By Michael O'Brien, VP of Products and Business Development
The long anticipated first ‘deadline’ of the European Union’s MRV regulation is quickly approaching. August 31, 2017 is when monitoring plans need to be submitted to verification companies for approval. As this date approaches the EU has provided some additional information and clarifications for Owners and Managers looking to finalize their plans.
In reviewing this information there are several points which are worth sharing to ensure clarity as you move forward with your MRV compliance.
Distance At Sea
StormGeo has contended all along and has built the FleetDSS tool around the idea of using the actual distance steamed. This of course will provide the most accurate data set in particular when it comes to the calculation of transport work.
The EU regulation 2015/757 allowed for two methods to calculate distance.
1. Estimated distance and
2. The actual distance.
In recent guidance provided by the EU it was stated as follows:
During a trans-ocean transit, a deviation to avoid heavy weather of up to some hundred nautical miles compared to a standard great circle distance is not unlikely.
Another deviation scenario could occur if a vessel is diverted for commercial reasons to another port of destination. It is self-explanatory that the distance already steamed to the initial destination has to be accounted for in addition. An application of a standard distance is not suitable for these scenarios.
Hence, applying a “most direct route” standard distance should be strongly discouraged.
Further to the above from the EU, it should be pointed out, that the IMO version going into force in 2019 will require distance over ground NOT an estimated distance thus the system you are using needs to use actual distance not estimated distances.
IN PORT CONSUMPTION
In our experience in dealing with clients around the world we have heard many questions about what the EU is considering as port time. StormGeo has been educating clients on this issue and now the EU has provided new documents to further clarify what they consider port time. The information they provide is in line with how StormGeo calculates in port time and consumption through the Fleet DSS – MRV web application.
The EU reported:
The total fuel consumed “in port” can be:
- the difference between the fuel measured on board when the ship arrives at the first berth of a port and the fuel measured on board when the ship leaves the last berth of the port (eventual fuel bunkered during the stay in the port is not accounted for in this measurement) ; and
- when applicable, the fuel consumed while the ship was waiting at anchor or is carrying out ship-to-ship transfers within the port area
All other fuel consumption except the above, should be considered as “at sea”.
The example the EU gave for a chemical tanker is as follows:
“in port” fuel consumption should include the total of the fuel consumed after the ship is securely moored at the first berth of a port including: fuel used for cargo operations to that berth and any other berth of the same port, fuel consumption used by the ship to move from one berth to another berth and fuel consumption used by the ship for moving out to sea for cargo tank cleaning and return to a berth of the same port.
EEDI and EIV
One of these values are required by the EU for use in the MRV system. Newer ships, post 2013, will have an Energy Efficiency Design Index (EEDI) value that is required in accordance with MARPOL Annex VI, Regulations 19 and 20. For ships that have the EEDI it will be simple to enter that number into the StormGeo MRV application for use in the annual emissions report as defined in the MRV regulation.
For older ships, that don’t have an EEDI value, the owner will need to provide the Estimated Index Value (EIV). The EIV can be calculated using the following equation, this equation is valid for ships, excluding container ships, ro-ro ships and LNG carriers.
As per the EIV guidance from the EU additional information on this topic can be gathered via MPEC documentation. Specific formulae (and input parameters - PME(i) and PAE) for containerships and vehicle carriers, ro-ro cargo ships, ro-ro passenger ships and LNG carriers are provided in MEPC.231(65).
For cruise passenger ships having non-conventional propulsion same information is provided in MEPC.233(65), remaining input parameters other than Capacity and Vref are provided in MEPC.1/Circ. 866.
StormGeo has produced a system that not only fully supports MRV, but when the IMO finalizes its definition/regulation, will be fully compliant with that version as well. StormGeo has contended that estimating distances would not be an effective way for handling MRV given the potential variations from estimated voyage distances and the actual voyage distance. The recent EU guidance strongly discouraging the use of estimated distances and the IMO decision to use distance over ground is in 100% agreement with the StormGeo opinion on this subject. StormGeo will continue to remain on the forefront of compliance, not only with MRV but with IMO as well.