Deadline Nearing for CO2 Monitoring Plan for Ships

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The European Union Monitoring, Reporting and Verification of CO2 emissions from maritime transport regulation entered into force in July 2015. The regulation contains three parts –

Monitoring

From 31 August 2017, all ships >5000GT calling EU ports will be required to carry on board a CO2 monitoring plan that has been reviewed by a third party verifier (usually Class).

Monitoring will be on a per-voyage basis, and data will be aggregated into an annual emissions report. A ‘voyage’ is defined as any movement of a ship that originates from, or terminates in, a port of call (EU port) and that serves the purpose of transporting passengers or cargo for commercial purposes.

Monitoring of CO2 will be from the following emission sources on board – main engines, auxiliary engines, gas turbines, boilers and inert gas generators.

As part of the monitoring plan, the actual fuel consumption for each voyage shall be determined and calculated using one of the following methods:

  • Bunker Fuel Delivery Note (BDN) and periodic stocktakes of fuel tanks;
  • Bunker fuel tank monitoring on board;
  • Flow meters for applicable combustion processes; or
  • Direct CO2 emissions measurements.

Any combination of these methods, once assessed by the verifier, may be used if it enhances the overall accuracy of the measurement.

Verification

Once monitoring is completed, data collected in accordance with the monitoring plan will require verification by an approved third party.

After completion of the verification process the ship will be issued a Document of Compliance which will need to be kept on board for inspection.

The penalties for failing to carry a Document of Compliance may include ship detention and the issue of an Expulsion Order that prohibits entry into EU ports.

Reporting

From 2018 ships >5000GT entering, departing or operating between EU ports will be required to report their verified emissions reports and other relevant information (i.e. the first reporting period requiring monitoring will be 1 January 2018 to 31 December 2018).

From 2019, verified annual reports must be submitted to the EU Commission and the flag authority for each ship by 30 April each year.

These reports will consist of:

  • Ship and company details
  • Energy Efficiency Design Index (EEDI) or Estimated Index Value (EIV – for ships for which the EEDI is not mandatory) (as applicable)
  • The monitoring methods used
  • The results of the annual monitoring

The Commission will make this information publicly available by 30 June each year.

*Exclusions:

  • Fishing vessels
  • Warships
  • Naval auxiliaries
  • Wooden ships of primitive build
  • Ships not propelled by mechanical means, and
  • Government ships used for non-commercial purposes

The European Commission has recently released a guidance on best practices which can be found on the EU website.

Members with ships trading in EU waters are encouraged to submit monitoring plans to verifiers for an assessment prior 31 August 2017 so sufficient time is provided for compliance with the upcoming EU MRV regulations.

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Source: The Standard Club