Verifavia, an emissions verification company for the transport sector, has warned against "overcomplicating" the European Union's Monitoring, Reporting, and Verification (EU MRV) and the International Maritime Organisation's Data Collection System (IMO DCS) regulations.
The company has highlighted what it refers to as "a common and unhelpful misconception" that data must be submitted to the verifier in a certain format, pointing out that if the content is complete and compliant with the requirements of the regulations, it can be submitted in any format - from simple spreadsheets (i.e. xlsx, csv, etc.) to advanced markup language format (e.g. xml), or more complex formats used in IT systems for monitoring vessel performance.
"The verifier can then extract the data as necessary to proceed with the verification process. This gives the shipowner / operator total flexibility and places the onus on the verifier to perform its role," Verifavia explained.
Julien Dufour, CEO, Verifavia Shipping, commented: "The EU MRV and IMO DCS regulations are now both in force but continue to perplex shipowners and operators. These regulations are relatively straightforward and the industry is overcomplicating its response to meeting requirements.
Verifavia argues that when the data required for EU MRV has been collated, IMO DCS compliance is "straightforward" as it follows a similar process.
Whilst the EU MRV has 37 items on its template of requirements, the IMO DCS template has nine. And Verifavia suggests that despite there being some "minor differences" between the two systems, "the same methodologies are acceptable for both regulations".
"The IMO DCS largely flows from the EU MRV and the reality is that if shipowners comply with EU MRV, they are also likely to comply with the IMO DCS. If the content submitted to the verifier is correct, the format of the data is largely irrelevant," Dufour said.
EU MRV
The EU MRV regulation requires shipowners and operators to monitor, report and verify CO2 emissions from their vessels calling at EU ports. 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.
Shipping companies with vessels of 5,000 gross tonnage (GT) and above operating within the EU must prepare plans to monitor and report their carbon emissions, fuel consumption, distance sailed, time at sea, and associated transport work.
A Monitoring Plan must be prepared for each applicable vessel. Each plan is subject to verification and must be submitted to an independent and accredited verifier.
The deadline for Monitoring Plan assessment was December 31, 2017, and the initial reporting period commenced on January 1, 2018.
IMO DCS
In April 2015, the IMO's Marine Environment Protection Committee (MEPC) agreed mandatory requirements for ships to record and report data on their fuel consumption, distance sailed, and hours underway.
At the 70th meeting in October 2016, it was decided that these requirements would be adopted as modifications to MARPOL Annex VI.
The IMO fuel oil consumption data collection system (IMO DCS) became effective on March 1, 2018, requiring ships of 5,000 GT and above to submit to their Administration annual reports on fuel oil consumption. The first reporting period starts on January 1, 2019.
Ship owners and operators are required to update their existing Ship Energy Efficiency Management Plan (SEEMP) to document the methodology that will be used to collect the required data and the processes that will be used to report the data. They will need to have a documented plan in place to monitor CO2 emissions by the start of next year.
The IMO has a data collection system roadmap through to 2023 which is focused on developing a comprehensive strategy for the reduction of GHG emissions from shipping.
