Climate talks in 2015 (UNFCCC COP 21), the discussion of a long-term target resurfaces, through a submission from the Marshall Islands (MEPC 68/5/1). This submission is signalled to be the start of the policy process leading up to the adoption of an emission reduction target by interviewees. In this submission, which was crafted with the help of several environmental CSOs, the Marshall Islands proposed:
“A quantifiable and ambitious GHG emissions reduction target for international shipping, consistent with IMO's principles and that is in line with the UNFCCC's ultimate objective in Article 2, with enhanced action starting immediately and continuing well into the post-2020 timeframe.”
Though no submissions respond to the proposal, during MEPC 68 it resulted in a long discussion. In response to the submission, the Secretary-General noted that “shipping is a
servant of the world community and trade between countries, and so if the world economy and seaborne trade would grow in future then shipping will also need to grow to support the world economy”, seemingly implying that an absolute in-sector reduction of GHGs from shipping
might not be viable. In the subsequent discussion, a clear majority of the statements made was in opposition of the proposal9 and some accused the Marshall Islands of hampering
negotiations and being uncooperative. The discussion seems to have ended with the closing remark:
“The debate remains as to whether the Organization is committed to reduce emissions from international shipping along with other sectors and countries in Paris later this year, and as the answer is not a clear "yes" then it is a poor reflection on the Organization and shipping.”
According to interviewees, the initial lukewarm response to the proposal from the Marshall Islands by other ambitious states is because the IMO was in the middle of negotiating a data-reporting system, which a discussion on long-term targets was thought to jeopardise. However, later that year in response to the Paris Climate Agreement, attitudes towards the discussion of an emission reduction target changed. In the run-up to the next meeting, MEPC 69 in 2016, several parties came out in support of the Marshall Islands request, both from industry and CSOs as well as a coalition of states, all citing the Paris Climate Agreement. The International Chamber of Shipping (ICS), industry’s most active trade association, called to “discuss the commitments for CO2 emission reduction on behalf of the entire international
shipping sector” (MEPC 69/7/1, para 2). The ICS however emphasized that shipping should
not be expected to decarbonize at the same speed as other sectors10, and have a non-binding
character11. The ICS proposal calls the Committee to agree to develop such a target “as soon
as possible”. This submission gained support from a coalition of industry groups12 (in MEPC
69/7/4), as well as the Clean Shipping Coalition (CSC), the most active CSO (in MEPC 69/7/3). CSC emphasized here that work on reducing emissions should start in parallel with data collection, and thus circumvent the three-step approach13. In a similar call, a submission of the
coalition of Belgium, France, Germany, the Marshall Islands and Solomon Islands called upon the IMO to develop a working plan to determine a fair share contribution (MEPC 69/7/2). That work plan ought to consist of a way to define the required emission reduction, the types of GHGs that should be covered, the reference years, the long-term objective, and the intermediate steps. This coalition of states slowly expanded over the course of the policy process and formed the Shipping Higher Ambition Coalition14, a group pushing for more stringent climate
regulations at the IMO. During the policy process, participating states actively worked together
10 “More than half of current international shipping activity now services developing economies, a
proportion that is expected to increase in the future. An expectation that international shipping should somehow decarbonize at the same rate at which developed nations have committed to decarbonize their economies in their INDCs would therefore be inconsistent with the "spirit of Paris" and the principle of differentiation” (MEPC 69/7/1).
11 ICS proposes the use of the term IMO Determined Contribution, to avoid “the implication that some kind
of sanction might follow any reduction target not being reached”, i.e. targets should be non-binding.
12, CLIA (Cruise Line International Association), WSC (World Shipping Council), IPTA (International
Parcel Tankers Association)., and INTERTANKO.
13 The CSC states: “The Third IMO Greenhouse Gas Study 2014 projects large future increases in ship GHG
emissions and new data is not required in order to decide on the necessity for, or to start work on, new measures. This should proceed as soon as possible, build on previous work and run in parallel with further data collection (and work on identifying shipping's fair share of emissions). Any final decision on the implementation of new measures will, in any case, inevitably be taken only after the fair share work has been completed and the MRV data is flowing.”
14 Belgium, France, Germany, the Netherlands, Denmark, Sweden, Canada, the Marshall Islands, Solomon
with CSOs and, more importantly according to some, the European Commission and European Parliament. Simultaneously, states like the Netherlands engaged in the lobbying of industry associations to raise their ambition.
