The associations of ports, port terminalists and European towing service operators fear that under the "Fit for 55" initiatives, the possible revision of EU Emissions Trading System (EU ETS), the quota trading system of the issuance of the European Union, could lead to the introduction of provisions that undermine the competitiveness of European ports. Highlighting that they recognise and reiterate the need for the maritime sector to reduce its emissions, the association of the ports European Sea Ports Organisation (ESPO), the association of private port terminalists FEPORT and the association of the operators of the European Tugowners Association (ETA) trailer services specified that they support both the provisions to reduce emissions produced by ships and the requirements for the use of cold ironing systems, to allow the fastening to the ground power grid of ships in ports in order to extinguish the onboard engines, and for the detection of sites in which to place these facilities. However ESPO, FEPORT and ETA have urged European politicians to consider three recommendations proposed by the three associations that they believe can avoid compromising the competitiveness of European portuality.

Specifically, the two ESPO and FEPORT associations propose that the possibility of ships circumventing the EU ETS would be impeded, which would result in a relocation of carbon emissions as well as businesses. Avoidance could happen in two ways : by adding on their route a stopover to a non-EU port in order to avoid the obligation to buy quotas, or by landing the cargoes at a non-EU transshipment port in order for them to be distributed via smaller vessels that transport them to EU ports. Therefore the two associations have specified both to firmly support the measures taken by the European Parliament that make it less attractive for ships to change course, to modify the scallops or to engage in other elusive behaviour. favourably the definition of "non-EU transhipment port", both to support the inclusion in the EU ETS of non-EU ports within a radius of 300 nautical miles from the European Union. ESPO and FEPORT have made it clear that, however, this should apply to the only non-EU ports carrying out the transhipment of containers in order to avoid negatively affecting the EU trade routes and short sea shipping.

In addition, ESPO and FEPORT expressed their support for the European Parliament's proposal to create an Ocean Fund that would allow investment in the supply and recharge infrastructure in ports as well as connections to the electricity grid in ports. In this regard, the two associations are demanding that a sufficient amount of quotas be allocated to the Ocean Fund and / or the Innovation Fund to ensure the decarbonisation of shipping. According to ESPO and FEPORT, then, in bridging the price gap between conventional fuels and alternative fuels, the costs associated with the installation of new infrastructure in ports should also be taken into account.

The second recommendation is to allocate the revenue generated by the EU ETS for the maritime sector to investment in the maritime and port sector, particularly in port infrastructure. Reiterating that the transfer of cargo flows to non-EU ports and the carrying out of elusive practices, with the scaling of ships to non-EU transhipment ports and the subsequent distribution of the loads to EU ports through feeder services, continue to represent a risk, ESPO and FEPORT recommend to establish a valid monitoring mechanism, entrusting the European Commission with the task of constantly monitoring and notifying any deviation of the flows of goods or any elusive stopover as early as the first day of application of the rules. EU Commission which, according to the two associations, will also have to propose measures to counter any elusive behaviour.

The third recommendation, formulated as well as by ESPO and FEPORT also by the European Tugowners Association, is to not broaden the scope of the EU ETS by applying it no longer to the vessels of the gross tonnage of at least 5,000 tonnes, but to those with a gross tonnage of at least 400 tonnes, as proposed by the European Parliament. Explaining that the categories of vessels within the range 400-5.000 tsl are very varied and so is their use, the three associations stressed that it is therefore very difficult to ensure that the different categories of ships, and consequently the ports, do not suffer adverse effects without an adequate impact assessment. ESPO, FEPORT and ETA have led, for example, to the category of port tugboats, vessels that do not carry cargo or passengers and which have as their primary mission the safety of ports, ships and the environment : if they are on the market, they are available fuels and alternative clean technologies-the three associations noted-none of these can offer the absolute guarantee that safety will be guaranteed in any type of port in any atmospheric condition and, therefore, penning these boats because they do not use alternative fuels, as the current technology does not allow them to operate safely, it would mean sending the wrong message that a higher standard of safety entails additional costs for the operator.

Urging therefore not to change the threshold of the 5,000 tonnes of gross tonnage, ESPO, FEPORT and ETA have specified that in their view this threshold is appropriate as it includes the vast majority of the emissions from ships that make scalp in the ports of the EU and covers 90% of the maritime sector's carbon dioxide emissions, while avoiding the creation of unjustified administrative burdens for smaller vessels, moreover-they recalled-the threshold is in line with that of the European regulation on monitoring, reporting and verifying emissions of anhydride carbon generated by maritime transport, which is precisely 5,000 tsl.