The EU Emission Trading System Tax Regime and the Issue of Unfair Maritime Competition

Round 1

Reviewer 1 Report (Previous Reviewer 1)

Comments and Suggestions for Authors

Overall, the author has substantially updated the paper and thereby providing a better structured paper. Therefore, I would suggest that the paper can be accepted subject to a minor revision. Two points to address in the minor revision: 1) pay attention and review carefully Sections 5 and 6 to ensure that they provide a balanced approach in terms of arguments (e.g. in my view the use of exclamation points should be avoided in a journal article); 2) as the revision has been rather substantial a careful review of the new text may be pertinent 

Comments on the Quality of English Language

Quality of English is appropriate

Author Response

I am sending a file.

Best regards

Duarte Lynce de Faria

Author Response File: Author Response.pdf

Reviewer 2 Report (Previous Reviewer 3)

Comments and Suggestions for Authors

The revised manuscript has got new subtitles and some new interesting ideas in added text. However, the form of the manuscript is not improved. The main weaknesses remained. Academic articles are typically well structured. I recommended to the author(s) reading MDPI "Instructions for authors" (https://www.mdpi.com/journal/information/instructions). After reading a revised version, I recommend again to the author to read carefully these instructions and consider options to increase a scientific level of this manuscript. In my opinion, the author(s) failed to transform a policy paper into a scientific paper. Also, to write the paper according to the MDPI rules.

There are two types of articles acceptable for publishing in MDPI: original research manuscripts and review. Author(s) should attempt to rewrite a paper to be a review article. According to MDPI rules, "Reviews offer a comprehensive analysis of the existing literature within a field of study, identifying current gaps or problems. They should be critical and constructive and provide recommendations for future research. No new, unpublished data should be presented. The structure can include an Abstract, Keywords, Introduction, Relevant Sections, Discussion, Conclusions, and Future Directions" (https://www.mdpi.com/journal/information/instructions).

It is fine to consider policy documents and whitepapers in the article. Though, it is not enough. A scientific paper contains a review of scientific papers to arguably identify a literature gap and an avenue for further research. Considering practical implications is also fine. Author(s) has/have to be more convinced that the scientific literature has not analysed a topic considered in this manuscript. Please, see the comments on the literature.

Again, revised version of the manuscript does not meet rules related to the scientific paper, including a review paper. For example, abstract does not contain the basic parts of the paper. Particularly, a scientific contribution is missed. Literature section does not deal with a literature review. There is a lack of the comprehensive scientific literature review, which is a starting point for paper motivation, goal(s) and which proves the paper scientific contribution. See also the comments on the relevant literature. Other parts (subsections) are not well elaborated in a manner of a scientific paper.

Comments on the Quality of English Language

The manuscript is readable sufficiently.

Author Response

I am sending a file.

Best regards

Duarte Lynce de Faria

Author Response File: Author Response.pdf

Reviewer 3 Report (Previous Reviewer 2)

Comments and Suggestions for Authors

The paper is improved. However, paragraphs are way too short. Rethink the structure of the paper, and the message of each paragraph.

the bibliography and references should be formatted in line with the journal guidelines. 
send a revised clean copy 

Author Response

I am sending a file

Best regards

Duarte Lynce de Faria

Author Response File: Author Response.pdf

Round 2

Reviewer 3 Report (Previous Reviewer 2)

Comments and Suggestions for Authors

Looks better

Author Response

Thank you!

This manuscript is a resubmission of an earlier submission. The following is a list of the peer review reports and author responses from that submission.

Round 1

Reviewer 1 Report

Comments and Suggestions for Authors

The topic covered in the paper is highly important considering the urgent need to decarbonise the transport sector. This creates particular problems for a global sector like the maritime sector incl. ports taking into account that speed in terms of policies vary between countries. The paper contains substantial information about the topic. However, my recommendation for this paper is that a major revision would be required prior to it being published. Key points to address include:

- At the moment the paper is mainly descriptive except the last part of the paper, it should adopt a more analytic style / approach

- Moreover, the formatting / structure of the paper makes it harder to read. Key issues include: 1) use of different font sizes, 2) indenting of several paragraphs, 3) (too) extensive use of footnotes (part of these could be incorporated in the main text, 4) sections not numbered and the overall structure of the paper is not well explained in the introductory part

- The paper lacks focus as it covers the EUs general approach to decarbonisation, transport related initiatives on decarbonisation, measures for the maritime sector. 

- In my view a more focused paper would be relevant. This could start with an overview of the maritime sector in Europe. This could be followed by a review of the EU measures for the maritime sector with focus on those linked to decarbonisation (perhaps even limiting it to the extension of the ETS to maritime). Subsequently, the paper could assess / discuss the extension of the ETS to maritime, highlighting the advantages and disadvantages with specific focus on the challenges.

Comments on the Quality of English Language

The quality of the English is good

Author Response

Please see the attachment.

Author Response File: Author Response.pdf

Reviewer 2 Report

Comments and Suggestions for Authors

European Green Deal:

Issue addressed: Maritime industry contributed to greenhouse gas emission. ETS (EU Emission trading system) could cause shipping routes to change, as people switch to non-EU ports to escape higher costs. This in addition to the lack of carbon tax on shipping fuel by the IMO, could cause unfair competition between EU and non-EU ports. (Exacerbated by recent disruptions e.g. Houthis in Red Sea)

The article is broken down into these sections: introduction, the european green deal, european current initiatives in the port sector, other EU initiatives, ETS including shipping emissions, conclusion

Each section is broken down and explained, where proposals of dierent initiatives are listed

• -  Visually, the proposals are often inserted in the paragraphs making it look blocky and doesn't ow well

• -  It may be better to visually separate the proposals from the rest of the paragraph to make it more clear and easy to read.

