The Role of International Policy in Mitigating Global Shipping Emissions

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1 The Role of International Policy in Mitigating Global Shipping Emissions James J. Corbett Professor University of Delaware James J. Winebrake Professor Rochester Institue of Technology Transportation has been called one of the four cornerstones of globalization, along with communication, international standardization, and trade liberalization. 1 International markets for goods only exist because transportation allows trading to occur efficiently, and international maritime shipping has been an important engine of international trade growth. Responding to strong market signals and adopting technological innovations, the maritime industry transformed its technologies, national registries, and labor resources over the past decades to serve the demands of globalization. Shipping and other international transport providers also identify themselves as a cross-sectoral link in a global supply network that must adapt to emerging constraints related to energy supply, the environment, and economics. International policy developments are directly addressing the movement of goods by ships for both environmental and security concerns. We focus on the environmental dimensions that have engaged international shipping in the socio-political dialogue. This article discusses the role of international policy in mitigating global shipping emissions to reduce climate impacts and protect the environment. We outline three policy paradigms informing international and domestic negotiations determining greenhouse-gas mitigation targets: a) the invisible hand of the market; b) the guiding hand of performance-focused policies; and c) the firm hand of regulatory requirements and restrictions. A policy implementation framework is presented to achieve environmental goals across all commercial freight modes including international shipping. Global economics and multinational policy contexts engaging international shipping in new climate and environmental protection strategies James J. Corbett is a professor in the College of Earth Ocean and Environment and in the College of Engineering at the University of Delaware. James J. Winebrake is a professor and chair of STS/Public Policy at the Rochester Institute of Technology. They are leading collaborators in a multi-university Sustainable Intermodal Freight Transportation Research program. Copyright 2010 by the Brown Journal of World Affairs

2 James J. Corbett and James J. Winebrake may benefit from matching strengths of these policy paradigms with technological and operational opportunities for integrated action. International Shipping and Intermodal Connectivity The logistics of moving international cargo are like a relay race where different modes of transport represent different runners. Like coaches choosing which runners will carry the baton during each leg of the race, logistics managers choose which modes will move products from origin to destination. Each freight mode (road, rail, water, or air) carries the cargo for part of the distance; for most international trade, no single mode can successfully deliver door-to-door or more accurately, from factory to retailer. With respect to maritime shipping, international movement of goods relies on a global freight transportation system that includes trans-oceanic, coastal, and inland waterway routes. In fact, sea-based transport accounts for approximately 90 percent of global freight transportation (measured in ton-miles). 2 Maritime shipping is one part of a larger multimodal goods transport network where transportation managers select modes based on logistics goals and route constraints. In the recent global economy, competing mode-choice factors include time, cost, and reliability of delivery. Low-cost modes may be less preferred than faster modes if the cargo is very time sensitive; however, slower modes often carry much more cargo and, with proper planning, these lower-cost modes can reliably deliver larger quantities to meet timely inventory needs even for containerized or courier (less than a truckload) cargoes. In addition, these low-cost modes may have energy and environmental advantages that can be exploited or disadvantages that must be addressed in ways discussed below. International Shipping in an Environmental Context Global warming is a leading international concern, and anthropogenic greenhouse gas (GHG) emissions such as carbon dioxide (CO 2 ) are directly linked to climate change. These GHGs create radiative forcing, which alters the energy balance of the earth and leads to a variety of climatic problems. 3 Radiative forcing from GHGs can be distributed uniformly across the globe (e.g., CO 2 ) or with significant regional variability (e.g., aerosols interacting with clouds). Several peer-reviewed scientific papers and a recent study by the International Maritime Organization (IMO) have evaluated GHGs and other emissions from shipping. 4 The results demonstrate that, in both past and future, international shipping has been an important contributor to climate change. 5 In 2007, international shipping the brown journal of world affairs

