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DCS F.A.Q.

1. What is the legal framework?

The Amendments to MARPOL Annex VI, Regulation 22A on a data collection system for fuel oil consumption of ships were adopted at MEPC70 on 28 October 2016 and came into force on 1st March 2018 (IMO Resolution MEPC.278(70).
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2. What are the key compliance deadlines?

1st September 2018: recommended deadline for the submission of the Data Collection Plans (SEEMP Part II) to the Flag administration or any duly authorized organization
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3. Which ships are subject to the IMO DCS?

All ships of 5000 GT or above performing international voyages regardless of Flag or country of ownership. Ships engaged on domestic voyages, ships not propelled by mechanical means and platforms, including FPSOs, FSUs and drilling rigs, are excluded.
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4. What are the key legal requirements?

Every ship must develop a Data Collection Plan (SEEMP Part II) and have it reviewed by the Flag Administration or any duly authorized organization. In addittion to 
 
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5. Which parameters shall be monitored?

Only three parameters shall be monitored. 
 
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6. Which fuel consumption monitoring methodologies can be used?

There are three acceptable fuel consumption monitoring methodologies.
 
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7. Which emissions sources must be considered?

There are five emissions sources for which fuel consumption shall be monitored for each type of fuel oil consumed, regardless of whether a ship is underway or not. 
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8. Which information shall be included in the SEEMP Part II (Data Collection Plan)?

The SEEMP Part II has 9 sections. 
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9. What are the differences between EU MRV and IMO DCS requirements?

The Table listed signify the difference between EU MRV & IMO DCS
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10. What happens if the Flag Administration of the vessel is changed during the year ?

In the event of the transfer of a ship from one Administration to another, the ship shall on the day of completion of the transfer or as close as practical thereto report to the losing Administration or any duly authorized organization, the aggregated data for the period of the calendar year corresponding to that Administration, and, upon prior request of that Administration, the disaggregated data.
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11. What happens if the Company changes during the year?

In the event of a change from one Company to another, the ship shall on the day of completion of the change or as close as practical thereto report to its Administration or any duly authorized organization, the aggregated data for the portion of the calendar year corresponding to the Company, and, upon request of its Administration, the disaggregated data.
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12. How shall the data be reported to the Flag Administration or any duly authorized organization?

The data shall be reported as per the standardized data reporting format laid out in Appendix 3 of IMO Resolution MEPC.282(70).
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13. How shall deadweight be calculated?

Deadweight means the difference in tonnes between the displacement of a ship in water of relative density of 1025 kg/m3 at the summer load draught and the lightweight of the ship. The summer load draught should be taken as the maximum summer draught as certified in the stability booklet approved by the Administration or any duly authorized organization.
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14. What is the format of the Confirmation of Compliance and Statement of Compliance?

The format of the Confirmation of Compliance (COC) is laid out in the Annex of the IMO Circular MEPC.1/Circ.876.

The format of the Statement of Compliance (SOC) is laid out in the Appendix X of the IMO Resolution MEPC.278(70).
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15. How shall the daily fuel oil consumption and BDN data be reported?

The daily fuel oil consumption data shall be reported as per the Appendix 1 of IMO Resolution MEPC.292(71).

The BDN summaries shall be reported as per the Appendix 2 of IMO Resolution MEPC.292(71).
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16. Is it mandatory to keep a paper version of the Confirmation of Compliance (COC) and Statement of Compliance (SOC) on-board, or is an electronic version sufficient?

This depends on the requirements of the Flag Administration.
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17. If a vessel performing a single international voyage exempted of IMO DCS reporting obligations?

 A ship which is not normally engaged on international voyages but which, in exceptional circumstances, is required to undertake a single international voyage, may be exempted by the Administration from any of the requirements in chapter 4 of MARPOL Annex VI as per the IMO MEPC.1/Circ.863.
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18. Who will provide the Confirmation of Compliance after review of DCP?

The Confirmation of Compliance (COC) will be issued by the Flag Administration or any duly authorized organization on its behalf.
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19. Who will provide the Statement of Compliance (SOC) after verification of DCS fuel oil data?

The Statement of Compliance (SOC) will be issued by the Flag Administration or any duly authorized organization on its behalf.
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20. Which documents must be provided for the verification of IMO DCS fuel oil data?

According to Resolution MEPC.92(71), documentation to facilitate data verification may include the following 
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21. Who is authorized to perform review of DCP and verification of fuel oil consumption data?

The vessel’s Flag Administration or any duly authorized organization by it.
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22. Can I use the assessed EU MRV Monitoring Plan (MP) for a vessel for elaborating a SEEMP Part II (Data Collection Plan)?

The DCP template provided by IMO is very similar to the MP template but only includes 9 procedures, most of which are the same as the procedures you can find in your MP. You may either prepare a separate DCP that is independent of the MP (and still re-use the procedures in the MP), or prepare a DCP that makes references to the relevant procedures of your MP.
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23. Is an on-board visit required during the review of SEEMP Part II / Data Collection Plan? During fuel oil data verification?

No, an on-board visit is not required.
 
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24. Is an office visit required during the review of SEEMP Part II / Data Collection Plan? During fuel oil data verification?

An office visit may be required only if information and documents cannot be communicated by electronic means.
 
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25. What are the penalties for non-compliance?

The DCP is a new statutory requirement and failure to present this document during PSC inspections may result in the detention of the vessel.
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26. Which information will be submitted to the IMO Ship Fuel Oil Consumption database?

As per appendix IX of the IMO Resolution MEPC.278(70), the following information shall be submitted. 
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27. Which data can be requested during the verification of fuel oil consumption submitted ?

As per Regulation MEPC.292(71) 2017 Guidelines for Administration verification of data, certain data shall be available so that it can be provided during the verification.
 
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