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Page 1: Blanc Doc - intertanko.com _Wor…  · Web viewtotal annual fuel consumption / annual transport work. ... when the Annual Emissions Report fulfils the requirements, issue a Document

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Version number Date1.0 12 May 2017

INTERTANKO Guidance to support drafting the template required forMonitoring Plan under EU MRV Regulation

Introduction

This Guidance is aimed to assist INTERTANKO Members in meeting the provisions of Regulation (EU) 2015/757 on the Monitoring, Reporting and Verification of carbon dioxide emissions from maritime transport (EU MRV Regulation).INTERTANKO Guidance will include advice and clarification for the Monitoring Plans and for the Annual Emissions Reports for oil tankers (including Shuttle Tankers), product tankers, chemical tankers and LNG/LPG carriers. However, the advice is for generic guidance only. Individual companies should develop their own Monitoring Plans for the specifics of their tankers.

The aim of this guidance is to clarify details on the data that needs to be included. It is not to be considered as the model for a ship Monitoring Plan.

Background

The EU Regulation 2015/757, also known as the EU MRV (monitoring, review and verification) Regulation, has entered into force on 1st July 2015

EU MRV Regulation mandates ships over 5,000 GT to report annual (calendar) aggregate operational data for each completed voyages to and from an EU Member State port as given in the table below.

SHIP IDENTIFICATION OPERATIONAL DATAName of the ship & IMO # Total annual fuel consumption (at sea and in port)

Port of registry & home port Total annual CO2 emissions (at sea and in port)

Name of the ship owner Total annual distance travelled

Ship type Total annual time spent at sea

DWT & GT Energy Efficiency indicators :

• total annual fuel consumption / total annual distance

• total annual CO2 emissions / total annual distance

• total annual fuel consumption / annual transport work

• total annual CO2 emissions / annual transport work

Class; Ice class; Flag (voluntary entries)

(CO2 emissions = fuel consumption x carbon factor)(annual transport work = total distance travelled x total cargo carried)

The reported data does NOT include:

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• port calls with no cargo operations – i.e. stops for fuelling, crew change, emergencies and voyage to dry-dock

• STS cargo operations outside port waters

For compliance, the MRV Regulation requires ships to:

• develop a Monitoring Plan and submit it for Verification (deadline 31st August 2017)• initiate first monitoring period for 1st January 2018 – 31st December 2018• submit an Annual Emission Report for Verification (deadline 30th April 2018)

Verifiers should:

• be accredited by one of the EU Member States National Accreditation Body• assess the conformity of the Monitoring Plan• assess the conformity of the Annual Emissions Report• when the Annual Emissions Report fulfils the requirements, issue a Document of

Compliance to the ship, valid 18 months from the end of the reporting period which was assessed

A list of all regulations and web access to them are as follows:

EU MRV Regulation 2015/757http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_. 2015.123.01.0055.01.ENG

EU Regulation 2016/2071 (amendments to Annexes I & II for clarification on distance, time and CO2 emissions calculation)http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_. 2016.320.01.0001.01.ENG

EU Regulation 2016/2072 (amendments to verification & accreditation provisions)http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_. 2016.320.01.0005.01.ENG

EU Regulation 2016/1927 (mandatory templates for Monitoring Plan, Annual Emission Report and Document of Compliance) http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_. 2016.299.01.0001.01.ENG

EU Regulation 2016/1928 (defining “ship types” & determination of the cargo carried)http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_. 2016.299.01.0022.01.ENG

In addition, the European Commission will issue various sets of guidance containing examples on how provisions and practices may be addressed. Listed below are the final drafts of Guidance which are most relevant to complete the Monitoring Plans:

• Guidance on Fuel (oil) Monitoring

• Guidance on LNG /Boil off Gas Monitoring

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• Guidance for monitoring voyages

• Recommendations on guidance for the preparation of the Monitoring Plans

• Practical guidance on relevant issues for verifiers assessing the Monitoring Plans

• Guidance for backward assessment of the Monitoring Plan (ships with unforeseeable EU port calls after 31st August 2017 which had not submitted Monitoring Plans)

The final drafts are attached. The official versions will be posted to the INTERTANKO web site as soon as they are made available.

The European Commission has also posted a Frequent Asked Questions List which can be accessed at https :// ec.europa.eu/clima/policies/transport/shipping_en#tab-0-3

General Remarks

Legal clarifications offered by the European Commission on provisions for the Monitoring Plans as required under the MRV Regulation (EU MRV Regulation 2015/757) are

Article 6:

• requires and establishes the minimum content of Monitoring Plans• shipping companies may determine who assumes the MRV obligation for submitting

the Monitoring Plan (entity called “MRV company”: e.g. ship owner, operator, . . . )• mandates accredited Verifiers to assess Monitoring Plans according to auditing

techniques (verification is concluded when Monitoring Plan found “in conformity” with the regulations)

Article 7: identifies the circumstances which may legally trigger modification of the Monitoring Plan (change of MRV company, due to non-conformities issued by the verifier, . . . )

Article 13: contains principles for the assessment of the MPs and identification of non-conformities by verifiers

The MRV Regulation requires ships to use electronic template forms for:

the Monitoring Plan to be submitted for verification by 31 August 2017, the Annual Emissions Reports and Document of Compliance.

