The global drive to reduce greenhouse gas (GHG) emissions from ships continues and the latest step in the initiative is the establishment of regulations to monitor, report and verify CO2 emissions.
Both IMO and the European Union (EU) have embarked on such rulemakings and, once again, the two entities are at loggerheads as to the finer points of such provisions, their pace of implementation and, more fundamentally, the duplication of effort.
As participants in a global industry, always seeking the level playing field, shipowners are left wondering where they stand if the regional EU scheme is not to be aligned with IMO’s international data-collection regime.
Establishing an emissions data capture system that is simple and works effectively is difficult enough without the extra challenge of two diverging paths to follow.
The EU’s regulation on monitoring, reporting and verification of CO2 emissions from maritime transport (EU-MRV regulation) entered into force on 1 July 2015.
It requires shipowners and operators to annually monitor, report and verify CO2 emissions for commercial vessels of 5,000 gross tonnes (gt) and larger that call at any EU port. Data collection, which takes place on a per voyage basis, is set to start on 1 January 2018.
The reported CO2 emissions, together with additional data such as cargo and energy-efficiency parameters, will be verified by independent surveyors and sent to a central
European Commission (EC) database, likely to be managed by the European Maritime Safety Agency (EMSA).
The EC will publish the first set of aggregated ship emission and efficiency data by 30 June 2019 and then every consecutive year. As of that date an estimated 16,400 ships will be directly affected by the EU-MRV regulation.
The EU states that the MRV scheme will provide it with more reliable data on ships’ fuel consumption, energy efficiency and CO2 emissions. By increasing ship operator focus on vessel fuel consumption, implementation of the scheme is expected to reduce CO2 emissions by an estimated 2 per cent.
Without action, says the EU, ship CO2 emissions in the region would probably more than double by 2050.
Although the EU-MRV regulation itself has entered into force, the implementing regulations which provide the detailed description of the relevant processes, steps and guidelines are still to be finalised.
Industry has provided input for these detailed provisions over the past year under the auspices of the European Sustainable Shipping Forum (ESSF), whose recommendations form the basis of the implementing regulations that the EU is set to bring into force in December this year.
To ensure compliance with EU-MRV shipowners will be obliged to prepare a monitoring plan for each of their ships covered by the regulation, and to submit this plan to an independent surveyor for verification by 31 August 2017.
In addition to a description of the onboard combustion machinery, including main engines, auxiliaries, boilers and inert gas generators, a ship’s monitoring plan will include the following information:
Under the EU-MPV implementing regulations, LNG carriers will use volume, as per custody transfer measurement system (CTMS) readings, to determine the amounts of cargo carried and boil-off gas (BOG) burned as propulsion fuel. Other gas carriers will use mass, as per bills of lading, to determine cargo carried.
At the international level IMO is developing its CO2 emissions-monitoring regime through amendments to the Ship Energy Efficiency Management Plan (SEEMP) guidelines for fuel-consumption data collection. It is fair to say that the EC’s alacrity with its MRV regulation has added impetus to the IMO move.
At the 69th session of IMO’s Marine Environment Protection Committee (MEPC 69) in April 2016 member states approved requirements for ships to record and report data on their fuel consumption, with additional data on proxies for the ‘transport work’ undertaken by the ship.
The mandatory data collection system is intended to be the first step in a three-step process in which analysis of the data collected will provide the basis for an objective, transparent and inclusive MEPC policy debate. This, in turn, will allow a decision to be made on whether any further measures are needed to enhance energy efficiency and address GHG emissions from international shipping.
There are ongoing attempts to align the two sets of requirements but for now the EU and IMO schemes differ. A comparison of EU and IMO regulatory regimes for collecting data on emissions and fuel consumption is given in the accompanying table.
|EU-MRV||IMO Data Collection|
|Entry into force||Jul-15||Expected March 2018|
|First monitoring period||2018||2019|
|Monitoring plan||Standardised template||Included in SEEMP|
|Basic parameters||Fuel and CO2||Fuel and CO2|
|Cargo carried||Design deadweight|
|Time at sea and in port|
|Reporting to||European Commission||Flag state|
|Verification||Accredited third party verifier||Flag state, via responsible organisations|
Quite aside from the issue of a possible harmonisation between the two systems, the implementation of the EU and IMO data collection regimes are particularly ambitious undertakings.
A key challenge is developing a fair and viable methodology for calculating a ship’s average energy efficiency that accommodates variables such as the weather, currents and charterer requirements as well as a situation in which differing types of ship are carrying the same cargo.
If recorded emissions data is unable to reflect considerations such as the voyage orders laid down by charterers, it will be open to misinterpretation.
There are also major concerns over the accuracy and possible mishandling of collected emissions data. Wherever there is a number, there will be a ranking and a comparison with others. The underlying principle that CO2 data collected should remain anonymous will be difficult to uphold.
Shipowner non-governmental organisations (NGOs) support a single global framework for collecting reliable ship CO2 emissions data, as long as such a regime does not impose unnecessary and additional administrative and operational burdens on vessels that compromise their safety.
A route to possible global harmonisation exists. The EU-MRV regulation contains a provision that allows the European Commission to propose adjustments to align with any similar regime adopted by IMO.
However, a major hurdle facing the harmonisation of the IMO and EU CO2 emissions data collection regimes is their timing. The development of the EU-MRV scheme, with its regional verification mechanism, is at least a year ahead of the IMO initiative and is unlikely to be abandoned before a global data-collection system is in place. That means there will be a period of misalignment, or overlap, even if all parties agree to harmonise.
Further discussions on the IMO data-collection system will take place at MEPC 70 in October.
And so next month’s discussion is building up to be one of the committee’s most important meetings in some time.