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What are the requirements regarding uncertainty of fuel measurements?

The EU MRV Regulation requires operators to provide information regarding the level of uncertainty (expressed as percentage) related to the fuel monitoring method(s) selected in their Monitoring Plan. The draft Implementing Acts specify that the use of default values or ship-specific estimate is allowed.
 
The EU MRV prescribes four methods to determine fuel consumption and hence CO2 emissions. Since the four methods are based on various sources of fuel data, the requirements towards uncertainty vary:
 
  • Method A (BDN and periodic stocktakes of fuel tanks) and Method B (Bunker fuel tank monitoring on-board) – the method for tank sounding (automated systems, soundings, dip tapes, etc.) and the associated uncertainty must be specified.
  • Method C (Flow meters for applicable combustion processes) – the calibration methods and uncertainty associated with flowmeters must be specified.
  • Method D:  Direct CO2 emissions measurement - the calibration methods and uncertainty associated with the devices must be specified. 
Operators are advised to refer to existing national laws, clauses in customer contracts or fuel supplier accuracy standards whenever possible when indicating the level of uncertainty associated to fuel measurements.
 
The Implementing Regulation on Emissions Templates indicates that “it is appropriate to allow the use of default values for the level of uncertainty associated with fuel monitoring”. The use of ship specific values is also possible.
 
Sources: Regulation 2015/757 Art. 6 and Annex I and section C.2.7 of the Implementing Regulation on Emissions Templates
 

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