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The original formats are provided in the EU Regulation 2016/1927 of 5 November 2016 and can be downloaded from the list of links above.

According to the European Commission, the mandatory template forms provided in EU Regulation 2016/1927 lay down the generic format and the minimum set of data expected to be included.

However, note should be taken that some data and tables are relevant for specific ship types only. Therefore, ships may adapt their own template forms by not including tables or rows of tables if the data required is not relevant to that type of ship.

Companies may also split the Monitoring Plan into:

• a Company specific and • a Vessel specific.

Company specific MP may include the tables B2 , B5, D, E and F1.

Companies may indicate at the beginning of the template which tables are Company Specific. Company specific part can be used horizontally for all vessels, where Vessel specific part is on individually basis.

The template requires information on various “procedures” across many activities related to monitoring of data and for description of methodologies used to check the completeness of the data, transmission of the data, quality control of measurement equipment, fuel consumption for cargo heating (voluntary), fuel consumption for use of dynamic positioning systems (voluntary), determining (voluntary) the average cargo density, etc. These procedures would be inserted into the respective tables either by direct reference to the current internal procedures as part of the ISM Code or could be presented into detail as annexes to the Monitoring Plan.

Fuel consumption “in port” – Fuel consumption during the time between ship being moored at the first berth of the port and time when ship leaves the last berth of that port. In cases ships have different practices (e.g. assessing bunker remaining on board at the pilot station) the fuel consumption from that place to the first berth could be calculated.

The table below (N.B. it is NOT part of the template) gives an example on language and style for filling in the requested information. This may promote easy communication with verifiers and avoid misunderstandings that could potentially lead to unnecessary costs..

Title Guidance Example

Reference to existing procedure Enter the name of the manual, the chapter and paragraph.

Office Operations Manual, Chapter 7.2.1

Version of existing procedures Use version or date of the doc Version 2

Description of EU MRV procedures if not already existing outside the MP

Describe the procedures or leave empty if a reference is made above

See procedure on Guidance on fuel oil monitoring

Name of person or position responsible for this procedure

Based on the official organogram Operational manager, HSQE manager, Master, etc.

Location where records are kept Ref to the company address and department or onboard ( master’s office)

Company's Office/Technical Department Files

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Name of IT system used Use name, version and module of the system used within procedure, as per IT system provider manual. For internal system specify characteristics for identification.

Software X,Module: vessel management

Data source Enter the source from where the data is collected

Noon Report, Oil Record Book, BDN, GPS etc.

Finally, a general important interpretation on how to consider STS cargo operations taking place between two ports of call (including cargo operation by Shuttle Tankers at offshore locations):

If STS cargo operation is carried out within any EU port limits, is to be considered a port of call as such - meaning the start or the beginning of a voyage under the scope of the EU MRV Regulation. In this case, ship’s activity will be considered “in port” activity i.e. fuel consumption at berth.

If STS cargo operation is carried outside port limits, it is not to be considered a port of call and rather considered as part of the voyage, i.e. fuel consumption during the STS operation is added to the fuel consumption of the voyage. The cargo will be subject to a weighted average. This is either if the ship starts on an EU-Port or ended at an EU-Port - meaning EU ports of call and meaning a voyage under the scope of the EU MRV Regulation.

If STS cargo operation is carried outside port limits, and if the voyage has started on a non EU port and ended at a non EU port - meaning non-EU ports of call, nothing is to be reported.

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Guidance for the Monitoring Plan Template (EU MRV Regulation)

Preamble

The tables included in this Guidance are as per the original format of the template provided by EU Regulation 2016/1927..

Text in red and CAPITAL LETTERS are just examples on what can be filled in.

Text in red provides explanatory notes on each specific table as appropriate.

The text in red and italics is text taken direct from the final drafts of the European Commission Guidance.

Remember: Deadline for submission of the Monitoring Plans to Verifiers is set for 31st August 2017.

HOWEVER – Article 6(2) may allow later submittal – Notwithstanding paragraph 1, for ships falling under the scope of this Regulation for the first time AFTER 31 August 2017, the company shall submit a MP to the verifier without undue delay and not later than two months after each ship’s first call in a port under the jurisdiction of a member State. (see also reference to Guidelines for backward assessment of the Monitoring Plan)

IMPORTANT: any comments should be send ASAP to [email protected].

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Monitoring Plan Template

Part A - Revision record sheet Version No

Reference date

Status at reference date (1)

Reference to Chapters where revisions or modifications have been made, including a brief explanation of changes

Part B - Basic data

Table B.1. Identification of the shipName of the shipIMO identification number B SEE ADVICE BELOWPort of registryHome port (if not identical with port of registry)Name of the shipownerIMO unique company and registered owner identification numberType of the ship (2)

Deadweight (in metric tonnes)Gross TonnageClassification Society (voluntary)Ice class (voluntary) (3)

Flag State (voluntary)Voluntary open description field for additional information about the characteristics of the ship C

SEE ADVICE BELOW

B Verifiers may check the IMO identification number with the IHS database. Please make sure the IHS Database has the correct IMO number.

