The deadline for compliance with the European Union’s new MRV (Monitoring, Reporting and Verification) regulation targeting CO2 emissions is fast-approaching.
By 31 August 2017, a Monitoring Plan must be submitted for any commercial ship over 5,000 GT undertaking one or more voyages into, out of and between EU ports indicating the method for monitoring and reporting CO2 emissions, irrespective of flag.
The company, which according to the regulations is the shipowner or any other organisation or person, such as the manager or the bareboat charterer, which has assumed the responsibility for the operation of the ship from the shipowner must submit the developed Monitoring Plan to a verifier accredited by an EU recognized accreditation body, and collect information and develop the Emission Report in accordance with the assessed Monitoring Plan.
The scheme therefore pushes ahead of IMO’s Energy Efficiency Design Index for new vessels, and its Ship Energy Efficiency Management Plan, which are the first steps in putting greenhouse gas emissions provisions in place for ships.
From 1 January 2018, under the EU scheme, the companies must be able to supply per-voyage and annual monitoring statistics. By April 2019, and by the same time in each subsequent year, verified annual emission reports must be submitted to the EC and the relevant flag state.
As of 30 June 2019, all ships must carry a valid Document of Compliance (DOC) covering the relevant reporting periods. EU Member States will be able to penalise the companies for failure to comply and, in the case of ships that do so for two or more consecutive reporting periods, penalties may include an expulsion order - notified to the EC, EMSA, the other EU Member States and the flag State concerned. Ultimately, EU regulators also see the MRV scheme as the basis for CO2 reduction targets.
ClassNK became one of the world’s first classification societies to receive accreditation from the United Kingdom Accreditation Service as an EU MRV verifier, effective from 1 March 2017.
“With extensive experience in the GHG verification, we are committed to providing the same high-quality assurance services for the EU MRV assessment and verification activities,” says Toshiro Koiwa, Director of ClassNK’s Assurance Operations Division.
Compliance demands transparent documentation of both method and procedures for each ship. Accordingly, the ClassNK service assesses Monitoring Plans, verifies Emission Reports and issues Documents of Compliance (DOC). After verification of the Emission Report and issuance of the DOC, companies must retain the DOC on board the ships.
The monitoring plan itself needs to contain details of the ship and its responsible party, plus a description of CO2 emission sources on board the ship, such as main engine, auxiliary engines, gas turbines, boiler and inert gas generators, and fuel types used. A description of the procedures for monitoring the fuel consumption of the ship is also required.
On a per voyage basis, companies need to monitor port and hour of departure, port and hour of arrival, amount and emission factor for each type of fuel consumed in total, CO2 emitted, distance travelled, time spent at sea, cargo carried, and transport ‘work’ (distance travelled x amount of cargo carried). These figures must also be provided on an annualised basis.
The reporting procedure relies on the use of properly formatted software. For authorised ClassNK users, this interaction takes place via the ClassNK MRV Portal, with companies submitting data and documentary evidence.
Once data and documentary evidence from the ship or from shore have been sent to the server, the company can check the stored data by using the ClassNK portal's visualization function. The software is an optional service for EU MRV that automatically notifies the shipping company if the accumulated data contains errors in accordance with the criteria which is set by the company. The benefit for companies that choose this service is that entries can be validated to ensure the smooth submission of the emission report to the verifier.
Mr Koiwa says the ClassNK MRV Portal minimizes the workload for shipping companies by controlling and accumulating voyage data in accordance with the EU MRV Regulation, effectively reducing the number of man-days required for emission report preparation.
The service also makes sure that the appropriate information is shared between ships and shore and reduces the follow-up work needed on board by following daily work flows, while the alerting system improves the accuracy of reported data. ClassNK certification services for EU MRV demonstrably reduce costs, Mr Koiwa says.
Following its accreditation in March, ClassNK has been working very hard to raise awareness among key clients of their impending responsibilities, and of the fully developed services that the Society has already put in place. ClassNK Consulting Service Co. Ltd., an independent company, also provides complementary EU MRV services, such as offering guidance on management plan development.
ClassNK believes that the standardized reporting involved in MRV may offer the consistency that can later be exploited for wider vessel performance monitoring and contribute to an ever advancing industry.