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DNV GL © 2017 SAFER, SMARTER, GREENER DNV GL © 2017
Torsten Mundt 14. March 2017
MARITIME
EU–MRV Regulatory update & the IMO Data Collection System IPTA/Navigate Chemical and Product Tanker Conference 2017
14. March. 2017
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Agenda
introduction to IMO’s fuel oil consumption “Data Collection System”
introduction to EU’s “MRV-Regulation”
– activities in both ESSF MRV sub-groups overview on Task Force / Work Package
Concluding remarks
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IMO DCS
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The CO2 challenge for mankind
Scientists and policy makers generally agree it is critical to limit the average global warming to no more than 2°C (1.5°C)
To do this, emission need to peak very soon and then decline sharply
Uncertainties significantly reduced; science points to a CO2 stabilisation target of no more than 450 ppm
Today's level is 400 ppm CO2, increasing by 2 ppm each year…
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IMO DCS, why? a bit of background.
IMO Assembly resolution A.963(23)1 tasked the MEPC to identify and develop the necessary mechanisms needed to achieve limitation or reduction of GHG emissions from ships…
a. …
d. the evaluation of technical, operational and market-based solutions;
As result IMO developed:
– as a technical measure: EEDI,
– as operational measures: EEOI and SEEMP,
and discussed:
– Marked based measures (with new momentum since Paris agreement)
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IMO DCS & EU MRV-Regulations
1 adopted in Dec. 2003
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Fuel oil consumption Data Collection System
All vessels ≥ 5000 GT need to report fuel consumption with data collection starting 1 January 2019.
A plan for data collection (SEEMP Part II) to be included in the SEEMP latest 31 December 2018
An annual fuel consumption report (covering 1 January to 31 December), should be submitted and verified within 1 June in the subsequent year.
A confirmation of compliance will be provided after the SEEMP Part II is updated and a Statement of Compliance will be issued after the annual report is verified and submitted to the Administration
To be reported: • IMO number • Ship type • GT, NT, DWT, • Power output engines
(engines over 130 kW)
• EEDI (if applicable)
• Ice class • Fuel oil consumption,
by fuel oil type • Distance travelled • Hours underway • Methods used for collecting
fuel oil consumption data
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Fuel oil consumption Data Collection System
Amendments to MARPOL Annex VI on the Data collection system for fuel oil consumption of ships have been adopted on 28 October 2016 by RESOLUTION MEPC.278(70)
outstanding issues: • guidelines on verification • guidelines on Data base
management • circular for non-party ships
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EU-MRV
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EU-MRV regulation, why? a bit of background.
EU established for EU international maritime transport a reduction target on GHG emissions (2011 White Paper on Transport1).
in June 2013, EU set out a revised strategy for integrating maritime emission into the EU’s policy, namely Monitoring, Reporting & Verification instead of an EU-ETS and the application of a three step approach2:
1. Implementing a system for MRV of emissions
2. Definition of reduction targets for the maritime transport sector
3. Application of a market based measure (MBM).
overall MRV-processes are blue printed from EU-ETS / Aviation (i.e. GHG- validation and verification based on ISO 14065)
– this might explain lack of application of general IMO shipping terms / procedures…
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1 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2011:0144:FIN: 2 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2013:0479:FIN
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EU-MRV regulation, legally binding documents.
