1. NAMEPA - Strengthening Your Culture Of Compliance
NAMEPA - Strengthening Your Culture Of Compliance.  Understanding EU MRV (Monitoring Reporting Verification) November 6, 2015
Wim Peetoom
Americas Operations Manager MMSO (Marine Management Systems Office(s))

2. Efficiency Measures Reduction Targets Data Collection
MRV is part of a wider EC strategy for GHG emissions reduction All sectors of the economy → transport sector → shipping
Efficiency Measures
(not specified)
Reduction Targets
Data Collection
There is a binding EU target for at least 40% domestic reduction of GHG emissions by 2030 compared to 1990 levels.
All sectors of the economy should contribute, including the transport sector and, within the transport sector, shipping (whether it is international operating within EU waters or domestic)
However, we are only in the beginning of this process. There is no discussion about targets or measures at this stage. The idea for the EC is to collect data, understand the current level of GHG emissions in order to make informed decisions.
MRV is only that
Timescales are not specified
Data collection only starts in 2018
We are here

3. Scope of MRV Regulation
All voyages to, from and between ports under Member State jurisdiction
Time at sea and at berth/anchor
All ships >5,000GT
Regardless of Flag
Except
Warships
Naval Auxiliaries
Wooden Ships of Primitive Build
Ships not Propelled by Mechanical Means
Government Ships on Non-Commercial Service
Scope includes some 14,371 ships of main types over 5000GT as of 2015 (from IHS Fairplay data)
Growing at the anticipated 3.3% annual rate, we can expect 16,364 ships by 2019
Source: Marine Traffic

4. Implementation schedule
EIF: Entry into force
3. Monitoring plans to be submitted to verifier
6. First report submitted to verifier
1. EIF
2. Preparation time
5. First monitoring period
2015
2016
2017
2018
2019
2020
JUL
AUG
APR
JUN
– Preparation and adoption of supporting technical legislation in 2015/2016 including broad stakeholder and expert involvement
– Accreditation of verifiers in 2017
– 31st August 2017 – Monitoring plan to be prepared and submitted for approval by an accredited verifier
– 1st January 2018 – Commence per-voyage and annual monitoring
– 2019 onwards – By 30th April each year, submit a verified emission report to the EC and relevant flag state
– 30th June 2019 onwards – Ships will need to carry a valid document of compliance relating to the relevant reporting period.
– 30th June each year – the EC will make each ship’s emissions reports publicly available including information specific to that ship, its fuel consumption, CO2 emissions, technical efficiency (EEDI or EIV as appropriate) along with other parameters.
4. Assessment of monitoring plans by verifier
7. Document of Compliance

5. What will it mean to me? Regulation could be called MVR instead of MRV
To be prepared and reviewed by 2017 for each vessel
Will cover the method to monitor CO2
The plan will be assessed for conformity by an accredited verifier
Monitoring Plan
Owner/operators need to engage with a 3rd Party Verifier to review and approve their reports
Verification
On an annual basis, reports are submitted to the EU
Reporting
These are discussed in more detail in the following slides

6. What we don’t know? Detailed guidance documents from the EC expected in 2016
Materiality
Accreditation bodies and methods
Monitoring plan format
Use of electronic templates
Data exchange formats
Uncertainty calculation guidance
Penalties for non-compliance
Future harmonization with IMO
Other?
Provide definition of materiality: How much we don’t have to check
Note that for penalties, the regulations state that 2-years of non-compliance will result in expulsion. Shorter term penalties will be decided by national administrations in the enacting legislation.
On Accreditation: The Commission shall be empowered to adopt delegated acts in accordance with Article 23, in order to further specify the methods of accreditation of verifiers.

7. Four permitted methods to measure fuel consumption May vary in complexity and cost. They can be used in combination
Bunker delivery note and periodic stocktake of fuel tanks*
Bunker fuel tank measurements on board
Fuel flow meters for applicable combustion processes
Direct emissions monitoring

8. Monitoring plan – what it may look like
Monitoring plan – what it may look like? An example from the aviation industry

9. What do I need to include in the annual report
What do I need to include in the annual report? Most of this will also be made publically available by the EC
Monitoring method and uncertainty
DoC issue and expiry dates
Identity of ship and owner
Name, IMO No., Port of Registry
Name, address and place of business
EIV Estimated Index Value
Technical efficiency (EEDI or EIV)
Ice Class (if available)
Who approved the emissions report
Technical details
Identity of verifier

10. Verification report – what it may look like
Verification report – what it may look like? An example from the aviation industry

11. Understanding MRV - Summary
General framework is known but key details are missing until mid 2016
Monitoring
Different monitoring methods and combinations are allowed
Reporting
First period First report April 2019
Verification
Comparable schemes exist and early preparation is possible

12. Verification – how will it work?
Verifiers will:
Be accredited by a recognized body
Assess conformity of monitoring plans
Assess emissions reports and verify they are accurate and correct to a reasonable level of assurance
Detail inconsistencies and give an opportunity to correct
Issue a verification report and document of compliance (DoC)
Inform the Commission and Flag State of DoC issue
Companies will:
Demonstrate compliance with the monitoring plan
Demonstrate how they have obtained, calculated, and arrived at, final reporting information and data
In a reasonable assurance engagement, the verifier will essentially want to see raw / source data and information. It is a moderate to high degree of scrutiny with a lower level of risk that limited assurance, which tends to look at aggregated data.

13. MRV: Strong parallels with EU Emissions Trading Scheme
Includes similar terminology
Guidance for interpretation is available
Operators effectively have permits and ‘monitoring plans’
Verifiers and Operators complete an AEM Report (Emissions Report) containing a Verification Opinion Statement (Document of Compliance)
Approved formats and templates are used
Automated systems are used (e.g. ETSWAP in UK, EC EU ETS Registry)

14. LR already has experience of similar schemes
EU ETS
Corporate reports
Aviation
Land-based installations
UKAS accredited
GHGs verification
CO2 data and information verification
ISO 14064
We already provide
Verification
Gap Analyses
Training
Facilitation
Quantification and reporting of GHG emissions verification
UKAS accredited

15. Thank you for your attention More information on www. lr
Thank you for your attention More information on
The content of this presentation (with more details) is available on our guidance document which can be downloaded from our website.