C The field on “voluntary open description” may include information related to the specifics of the ship’s activities. This information may help to gain a better understanding of the potential fluctuation of CO2 emissions between certain voyages or reporting periods (e.g. dry docking, breakdown, cargo heating, etc.). Oil Tankers should include information on using cargo heating systems and DP Shuttle Tankers may need to include the installed power on the DP systems (to explain the higher fuel consumption) Companies may insert additional technical characteristics of ships that may affect the operational efficiency of the vessel (e.g. Mewis Duct, Propeller boss cap fin, Anti-fouling, Hull surface coating)

Table B.2. Company informationName of the companyAddress Line 1Address Line 2CityState/Province/RegionPostcode/ZIPCountryContact personTelephone numberEmail address

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Definition of a “company” in the EU MRV Regulation (Article 3 (d)) provides flexibility to be decided on who is the reporting entity, i.e.:

• the ship owner • the ship operator or • the ship manager/bareboat charterer

Therefore, the name for the “ship owner” in Table B.1 and the name of “the company” in Table B.2 may not need to be the same.

Table B.3. Emission sources and fuel types usedEmission source reference no.

Emission source (name, type)

Technical description of emission source(power, specific fuel oil consumption (SFOC), year of installation, identification number in case of multiple identical emission sources, etc.)

(Potential) Fuel types used (4)

1 MAIN ENGINE TYPE OF THE ENGINE, MAKER AND DATA REQUIRED ABOVE

HFO, LSFO, ULSFO, MGO

2 AUXILIARY ENGINE

TYPE OF THE ENGINE, MAKER AND DATA REQUIRED ABOVE

HFO, LSFO, ULSFO, MGO

3 BOILER TYPE OF BOILER, MAKER AND RELEVANT DATA

HFO, LSFO, ULSFO, MGO

Verifiers may request copies of:• Certificates (e.g. Certificate of Registry, Certificate of Class)• Certificates of emissions sources (e.g. EIAPP)• General Arrangement Plan• Flow meters installation diagrams-piping diagrams• Description of calibration and details of flow meters• Bunkering/Fuel Management/Fuel Testing (storage of BDNs & noon reports, etc.)• Procedures, processes and/or flowcharts• Data Management systems (IT landscape incl. IT maintenance planning system)• Company’s Manuals (SEEMP, relevant Section of ISM Manual)• Control activities (risk assessment, handling data gaps, responses / handling of non-

conformities, other relevant items as part of the quality assurance etc.) • Any other information on the exiting management system relevant to MP assessment

Table B.4. Emission factors Fuel type IMO emission factors

(in tonnes of CO2/tonne fuel)

Heavy Fuel Oil (Reference: ISO 8217 Grades RME through RMK) 3,114Light Fuel Oil (Reference: ISO 8217 Grades RMA through RMD) 3,151Diesel/Gas Oil (Reference: ISO 8217 Grades DMX through DMB) 3,206Liquefied Petroleum Gas (Propane) 3,000Liquefied Petroleum Gas (Butane) 3,030Liquefied Natural Gas 2,750Methanol 1,375Ethanol 1,913Other fuel with non-standard emission factor D 3.151

In case of use of non-standard emission factors:Non-standard fuel Emission

factor EMethodologies for determining the emission factor (methodology for sampling, methods of analysis and a description of the laboratories used, if any)

e.g. HDMO 50 ? ?

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D “other fuel oils with non-standard emissions factors” (i.e. new products used in ECA but not defined under the ISO 8217) would all fall under the characteristics of the Light Fuel Oil/RMA-RMD grade and have the emission factor of 3.151

E if the maker of a «non-standard fuel oil» provides the specific value of the emission factor, this value and the methodology used to find it have to be provided

Table B.5. Procedures, systems and responsibilities used to update the completeness of emission sourcesTitle of procedure Managing the completeness of the list of

emission sourcesReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureLocation where records are keptName of IT system used (where applicable)

Example given by the European Commission Guidance:

• Procedure : In case any change in the emission sources occur for the vessels under the Company’s management, the Technical Manager is responsible to fully inform the assigned Superintendent Engineer for the changes and provide them with all the necessary information.

• The responsible assigned Superintendent Engineer must review and update the list of the emission sources in the related Monitoring Plan(s) and in any other report and document that the Company maintains with the latest information of the emission sources on board, when applicable, in order to ensure completeness and accuracy

• Name of person or position : Assigned Superintendent Engineer / Technical Department• Location where records are kept : The list is saved at the vessel's Monitoring Plan which is

located at the Company's Office/Technical Department Files.

