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Have your say on the draft EU MRV Delegated and Implementing Acts!

The European Commission has published the draft Delegated and Implementing Acts pursuant to Regulation 2015/757 (Shipping MRV). The Acts are now open for public consultation until 25/26 August 2016 and feedback can be provided online directly on the Commission's website.

The consultation is divided into four categories:

The draft Delegated Act on Verification and Accreditation, which presents the detailed rules for the assessment of the Monitoring Plan, verification of the Emissions Report, and accreditation of verifiers
The draft Implementing Act on Emissions Templates, which includes the draft templates for the Monitoring Plan, the Emissions Report and the Document of Compliance (DoC)
The draft Implementing Act on Cargo Carried, which presents the parameters to be used to monitor the cargo carried on-board ship types other than passenger ships, containerships and ro-ro ships
The draft Delegated Act on Monitoring Methods, which provides an update of the methodologies to calculate fuel consumption and carbon emissions (Annex I)

While the deadline to provide feedback on the Delegated Act on Verification and Accreditation is 26 August 2016, the deadline for the other Acts is 25 August 2016. Feedback can be provided online on the Commision's dedicated web page.

The key document is the draft Monitoring Plan template which can be used by ship operators to describe their procedures and systems in place to monitor fuel consumption and other relevant information. We strongly recommend ship operators begin drafting their Monitoring Plan and have it assessed by an independent verifier, to identify any corrective action in a timely manner. As experts in the EU MRV Regulation, Verifavia Shipping is able to offer ship operators guidance on interpreting and understanding the nuances and requirements of the regulation.

The other key point to note is the cargo parameters and the cargo units to be reported for the various types of ships, which include:

For passenger ships: the number of passengers
For ro-ro ships, container ships, oil tankers, chemical tankers, gas carriers, bulk carriers, refrigerated cargo ships and combination carriers: the mass of cargo carried expressed in tonnes
For LNG carriers and container/ro-ro cargo ship: the volume of cargo carried expressed in cubic metres
For general cargo ships: the mass of cargo expressed in tonnes of deadweight carried, or both tonnes of deadweight carried and tonnes
For vehicle carriers: the mass of cargo carried expressed in tonnes, or both tonnes and tonnes of deadweight carried
For ro-pax ships: the mass of the cargo carried expressed in tonnes and the number of passengers
For other ship types: the mass of the cargo carried expressed in tonnes or in tonnes of deadweight carried

Finally, the Acts stipulate that:

Default emission factors to be used to determine CO2 emission are the ones set at international level in the IMO Resolution MEPC 245
Companies using fuel monitoring methods A and C may determine actual density on the basis of the density measured by an accredited fuel test laboratory
Time spent at sea and distance travelled shall be calculated on a ‘berth-to-berth’ basis rather than between ‘departure’ and ‘arrival’
Actual mass of cargo may be used as an additional option to determine cargo weight for ro-ro ships

Verifavia has been an active member of the Commission's MRV working group on Verification and Accreditation under the umbrella of the European Sustainable Shipping Forum (ESSF) responsible for supporting the European Commission in drafting these Acts. As such, we can answer most technical or administrative questions you may have on the EU MRV Regulation and on the draft Delegated and Implementing Acts.