The Japan P&I Club has published an article on its website to provide a summary of the latest developments regarding the Implementation Requirements for the Monitoring, Reporting and Verification of CO2 emissions from vessels (EU MRV). The new EU Regulation 2015/757 came into force on 1 July 2015.
The Regulation follows the European Parliament’s Resolution of 5th February 2014, which called upon the Commission and Member States to set a binding target of reducing domestic greenhouse gas emissions by at least 40% compared with levels observed in 1990.
Maritime transport has an impact on the global climate and on air quality, as a result of carbon dioxide and other emissions. CO2 emissions from international shipping, related to the European Union alone, increased by 48% between 1990 and 2007. However, as yet international maritime shipping remains the only means of transportation which has not been included in Community proposals to reduce greenhouse gas emissions.
In light of the developing scientific understanding of the impact of maritime transport on the global climate, it has been decided that this should be assessed regularly and that the European Commission should consider implementing policies and measures to reduce both CO2 emissions and other kinds of emissions from vessels in future. According to data provided by the IMO, the energy consumption and emissions of ships could be reduced by up to 75% by applying operational measures and implementing technologies which already exist. It is believed that the best option for reducing CO2 emissions from shipping is to set up a system for monitoring, reporting and verification (MRV) of CO2 emissions based on the fuel consumption of ships. The MRV system is set out in the form of a Regulation due to the complex and highly technical nature of the provisions introduced, the need for uniform rules applicable throughout the European Union, and to facilitate implementation of these proposals throughout the European Union.
MONITORING, REPORTING AND VERIFICATION (MRV)
Article 4 of the Regulation sets out ‘common principles’ for monitoring and reporting. For each ship with a gross tonnage above 5000GT, ship owners must provide a complete report covering CO2 emissions from the combustion of fuels whilst ships are at sea as well as at berth. It is important to apply appropriate measures to prevent any gaps in the data – the whole period must be covered (Article 4(2)). The data produced must also be accurate – the burden is on the ship owner to identify the source of any inaccuracies and prevent them (Article 4(5)).
Monitoring and reporting must also be consistent. The same monitoring methods and data sets should be used so that the data acquired can be compared overtime and any increase or decrease in emissions can be accurately monitored (Article 4(3)). The monitoring data itself must be collected and documented in a transparent manner. This will enable any independent verifier to reproduce the methods used to determine the vessel’s CO2 emissions (Article 4(4)).
Article 5 of the Regulation sets out specific methods for monitoring and reporting vessel emissions, as well as other relevant information, by reference to Annexes I and II. By Article 5(1) any of the methods set out in the Annexes may be used to determine CO2 emissions and other relevant information.
Methods for determining CO2 Emissions
It is recommended that Members look into the detailed provisions of Annexes I and II themselves. However, we include a brief summary of the key points below. Four methods for determining CO2 emissions are given in the Regulation, as set out in the following formulae: (from Annex I):
Fuel consumption x emission factor
For the emission factor, default values shall be used unless the company decides to use the fuel quality data set out in the bunker delivery note for that fuel.
For the actual consumption of fuel, Annex I provides the following approved methods:
Method A: Bunker Delivery Notes and Periodic Stock-Takes of Fuel Tanks
This method is based on the quantity and type of fuel as defined in the bunker delivery notes, compared with information gained from periodic stock-takes. The fuel at the beginning of the monitoring period, plus deliveries, minus fuel available at the end of the period and de-bunkered fuel will indicate how much fuel has been consumed.
Fuel tank readings must be carried out by methods such as automated systems, soundings and dip tapes. Whichever method is used, it must be specified in the monitoring plan. (See below.)
Method B: Bunker Fuel Tank Monitoring On-Board
This method is based on fuel tank readings for all the fuel tanks on board. The readings must take place daily when the ship is at sea and each time the ship is bunkering or de-bunkering. The cumulative variations of the fuel tank level between two readings will constitute the fuel consumed over the period, which might be the time between two port calls or time spent within a port.
As above, the method of taking fuel tank readings must be an ‘appropriate method’ and be specified in the monitoring plan.
Method C: Flow Meters for Applicable Combustion Processes
This method is based on measured fuel flows on board. The data from all the flow meters linked to relevant emission sources will be combined to determine all fuel consumption for a specific period. Again, the period might be the time between two port calls or time spent within a port.
