Carbon Emissions Verification
Independent carbon emissions verification is a legal environmental audit that all ship operators operating ships of 5,000 GT or above calling at EU ports from 2018 will be required to conduct.
The first task of the verifier is to assess the conformity of the Monitoring Plan prepared by the ship operator against the requirements of the EU MRV Regulation.
The second task of the verifier is to independently verify the emissions report prepared by the ship operator in order to reach an opinion with reasonable assurance that:
- The procedures conform with the approved monitoring plan and with the requirements of the EU MRV Regulation and the Delegated & Implementing Acts
- The data submitted in the emissions report is fairly stated, i.e. free from material misstatements
The verification process
Verification is an interactive process aiming to continuously improve the ship operator's MRV management and control systems. The process follows a two-stage approach:
- Analysis of the design and implementation of the ship operator's MRV management system (organisation, procedures, IT) and control system, identification of risk areas, and assessment of whether the procedures conform with the Monitoring Plan and the EU MRV Regulation
- Detailed testing and analysis of fuel data and other relevant information, independent technical review, materiality analysis, verification opinion and document of compliance
Step 1 – Risk Analysis
The aim of the risk analysis is to identify where there are risks of misstatements or non-conformities in the procedures and emissions report, so that the verification activities can be focused on the higher risk areas.
Verifavia considers the following inputs:
- The assessed Monitoring Plan and any changes to-date
- The nature, scale and complexity of the ship operator's operations and MRV processes
- The complexity of IT systems used to handle fuel data and other relevant information
- The existence of an environmental or a quality management system
- The existence of quality control and assurance processes related to data monitoring
- The organisational structure of MRV and how it is integrated into the business
- The availability of information and data in terms of access, completeness and accuracy.
Step 2 – Verification Plan
Based on the outcome of the strategic and risks analysis, Verifavia prepares a plan, which includes:
- A programme that includes the nature, scope and timeframe of verification activities
- The list of people to interview, and IT systems and processes to observe
- A data analysis plan setting out the data to be sampled and tested
- The details of any site visit at the shipping company's office, if required.
Step 3 – Business Process Analysis
Verifavia implements the verification plan in order to assess the reliability, credibility and accuracy of the monitoring systems, confirm that the collection of the data has been carried out in accordance with the applicable rules and check that the relevant records of the ship are complete and consistent.
The process analysis is based on interviews, document review, observation of systems and processes, and corroboration of information. The process includes:
- Interview with staff involved in the data collection and transformation processes
- Observation of IT systems or spreadsheets used to process fuel data and other information
- Review of documents including quality manuals, MRV manuals, calibration certificates and documented quality procedures and maintenance activities
- Review of voyage documentation including relevant logs, noon reports, bunker fuel delivery notes, etc.
Step 4 – Data Analysis
Verifavia conducts a thorough analysis of fuel data and other relevant information to identify data gaps and highlight implausible and potentially erroneous values.
We assess the reliability, credibility and accuracy of the reported data and information relating to carbon emissions, in particular:
- Attribution of fuel consumption to voyages
- Reported fuel consumption data and related measurements and calculations
- Choice and employment of emission factors
- Calculations leading to the determination of the overall carbon emissions
- Calculations leading to the determination of the energy efficiency
- Check data credibility by comparing reported data with estimated data based on ship tracking data (e.g. AIS) and ship characteristics, such as the engine power
- Perform consistency checks between the total volume of fuel purchased by the ship and the aggregate fuel consumption during voyages
- Conduct data sampling of fuel data and other relevant information on selected voyages
Steps 5 – Reporting
Throughout each stage, Verifavia maintains an Issues Log that lists all issues arising. This is shared with the shipping company so that there is a common list of issues to be closed out before completion of the audit.
Some issues that are not critical can be viewed as 'improvement opportunities' and carried forward for future implementation.
At the end of the verification, we evaluate our findings and conduct a materiality analysis on any outstanding errors and misstatements. An opinion statement is then drafted which compiles all work papers and collected evidence into a verification pack.
Step 6 – Technical Review
Before a decision can be made to issue the final verification opinion, the verification pack must be independently reviewed and validated by an independent technical reviewer.
The objective of the independent review is to ensure that the verification process was conducted in accordance with the verification rules, that due professional care and judgment have been adopted, and that any verification risks have been minimised.
Steps 7 and 8 – Final Verification Report & Document of Compliance (DoC)
Verifavia submits a verification opinion statement and a document of compliance to the ship operator. The document of compliance must be kept on board the ship to demonstrate compliance with the obligations for monitoring, reporting and verification.
Verifavia must inform the Commission of the issuance of the document.
> More information on the timeline of verification
> More information on the scope of verification
> More information on the accreditation of verifiers
Regulations & Criteria
Verifavia conducts the GAP-Analysis audit according to the following regulations and criteria:
- Regulation 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport ('EU MRV Regulation') amended by the Delegated Regulation (EU) 2016/2071 as regards the methods for monitoring carbon dioxide emissions and the rules for monitoring other relevant information
- ISO 14065:2013 on the Requirements for greenhouse gas validation and verification bodies for use in accreditation
- Commission Implementing Regulation (EU) 2016/1928 on determination of cargo carried for categories of ships other than passenger, ro-ro and container ships pursuant to EU MRV Regulation
- Commission Implementing Regulation (EU) 2016/1927 on templates for monitoring plans, emissions reports and documents of compliance pursuant to the EU MRV Regulation
- Commission Delegated Regulation (EU) 2016/2072 on the verification activities and accreditation of verifiers pursuant to the EU MRV Regulation
> More information on the required content of the emissions report