Part C - Activity data Table C.1. Conditions of exemption related to Article 9(2)Item Confirmation

fieldMinimum number of expected voyages per reporting period falling under the scope of the EU MRV Regulation according to the ship's scheduleAre there expected voyages per reporting period not falling under the scope of the EU MRV Regulation according to the ship's schedule? (5)

Conditions of Article 9(2) fulfilled? (6)

If yes, do you intend to make use of the derogation for monitoring the amount of fuel consumed on a per-voyage basis? (7)

Article 9(2) – exemptions for monitoring on per-voyage basis if over 300 voyages

Table C.2. Monitoring of fuel consumption

C.2.1. Methods used to determine fuel consumption of each emission source:Emission source (8) Chosen methods for fuel

consumption (9)

SELECT BETWEEN “All sources”, “Main Engine (s)”, “Auxiliary METHOD A, B, C

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engine(s)”, “Gas turbines(s)”, “Boiler(s)” or “IGS generator”,

The company may select more than one method for each emission sources.

Calculation/assessment of fuel consumption per emission source is allowed.

Fuel consumed “in port” - Fuel consumption during the time between ship being moored at the first berth of the port and time when ship leaves the last berth of that port. In case ships have different practices (e.g. measuring bunkers remaining on board at the pilot station), the fuel consumption from that place to the first berth could be calculated.

C.2.2. Procedures for determining fuel bunkered and fuel in tanks:Title of procedure Determining fuel bunkered

and fuel in tanksReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureLocation where records are keptName of IT system used (where applicable)

Ship can make reference to existing various procedures in the ship’s ISM Code.

Alternatively and forease of verification, ship may include a specific procedure for fuel oil monitoring. Such a specific procedure, if provided, it should be annexed to the MP (see reference to final draft of Guidance on Fuel Monitoring which will be issued by the European Commission). IT system – include information on the provider and any relevant reference. It is not yet clear how much “verification” should be performed on software.

Example given by the European Commission Guidance

• Procedure : detailed procedure can be found in the XXXX• Responsible Person : Chief Engineer, Operations Manager• Location where records are kept : log book (on board), noon report (on board / op. dept.) • Name of IT system used : the system where documents are stored (e.g. ERP system)

C.2.3. Regular cross-checks between bunkering quantity as provided by BDN and bunkering quantity indicated by on-board measurement:Title of procedure Regular cross-checks between bunkering quantity as provided

by BDNs and bunkering quantity indicated by on-board measurement F

Reference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedure

F Example given by the European Commission Guidance:

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“The Chief Engineer performs cross-checks between the sounding readings and the BDN(s), every time upon completion of the bunkering operations. The quantity and receipt number of the BDN(s) are recorded into the Sounding Form located on board”.

This could be improved or modified as appropriate.

C.2.4. Description of the measurement instruments involved:Measurement equipment(name)

Elements applied to (e.g. emission sources, tanks)

Technical description(specification, age, maintenance intervals)

NAME OF THE MANUFACTURER & MODEL

This applies to all measurement equipment whether it is a flowmeter, radar or other measurement equipment used, including sounding tapes.

C.2.5. Procedures for recording, retrieving, transmitting and storing information regarding measurements:Title of procedure Recording, retrieving, transmitting and storing

information regarding measurementsReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureLocation where records are keptName of IT system used (where applicable)

Example given by the European Commission Guidance

Procedure: Recording and retrieving: The Chief Engineer responsible for recording fuel measurements performing manually daily tank soundings. Chief engineer then informs the Master who is responsible for retrieving these values and entering them into the X system in order to be transmitted to shore.

Transmitting and Storing: The exchange of information or “transmitting” regarding fuel measurements for all CO2 emissions sources installed on board, is governed by internal procedure (reference) sets clearly the steps which need to be followed: four types of reports (arrival, departure, noon and port) are sent from the Master through the system X to the Technical and Operations departments on shore each with specific values on the fuel consumed per CO2 emission source at specific time intervals.

C.2.6 Method for determination of density:Fuel type/tank

Method to determine actual density values of fuel bunkered (10)

Method to determine actual density values of fuel in tanks (11)

Information on the determination / calculation of the fuel density may be part of the ship’s existing Bunkering Procedure. In such a case, information provided in this table could only make reference to the existing Bunkering Procedure.

C.2.7. Level of uncertainty associated with fuel monitoring:Monitoring method (12) Approach used (13) Value

DEFAULT orSHIP SPECIFIC

+/- 10%?

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It was agreed that, temporarily, Monitoring Plans include a default value of +/- 10% (see final draft of the Guidance on Fuel Monitoring which will be issued by the European Commission) If ships use two monitoring methods, the same default value of +/- 10% could be used for each method . However, if they so wish, ships can be more specific on a combined uncertainty. The default values are not mandatory. Therefore, ships may choose a ship specific uncertainty but, in such a case, the method for establishing such a specific value needs to be checked and approved by the Verifier.

C.2.8. Procedures for ensuring quality assurance of measuring equipment:Title of procedure Ensuring quality assurance of measuring

equipmentReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureLocation where records are keptName of IT system used (where applicable)

Example given by the European Commission Guidance (in case of manual sounding):

Before performing a sounding, the Chief Engineer or the crew member assigned by the Chief Engineer to perform the sounding, shall make sure that the sounding tape to be used:

• is of sufficient length for the height of the tank to be gauged• is graduated in inches, and fractions of an inch; feet and hundredths of a foot; or meters,

centimeters, and millimeters (markings are visible)• is not kinked or spliced.