3 The Role of International Policy in Mitigating Global Shipping Emissions emitted about 1,050 million metric tons of CO 2, which accounted for approximately 3 percent of the global CO 2 inventory. 6 If the global shipping industry were a country, it would be the sixth largest GHG emitter, exceeding Germany s emissions, according to the United Nations Millennium Development Goals Indicators. 7 In addition to CO 2, ships produce emissions of volatile organic compounds (VOC), methane (CH 4 ), black carbon (BC), organic carbon particles (OC), nitrogen oxides (NOx), nitrous oxide (N 2 O), sulfur oxides (SOx) and carbon monoxide (CO). These pollutants from shipping lead to detrimental regional impacts on air quality, coastal environments, and human health, and contribute to important climate-scale effects primarily associated with aerosol emissions ( cooling effects ) and black carbon ( short-lived climate forcers ), which will be discussed in greater detail below. 8 CO 2 emissions from ships are expected to rise considerably over the next few decades (Figure 1.a), given growth expectations in international trade. Trends and forecasts suggest shipping growth is tightly coupled with economic activity and may increase faster than non-transport sectors of similar size. Importantly, health and environmental benefits of cleaner air and cost-effective measures such as fuel switching and engine emissions controls motivated the IMO to require reductions in pollutants over the next decade, such as NOx, SOx, and particulate matter (PM). 9 Figure 1.b depicts emissions from shipping for NOx and SOx based on expected impacts of IMO policies regulating sulfur content in marine fuels and combustion control requirements. Because sulfur emissions act as global cooling agents and because ships emit large quantities of sulfur in sensitive ocean regions, regulations aimed at reducing sulfur in fuel will actually make maritime activity the only transportation mode estimated to switch from net cooling to net warming over the coming decades. 10 In other words, reducing harmful air pollutants from shipping unmasks the underlying warming effects of long-lived greenhouse gases, and may result in observed increases of climate change effects both regionally and on a global average. However, relying upon high-sulfur aerosols from ships to stave off GHG warming (one form of so-called geoengineering) may also be unwise, as it may also be as unwise as it may be infeasible given priorities to mitigate today s PM health impacts. Shipping aerosol emissions affect more than cloud reflectivity and lifetime; aerosols emitted over ocean regions also change the location of cloud formation and modify the patterns of eventual precipitation. 11 When cast simplistically as direct tradeoffs, these create a conundrum for regulators working to address both human health impacts and climate change impacts simultaneously. In addition, other types of emissions from ships contribute to regional impacts that affect sensitive ecosystems and may lead to increased climate change. For example, shipping emissions of small BC particles may accelerate ice melt in important regions, notably the Arctic. 12 As climate change melts Arctic sea ice more rapidly, access to polar

4 James J. Corbett and James J. Winebrake resources will increase the demand for maritime transport. Increased shipping in and near the sensitive Arctic may accelerate unwanted regional climate impacts from BC emissions in close proximity to ice and snow. Most dramatically, new navigable routes among major trading nations may emerge as ice recedes at least during summer and fall, for example the so-called Northeast Passage along the coasts of Russia and Scandinavia. Action to reduce short-lived forcing emissions, such as BC, may offer methods to slow global warming, especially from ships operating within sensitive regions like the Arctic. Figure 1.a: Trends in Emissions from Ships for expected CO 2 emissions given trends in demand, technology, and operations. Figure 1.b: Trends in Emissions from Ships for projected changes in NOx and SOx pollution from controls mandated by recent IMO action. Note: forecast trends conform to scenarios in the Second IMO GHG Study the brown journal of world affairs

5 The Role of International Policy in Mitigating Global Shipping Emissions Policy Paradigms Applied to International Shipping Multimodal transportation logistics serving global trade are not easily captured in traditional environmental regulations, which tend to be sector-specific and not international. International shipping has been required to meet national security policies and international trade and maritime law, but mainly through a complicated maze of flag state and port state control, exempt from most domestic regulation even though ships operate mostly at the edges of national domains with more than 70 percent of activity within the exclusive economic zones of nations). Because ships are economically linked to the shippers, other forms of transportation, and the receivers of the cargo, ship activity is becoming more visible through supply chain transparency and green marketing. In environmental contexts, the IMO is the premier international regulatory forum for international shipping, addressing environmental issues important to avoiding catastrophic damage (e.g., oil spill, invasive species) and to preserving special ecosystems (e.g., marine mammal protection). Given the global interest in reducing GHG emissions from international shipping, as well as the complex regulatory structures in which such mitigation policies would reside, a descriptive framework may help understand debate about the application of various policy alternatives. Through the United Nations Framework Convention on Climate Change (UNFCCC), nations have agreed to work with the IMO to lead climate change mitigation efforts for shipping. Like other international policy bodies, the IMO follows a consensus-action decision-making process with a tradition of technology-focused solutions that may take years to negotiate and additional years to enter into force. Compared to other international policy bodies, the strong influence of industry on the IMO process tends to reinforce the status quo. In the climate debate, the UNFCCC is engaging the IMO to develop non-incremental policies to meet new targets matching those under discussion in the international climate policy dialogue. One can frame the diversity of dialogue with respect to three paradigms that address international environmental problems (see Figure 2). Like other international policy bodies, the IMO follows a consensus-action decision-making process with a tradition of technology-focused solutions that may take years to negotiate and additional years to enter into force.