Three layers of legal documents exist:
1. the regulation itself: “REGULATION (EU) 2015/757 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 29 April 2015 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport, and amending Directive 2009/16/EC” consider: regulation entered into force in July 2015
2. the Implementing & Delegated Regulations: i. (EU) 2016/1927 on templates for monitoring plans, emissions reports …
ii. (EU) 2016/1928 on determination of cargo carried for categories of ships other than…
iii. (EU) 2016/2071 amending Regulation (EU) 2015/757…
iv. (EU) 2016/2072 on the verification activities and accreditation of verifiers pursuant to…
3. Guidelines supporting the regulations… are still under development… (coming slides)
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1 for download under: https://www.dnvgl.com/maritime/eu-mrv-regulation/index.html or http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:JOL_2015_123_R_0007
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EU “Monitoring, Reporting and Verification” (MRV): Reporting needs
For each ship (>5000 GT) and for each voyage* (including ballast) to, within and from EU ports
1. port of departure / arrival 2. amount and emission factor for
each type of fuel consumed in total […]
3. CO2 emitted 4. distance travelled 5. time spent at sea 6. cargo carried (ship type specific!) 7. transport work 8. differentiation of CO2 emissions
between sea and at berth
Monitoring
Reporting
Verification
Reporting needs:
*possible exemption from voyage reporting and rather bulk yearly reporting: all voyages during that year under jurisdiction of a Member State more than 300 voyages during the reporting period
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Methods for determining CO2 emissions
Actual fuel consumption shall make use of one of the following methods:
a) Bunker Fuel Delivery Note (BDN) and periodic stocktakes of fuel tanks;
b) Bunker fuel tank monitoring on board;
c) Flow meters for applicable combustion processes;
d) Direct CO2 emission measurements (less relevant, because no type approved equipment available)
Any combination of these methods, may be used if it enhances the overall accuracy of the measurement.
Fuel consumption shall include fuel consumed by main engines, auxiliary engines, gas turbines, boilers and inert gas generators.
Fuel consumption within ports at berth shall be monitored/calculated separately.
CO2 emissions = Fuel consumption × emission factor
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EU MRV Timeline: 2015-2017
J A S O N D J F M A M J J A S O N D J F M A M J J A S O N D 2015 2016 2017
1 July 2015 Entered into force
31 December 2016 Implementing acts adopted
31 August 2017 Monitoring plans submitted to accredited verifiers
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EU MRV Timeline: 2018 onwards
J F M A M J J A S O N D J F M A M J J A S O N D 2018 2019
1 January 2018 Start of first reporting period
30 April 2019 Emission report submitted
31 December 2018 End of first reporting period
30 June 2019 Publication of data by EC
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overview Task Forces
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Stakeholder engagement through the ESSF
Under the advisory body ESSF (European Sustainable Shipping Forum), the subgroups comprised of government and industry stakeholders provide the EC with input to the practical implementation of the Regulation
– ESSF MRV subgroup on “monitoring & reporting”
– ESSF MRV subgroup on “accreditation & verification”
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Subgroups to complete their work and report by June 2017
– Guideline Work is running as “Work Packages” under the Monitoring group
– within the A&V–group, the work is covered in various “Task Forces” (TF´s)
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Task Forces in ESSF verification and accreditation subgroup (1/3)
Task Force ToR´s TF leader final discussion1
TF1: Risk Assessment to be carried out by verifiers
To provide guidance how verifiers should use ship’s tracking data from an external source and how the verifier should interpret the information for the purpose of the verification of the emissions report.
Torsten Mundt, DNV GL
February 2017
TF2: Recommenda-tions for improvement
To provide examples of what would be allowed and not, which serves as a preventive means in the MRV system to safeguard impartiality of verifiers, in the form of the risk of self-review. In basis verifiers would be allowed to recommend on the “what”, but not on the “how” and verifiers cannot have any role in the implementation of the monitoring plan.
Katharine Palmer & Ged Farmer, Lloyds Register
February 2017
TF3: Materiality & verification of the emissions report
To provide guidance for verifiers how sampling, based on proven concepts and best practices, can be performed effectively in the context of maritime MRV. So as to allow for better understanding of the meaning of sampling for the emissions report verification. It also provides verifiers having less experience in data auditing insight in the relation of sampling with other verification activities and materiality.