In case any of the above does not hold, then the sounding tape should be discarded and a sounding tape fulfilling the criteria above shall be used.

Example given by the European Commission Guidance (in case of flow meters) :

The quality of measuring equipment is supported by the fact that company performs maintenance and calibration of flow meters according to the manufacturer’s specifications and if not feasible by the operating experience. This is outlined in the company’s Planned Maintenance System (PMS) which describes clearly the procedure and the roles of doing so. Additionally the technical department checks periodically the output of the flowmeter to ensure that works properly.

If a flow meter malfunctions, then the chief engineer informs the technical department and all the necessary steps are followed to immediate replace it.

C.2.9. Method for determining the split of fuel consumption into freight and passenger part (for ro-pax ships only): IRELEVANT FOR TANKERS / CAN BE REMOVED

C.2.10. Procedures for determining and recording the fuel consumption on laden voyages (voluntary monitoring):Title of procedure Determining and recording the fuel

consumption on laden voyagesReference to existing procedureVersion of existing procedure

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Description of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureFormulae and data sourcesLocation where records are keptName of IT system used (where applicable)

C.2.11. Procedures for determining and recording the fuel consumption for cargo heating (voluntary monitoring for chemical * tankers): Title of procedure Determining and recording the fuel

consumption for cargo heatingReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureFormulae and data sourcesLocation where records are keptName of IT system used (where applicable)

* It should be applicable to all tankers that transport heated cargo. Information needs also to be made in Table B.1 at “Voluntary open description field for additional information about the characteristics of the ship”

C.2.12. Procedures for determining and recording the fuel consumption for dynamic positioning (voluntary monitoring for oil tankers and ‘other ship types’):Title of procedure Determining and recording the fuel consumption

for dynamic positioningReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureFormulae and data sourcesLocation where records are keptName of IT system used (where applicable)

Shuttle Tankers with DP systems should enter information on their extra installed power and additional fuel consumption in Table B.1 at “Voluntary open description field for additional information about the characteristics of the ship”

Attention to be paid to the interpretation on how to record fuel consumption for ships having STS or at offshore position cargo operations (see last clarification under General Remarks).

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Table C.3. List of voyages G

Title of procedure Recording and safeguarding completeness of voyages

Reference to existing procedureVersion of existing procedureDescription of EU MRV procedures (including recording voyages, monitoring voyages etc.) if not already existing outside the MPName of person or position responsible for this procedureData sourcesLocation where records are keptName of IT system used (where applicable)

Example given by the European Commission Guidance:

Procedure: The recording of all voyages is done through the noon, arrival, departure and port reports which are reviewed by the Operations Department. This information is processed through system X, which maintains information for all voyages. The filtering of EU MRV voyages is done through the XY system as per EU voyage definition.

G Attention to be paid to the interpretation of a “voyage” when ship has a stop for STS cargo operations (see last clarification under General Remarks).

Table C.4. Distance travelled Title of procedure Recording and determining the

distance per voyage madeReference to existing procedureVersion of existing procedureDescription of EU MRV procedures (including recording and managing distance information) if not already existing outside the MPName of person or position responsible for this procedureData sourcesLocation where records are keptName of IT system used (where applicable)

Distance travelled is determined as distance over ground. Should the vessel be adrift (i.e. while waiting for a berth) the distance should be included as the vessel is considered underway.

Example given by European Commission Guidance:

The distance travelled is calculated by the two (2) Electronic Chart Display and Information System (ECDIS) which are installed on board per vessel and connected with the two (2) GPS apparatus. The Master reports distance travelled through the daily messages (departure/ noon/arrival) and records distance travel on the Log Book

Procedures for determining and recording the distance travelled when navigating through ice (voluntary monitoring):Title of procedure Determining and recording the

distance travelled when navigating through ice

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Reference to existing procedureVersion of existing procedureDescription of EU MRV procedures (including recording and managing distance and winter conditions information) if not already existing outside the MPName of person or position responsible for this procedureFormulae and data sourcesLocation where records are keptName of IT system used (where applicable)

Table C.5. Amount of cargo carried & Number of passengersTitle of procedure Recording and determining

the amount of cargo carried and/or the number of passengers

Reference to existing procedureVersion of existing procedureDescription of EU MRV procedures (including recording and determining the amount of cargo carried and/or the number of passengers and the use of default values for the mass of cargo units, if applicable) if not already existing outside the MPUnit of cargo/passengers (15)

Name of person or position responsible for this procedureFormulae and data sourcesLocation where records are keptName of IT system used (where applicable)

Example given by the European Commission Guidance for a Tanker

Procedure: Before loading, the Chief Officer performs ullage measurements using portable instruments (which are certified and annually inspected). A second ullage measurement is performed again upon completion of loading.

Ullage measurements on all cargo tanks are converted from volume to mass of cargo through utilisation of density. Cargo calculation reports are then cross checked by the Captain with the Bill of Lading (B/L).

Loading takes place always at the presence of a Cargo Surveyor (who can be from the supplier’s side when loading or buyer’s side when unloading).

