The below is a web alert from The Standard Club recommending shipping operators to streamline their procedures, systems and responsibilities to ensure common and consistent set of procedures valid for both EU-MRV and IMO-DCS:
The Club's previous web alert on MEPC-70 outcome mentioned about IMO’s introduction of the Data Collection System (IMO-DCS), which runs in parallel to the European Union Monitoring, Reporting and Verification (EU-MRV) regulation, but on a different timeline.
IMO-DCS entered into effect on 1 March 2018, with first data 'calendar year' beginning 1 January 2019. It requires ships ≥ 5,000 GT to submit to their Administration annual reports on fuel oil consumption. This requirement was added to chapter 4 of MARPOL Annex VI under Regulation 22A.
In essence both EU-MRV and IMO-DCS are developed in the context of reduction of greenhouse gases (GHG)/carbon dioxide emissions; with a target to measure and potentially reduce the CO2 emissions in the maritime industry.
Both schemes overlap in various areas; however, two new sets of regulations, running on two different timescales, may pose some challenges for the members. The table below sets out the core components of the two systems alongside each other for ease of comparison:
|Applicability||Ships ≥ 5000 GT|
|Exemptions||Warships, naval auxiliaries, fishing vessels, wooden ships of primitive build ships not propelled by mechanical means and government ships used for non-commercial purposes.||TBD|
|Monitoring voyages||Voyages to/from EU ports||Global|
|Shipboard Plan||EU Monitoring Plan||SEEMP with amendment|
|Monitoring period||Starting 1 January 2018||Starting 1 January 2019|
|Range for monitoring||Per-voyage||Not specified|
|Data of cargo carried||Actual amount of cargo||Design deadweight (DWT)|
|Parameters||Fuel consumption & CO2 emissions||Fuel consumption & CO2 emissions|
|Distance & Time||Distance & Time|
|Transport work (based on actual cargo carried)|
|Verification||Robust verification procedures based on ISO 14064||Practical verification procedures considering the administrative burden (under discussion)|
|Verifier||Accredited by European national accreditation bodies||Flag State or Recognised Organisation|
|Reports to||European Commission||Flag State|
|Certification||Document of Compliance (June 2019)||Statement of Compliance|
|Centralized database||'THETIS MRV' operated by EMSA||Ship fuel oil consumption database managed by IMO|
|Publication||Annual reporting data including the individual ship information will be made available to the public||Anonymous data will be made available to IMO member states|
Based on this table, it is recommended to streamline the procedures, systems and responsibilities to ensure common and consistent set of procedures valid for both EU-MRV and IMO-DCS.
Members are encouraged to start considering the methodology for collecting the fuel oil consumption data that is most appropriate for each ship, which may be similar to the methodology selected for the EU-MRV Regulation since the acceptable methodologies are the same between the two schemes. The Ship Energy Efficiency Management Plan (SEEMP) shall be amended using the template outlined in Appendix 2 of MEPC.282 (70); and data collection plan should be submitted to the Flag State (or Class) for approval by December 2018.
Photo credit: Transport & Environment
Published: 26 March, 2018
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