  Explains the current EU initiative in maritime operations

- Need for Global Regulation, Implementation Roadmap, Energy Transition Challenges, European Green Deal (EGD) Impact, Maritime Transport and Ports Initiatives, Port Services and Environmental Regulations, Key Direct Impact Initiatives, Supporting Activities, Specic Policies and Strategies, Portuguese Presidency Priorities, Revising TEN-T Guidelines, Decarbonization and Digitalization, Carbon Border Adjustment Mechanism (CBAM), Green Ports Initiative, Air Quality Directive Review

Then goes onto explain other EU initiatives:

- Port Services Regulation (PSR), Ship Waste Management, Border Monitoring, Maritime Safety and Trac Monitoring etc

Explain the inclusion of shipping emissions to the ETS

• -  ETS will be extended to the maritime sector starting in 2024, with full coverage by 2026.

• -  maritime ETS aims for a 43% emission reduction by 2030 compared to 2005 levels.

• -  Revenues from ETS allowances will support investments in infrastructure and clean technologies.

• -  ISSUE: The inclusion of maritime transport in the ETS faces criticism due to potential unfair

  competition, risk of business and carbon leakage.

  Conclusion:

• -  The European Green Deal (EGD) outlines a strategy for addressing climate and environmental challenges by emphasising innovation

• -  Eight key objectives of the EGD outlined in the article, requires annual investment of €260 billion

• -  Financial impacts of the EU ETS on shipping will be phased in, with allowances costs varying by

  ship type and segment.

• -  Shipping route optimization and fuel eciency improvements are key strategies for reducing emissions and costs.

• -  Urgent measures are needed to prevent operational shifts from EU ports caused by ETS legislation, ensure fair competition, and avoid carbon leakage

• -  Houthis attacks on shipping routes have exacerbated the need for immediate action to sustain fair competition

• In terms of reference and relevant literature, the work of Serena Sandri on the European Green Deal would be a suitable article that would better solidify this manuscript within the relevant literature: Sandri, Serena "The European green deal: Challenges and opportunities for the Southern Mediterranean." Mediterranean Politics (2023): 1-12.

Author Response

Please see the attachment.

Author Response File: Author Response.pdf

Reviewer 3 Report

Comments and Suggestions for Authors

The manuscript considers EU policy and regulations related to maritime greenhouse gases emissions. The topic is widely explored and discussed in the paper and some interesting thoughts are presented. However, the article rather looks like a policy paper than an academic paper. The research question and hypothesis are missed. The research description and scientific contribution, as well as other standard elements of the research article are missed. Please, see Instructions for Authors - type of articles for this journal https://www.mdpi.com/journal/sustainability/instructions.

Comments on the Quality of English Language

The language is fine to me. 

Author Response

Please see the attachment.

Author Response File: Author Response.pdf

Reviewer 4 Report

Comments and Suggestions for Authors

The relevance of the article under review is due to the fact that climate and environmental problems on the planet deserve the attention of the world community. Achieving environmental sustainability in the transport industry, including maritime transport, is relevant from this point of view, since the maritime industry is the sixth largest source of greenhouse gas emissions, as well as gases such as sulfur oxides, nitrogen oxides and aerosols, and oil spills at sea. The title of the article and keywords adequately reflect its content.

In the abstract, the authors present the essence of the problem, its relevance, and recommendations. The introduction is devoted to the history of the study and the rationale for its relevance. In section 2, the authors provide an overview of studies that have covered this issue and formulate the main goal of the European Green Deal. In Section 3, the authors identify current European Commission initiatives in the international seaports sector to address the energy transition and decarbonization. Section 4 presents other EU initiatives that aim to regulate the provision of port services, protect port operators from uncertainty and improve the efficiency of public and private investment. Section 5 introduces the emissions trading system (ETS). Allows emissions from shipping to be included in the EU Emissions Trading Scheme. It is expected that greenhouse emissions will be reduced by at least 55% by 2030. The system covers emissions of carbon dioxide (CO2), nitrous oxide (N2O), etc. In section 6, the authors summarize the work on the application of the research results.

The article was prepared in accordance with the instructions for authors and corresponds to the topic of research and publication. In our opinion, the paper is in line with the topic of Greening Shipping and is of the same type as the Preliminary Study.

Comments:

1. The topic is interesting, but, in our opinion, the authors do not clearly formulate the purpose and objectives of the study. In our opinion, scientific research as part of the collection of evidence was not carried out .

2. The authors analyzed existing problems, but did not provide a rationale for the causes of global warming on Earth. There is no convincing evidence that the cause of global warming is the release of greenhouse and other gases.

3. It is known that carbon dioxide is vital for our planet and for all living organisms and the natural environment. The article does not provide data on the sources of carbon dioxide on the planet, as well as quantitative relationships in comparison with emissions during fuel generation.

4. The atmosphere is a physical system and as such satisfies the balance equations of energy, mass and momentum. All these types of balance are closely linked to each other; a violation of energy consumption will lead to a violation of the impulse balance, and therefore the thermal balance, which can accelerate the process of climate warming on Earth.

5. No studies have been conducted on the effect of temperature on the emission of carbon-containing resources. The issue of alternative sources creating the greenhouse effect, such as water vapor, was not considered.

6. There is no scientific justification for decarbonization, green energy and the energy transition to renewable energy sources; their impact on the economy and ensuring a normal life for the population, which may be negative, is not given.

Comments for author File: Comments.pdf

Author Response

Please see the attachment.

Author Response File: Author Response.pdf