6 James J. Corbett and James J. Winebrake Policy Paradigms for International Shipping Invisible Hand: Price Signals Profitmaximizing Innovation Consumer Preferences Guiding Hand: Market-based Policies Taxes, Fees, Levies Direct Subsidies Firm Hand: Regulatory Requirements Reporting and Enforcement Regulatory Prohibitions Figure 2. Alternative paradigms informing the dialogue on environmental policy as applied to international shipping. Invisible hand of the market: Invoking Adam Smith, this represents an unfettered market in which industry is responsive only to market forces. 14 The premise is that self-interested behavior of individuals (or corporations), along with the self-regulating nature of free markets, ultimately maximizes social welfare. Under the invisible hand of the market, price signals and consumer preferences dictate industry response. Profit maximization allows those companies that are most responsive to customer requirements to stay in business. If market conditions (e.g., customer demands and preferences) expect environmental performance in shipping, then the industry will provide environmental improvements. Industry prefers an unfettered market, but this could lead to an outcome shown Figure 1a and reported in the Second IMO GHG Study: an increase in CO 2 emissions in the shipping sector. 15 Because the costs of climate change are external to the market prices for shipping goods, a need exists to look beyond the invisible hand if society wishes to control GHG emissions from ships. Firm hand of regulation: In some contexts, the invisible hand cannot identify a market-value or price of socially important behaviors. Firms will have little reason to pursue such actions if they increase cost to an industry. Where such action increases cost to an industry, firms will have little reason to pursue these. This is a tpe of market failure to which policy action may require industry to provide socially important actions or products. Maritime security zones and navigation restrictions for marine mammal protection are typical of firm-hand policies for shipping. The future scenarios for NOx and SOx, shown in Figure 1.b, illustrate the firm hand results of more than a decade of negotiations to adopt and revise the International Convention for the Prevention of Air Pollution from Ships, known as MARPOL Annex VI. the brown journal of world affairs

7 The Role of International Policy in Mitigating Global Shipping Emissions Guiding hand of performance-based instruments: Where market levers are understood, apparently missing economic signals for social preferences can be communicated through policy incentives and disincentives. Fees, levies, rebates, and subsidies are economic mechanisms set by policymakers that increase the costs of undesired actions and/or reward desired actions. Emissions trading systems act to provide these incentives, by identifying market-optimized actions that achieve environmental targets. Fees or subsidies offer the advantage of highly certain costs per unit of action, for example, fuel levies for international marine fuels or cargo fees per unit shipped; trading systems allow for market volatility in price, but can provide greater confidence in performance if so designed (e.g., cap-and-trade markets for CO 2 in Europe or SOx in the U.S.). Each of these paradigms is present in the international policy dialogue concerning shipping and environment. The question the international shipping sector faces is which approaches (invisible, firm, or guiding) are best suited for achieving GHG reduction targets. The invisible hand is not beyond influence to meet GHG emissions objectives. For example, CO 2 reductions may occur if increasing fuel prices inspire fuel saving technologies or operational changes, such as speed-reduction. 16 Additionally, voluntary eco-labeling, industry environmental management systems, and environmental awards programs may add market value to green behavior and could be pursued by industry without regulatory intervention. 17 The IMO and the UNFCCC are discussing both firm-hand and guiding hand policies for climate change mitigation, ranging from new design and operation metrics to carbon levies and emissions trading markets. Unilateral action is also proposed (and may in part motivate stronger international agreements). If the effect of IMO s multilateral initiative is unsatisfactory, the European Commission is considering a guiding hand approach that may add the shipping industry to the European Union emission trading system or include ships in emission-related harbor dues and binding CO 2 index limits. 18 In addition, possible firm-hand actions are now proposed that are taking aim at ship emissions; for instance, California enacted the Global Warming Act of 2006, requiring reduction of GHG emissions from all sectors including ships while in port. 19 Searching for Policies That Fit Government authorities have iteratively applied regulation to prevent the worst behavior while supporting voluntary measures such as industry best-practice standards across all sectors. Historically, international policy for global shipping has oscillated between relying on the invisible hand of unregulated markets and the firm hand of regulatory prescription. The choice is largely related to the perception of environmental risk and the ability of stakeholders to achieve consensus about this risk. Where consensus on the

