After a period of development and assessment of each vessel’s Monitoring Plan (until 31st December 2017), companies are, at this stage, gathering data from fuel types consumed on board, their respective impact on the environment, and vessel´s activity data (transport work, distance travelled, hours underway, cargo carried, energy consumption, among others).

This stage which goes until the end of the present year, corresponds to the reporting period. Completed this period, companies have until 30th April 2019 to submit an emissions report to be verified by an accredited entity.

Once the emissions report is verified, the company receives a Document of Compliance (DOC) which has validity for 18 months and has to be carried on board. This document proves the conformity of the vessel regarding the imposed MRV Regulation and prevents the company from any possible penalty.

Penalties can go from small dissuasive and proportionate sanctions, to the possibility of prohibition from entering EU ports in case of failing to comply for two or more consecutive reporting periods.

This regulation has implications only in EU ports, and considers only ships with 5000 GT or higher, ships for commercial purposes (carrying passengers or cargo), regardless of the flag or country of the shipowner.

People are still adapting to this recent regulations, although there is still much more to come.

IMO Data Collection System

On May 2015 IMO MEPC (Marine Environment Protection Committee) 68 agreed a three-step approach to enhance the energy efficiency of ships. It comprises a data collection step, followed by data analysis and ending in decision-making on what further measures can be done.

In this context, IMO established a “Data Collection System” (DCS) for fuel oil consumption as part of a roadmap for developing a comprehensive strategy on reduction of GHG emissions from ships. For this approach IMO MEPC developed several resolutions and guidelines:

• Resolution MEPC.278(70) – Amendments to MARPOL Annex VI (Data collection system for fuel oil consumption of ships);
• Resolution MEPC.278(70) – 2016 Guidelines for the development of a ship energy efficiency management plan (SEEMP);
• Resolution MEPC.292(71) – Resolution on 2017 Guidelines for administration verification of ship fuel oil consumption data;
• Resolution MEPC.293(71) – 2017 Guidelines for the development and management of the IMO ship fuel oil consumption database;
• MEPC 70/18/Add.1/Corr.1- Report of the Marine Environment Protection Committee on its seventieth Session-Corrigendum.

On 1st March 2018, amendments to MARPOL Annex VI, Regulation 22A on fuel oil data collection of ships came into force. From calendar year 2019, each ship of 5,000 gross tonnages and above shall collect the data specified in appendix IV of Annex 3 MEPC 70/18, and the processes that will be used to report the data to the ship’s administration.

Reported data should be transferred to the IMO Ship Fuel Oil Consumption Database via electronic communication (THETIS Platform) and using standardized forma (Appendix 3 of Annex 10-MEPC 70/18).

Each ship to which regulation 22A applies must present before 31st December 2018 an updated SEEMP (Ship Energy Efficiency Plan) that ensures the methodology and processes prior to the beginning of the vessel first reporting period. There are two parts of a SEEMP:

Part I

Provides a possible approach for monitoring the ship and fleet efficiency performance over time and some options to be considered when seeking to optimise the performance of the ship. In addition, many companies already develop, implement and maintain a Safety Management System. In such case, part I of the SEEMP may form part of the ship’s Safety Management System. SEEMP Part I might be seen as a tool to assist a company in managing the ongoing environmental performance of the vessels. In that way it is recommended that a company develops procedures for implementing the plan in a manner which limits any on-board burden.

It should reflect efforts to improve a ship’s energy efficiency through four steps:

1. Planning
2. Implementation
3. Monitoring
4. Self-evaluation and improvement

It is important to notice that the improvement of energy efficiency of ship’s operation does not necessarily depend on a single ship management. Rather it may depend on many stakeholders including ship repair yards, ship owners, operators, charterers, cargo owners, ports and traffic management services, among others. All involved parties should consider the inclusion of efficiency measures in their operations both individually and collectively. Some measures could be, for example, improve voyage planning, weather routeing, speed optimisation, optimise shaft power, optimum use of rudder and heading control systems (autopilots) or perform hull maintenance.

Part II

The part II, in other way, provides the methodologies ships should use to collect the data required pursuant to regulation 22A of MARPOL Annex VI and the processes that the ship should use to report the data to the classification societies or any organization duly authorized.

The most relevant data to be collected is related to fuel oil consumption, distance travelled and hours underway. These new regulations do not focus on direct CO2 emission measurement, as it is imposed by the MRV Regulations.

Besides the collected data, companies should specify the vessel data (ship particulars and technical characteristics – gross tonnage, net tonnage, deadweight, power output of emission sources), IMO number and period of calendar year for which the data is submitted.

Along with the submission, companies should send documents, such as a copy of the Ship’s Data Collection Plan, summaries of BDNs with detail, summaries of disaggregated data, and information that proves the vessel follow the Data Collection Plan as set out in its SEEMP.