Method D: Direct Emissions Measurement
This method may be used for voyages within the scope of the Regulation and emissions occurring in ports located in a Member State’s jurisdiction. For ships on which reporting is based on this method, fuel consumption will be calculated using measured CO2 emissions and the applicable emission factor of the relevant fuels.
This method is based on the determination of CO2 emission flows in exhaust gas stacks (funnels) by multiplying the CO2 concentration of exhaust gas by the exhaust gas flow.
Monitoring Plan
Under Article 6(1), by 31st August 2017 a monitoring plan must be submitted to the verifiers which indicates the method chosen to monitor and report emissions and other relevant information. Each ‘company’ must submit a separate plan for each ship to which the Regulation applies. Should ships fall within this Regulation only after the 31st August 2017, the plan must be submitted without undue delay (Article 6(2)).
The monitoring plan is meant to be a complete, transparent documentation of the monitoring methodology for the specific ship. It must contain:
- a) the identification and type of ship (including its name, IMO number, port of registry and owners’ name);
- b) contact details for the ‘company’ responsible for monitoring and reporting;
- c) a description of the emission sources on board (the main engines, auxiliary engines, gas turbines, boilers, inert gas generators) and the fuel types used;
- d) a description of procedures, systems and responsibilities used to update the list of emission sources;
- e) a description of procedures used to monitor the completeness of the list of voyages;
- f) a description of the procedures for monitoring fuel consumption, emission factors for each fuel type used (including how these were calculated in the case of alternative fuels);
- g) a description of the procedures used to determine activity data per voyage, a description of the method to be used to determine surrogate data (in the case of data gaps); and
- h) a revision record sheet to show any revisions which have been made.
As can be seen from the above this is a comprehensive document and therefore templates will be provided in order to streamline and standardise this process. The form these will take is as yet undecided, but it is indicated by Article 6(4) that these will be determined by means of implementing acts in the near future.
Under Article 7, the company is required to modify the monitoring plan in certain situations:
- a) if there is a change of company (i.e. another party takes on that role in relation to the vessel);
- b) if there are new emission sources or fuels are used which are not yet referred to in the monitoring plan;
- c) where there is a change in the availability of data (e.g. because new methods are being used to collect it);
- d) where data resulting from previously used methods has been found to be incorrect; or
- e) if the monitoring plan does not conform to the above requirements. (If the monitoring plan does not conform, the verifier will request that the company modifies the plan. In other circumstances, the company must notify any planned modifications to the verifiers without undue delay.)
Having chosen a method and prepared a monitoring plan, companies must then monitor emissions for each ship both on a per-voyage and annual basis (Article 8).
Where emissions are monitored on a per-voyage basis, Article 9 stipulates that the following information must be monitored:
- a) the ports of departure and arrival (including date and time of departure/arrival);
- b) the total amount and emission factor for each type of fuel consumed;
- c) CO2 emitted;
- d) distance travelled;
- e) time spent at sea;
- f) cargo carried; and
- g) transport work.
However, ships are exempted from the need to monitor emissions on a per-voyage basis if all the ship’s voyages either start or end at a port under the jurisdiction of a Member State or the shipper forms more than 300 voyages in a year.
Where emissions are monitored on an annual basis, for each ship the company must monitor:
- a) the amount and emission factor for each type of fuel consumed in total;
- b) the total aggregated CO2 emitted;
- c) the aggregated CO2 emissions from all voyages:
(1) between ports under a Member State’s jurisdiction,
(2) which departed from ports under a Member State’s jurisdiction,
(3) to ports under a Member State’s jurisdiction, and
- d) any CO2 emissions which occurred at berth within ports under a Member State’s jurisdiction.
- e) In addition, the total distance travelled, total time spent at sea, total transport work and average energy efficiency of the vessel must be monitored.
Although the monitoring plan must be submitted to verifiers by 31 August 2017, Recital 39 makes clear that the “first reporting period” begins on 1 January 2018. The purpose of the delay is to allow Member States, ship owners and others time to prepare for the MRV obligations provided by the Regulation.
Source: The Japan P&I Club
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