Katharine Palmer & Ged Farmer, Lloyds Register
February 2017
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1 final discussion means the work on finalizing the document goes on until April or Mai
now: “sampling”
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Task Forces in ESSF verification and accreditation subgroup (2/3)
Task Force ToR´s TF leader final discussion
TF4: Verification of the emissions report-backward verification
To provide practical guidance on how to deal with backward verification in different scenarios (late submission of MP due to change of owner/manager, change in schedule. This both relates to content and timing.
Martine Meerburg , SGS
May 2017
TF5: Verification of the emissions report-to provide examples of how verification activities can be carried out by the verifier
To provide examples of how verification activities can be carried out by the verifier for ships reporting under the EU MRV Regulation in different aspects such as completeness of voyages, verification of information on fuel monitoring.
Julien Dufour, Verifavia
May 2017
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Task Forces in ESSF verification and accreditation subgroup (3/3)
Task Force ToR´s TF leader final discussion
TF6: Assessment of verifiers by NABs in order to issue an accreditation certificate
Practical guidance on the best way to setup the accreditation process between verifiers and NABs; how accreditation can be received in time during the initial phase (chicken and egg issue).
Niels Christian Dalstrup, EA
February 2017
TF7: How verifiers, companies and authorities should deal with the situation in which the accreditation is suspended or withdrawn
Practical guidance on how verifiers, companies and authorities should deal with the situation in which the accreditation is suspended or withdrawn close to the planned issuing date of the Document of Compliance (DOC) by the verifier.
Niels Christian Dalstrup, EA
February 2017
TF8: Monitoring Plans
Practical guidance on relevant issues for verifiers assessing monitoring plan.
Helena Athoussaki, PwC
May 2017
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Work Packages in ESSF monitoring subgroup (1/1)
Work Package
ToR´s TF leader final discussion
WP5: Guidance on the monitoring of fuel consumption
1. … provide recommendations on guidance and identify, where relevant, best practice on the monitoring of fuel consumption.
2. Address at least…: a. on Method B (fuel tank readings) in cases of
equipment failures b. fuel consumption for LNG carriers using BOG c. best practice on fuel density measurement
(taking into account varying fuel temperatures) d. guidance on expected level of uncertainties
Torsten Mundt, DNV GL
May 2017
WP6: Guidance on the determination of distance travelled and time spent at sea
1. … best practice on the determination of distance travelled and time spent at sea.
2. Address at least…: a. measurement through the water or over ground,
the possible consideration of drifting, movements for tank cleaning and interpretation of the term 'berth'
b. take into account earlier ESSF work / studies …
Wolfram Guntermann, Hapag Lloyd
February 2017
WP7 (new): Guidance for the preparation of monitoring plans
provide recommendations on guidance and identify, where relevant, best practise for the preparation of monitoring plans.
Helena Athoussaki, PwC
May 2017
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Additional MRV information
MRV regulation, all delegated / implementing acts (bottom of page under latest initiatives): https://www.dnvgl.com/maritime/mrv-regulation.html
MRV brochure on the DNV GL website under Maritime Studies and Papers; https://www.dnvgl.com/maritime/mrv-regulation.html
TECHNICAL AND REGULATORY NEWS No. 18, 2016; https://www.dnvgl.com/maritime/technical-regulatory-news/index.html
MRV webinar stream; https://www.dnvgl.com/maritime/mrv-regulation-webinar.html
and DNVGL MRV support: https://www.dnvgl.com/maritime/mrv-regulation.html
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Concluding Remarks
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CO2 – regulations and policy developments EU system becoming effective in 2018 (“EU MRV”)
IMO system becoming effective in 2019 (“Data Collection System”)
Ships must collect voyage data under both systems, allowing for monitoring, reporting and verification of CO2 emissions and vessel efficiency data
Similarities, but also significant differences between systems, with technical, commercial and enforcement implications.
Key question for industry: will systems be harmonised?
– politically difficult both inside EU and in the IMO
– several years of overlapping systems expected
IT systems for monitoring and reporting becoming a practical necessity
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Happy about any questions!
Thank you for your kind attention.
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