Fuel oil consumption should include all the fuel oil consumed on board including the fuel oil consumed by the main engines, auxiliary engines, gas turbines, boilers, and inert gas generator, for each type of fuel oil consumed, regardless of whether a ship is underway or not. Some methods to collect fuel oil consumption data would be: require to use of bunker delivery notes (BDNs), use of flow meters or use of bunker fuel oil tank monitoring on board.

Data related to distance travelled is related to distance travelled over ground in nautical miles (recorded in log-book) while hours underway relate to the duration while the vessel travel underway under its own propulsion.

The Data Collection Plan should include data quality control measures to be incorporated into the existing shipboard safety, namely a procedure for identification of data gaps and corrections, a procedure to address data gaps if monitoring data is missing (for example, flow meter malfunction).

What are the most relevant exemptions in IMO-DCS?

• There are some exemptions in terms of the types of ships to which the regulations apply to. Ships engaged on domestic voyages, or ships not propelled by mechanical means and platforms, including FPSOs, FSUs and drilling rigs are exempt from reporting;
• When a ship diverts from its scheduled passage to engage in search and rescue operations, it is also exempt from a per voyage monitoring.

The information required by these new regulations is anonymous and confidential.

After the reporting period, as in comparison to the MRV, companies have to submit the report on fuel oil consumption data until 31st March 2020. Classification societies or duly authorized verifiers analyse the conformity of the report and until 31st May 2020 emit a Statement of Compliance related to fuel oil consumption that must be kept on board of each ship. The Statement of Compliance shall be drawn up in a form corresponding to the model given in appendix X of MEPC 278(70) and shall be at least in English, French or Spanish. It is valid for the calendar year which it is issued and for the first five month of the following calendar year.

MRV vs. IMO 

The similarities and differences between the MRV Regulation process and IMO-DCS can be resumed in the following table:

As a conclusion of the facts mentioned above, ship owners need to take these regulations very seriously, as shipping is facing in a very short period of time a big green wave of requirements.

It is recommendable that ship owners select a classification society and/or accredited verifier for EU MRV and IMO-DCS, in order to utilize expected synergies between EU MRV and IMO-DCS system and overcome future penalties and burdens. Also the resort to help from companies with accumulated knowledge in the sector is considered a valuable asset especially in terms of finding solutions to optimise the energy efficiency of the vessel, its fuel consumption and operation.

Source: Tecnoveritas

"After eight years of crisis and three economic adjustment programs, Greece exits a long period of uncertainty and is on the verge of retuning to normality," Stournaras said in a written statement on Tuesday.

According to the bank's estimates, GDP growth is expected at 2 percent and 2.3 percent for 2018 and 2019 respectively, while the fiscal situation has improved significantly, with a primary surplus in 2017 exceeding 4 percent of GDP, he noted.

The current account deficit, which used to be as high as 15 percent of GDP in 2008, has also disappeared. Unemployment is falling, tax collection has improved a lot, banks are consolidated and recapitalized, and labor and product markets have been liberalized, the Greek official added.

Still, Greeks face fundamental economic challenges, Stournaras stressed.

Public debt is very high (178 percent of GDP), non-performing exposures must be radically reduced and high taxation is discouraging investors, who are also facing red tape and a constantly shifting legislative and regulatory framework in Greece, he explained.

"Public sector needs a lot of improvement, we have to make more efforts in privatizations and in liberalizing the energy sector, but the most important of all is to strengthen our institutions and respect their independence," he said.

The definitive proof that the Greek economy has turned a page will come after the successful return to the international sovereign bond markets, the central banker underlined.

"Investors are watching us, as they are checking if we honor our commitments in full and if we implement all the measures agreed with our creditors," he said.

"As we are approaching elections, our political system should not repeat mistakes of the past and fall back to the old bad habits, like the irresponsible fiscal policies that led us to the crisis ten years ago. This would be a disaster and would show disrespect to the sacrifices made by the Greek people," Stournaras stressed.

As Greeks are now on their own, without the protection of a program, and with a lot of economic and political uncertainty surrounding them, they have to show to the world that they can deliver their promises, he explained.

"Otherwise, the markets will abandon us and that's something we have to avoid," he said.

A sudden increase in the borrowing cost could endanger the recovery and could increase the debt servicing cost.

"It is wrong to assume that the Euro group decision of 21 June 2018 would be enough to assure our exit to the markets. Although this decision ensures the sustainability of Greek public debt in the medium term, in order to gain market confidence in the long term, we must continue with the full implementation of reforms and keep up with the fiscal effort for many more years," Stournaras stressed.

XINHUANET.COM