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.
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).
The three key differences between the MRV and DCS:
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:
SEEMP Part II is to be on board all ships in service on or before 31 December 2018, regardless of the delivery date.
The SEEMP remains with the ship and should be handed over to the new owner.
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.
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.
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:
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