1. ISTEC / ENVIRONMENTAL COMMITTEE JOINT WORKING GROUP ON MRV (JWG/MRV)
REPORT FROM THE
ISTEC / ENVIRONMENTAL COMMITTEE
JOINT WORKING GROUP ON MRV (JWG/MRV)
Hellenic Mediterranean Panel
Athens, October 10th 2013

2. Summary
EU Commission has put forward a legislative proposal to establish an EU system for:
Monitoring, Reporting and Verifying (MRV) of CO2 emissions from large ships calling in EU ports
Proposed to enter into force in July 2015 and
to apply to shipping activities carried out from
1 January 2018

3. EU PROPOSED REGULATION on MRV
The Rules are aiming for:
Accurate Monitoring, Reporting and Verification of CO2 emissions
The reduction of CO2 emissions from maritime transportation in a cost effective manner
It is the first step “of a staged approach” to include the maritime transport emissions in the EU Greenhouse Gases reduction commitment

4. EU PROPOSED REGULATION on MRV
Applicability
All ships > 5,000 GRT calling to EU ports
The reporting is mandated for CO2 emissions when ships travel:
between EU ports,
an incoming voyage from an non-EU to an EU port
an outgoing voyage from an EU port to a non-EU port

5. EU PROPOSED REGULATION on MRV
The data reported should assist to monitor the ship’s average energy efficiency at least with the following four criteria:
Fuel consumption/distance
=total annual fuel consumption/total distance travelled
Fuel consumption/transport work
= total annual fuel consumption/total transport work
(transport work = distance x cargo)
CO2 emission/distance
= total annual CO2 emissions / total distance travelled
CO2 emissions/ transport work
= total annual CO2 emissions / total transport work  

6. EU PROPOSED REGULATION on MRV
Every Ship should have a Monitoring Plan approved by an accredited “Verifier”
The Reporting is on annual basis (calendar year).
Verifiers should check the reporting is in conformity with the Monitoring Plan
Verifiers should check “credibility” of the reported data
The reporting should be done by ‘companies’, i.e. the DOC holder, who must provide an emissions report for the previous calendar year’s activity

7. EU PROPOSED REGULATION on MRV
Options to calculate the fuel consumption:
use of BDN and periodic stock takes of fuel tanks;
onboard monitoring of bunker tanks,
flow meters for applicable combustion processes and
direct emissions measurement
The proposed rule has provisions with obligations for “verifiers” and it requests EU Member States to consider penalties for ships which do not comply with the reporting, including “expulsion”.
If verification is successful, the verifier will then issue a Document of Compliance to the Company.

8. EU PROPOSED REGULATION on MRV
Dates for implementation:
1st July 2015 – enter into force
31st August 2017 – companies should prepare and submit to “verifiers” Monitoring Plan (monitoring plans for ships coming in operations after 1 January 2018 should be provided not later than 2 months after first call to an EU port)
1st January 2018 – starts first annual reporting period
2019 and after – by 30th April each year, companies shall submit a verified emissions report to the EU Commission and to the Flag State
30th June each year - the EU Commission will make the emissions reported by ships publicly available

9. INTERTANKO COUNCIL DECISION
INTERTANKO supports the concept of MRV of the CO2 emissions of ships in operations.
In addition, INTERTANKO will continue investigations and assessments on the best model of a MRV concept adapted to the specific operations of oil and chemical tankers.

10. INTERTANKO COUNCIL DECISION
Investigation & assessments take into account the following principles/actions:
1. Ship’s efficiency is the best method to measure performance improvement with the fuel consumption being the critical parameter. (“ship’s efficiency” should, in a broader sense be weighted and clarified versus the term of “transportation efficiency”)
2. For internal use only, initiate data collection from all members on the annual fuel consumption data (years 2010, 2011 and 2012) using the cumulative data on BDNs for each type of fuel.
3. Additional data should also be reported to assist in determining the best definition of ship’s efficiency when assessing the various proposals at IMO and the EC.
4. Report to the next Council meeting in Nov with the attempt of finalising the assessment and considering preparing a draft submission to IMO/MEPC 66 for March 2014.