8 James J. Corbett and James J. Winebrake urgency of action has been achieved, international negotiations have reached firm-hand agreements. For example, international agreement on prevention of tanker oil spills was protracted until the perceived risk evident in the Exxon Valdez and Erika disasters justified the cost of recapitalizing the tanker fleet with double-hull tanker designs. Other examples in shipping include IMO conventions and annexes prohibiting dumping and safety-of-life-at-sea (SOLAS) requirements. On the contrary, in cases where perceived environmental risks are low or when significant stakeholder disagreement exists about these risks, an invisible hand has been allowed to operate. Under these cases, industry may still respond with environmentally responsible behavior, as long as such behavior increases profits through cost reductions or by meeting consumer preferences. When perceived risks are uncertain or stakeholder agreement is less than unanimous, market-based policy instruments through a guiding hand could be pursued. Market-based incentives such as port fees and rebates for vessels that meet emissions standards are useful in encouraging environmentally responsible industry behavior. 20 Other examples in shipping include IMO air pollution regulations, ballast water treatment requirements, and special area designations for protecting marine mammals or ecosystems. The advantage of the guiding hand is that it maintains direct proximity to effective invisible-hand levers and enables firm-hand controls to be applied when necessary. Market based instruments offer an effective way to reduce conflict among stakeholders from politically and ideologically different points of view that must agree on environmental policy. 21 Implementation Framework for Environmental Performance A suite of potential actions can be taken by the shipping industry to improve performance and achieve regional and global targets for energy use, climate change and environmental protection. Categorically, these range from new vessel designs, innovation and diffusion of better technologies, and operational changes, which were all summarized in some detail in the recent IMO study. 22 In addition, industry, advocacy, and regulatory stakeholders are debating and ranking the merits and costs of these approaches. Improving environmental performance of movement of goods involves reconfiguring freight mode technologies, operations, and infrastructures across six dimensions (Table 1). 23 These include: a) Intermodal infrastructure; b) Fuel alternatives; c) Technological alternatives; d) Operational practices; e) Logistical realignment; and f) Demand changes for goods and packaging. This is termed the IF-TOLD framework for improving economic, energy, and environmental performance of movement of goods. Recently increasing fuel prices and requirements to reduce emissions of both traditional and GHG emissions correlates with observed responses by industry and the brown journal of world affairs

9 The Role of International Policy in Mitigating Global Shipping Emissions government to modify these IF-TOLD elements for greener freight systems. Some industry responses are consistent with either invisible hand pricing or firm hand regulation. In the maritime sector, this includes new investments in vessels and port terminals, fuel-switching, advanced retrofits for energy efficiency and emission control, slow-speed operations, new logistics routing plans, and improved matching of containerpayloads and warehouse-inventory needs in the supply chain. However, some responses are unintended, such as industry practices to hold onto second hand vessels past their design life to avoid the added cost of greener designs. An implementation framework like IF-TOLD can be matched with policy instruments that enable a three-handed synergy in international regulation. astructure Infra Fuel Tech hnology Oper rations istics Logi Dem mand Example Policy Instruments I F T O L D Performance standards Taxes Subsidies Technology mandates Infrastructure Investment R&D investment Alternative/low-carbonti fuels Size/weight restrictions Operator training/education Demand management Table 1. Example matrix of policy instruments for implementing aspects of the IF-TOLD strategy framework. Some disagreement exists among stakeholders regarding the costs and benefits of the impacts of GHG emissions and their control. We think that the guiding hand will be the regulatory approach that comes to the fore for international shipping regulations. Table 1 presents an application of different guiding-hand mechanisms across the range of IF-TOLD options. Taxes and subsidies are clearly a guiding hand approach that crosses all IF-TOLD areas. Investment in research and development and infrastructure is potentially important and viable. Finally, performance standards that normally would be considered a firm-hand approach can be combined with credit-trading as a way to price externalities instead of banning them. For example, a performance standard for

