EU Agrees to Monitoring of CO2 Emissions From Ships

The European Parliament voted on 28 April 2015 to adopt the Regulation on the Monitoring, Reporting and Verification (MRV) of CO2 emissions from ships. This follows the agreement reached in December 2014 by EU environment ministers.

The agreement relates to the European Commission document drafted in June 2013 titled “Proposal for a Regulation of the European Parliament and of the Council on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport and amending Regulation (EU) No. 525/2013”.

Until recently, maritime shipping was the only method of transport not included in the EU’s program to reduce greenhouse gas (GHG) emissions as detailed in EU Regulation 525/2013.

Consideration at IMO

Concerns have been raised by some parties within the shipping industry, such as INTERCARGO, BIMCO and the International Chamber of Shipping, regarding the EU’s decision to pre-empt the ongoing IMO negotiations and how this scheme will be compatible with whatever might be agreed by IMO for global application.

Application of the Regulation

The Regulation includes a means of establishing a monitoring, reporting and verification (MRV) scheme for CO2 emissions from ships:

This MRV scheme will initially provide the EU with information to create a GHG emissions inventory and this data will be used to form any future emissions reduction scheme which in turn may influence future EU environmental policy and legislation.

The Regulation will apply to vessels 5,000 GT and above and the obligation to monitor CO2 of voyage regardless of flag:

• Intra-EU voyages – voyages between EU ports.
• Incoming voyages – voyages from the last non-EU port to the first EU port of call.
• Outgoing voyages – voyages from a EU port to the next non-EU port of call.

It is also expected that monitoring will apply whilst at an EU berth or moving within a port.

To ensure compliance with the proposed Regulation, the first step for a shipowner (or any other person who has assumed the responsibility for a vessel’s operation) is to produce a monitoring plan for each vessel. This plan will include details on the method of monitoring and allow for emission data to be collected for all voyages conducted into, out of and between EU ports on botha ‘per voyage’ and annual basis.

When the Regulation comes into effect, the deadline for the submission and verification of monitoring plans is understood to be 31 August 2017, with actual monitoring and recording commencing 1 January 2018.

We understand the EU’s intention is that there should be no need to fit new or additional equipment or systems on ships in order to meet the monitoring and recording requirements. The Regulation would be based on information already accessible on board the vessel.

The emissions will be calculated by one or more of the following methods:

I. Use of bunker delivery notes and periodicmeasurement of remains on board (ROB).

II. Daily monitoring of fuel tanks contents – remains on board (ROB).

III. Flow meters for fuel oil consumers.

IV. Direct CO2 measurement of emissions.

The following includes examples of what will be recorded on both a ‘per voyage’ and annual basis:

a) Departure and arrival ports including times and dates.

b) Emissions for each type of fuel consumed, differentiating between fuels burnt inside and outside any emission control areas (ECAs) and at berth.

c) CO2 emitted.

d) Distance travelled.

e) Time spent at sea.

f) Cargo carried.

g) Transport work.

h) Average energy efficiency (annual only). As well as the ship’s monitoring plan, the annual reports will be required to undergo a verification process by a third party. It is expected that this will be undertaken by most classification societies.

From 30 June 2019, vessels will be required to carry on board a valid Document of Compliance issued by the verifying authority which will be valid for 18 months from the end of the previous reporting period.