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By North of England P&I (North P&I)

The European Union Monitoring, Reporting and Verification (EU MRV) regulation requires shipowners and operators to monitor, report and verify CO2 emissions from their vessels calling at EU ports. Two important milestones in its implementation are coming soon.

Adopted in 2015, the regulation concerns CO2 emissions released for voyages that either start or end in the port of an EU Member State, voyages between EU ports and periods at berth in EU ports. This also includes ports in the EEA countries, namely Iceland and Norway. It applies to ships above 5,000 GT regardless of Flag State.

The regulation will reach two important milestones in the next six months:

Ship-specific Monitoring Plan

The first step is to prepare a monitoring plan for each applicable vessel. The monitoring plans are subject to verification and must be submitted to an independent and accredited verifier by August 31, 2017. A verified monitoring plan must be in place before the requirements on monitoring and recording enter into force.

Companies providing verification must be accredited in accordance with ISO 14065:2013 (Greenhouse gases - Requirements for greenhouse gas validation and verification bodies for use in accreditation or other forms of recognition). Verifiers already achieving accreditation include the major classification societies as well as some independent consultancies.

The monitoring plan is a description of how monitoring and reporting will be managed. The plan should be developed in line with EU Regulation 2015/757.

As well as including the important definitions (such as 'port of call' and 'voyage'), the Regulation states that the monitoring plan should detail the method of monitoring and contain the following as a minimum:

- Information on the vessel and the shipowner or operator, complete with appropriate contact details

- A description of the CO2 emission sources on board: main engines, auxiliary engines, gas turbines, boilers and inert gas generators and what the fuel types are used in each

- A description of the procedures, systems and responsibilities to ensure the list of CO2 emission sources is kept up to date and any changes over the reporting period are accounted for

- A description of the procedures to monitor and ensure the list of voyages is complete

- A description of the procedures for monitoring the fuel consumption of the ship, including:

... the method chosen for calculating the fuel consumption of each CO2 emission source

... the procedures for measuring fuel bunkered and fuel remaining on board

... the method chosen for determining density of fuels, where applicable

... a procedure to ensure that the uncertainties in fuel measurements are consistent with the Regulation

- The emission factors used for each fuel type, or in the case of alternative fuels, the methods used to determine the emission factor

- A description of the procedures used for determining activity data per voyage, including:

... the procedures, responsibilities and data sources for determining and recording the distance

... the procedures, responsibilities, formulae and data sources for determining and recording the cargo carried and/or the number of passengers, as applicable

... the procedures, responsibilities, formulae and data sources for determining and recording the time spent at sea between the port of departure and the port of arrival

- A description of how any data gaps will be managed (e.g. in the event of a failure of a flowmeter) and the use of secondary data to fill in these gaps

- A revision record sheet to record all changes and modifications to the plan.

The EU has provided a template for the monitoring plan which can be found in Annex I of this document.

Additionally, the European Sustainable Shipping Forum (ESSF) has provided guidance which can be downloaded here.

Monitoring and Recording CO2 Emissions

Emissions monitoring and recording in accordance with the verified plan commences on January 1, 2018 on both a per-voyage basis and annual basis.

Vessels that exclusively trade domestically in an EU/EEA member state or perform more than 300 applicable voyages during the reporting period are exempt from reporting on a per-voyage basis and only need to report on an annual basis.

The ESSF have published guidelines on monitoring and reporting and can be read here.

The reporting period reoccurs annually, from January 1 to December 31 each year. At the end of each reporting period, the shipowner or operator must prepare an emissions report. This report is submitted by the end of each April. Therefore the first emissions report must be submitted by April 30, 2019.

IMO Monitoring Programme

Some industry groups have expressed concern on the EU MRV programme. Their apprehensions are not through any opposition to the principle of the regulation but due to a lack of harmony with the IMO study on greenhouse gases.

It is understood the EU were frustrated with the rate of progress of this study and acted accordingly. But in October 2016, MEPC 70 adopted a data collection system which will commence in January 2019. This will be known as the IMO DCS (Data Collection System for fuel oil consumption).

Similar to the EU MRV, the IMO DCS will apply to vessels 5,000 GT and greater. However, the monitoring plan will not be separate. Instead it will be integrated as part of the Ship Energy Efficiency Management Plan.