As a control, a second measurement can be obtained from electronic cargo tank soundings which are conducted by the Chief Officer before and after loading.

Further cross-check is performed between cargo tank electronic readings and ullage measurements.

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Procedures for determining and recording the average density of the cargoes transported (voluntary monitoring for chemical tankers, bulk carriers and combination carriers):Title of procedure Determining and recording the

average density of the cargoes transported

Reference to existing procedureVersion of existing procedureDescription of EU MRV procedures (including recording and managing cargo density information) if not already existing outside the MPName of person or position responsible for this procedureFormulae and data sourcesLocation where records are keptName of IT system used (where applicable)

If appropriate, can be applied to all tankers

Table C.6. Time spent at seaTitle of procedure Determining and recording the time spent

at sea from berth of port of departure to berth of the port of arrival

Reference to existing procedureVersion of existing procedureDescription of EU MRV procedures (including recording and managing port departure and arrival information) if not already existing outside the MPName of person or position responsible for this procedureFormulae and data sourcesLocation where records are keptName of IT system used (where applicable)

Time spend at sea is measured from (a) the date and time ship left the last berth of the port of departure to (b) the date and time ship is moored at the first berth of the port of arrival.

Anchorage is excluded from time spent at sea

Drifting is included as part of time at sea

(INTERTANKO raised the point of different treatment for ships “waiting for orders at anchor” and ships “waiting for orders drifting”. Still, the European Commission decided to consider “drifting” as part of the voyage. Less important detail since “time spent at sea” is not used for any assessments or calculation. However, this detail is important in case “time spent at sea” is used to calculate speed during the voyage.)

Example given by the European Commission Guidance:

The Master reports the time as per the GPS indications (or the Master’s Clock / local time zone or GMT) in the Deck Log Book and in the Daily Noon Reports, Arrival and Departure. Time spent at sea is calculated at the end of each voyage and recorded in the voyage documents.

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Procedures for determining and recording the time spent at sea when navigating through ice (voluntary monitoring):Title of procedure Determining and recording the

time spent at sea when navigating through ice

Reference to existing procedureVersion of existing procedureDescription of EU MRV procedures (including recording and managing port departure and arrival and winter conditions information) if not already existing outside the MPName of person or position responsible for this procedureFormulae and data sourcesLocation where records are keptName of IT system used (where applicable)

Part D - Data gaps

Clarification given by the European Commission Guidance:

The risk of the occurrence of data gaps should be minimized by developing an appropriate monitoring plan. However, it is not possible to completely exclude events that require the closure of a data gap.There are several reasons for data gaps or estimations in order to deliver data to be used in the emissions report. It can be distinguished between events that require the closure of a data gap and those that require the correction of existing data. Corrective measures can be made by using secondary data. In contrast to this, estimations have to be used for real data gaps, i.e. when no information by the applied monitoring approach is available.

Companies will be asked to provide a brief description of the method to treat data gaps regarding the parameters other than fuel consumption (i.e. list of voyages, distance, total time spent at sea, cargo carried) as well as control activities to prevent missing data.

This may be the case if information is missing, lost or found corrupt. It should include a back-up solution for each parameter and a formula/description of the calculation.  For example, assume that a flow meter did not output values for 1 day. The Chief Engineer is responsible for noticing this data gap and applying the back-up monitoring method e.g. tank sounding. The Chief Engineer should report the failure promptly to the managing office. If for any other reason, the Chief Engineer cannot close or detect this data gap, then the shore side is responsible for closing it, by applying formulae, historic data etc.

Table D.1. Methods to be used to estimate fuel consumptionTitle of method Method to be used to estimate fuel

consumptionBack-up monitoring method (16)

Formulae usedDescription of method to estimate fuel consumptionName of person or position responsible for this methodData sourcesLocation where records are keptName of IT system used (where applicable)

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Examples given by the European Commission Guidance:

Example using Method AIn the event of a data gap due to unexpected conditions, the performance manager (shore) communicates its existence to the Chief Engineer who fills the gap once arrival established using the average of the ROB difference between arrival and departure ROBs. Chief Engineer then records the value as an error to the engine log book and communicates this to the Performance Manager (shore).

Example using Method BWhen the related data is missing, the Chief Engineer requests to perform as soon as possible tank sounding in order to close the gap. In the case where the missing data is not immediately identified then the responsible Superintended shall close the gap manually by using the average fuel consumption of the previous and the next day.

If one choses another method from those listed (A, B, C or D), one needs to insert “N/A” but add the name of the alternative method and describe it

Table D.2/D.3/D.4. Methods to be used to treat data gaps regarding distance travelled/cargo carried/time spent at seaTitle of method Method to treat data gaps regarding distance

travelledFormulae usedDescription of method to treat data gapsName of person or position responsible for this method

Data sourcesLocation where records are keptName of IT system used (where applicable)

Probably no data gaps expected for tankers. In any case, examples given by the European Commission Guidance for data gaps on:

Distance: In the event of a data gap related to distance traveled, while using an automated / electronic chart navigation system, the master can fill the gap by means of back-up methods such as terrestrial or celestial navigation being documented in the Deck Log Book

Cargo carried: In the event of a cargo related document been lost and therefore the occurrence of a data gap, then the Master calculate the actual displacement of the ship using the draught readings and obtain the mass of cargo onboard by subtracting the lightweight of the ship, consumables, provisions, spares and Crew.

