What is the timeline for IMO DCS implementation?
What is the difference between IMO DCS and EU MRV?
Is DNV GL authorized by all flags to perform IMO DCS?
Will there be any flag-specific requirements, or will the plan prepared in accordance with MEPC.282(70) suffice?
This is still to be determined, and we will inform our customers if this is the case. Nevertheless, we do not expect significant flag-specific requirements to be adopted.
If I have class with another class society, can I choose to perform IMO DCS verification and approval with DNV GL?
It depends on the flag, however, for practical purposes, we do recommend our customers to use the same verifier for EU MRV and IMO DCS. But if you are using another class society for statutory certificates, the flag must accept that another RO is used for DCS (similar as for ISM/ISPS/MLC).
Will EU MRV and IMO DCS converge, and create one common scheme in future?
The three key differences between the MRV and DCS:
- The collection of data on transport work. The MRV uses real cargo carried, the DCS uses deadweight carried as a proxy.
- Robustness of verification. MRV is extremely rigorous, the DCS grants great flexibility to the Flag state.
- Confidentiality. The DCS data will be held in confidence by the IMO Secretariat, whereas annually aggregated per-vessel figures will be published by the EU.
Both the EU (in particular the European Parliament) and IMO hold very strong views on why their approach is the preferred one, giving limited flexibility regarding convergence on these core issues.
Convergence between MRV and DCS - what we know:
- The IMO DCS will not be harmonized towards the EU MRV. The discussions re. DCS design at IMO are concluded, and while minor future tweaks are always possible, no significant changes can be expected.
- The EC is working on a legislative proposal that will address MRV convergence towards the DCS. The proposal was originally expected this spring, but has not yet been published. Signals are it will happen later this year.
- Industry input on the matter was solicited and given, but a planned workshop was canceled.
- The analysis documents underpinning the yet to be published legislative proposal look at a range of options, from no convergence to full alignment, without making recommendations. The delay may be partially caused by the technical and political complexities of designing an acceptable proposal.
- Any legislative proposal has to be acceptable to the EC, the EP, and the EU Council (“the Trialogue”). Political signals are that this makes any proposal for full convergence towards the DCS non-viable, and the EC is therefore likely tailoring its proposal to something that can survive negotiations between the three EU parties.
- The EP has made the political decision to unilaterally impose GHG regulations, most likely by including shipping in the EU Emission Trading Scheme, if the IMO has not made satisfactory progress on controlling GHG emissions by 2023. Given its political history the MRV can reasonably be expected to be the key vehicle for this. Aligning the MRV with the DCS would thus potentially constrain the EU’s freedom to act in 2023. The situation may change if the EU in 2023 decides the IMO efforts are satisfactory, thus possibly creating a political window of opportunity for reconsidering convergence. However, the MRV will be well-established by then, and the EU is therefore considered un-likely to be interested in re-opening the issue.
- Given the above we do not expect the EC proposal to promote full alignment. At most we expect alignment on minor matters, such as e.g. the tonnage cut-off limit which differs slightly between the schemes today.
- A window of opportunity for convergence may open in 2023, but this is not considered likely.
- Operators accordingly need to plan for reporting to both the MRV and DCS regimes for the foreseeable future.
Do I need to report both EU MRV and IMO DCS?
Can I then do combined reporting?
How can I set up the reporting procedure in my company?
I subscribe to DNV GL’s ECO Insight performance solution. Will anything be modified to accommodate the IMO DCS data?
No. ECO Insight, no matter whether on-board data come from Navigator Insight or from an interfaced in-house or third-party vessel reporting solution, already covers all IMO DCS requirements. Navigator Insight already produces an annual fuel oil consumption report per the regulation.
How to report "new hybrid fuels"?