11. JWG/MRV TERMS OF REFERENCE
1. Determine the best approach for INTERTANKO to assess fuel or vessel efficiency with specific recommendations on:
mechanism for initiating collection of fuel consumption data (this data being identified as the common denominator of any option to be considered);
the best measure of improvement (fuel consumption or ship’s efficiency)
if the latter, the best definition of ship’s efficiency
eventual collection of other data if found relevant to the best approach considered
proposal on how to integrate or remove from the measurement, the involvement / influence of other stakeholders (importers, charterers, cargo owners, etc.)
pros and cons of such measures also applying to EEDI compliant ships …

12. JWG/MRV TERMS OF REFERENCE
2. Consider all above tasks as a high priority matter.
3. Prepare a written report for review by ISTEC and the Environmental Committee for submission to the next Executive Committee meeting on 28 May 2013.
General guideline for setting up a MRV system: the model should be simple (protect its credibility through its simplicity), easy to verify, use data already mandated through existing regulations.

13. DATA COLLECTION FOR INTERNAL USE
Vessel # (for confidentiality, ship’s name or IMO # not required)
DWT (max. summer draught)
Type tankers (oil, product, chemical/product, chemical)
Total time on laden voyages (hours) / reporting period (one year)*
Total distance in laden voyages (nm) / reporting period (one year)*
Total number of voyages / reporting period (one year)*
Total cargo onboard (tonnes) / reporting period (one year)*
Total time on ballast voyages (hours) / reporting period (one year)*
Total time at berth (hours) / reporting period (one year)* –
Total fuel consumption at berth / reporting period (one year)*
Total fuel consumption (tonnes) / reporting period (one year)* (HFO- LSHFO- MGO)
Σ tonne-miles for all voyages / reporting period (one year)*
* reporting period (one year) – INTERTANKO proposed definition:
“All completed voyages in one calendar year during which emissions have to be monitored and reported”

14. DATA COLLECTION FOR INTERNAL USE
Data required in a tabular format
Each row represents the data for one ship for one reporting period (e.g or 2011 or 2012)
There should be separate reports / tables for each reporting period (i.e. one table for each reporting period)
Data received so far:
VLCCs 31
Suezmaxes 36
Aframaxes 43
LRs 4
Product 22
Chemical 11
WE NEED MUCH MORE DATA!!

15. EU PROPOSED REGULATION on MRV

18. EEOI

19. INTERTANKO JOINT WORKING GROUP ACTIVITY
Provide comments to the EU proposed MRV regulation &
Develop a Monitoring Plan for tankers
Promote these with the EU Commission, Parliament and Council
Continue to collect data from Members & Find best approach to assess tankers’ fuel efficiency
Propose how to distinguish or remove from the assessment the involvement / influence of other stakeholders (importers, charterers, cargo owners, etc.)
Attempt to develop an INTERTANKO model to take into account the above

20. INTERTANKO possible model
General guideline for setting up a MRV system: the model should be simple (protect its credibility through its simplicity), easy to verify, use data already mandated through existing regulations
Monitoring by using the BDN data together with periodical sounding of bunker tanks.
BDN data is an “over reporting” of fuel consumption (HFO) – ask DNVPS for statistics to determine a correction facto (e.g. 1%, 1.5% or 2%)
Other uncertainties ref. fuel delivered:
delivery shortage
HFO calorific values (38 to 41 MJ/kg or some 7% difference)
fuel density
temperature correction factor
Ask DNVPS to check deviation of fuels calorific values versus the value for which the CF values are calculated

21. INTERTANKO possible model
Assessment of the tanker fuel efficiency - A two-tier approach may be considered. For example:
- The “overall indicator” reflecting the transportation performance in operation (defining the “transportation efficiency”; e.g. a sort of EEOI )
An additional Energy Efficiency Tanker Indicator (EETI) indicating the ship’s technical efficiency considering only parameters under the ship owners’ control
If tanker is not compliant with the mandated “transportation efficiency” baseline, EETI could indicate whether tanker is still in compliance by its own performance not taking into account factors outside the tanker operator’s control

