EU-MRV Regulation: Your Monitoring Plan
01 February 2017 | C17005
Following Dromon Circular C16033, companies with ships greater than 5,000 GT must submit a ship-specific monitoring plan for an assessment to an accredit verifier by 31st August 2017.
Ship Owners / Managers / Operators | Surveyors
The Monitoring Plan (MP) must indicate the method chosen to monitor and report CO2 emissions and other relevant information.
As per Article 6 of the EU-MRV Regulation, the MP shall consist of a complete and transparent documentation of the monitoring method for the ship concerned and shall contain at least the following elements:
- the identification and type of the ship, including its name, its IMO identification number, its port of registry or home port, and the name of the shipowner;
- the name of the company and the address, telephone and e-mail details of a contact person;
- a description of the following CO2 emission sources on board the ship: main engines, auxiliary engines, gas turbines, boilers and inert gas generators, and the fuel types used;
- a description of the procedures, systems and responsibilities used to update the list of CO2 emission sources over the reporting period;
- a description of the procedures used to monitor the completeness of the list of voyages;
- a description of the procedures for monitoring the fuel consumption of the ship, including:
- the method chosen from among those set out in Annex I of the EU MRV Regulation for calculating the fuel consumption of each CO2 emission source, including, where applicable, a description of the measuring equipment used
- the procedures for the measurement of fuel uplifts and fuel in tanks, a description of the measuring equipment used and the procedures for recording, retrieving, transmitting and storing information regarding measurements, as applicable,
- the method chosen for the determination of density, where applicable,
- a procedure to ensure that the total uncertainty of fuel measurements is consistent with the requirements of this Regulation, where possible referring to national laws, clauses in customer contracts or fuel supplier accuracy standards;
7. single emission factors used for each fuel type, or in the case of alternative fuels, the methodologies for determining the emission factors, including the methodology for sampling, methods of analysis and a description of the laboratories used, with the ISO 17025 accreditation of those laboratories, if any;
8. a description of the procedures used for determining activity data per voyage, including:
- the procedures, responsibilities and data sources for determining and recording the distance,
- the procedures, responsibilities, formulae and data sources for determining and recording the cargo carried and the number of passengers, as applicable,
- the procedures, responsibilities, formulae and data sources for determining and recording the time spent at sea between the port of departure and the port of arrival;
9. a description of the method to be used to determine surrogate data for closing data gaps;
10. a revision record sheet to record all the details of the revision history.
The MP may also contain information on the ice class of the ship and/or the procedures, responsibilities, formulae and data sources for determining and recording the distance travelled and the time spent at sea when navigating through ice.
Template of the monitoring plan
Companies shall use standardized MPs based on the template released by the Implementing Regulation (EU) 2016/1927.
Modifications of the monitoring plan
As per Article 7 of the EU-MRV Regulation, Companies shall check regularly, and at least annually, whether a ship’s monitoring plan reflects the nature and functioning of the ship and whether the monitoring methodology can be improved.
Companies shall modify the monitoring plan in any of the following situations:
- where a change of company occurs;
- where new CO2 emissions occur due to new emission sources or due to the use of new fuels not yet contained in the monitoring plan;
- where a change in availability of data, due to the use of new types of measuring equipment, new sampling methods or analysis methods, or for other reasons, may affect the accuracy of the determination of CO2 emissions;
- where data resulting from the monitoring method applied has been found to be incorrect;
- where any part of the monitoring plan is identified as not being in conformity with the requirements of the EU MRV Regulation and the company is required to revise it pursuant to Article 13(1).
Companies shall notify to the verifiers without undue delay any proposals for modification of the monitoring plan.
Modifications of the monitoring plan under points (b), (c) and (d) above shall be subject to assessment by the verifier in accordance with Article 13(1) of the EU-MRV Regulation. Following the assessment, the verifier shall notify the company whether those modifications are in conformity.
Ship owners/ Managers/ Operators are encourage to start drafting their monitoring plan to ensure on time compliance with the EU-MRV Regulation.