Time spent at sea: In the event of a data gap related to time spent at sea, the responsible Operator must immediately communicate with the Master and raise the existence of it and close it using the data from the Statement of Facts documents.The data gap can be filled by using the average of the time difference in hours between Arrival and Departure.

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Part E – Management

Table E.1. Regular check of the adequacy of the monitoring planTitle of procedure Regular check of the adequacy of the

monitoring planReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureLocation where records are keptName of IT system used (where applicable)

Example given by the European Commission Guidance:

The HSQE manager includes the Monitoring Plan in the official company procedures being subject to review and/or updates through the Management of Change procedure (see Section X). This should be done on a when needed basis for example when new flow meters are installed, new procedures are in place or roles and responsibilities are amended, and in general changes which can affect the Monitoring Plan of a vessel.

Table E.2. Control activities: Quality assurance and reliability of information technologyTitle of procedure Information Technology Management (e.g. access

controls, back up, recovery and security)Reference for procedureBrief description of procedureName of person or position responsible for data maintenanceLocation where records are keptName of system used (where applicable)List of relevant existing management systems

Example given by the European Commission Guidance:

Backup Servers will occur every day after regular business hours. Full Backup includes all the source files. Only one full backup will be done once a week. Incremental Backups includes only files that have changed since the last full backup. The next time an incremental backup is done, this file is skipped (unless it is modified again).

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Table E.3. Control activities: Internal reviews and validation of EU MRV relevant dataTitle of procedure Internal reviews and validation of EU MRV

relevant dataReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureLocation where records are keptName of IT system used (where applicable)

Companies are supposed to have a procedure which ensures quality of information before submitting the respective reports to verifiers. The written procedure should lay down checks to be performed. Minimum review check may include: data completeness check; trend analysis (comparison of the data over several years) etc.

Example given by the European Commission Guidance:

This procedure will formalize all actions conducted by the Operations Department with regards to the checks and the reviews applied to measurements related to fuel, time, distance and cargo.

Cargo: The reported cargo values are observed so as to make sure that the number is not bigger than the DWT nominal value. If discrepancies are found, communication with the vessel is established.

Distance: Distances are validated by the Operations Department with the geographical shape and previous similar voyages. Noon reports and reported distances are checked on a monthly basis and verified. In rare cases a big deviation is found, communication is established with the vessel directly.

Time: The Operations Department performs cross-checks between the sum of steaming hours + non steaming hours + off hire hours versus the difference (in hours) between dates from berth to berth. If a difference higher than 2 hours is identified, communication is established with the vessel directly and it is included as an error in the Logbook.

Table E.4. Control activities: Corrections and corrective actionsTitle of procedure Corrections and corrective

actionsReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureLocation where records are keptName of IT system used (where applicable)

Clarification given by the EU Commission Guidance:

To establish a systematic and controlled way of reporting and reviewing, any non-conformity (NC) identified within the Company or on board the vessels, and of deciding and following-up on corrections and corrective actions.

NC is an observed situation where the objective evidence indicates the non fulfilment of a specific requirement. Such requirements are MRV related procedures, control and MRV management system performance.

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The procedure to be described shall include: (1) how a MRV non-conformity is reported, (2) Review of a non-conformity, (3) how to Implement the corrective action and (4) how corrective actions are followed-up.

Companies can make a reference to existing procedures on ISM with an extended scope to include MRV.Table E.5. Control activities: Outsourced activities (if applicable)Title of procedure Outsourced activitiesReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureLocation where records are keptName of IT system used (where applicable)

Clarification given by the EU Commission Guidance:

A procedure for deciding how to outsource to a third party a service related to the Company’s MRV management system, and for ensuring quality of outputs.

The procedure should describe how the decision to outsource an activity related to MRV is taken, and (2) how quality in delivering is ensured. The Company might develop a Supplier Performance Rating system and a series of criteria (e.g. level of confidence, response and time availability etc.) based upon which the quality of the services received by the third party is assessed at periodic intervals depending on the length of the outsourced service.

Table E.6. Control activities: DocumentationTitle of procedure DocumentationReference to existing procedureVersion of existing procedureDescription of EU MRV procedures if not already existing outside the MPName of person or position responsible for this procedureLocation where records are keptName of IT system used (where applicable)

Clarification given by the EU Commission Guidance:

All companies which are ISM certified do have in place such a procedure. Companies may consider to extend the scope in order to include MRV relevant documents as well as the new legal documents imposed by the EU MRV Shipping Regulation (Monitoring Plan, Emissions Report and Document of Compliance) including the retention period (e.g. DOC 18 months)

Example given by the EU Commission Guidance:

All records should be kept in specific files both on board and in the office and be legible, readily identifiable and retrievable. Records should be stored and retained in such a manner as to avoid deterioration or damage.