10 James J. Corbett and James J. Winebrake CO 2 emissions that allows for the buying, selling, and banking of emissions reduction credits can be used to achieve the goals of CO 2 reduction, but using a market-based approach. In this way, a number of approaches can be influenced by guiding-hand approaches to achieve goals more quickly than firm-hand approaches and with greater certainty than invisible-hand approaches. Conclusion 10 Given its visibility as a sector without nationally divided statistics of energy, emissions, or economics, shipping is unique in the climate change and energy efficiency debates of policymakers. Moreover, shipping contributes to global environmental impacts and offers solutions to environmental problems comparable to major nations but without sovereign authority to negotiate its own role for action. The environmental stakes are high and complex: shipping is the only transport mode where the climate impact will change sign (from cooling to warming) in the next several decades. Equally, the opportunity is substantial: improved performance by shipping, a key link in the supply chain, can be as transformative as when the shift to containerized ships enabled timely global logistics. From these observations of the dialogue around global shipping and environmental policy, and within the three-hand paradigms motivating policy selection, we suggest that several patterns may emerge. First, industry will still argue for the invisible hand of markets without regulation, advocating international (and preferably uniform) standards through the IMO. Second, government bodies will continue to pursue the firm hand of regulation, sometimes unilaterally in situations without much probability of multilateral consensus. For problems that are more important and critical, a firm hand will be needed, and may be chosen where consensus agrees urgent action is needed or complex barriers to market integration exist. Third, these approaches may be necessary but insufficient for the global shipping sector, which means a guiding hand approach will develop market based environmental regulatory regimes with mandatory reporting that will effectively address many environmental problems in shipping. International maritime transportation has played a crucial role in the globalization of economies, technologies, and cultures. Without policy action, the invisible hand of energy prices and trade could change shipping over the next few decades in ways that are comparable to the transition from sail to steam to motor throughout the past century. With policy action, positive transformations for the environment will be more likely. Increasingly, international organizations and national stakeholders are evaluating how best to use the guiding hand of market-based measures in shipping in negotiated treaties and/or exercising jurisdictional authority. The result could be a new the brown journal of world affairs

11 The Role of International Policy in Mitigating Global Shipping Emissions century of innovation for the movement of goods, in which shipping may again play W a linchpin role. A Notes 1. Shashi Kumar and Jan Hoffmann, Chapter 3 Globalization: the Maritime Nexus, Handbook of Maritime Economics and Business, ed. Costas Grammenos (London: Lloyds List Press, 2002): Ø. Buhaug, J.J. Corbett, Ø. Endresen, V. Eyring, J. Faber, S. Hanayama, D.S. Lee, H. Lindstad, A. Mjelde, C. Pålsson, W. Wanquing, J.J. Winebrake, K. Yoshida, Second IMO Greenhouse Gas Study 2009, International Maritime Organization (London: March 2009). 3. S. Ribeiro and S. Kobayashi; Lead Authors: M. Beuthe, J. Gasca, D. Greene, D.S. Lee, Y. Muromachi, P.J. Newton, S. Plotkin, D. Sperling, R. Wit, and P.J. Zhou; Contributing Authors: H. Hata, R. Sims, K.O. Skjolsvik, Fourth Assessment Report, Working Group III: Chapter 5, Transportation and its infrastructure, in Intergovernmental Panel on Climate Change (Geneva: 2007). 4. See Kumar 62; J. Fuglestvedt, T. Berntsen, G. Myhre, K. Rypdal, R.B. Skeie, Climate forcing from the transport sectors, Proceedings of the National Academy of Sciences 105, no 2 (2008): ; R.B. Skeie, J. Fuglestvedt, T. Berntsen, M.T. Lund, G. Myhre, K. Rypdal, Global temperature change from the transport sectors: Historical development and future scenarios, Atmospheric Environment 43 no. 39 (2009): ; K. Capaldo, J.J. Corbett, P. Kasibhatla, P. Fischbeck, S. Pandis, Effects of Ship Emissions on Sulphur Cycling and Radiative Climate Forcing Over the Ocean, Nature no. 400 (1999): ; J. Fuglestvedt, T. Berntsen, V. Eyring, I.S.A. Isaksen, D.S. Lee, R. Sausen, Shipping Emissions: From Cooling to Warming of Climate and Reducing Impacts on Health, Environmental Science & Technology 43 no. 24 (2009): Ø. Buhaug, et al., Second IMO Greenhouse Gas Study 2009, International Maritime Organization (London: March 2009). 6. Ibid. 7. Millennium Development Goals Indicators, Millennium Development Goals Report 2009, United Nations (2009), 8. A. Lauer, V. Eyring, J.J. Corbett, C. Wang, J.J. Winebrake, An assessment of near future policy instruments for international shipping: Impact on atmospheric aerosol burdens and the Earth s radiation budget, Environmental Science and Technology (2009). 9. J.J. Winebrake, J.J. Corbett, E.H. Green, A. Lauer, V. Eyring, Mitigating the Health Impacts of Pollution from Oceangoing Shipping: An Assessment of Low-Sulfur Fuel Mandates, Environmental Science & Technology 43 no. 13 (2009): ; J.J. Corbett, J.J. Winebrake, E.H.Green, P. Kasibhatla, V. Eyring, A. Lauer, Mortality from Ship Emissions: A Global Assessment, Environmental Science & Technology 41 no. 24 (2007): Jan Fuglestvedt, Shipping Emissions: From Cooling to Warming of Climate and Reducing Impacts on Health, Environmental Science & Technology 43 no. 24 (2009): A. Jones, J. Haywood, and O. Boucher, Climate impacts of geoengineering marine stratocumulus clouds Journal of Geophysical Research. 114 (2009). 12. L. Brigham, R. McCalla, E. Cunningham, W. Barr, D. Vanderzaag, V. Santos-Pedro, R. Mac- Donald, S. Harder, B. Ellis, J. Snyder, H. Huntington, H. Skjoldal, M. Gold, M. Williams, T. Wojhan, J. Falkingham, Arctic Marine Shipping Assessment 2009 Report, Arctic Council (Tromsa: 2009): Ø. Buhaug, J.J. Corbett, Ø. Endresen, V. Eyring, J. Faber, S. Hanayama, D.S. Lee, H. Lindstad, A. Mjelde, C. Pålsson, W. Wanquing, J.J. Winebrake, K. Yoshida, Second IMO Greenhouse Gas Study 2009, International Maritime Organization (London: March 2009). 14. Adam Smith, An inquiry into the nature and causes of the wealth of nations. London: W. Strahan and T. Cadell, Ø. Buhaug, et al., Second IMO Greenhouse Gas Study 2009, International Maritime Organization (London: March 2009). 11