22. INTERTANKO possible model
SHIP TECHNICAL STATUS REFERENCE
OPERATIONAL STATUS (NEW & EXISTING)
NEW SHIP
EXISTING SHIP
TECHNICAL EFFICIENCY
TRANSPORTATION EFFICIENCY
EEDI
EEI
EETI
EEOI (or equivalent)
ONE-OFF INDEX determined upon vessel’s delivery
ONE-OFF INDEX OR Speed-Power Curve
Reference to the “as built” condition
Indicating the status at any given time during ship’s life and the deviation from the reference values (EEI or S-P CURVE)
Measure of transportation efficiency over a period of time
ESTABLISHED
TO BE DEVELOPPED
(IMO definition)
Reference to a ship but also used to create reference line(s) for tanker types: e.g. chemical/oil; parcel; oil)
Indicator for the ship’s energy efficiency not influenced by commercial parameters (cargo utilization, speed)
(IMO definition used in SEEMP)

23. INTERTANKO possible model
JWG considered two options on how to approach a definition of EETI:
Option 1 – Direct assessed ship technical indicator (i.e. S-P curves)
Option 2 – Normalising the EEOI versus the commercial criteria
The discussions led towards a hybrid of the two options above on which EETI should be an indicator that can be derived from EEOI and which represents the carbon intensity of a ship in a reference condition. The EETI might enable a transparent performance benchmarking. Mr. Tristan Smith from UCL suggested such an idea
The EEOI formula can be mathematically expressed and split into :
a technical factor and
a logistics factor

24. INTERTANKO possible model
The technical factor relates the fuel consumption ( as reported in the calculation of the EEOI) with the ship’s design parameters, i.e. full load (dwt) and the designed speed (Vdes)
The logistics factor can be analysed into three elements:
the “cargo utilisation” (actual cargo/over maximum cargo capacity mL/dwt),
the “distance utilisation”(distance covered in laden condition versus the total distance [dL/(dL + dB)]
the “speed utilisation” (actual average speed for the period used to calculate the EEOI/ design speed or Vop/Vdes)
For the calculation of the EETI it is necessary to apply a correction for the Fuel consumption, which has to be related to the design speed. Therefore a fuel consumption correction factor “fss” is used (which can be derived from S-P curves) but for most ships is adequate to assume : fss =(Vdes/ Vop)^3
By applying all above factors to the EEOI, then the EETI is calculated as a “normalized” figure of the EEOI, somehow “neutralizing” the influence of commercial parameters in the logistics factor

25. INTERTANKO possible model
CALCULATED EETI ( DERIVED FROM OPERATIONAL DATA USED FOR EEOI)
FOR SAME SHIP IN DIFFERENT CARGO LOADING AND SPEED CONDITIONS
Baseline
Low Utilisation
High Uitilisation
Speed
Cons.
dL/(dL+dB)
0.5
0.7
DWT(t)
Vdes (kn)
Vop
(kn)
FC (ton/d)
 mL/dwt
0.9
300,000 15
100
EEOI
6.38
8.20
4.56
EETI
2.87
Slow Steaming 14 80
5.47
7.03
3.91
2.82
Hull Fouled
120
7.65
9.84
3.44

26. INTERTANKO possible model

27. INTERTANKO possible model

28. INTERTANKO possible model
FURTHER ISSUES TO ADDRESS:
How to determine the “base line” from which a target mandatory value can be established (e.g. could EEOI calculated for the operational condition at designed speed and fully loaded be the base line?)
if so, the “target EEOI/EEI” mandatory curve could probably be decided by imposing a reduction from the base line by a certain percentage; such a percentage may be assessed by using the data collected under MRV
if ship is not compliant with the “target EEI”, how should EETI value be used as a secondary compliance indicator, etc.?
There were other various suggestions such as trying to limit the ship’s cargo capacity utilisation by using ship’s displacement.
There also questions whether data collected would indicate that ships are properly used and using EEOI only would be a simpler approach

29. QUESTIONS?