The Company’s filing system is divided in the filing system of each department (i.e. Operations Department, Technical Department and HSQE Department). Each Department is responsible to maintain all hard copies in the floor it is located for at least 3 years after the date of issue. Document of compliance should be kept for at list 18 months. The filing system on board each ship is divided in the systems of the Master, Chief Engineer, Chief Officer and bridge. All records are retained for at least 3 years after the date of issue

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Part F - Further information

Table F.1. List of definitions and abbreviationsAbbreviation, acronym, definition Explanation

Clarification given by the EU Commission Guidance:

Companies should list any (individual) abbreviations, acronyms or definitions that they have used in completing this monitoring plan (e.g. PMS: Plant Management System, SMS: ship Management system etc.)

Table F.2. Additional information

Clarification given by the EU Commission Guidance:

In this chapter companies may enter any additional information on the MRV matter that they consider relevant for their ship and relevant management procedures (e.g. Data flow diagrams, tasks lists, organizational diagram etc.)

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(1) Select one of the following categories: ‘Working draft’, ‘Final draft submitted to the verifier’, ‘Assessed’, ‘Modified without need for re-assessment’.

(2) Select one of the following categories: ‘Passenger ship’, ‘Ro-ro ship’, ‘Container ship’, ‘Oil tanker’, ‘Chemical tanker’, ‘LNG carrier’, ‘Gas carrier’, ‘Bulk carrier’, ‘General cargo ship’, ‘Refrigerated cargo ship’, ‘Vehicle carrier’, ‘Combination carrier’, ‘Ro-pax ship’, ‘Container/ro-ro cargo ship’, ‘Other ship types’.

(3) Select one of the Polar Classes PC1 — PC7 or one of the Finnish-Swedish Ice Classes (IC, IB, IA or IA Super).

(4) Select one of the following categories: ‘Heavy Fuel Oil (HFO)’, ‘Light Fuel Oil (LFO)’, ‘Diesel/Gas Oil (MDO/MGO)’, ‘Liquefied Petroleum Gas (Propane, LPG)’, ‘Liquefied Petroleum Gas (Butane, LPG)’,‘Liquefied Natural Gas (LNG)’, ‘Methanol’, ‘Ethanol’, ‘Other fuel with non-standard emission factor’

(5) (6) Select either ‘Yes’ or ‘No’.

(7) Select ‘Yes’, ‘No’ or ‘Not applicable’.

(8) Select one of the following categories: ‘All sources’, ‘Main engines’, ‘Auxiliary engines’, ‘Gas turbines’, ‘Boilers’ or ‘Inert gas generators’.

(9) Select one or more of the following categories: ‘Method A: BDN and periodic stocktakes of fuel tanks’, ‘Method B: Bunker fuel tank monitoring on-board’, ‘Method C: Flow meters for applicable combustion processes’ or ‘Method D: Direct CO2 emissions measurement’.

(10) Select one of the following categories: ‘On-board measurement equipment’, ‘Fuel supplier’ or ‘Laboratory test’.

(11) Select one of the following categories: ‘Measurement equipment’, ‘Fuel supplier’, ‘Laboratory test’.

(12) Select one or more of the following categories: ‘Method A: BDN and periodic stocktakes of fuel tanks’, ‘Method B: Bunker fuel tank monitoring on-board’, ‘Method C: Flow meters for applicable combustion processes’ or ‘Method D: Direct CO2 emissions measurement’

(13) Select one of the following categories: ‘Default value’ or ‘Ship specific estimate’.

(14) Select either ‘Mass method’ or ‘Area method’.

(15) For passenger ships, the ‘Unit of cargo/passengers’ shall be specified as ‘passengers’.For ro-ro ships, container ships, oil tankers, chemical tankers, gas carriers, bulk carriers, refrigerated cargo ships, combination carriers, the ‘Unit of cargo/passengers’ shall be specified as ‘tonnes’.For LNG carriers, container/ro-ro cargo ships, the ‘Unit of cargo/passengers’ shall be specified as ‘cubic metres’.For general cargo ships, the ‘Unit of cargo/passengers’ shall be specified by selecting one of the following categories: ‘tonnes of deadweight carried’, ‘tonnes of deadweight carried and tonnes’.For vehicle carriers, the ‘Unit of cargo/passengers’ shall be specified by selecting one of the following categories: ‘tonnes’, ‘tonnes and tonnes of deadweight carried’.For ro-pax ships, the ‘Unit of cargo/passengers’ shall be specified as ‘tonnes’ and as ‘passengers’.For other ship types, the ‘Unit of cargo/passengers’ shall be specified by selecting one of the following categories: ‘tonnes’, ‘tonnes of deadweight carried’.

(16) Select one of the following categories: ‘Method A: BDN and periodic stocktakes of fuel tanks’, ‘Method B: Bunker fuel tank monitoring on-board’, ‘Method C: Flow meters for applicable combustion processes’, ‘Method D: Direct CO2 emissions measurement’ or ‘Not applicable’. The selected category must be different from the category selected under ‘Chosen methods for fuel consumption’ in table

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C.2. (Monitoring of fuel consumption — Methods used to determine fuel consumption of each emission source).

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