With reference to the EU/MRV ‘Guidance/Best practices document on monitoring and reporting of fuel consumption, CO2 emissions and other relevant parameters pursuant to Regulation 2015/757 on monitoring, reporting and verification emissions from maritime transport’, please note paragraph 5.1.6 advising that the emissions factor to be applied for “hybrid-fuels” within RMA to RMD grades is the same as for light fuel oil. Therefore, please kindly report the ULSFO/RMD80 as ‘LFO’.
Paragraph 5.1.6. Emission factors for "Non-standard-fuels"
Since 1 January 2015, ships have been supplied with an increased number of Ultra Low Sulphur Fuel Oils (ULSFO) which are new products not yet categorised under the ISO 8217. In regard of the CO2-conversion factor of these fuels, it is thatr test results from accredited laboratories indicate that the large majority of these new products are within the RMA-RMD grade (i.e. residuals - light oils ) and only one or two are categrorised as DMB grades (i.e. distillates).
For simplicity and consistency reasons, it is suggested that such new fuels (so-called "hybrid-fuels") should use the standard CO2-conversion factors applied for light fuel oil (i.e. 3,151 wen its viscosity is within RMA to RMD grade) and for distillates (i.e. 3,206 when similar to DMA or DMZ grades) as per this regulation.
Type of fuel: Distillates (MGO/MDO) / Reference: ISO 8217 Grade DMA through DMZ / Emission factor (t-CO2/t-fuel): 3,206
Type of fuel: Light fuel oil (LFO) / Reference: ISO 8217 Grade RMA through RMD / Emission factor (t-CO2/t-fuel): 3,151
The above mentioned assignment should not be seen as an exhaustive list as new products might be provided in the future.
SEEMP Part II
What is the SEEMP Part II plan and where can I find the template for this?
- SEEMP Part II is also referred to as the ship fuel oil data collection plan. It is part of the SEEMP and it describes the procedures for monitoring fuel oil consumption. The guideline for the plan is included in Resolution MEPC.282(70).
- DNV GL provided a digital template/app for submitting the plan for approval. Customers should only submit plans through this app. Customers should submit the plans by the end of August 2018.
If I have class/SEEMP with another class society, can I perform SEEMP Part II with DNV GL?
I already have an initial main SEEMP on board – can I now make a combined SEEMP which also includes SEEMP Part II?
When now preparing a SEEMP Part II, must also Part I of the SEEMP be updated?
Do ships for which the delivery date is on or after 1 March 2018 need to have SEEMP Part II confirmed by the administration or RO upon delivery?
SEEMP Part II is to be on board all ships in service on or before 31 December 2018, regardless of the delivery date.
In case of sale and purchase, is the seller obliged to hand over the plan to buyers?
The SEEMP remains with the ship and should be handed over to the new owner.
What is the fee for approval, and is there any discount if DNV GL has approved the EU MRV plan?
What should I do now?
DNV GL, as a verifier for the yearly fuel oil consumption reports for DCS, will in due course inform its customers on how to prepare for verification. This includes but is not limited to:
- Preparing SEEMP Part II using the SEEMP Part II digital reporting tool at www.dnvgl.com. This is an online template where customers will be guided to prepare the document. We recommend you prepare SEEMP Part II using this app well in advance of the 31 December 2018 deadline to ensure timely assessment for compliance.
- DNV GL strongly recommends companies to use our combined service for EU MRV and IMO DCS, where the already approved MRV Monitoring Plan will be accepted as basis for the SEEMP Part II for IMO DCS compliance (applicable only for vessels verified for EU MRV by DNV GL).
- In due time, prepare for the DCS reporting of the required data once announced by DNV GL. As for MRV, DNV GL will offer a fully digital reporting approach:
- In line with state-of-the-art industry standards for ship-to-shore reporting, minimizing efforts on client’s side
- Providing data quality checks of reported voyage data upon upload so that clients get immediate security about the correctness and completeness of the data they are monitoring and reporting
Whom at DNV GL can we contact in case of further questions?
In order to receive the fastest response, clients should approach THD/DATE in case of questions. The THD-support team will be supported by further experts if required.Click to get in touch with our experts