Guidance for updating the Monitoring Plan
We understand that changes in regulations and standards can impact your monitoring plans significantly. Considering the recent updates in the monitoring plan for GHG emissions based on Reg. 2015/757 Annex I and Commission Implementing Regulation (EU) 2023/2449 of 6 November 2023), here are the major changes that need to be addressed: 1. Table B.1 - Identification of the ship and shipowner details
Country of Registration: As recorded under the IMO Unique Company and Registered Owner Identification Number Scheme.
Ice class – Mention the ICE class of the vessel as per the Certificate of Registry, Ice-Class Certificate issued by the flag state, or Class Certificate and Classification Notation issued by the classification society.
Documents required to assess the information – CSR, Certificate of Registry.
2. Table B.2 - Company information
Nature of the company – This section should be filled as per the scope of the ISM code. Under the scope of ISM code Shipowner and ISM Company distinct from the shipowner should be selected.
Documents required to assess the information - CSR.
3. Table B.3- Emission sources and fuel types used
Type of the emissions source - Select one of the following categories: 'Main engines,' 'Auxiliary engines,' 'Gas turbines,' 'Boilers,' 'Inert gas generators,' 'Fuel cells,' 'Waste incinerators,' or other.'
Emissions source class - Select one of the following categories: ICE (other), LNG Otto (dual fuel medium speed), LNG Otto (dual fuel slow speed), LNG Diesel (dual fuel slow speed), LBSI, Gas turbine, Boilers, Fuel Cells, Waste Incinerators, Inert Gas generators.
4. Table B.4. Emission factors referred to in Annex I to Regulation (EU) 2015/757
Emission factors for methane and nitrous oxide - Implement the revised emission factors according to Annex I to Regulation (EU) 2015/757. Verify that all fuel types and associated emission factors align with the updated guidelines.
Please refer to Annexes I to The Commission Delegated Regulation on the rules for monitoring greenhouse gas emissions and other relevant information from maritime transport.
5. Table B.5 - Slippage coefficient referred to in Annex I to Regulation (EU) 2015/757
The slippage coefficient (as % of the mass of fuel used by the specific emission source) in accordance with Annex I to Regulation (EU) 2015/757 should be mentioned in this section.
The below table suggests the slippage coefficient:
- 3.1 for LNG Otto (dual fuel medium speed)
- 1.7 for LNG Otto (dual fuel slow speed)
- 0.2 for LNG Diesel (dual fuel slow speed)
- 2.6 for Lean-Burn Spark Ignited (LBSI)
6. Table B.6 - Application of carbon capture and storage technologies referred to in Part C, point 1.4, of Annex II to Regulation (EU) 2015/757
Vessels using carbon capture and storage technologies should mention the Supporting evidence for compliance with the requirements spelled out in Article 12(3a) or Article 12(3b) of Directive 2003/87/EC and the Emissions source to which capture and storage and/or carbon capture and usage is applied.
7. Table B.8 - Procedures, systems, and responsibilities used to determine and update emission factors in accordance with Annex I to Regulation (EU) 2015/757
The description of the procedure must identify how actual emission factors listed under Table B.4 and B.5 are derived for approval, including the method by which compliance with the conditions and restrictions for diverging from default values in accordance with Annex I to Regulation ( EU) 2015/757 is demonstrated.
Clearly define and document the procedures, systems, and assigned responsibilities for determining and updating emission factors.
8. Table B.9 - Procedure for Determining CO2 Emission Factors of Biofuels and RFNBOs/RCFs
The description of the procedure must identify how CO2 emission factors are derived for approval, including the method by which compliance with the conditions set under Part C, point 1.2, of Annex II to Regulation (EU) 2015/757 is demonstrated.
The CO2 emission factor of the biomass fraction of the fuel is determined to be zero for fuels that meet the sustainability and greenhouse gas emission saving criteria for the use of biomass established by Directive (EU) 2018/2001, with any necessary application adjustments outlined in Implementing Regulation (EU) 2018/2066. When a ship uses Recycled Carbon Fuel (RCF) and Renewable Fuels of Non-Biological Origin (RFNBO), the CO2 emission factor is calculated in compliance with Implementing Regulation (EU) 2018/2066.
9. Table C.2.1 - Monitoring of greenhouse gas emissions and fuel consumption
The updated MP contains GHG emissions instead of only CO2. “Emissions source reference No.” and “Emissions source type” have been added and should be filled as reported in Table B.3 and emissions sources used on board, respectively.
10. Table D.1 - Methods to be used to estimate greenhouse gas emissions and fuel consumption.
Clearly specify and implement the methods stipulated in Table D.1 for estimating GHG emissions and fuel consumption accurately.
The calculation to estimate the greenhouse gas emissions should be performed as per Annexes I to The Commission Delegated Regulation on the rules for monitoring greenhouse gas emissions and other relevant information from maritime transport.
11. Table E.2 - Procedures for data flow activities
For monitoring and reporting GHG emissions companies need to ensure that data is retrieved, collected, transported, and stored in a controlled way. To obtain a clear picture of how data about fuel consumption, transport work, and other relevant information is collected from various sources and aggregated for the emission report in accordance with the requirement of the MRV Shipping Regulation a clear description of the data flow is necessary. Preparing simple process flow charts provides an efficient means to obtain a good overview of data exchange between departments/locations.
Documents required to assess the information - Company procedure incorporating the MRV data flow.
12. Table E.3 – Procedure for Risk Assessment
Table E.3 should delve into the below details. The company shall carry out a risk assessment to identify sources of risks of errors in the data flow from primary data to final data in the emissions report and shall establish, document, implement, and maintain an effective control system to ensure that the reports resulting from data flow activities do not contain misstatements and are in conformity with the monitoring plan and comply with the Regulation.
The company shall make the risk assessment referred to in the above paragraph available to the administering authority responsible upon request. The company shall also make it available for the purposes of verification.
When the company finds the control system ineffective or not commensurate with the risks identified, it shall seek to improve the control system and update the monitoring plan or the underlying written procedures for data flow activities, risk assessments, and control activities, as appropriate.
Risk assessment should include all the risks associated with the data flow activities. A few points that should be addressed are as follows:
- Human errors in the data input to your IT systems
- Data errors or loss.
- Human error or lack of knowledge.
- Mismatch in the data.
- Insufficient procedure to mitigate the data gaps
Readings and References
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Disclaimer:
The content within this guidance document aligns with the most recent Commission Implementing Regulation (EU) 2023/2449 dated 6 November 2023 concerning the template of the Monitoring Plan and Emissions report. While we await the final guidance from the European Commission, we are committed to promptly sharing any upcoming updates, amendments, or revisions with you. Back to all Industry News