At MEPC 69, the topic of long-term targets was again extensively debated, centring mostly on the appropriate level of ambition, the CBDR principle, and the three-step approach. Particularly the latter remained divisive, with some insisting for the need for immediate start on the formulation of a level of ambition in the form of an action plan and others arguing that decisions on long-term ambitions should be informed by data collection, and thus be postponed. However, since the last session a shift seemed to be noticeable with more and stronger support for the proposed action plan, signalling the importance of the Paris Climate Agreement and the momentum it created. In the end the Committee “agreed to establish a
working group under this item at MEPC 70, with a view to an in-depth discussion on how to progress the matter, taking into account all documents submitted to this session and comments made, and any further related proposals”, which set in motion the development of a reduction
target.
In the run-up to MEPC 70, several members and observers separately gave fair share suggestions, though with differing urgency and level of ambition15. Similarly, several
submissions were calling for a long-term GHG strategy16. Among them is the submission of
the ICS, together with BIMCO, INTERTANKO, INTERCARGO and WSC, endorsing the plan of developing a road map to determine a fair share contribution. Here they add several principles, of which the first is “consistent with the Paris Agreement, a fair share should be
"in-sector" and take account of circumstances that are relevant to international shipping”
(MEPC 70/7/8, para. 19). This stance is surprising since in-sector reductions will likely be costlier to industry than an off-setting mechanism, but the choice for in-sector reductions does prevent that money flows out of the sector through the purchase of emission credits. The ICS however also warns against absolute CO2 reductions17. Furthermore, it called for decisions to
15 Japan opposing the idea of an emission cap (MEPC 70/7/3) as did a coalition of Angola, Brazil, Bolivia,
China, Ecuador, India, Iran, South Africa and Uruguay (MEPC 70/7/4). ICHCA floating the idea of CNG (MEPC 70/7/10). CSC on the other hand firmly stating that emissions should be in line with the 1.5-2.0°C target (MEPC 70/7/11).
16 Norway and the US call for a long-term strategy (MEPC 70/7/5), Angola et al. proposing the development
of a roadmap (MEPC 70/7/4) as do the ICS et al. (MEPC 70/7/8).
17 “An unrealistic contribution to reduce the sector's absolute CO2 emissions could lead to a shift to less
be made in line with the three-step approach18, putting the earlier invitation to the committee
to develop a target as soon as possible into perspective. The submission by ICS was subsequently supported by number of industry associations19. However, many floated their
own ideas on the three-step approach and their own reduction pathways. Thus, though there was some cooperation, industry was fragmented into associations eager to get a deal to avoid reputational damage and more conservative members. According to several interviewees, the fact that industry lacked a unifying vision allowed CSOs and the Shipping Higher Ambition Coalition to successfully push for more stringent targets. However, others pointed out that during the final stages of the policy process, less ambitious industry associations and companies were asked to keep quiet and fall in line, and suspected that if more vocal opposition would have come from inside industry, reaching a deal would have been harder given the importance of industry approval.
Either way, though some argued for delay in accordance with the three-step approach20,
the reception was far more generous compared to the reception of the submission by the Marshall Islands at MEPC 68, when efforts were made to push discussions of emission reduction targets off the agenda. Still, the submissions and the ensuing discussion do show a continuing clash of the three-step approach with a long-term target and an emissions cap with the CBDR principle21. In conclusion, however, the Committee adopted the ‘Roadmap for
Developing a Comprehensive IMO strategy on the reduction of GHG Emissions from Ships’22,
in which it aims to adopt the Initial IMO GHG Strategy, including a list of candidate short-, mid- and long-term measures and agree on the level of ambition at MEPC 72 in 2018, to be revised in 2023.
To increase the level of ambition, and ensure a deal be reached, the European Parliament formalized its threat of the inclusion of shipping into the EU ETS ahead of MEPC
18 “Until the IMO CO2 data collection system is up and running, there is insufficient data to determine
whether or not it would be realistic for IMO to adopt a firm contribution on behalf of the sector” (MEPC
70/7/8, para. 12).
19 IAPH (MEPC 70/7/9), CLIA (MEPC 70/7/12), and ICHCA (MEPC 70/7/10),
20 In support of parallel development: Antigua and Barbuda, Belgium, Côte d'Ivoire, Denmark, France,
Germany, the Marshall Islands, Monaco, Morocco, Solomon Islands and Tonga (MEPC 70/7/6), in opposition: Turkey (MEPC 70/7/6) and CLIA (MEPC 70/7/12).
21 Of the 32 comments made during the discussion, 8 related to the three-step approach, with the majority
(6) in support of it, i.e. calling for the collection of more data before setting long-term reduction targets. Also, 7 comments related to the needs of developing countries, and thus differentiated responsibility. Furthermore, 3 comments were made that related to the economic importance of shipping and rising demand, i.e. cautioning against an absolute reduction of emissions, a recurring theme in the submissions as well, often pointing to a lack of alternative fuels in shipping.
