Everything You Need to Know About EU MRV Compliance
With less than two months to go until the first compliance deadline, getting ready for the new EU regulations on monitoring, reporting and verification of fuel consumption (MRV Shipping) has become top priority for shipowners and managers with operations in European waters
Participation in MRV Shipping is mandatory for merchant vessels above 5,000 GT calling at European ports. But even if your vessels do not currently trade in Europe, you might want to prepare your fleet for compliance anyway to continue to successfully compete for charters.
No matter at what stage you are in the compliance process, the success of this undertaking largely depends on having reliable information at hand. To give you all the information you need, we have recently released The Definitive Guide to MRV Shipping. This easy-to-read guide introduces you to the MRV process and touches on other relevant topics, such as document of compliance, publication of information and penalties.
Below, we answer some of the questions from The Definitive Guide about monitoring, reporting and verification.
The 'M' in MRV stands for monitoring of CO2 emissions information and activity data.
But before you start the monitoring exercise in 2018, you will need a verified monitoring plan for each qualifying ship in your fleet.
What Is A Monitoring Plan?
The monitoring plan consists of a complete and transparent documentation of your vessel's MRV management and control system. It must be complete, conform and correct.
You are required to create and submit a ship-specific monitoring plan to an accredited EU MRV verifier by 31 August 2017. If you operate a vessel in Europe for the first time after this date, you will need to submit your plan without undue delay and no later than 2 months after your first call in a European port.
What Information Does The Monitoring Plan Contain?
Basic company and ship information. And a detailed description of your MRV management and control system. The latter includes written procedures for the monitoring of emissions and activity data, data flow and control activities, management and responsibilities, quality insurance, IT systems and data gaps.
What Should You Monitor?
From 1st January 2018, you have to carry out the monitoring in accordance with your ship's satisfactorily assessed monitoring plan.
First and foremost, the monitoring is done on a per voyage basis. This means you must measure and record certain information for each qualifying voyage. In addition, you must aggregate the respective per voyage data to obtain annual values. The EU also requires vessels to keep track of their fuel consumption and emissions within EEA ports while at berth. It's important you don't mix up voyage and port related data as they must be reported separately.
How Should You Monitor?
This depends primarily on data availability. The EU gives you some flexibility when it comes to choosing a method for bunker fuel and emissions monitoring. You are free to pick any of the four approved monitoring methods. Only requirement. The method must be consistently applied once chosen. Which does not mean that you cannot use more than one method for different emission sources.
The 'R' in MRV stands for Reporting. It must be completed by 30 April of the year following the calendar year to which the report pertains. Your first reporting deadline is 30 April 2019. This is the date by which you will need to submit to the European Commission a verified emissions report for the first time.
The Regulation requires you to submit an emissions report for each ship under your responsibility. The emissions report includes data identifying the ship and the company, information on the verifier that assessed the emissions report, information on the monitoring method used and the related level of uncertainty and (most importantly) the results from the annual monitoring.
The 'V' in MRV stands for the verification. The MRV verification is performed by an accredited EU MRV verifier. The role of the verifier consists in assessing your monitoring plan, verifying your annual emissions report and issuing the document of compliance.
How Is Your Monitoring Plan Assessed?
Essentially, your verifier will check whether your monitoring plan is complete, conform and correct. This means it will check whether your monitoring plan contains all mandatory information. Your MRV management and control system will also undergo an examination. This is to check whether your system is in line with the Regulation and matches your monitoring plan description. If the verification identifies any non-conformities, you must resolve them before the start of the first reporting period by the end of 2017.
How Is Your Emissions Report Verified?
The core of the verification of an emissions report is the process and data analysis. During the process analysis, your verifier checks whether implemented procedures are in conformity with the Regulation and whether they are accurately described in the monitoring plan. Remember. This is the second time your verifier looks for non-conformities as this has already been done when assessing your monitoring plan.
During the data analysis, your verifier looks for misstatements. Misstatements can be a result of measuring, calculation, typing or transmission errors before or during the preparation of the emissions report. Those errors can be identified thanks to data testing and sampling.
Tobias Konick is the CEO of First Choice Carbon, a compliance management firm that helps shipowners and managers reduce costs and risks related to the European system of monitoring, reporting and verification of carbon emissions (EU Shipping MRV).
First Choice Carbon (http://www.firstchoicecarbon.com) and Deltamarin (https://www.deltamarin.com) have teamed up to protect ship owners and managers from the European MRV system. This unique collaboration combines the best of two worlds: Deltamarin’s long experience in the marine industry and First Choice Carbon’s expertise in European MRV regulations. The support service was specifically designed to offer ship owners and managers the highest level of protection. We achieve this by taking over all management related and administrative tasks. This even includes the verification by an accredited MRV verifier.
The opinions expressed herein are the author's and not necessarily those of The Maritime Executive.