Standard Club has notified members that the IMO’s introduction of the Data Collection System (IMO-DCS), which runs in parallel to the European Union Monitoring, Reporting and Verification (EU-MRV) regulation, but on a different timeline, was now in effect.
IMO-DCS became operative on March 1st 2018, with first data ‘calendar year’ beginning January 1st 2019. It requires ships of 5,000 gt or more to submit to their Administration annual reports on fuel oil consumption. This requirement was added to chapter 4 of MARPOL Annex VI under Regulation 22A.
Standard Club noted that, in essence both EU-MRV and IMO-DCS had been developed in the context of reduction of greenhouse gases (GHG)/carbon dioxide emissions; with a target to measure and potentially reduce the CO2 emissions in the maritime industry.
The schemes overlapped in various areas; however, the Club said that two new sets of regulations, running on two different timescales, might pose some challenges for the members. It therefore created a table to compare the core components of the two systems.
|Applicability||Ships ≥ 5000 GT||Ships ≥ 5000 GT|
|Exemptions||Warships, naval auxiliaries, fishing vessels, wooden ships of primitive build ships not propelled by mechanical means and government ships used for non-commercial purposes.||TBD|
|Monitoring voyages||Voyages to/from EU ports||Global|
|Shipboard Plan||EU Monitoring Plan||SEEMP with amendment|
|Monitoring period||Starting 1 January 2018||Starting 1 January 2019|
|Range for monitoring||Per-voyage||Not specified|
|Data of cargo carried||Actual amount of cargo||Design deadweight (DWT)|
|Parameters||Fuel consumption & CO2 emissions||Fuel consumption & CO2 emissions|
|Distance & Time||Distance & Time|
|Transport work (based on actual cargo carried)|
|Verification||Robust verification procedures based on ISO 14064||Practical verification procedures considering the administrative burden (under discussion)|
|Verifier||Accredited by European national accreditation bodies||Flag State or Recognised Organisation|
|Reports to||European Commission||Flag State|
|Certification||Document of Compliance (June 2019)||Statement of Compliance|
|Centralized database||‘THETIS MRV’ operated by EMSA||Ship fuel oil consumption database managed by IMO|
|Publication||Annual reporting data including the individual ship information will be made available to the public||Anonymous data will be made available to IMO member states|
Standard Club recommended members to streamline the procedures, systems and responsibilities to ensure common and consistent set of procedures valid for both EU-MRV and IMO-DCS.
Members were encouraged to start considering the methodology for collecting the fuel oil consumption data that was most appropriate for each ship.
The Ship Energy Efficiency Management Plan (SEEMP) shall be amended using the template outlined in Appendix 2 of MEPC.282 (70); and data collection plan should be submitted to the Flag State (or Class) for approval by December 2018.