12 12 James J. Corbett and James J. Winebrake 16. International Maritime Organization; Energy Information Administration; Department of Energy Spot Prices for Crude Oil and Petroleum Products, d.htm (accessed November 2009). 17. Aditya Mattoo and Harsha Singh, Eco-Labeling Policy Considerations, Kyklos 47 no. 1 (1994): 53-65; S.K. Swallow, R.A. Sedjo, Eco-labeling consequences in general equilibrium: A graphical assessment, Land Economics 76 no. 1 (2000): 28-36; Roger Sedjo and Stephen Swallow, Voluntary eco-labeling and the price premium, Land Economics 78 no. 2 (2002): ; Alain Nadai, The Impact of Industrial Strategy and Expert Information on Eco-Labels, Improving Regulation: Cases in Environment, Health, and Safety, (Washington, D.C. 2001). 18. European Union, Directive 2009/29/EC of the European Parliament. Directive 2009/29/EC of the European Parliament of 23 April 2009 amending Directive 2003/87/EC so as to improve and extend the greenhouse gas emission allowance trading scheme of the Community (2009). 19. State of California, AB32: California Global Warming Solutions Act of In Board, ed. A.R. (Sacramento: 2006). 20. P. Kågesonand, Economic instruments for reducing emissions from sea transport, Swedish NGO Secretariat on Acid Rain, The European Federation for Transport and Environment (T&E) and the European Environmental Bureau (EEB), (Göteborg and Brussels: 1999); B. Volk, G.A. Hader, M. Zachcial, Incentive-based Instruments for Environmentally Acceptable Sea Transportation, Institute of Shipping Economics and Logistics (Bremen: 2000); Environmental Protection Agency, The United States Experience with Economic Incentives for Protecting the Environment (January 2001). 21. J.J. Winebrake, A. Farrell, M. Bernstein, The Clean Air Act s sulfur dioxide emissions market: Estimating the costs of regulatory and legislative intervention, Resource And Energy Economics 17 no. 3 (1995): Ø. Buhaug, et al., Second IMO Greenhouse Gas Study 2009, International Maritime Organization (London: March 2009). 23. J.J. Winebrake, J.J. Corbett, Improving the Energy Efficiency and Environmental Performance of Movement of goods; ed. James Cannon (Sacramento: UC Davis, 2010). the brown journal of world affairs

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