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Circular 169/ 2018 To: Owners, Technical Managers, Deputy Registrars, Fleet Managers, Surveyors, Recognised Organisations Subject: MARPOL Annex VI Fuel Oil Consumption Data Collection Date: 12th April 2018 Attachments: IMO Resolution MEPC.278(70): Amendments to MARPOL Annex VI (Data collection system for fuel oil consumption of ships) Summary Overview: This circular aims to inform technical managers about the amendments to MARPOL Annex VI detailed in the following reference document, which entered into force on 1 March 2018: IMO Resolution MEPC.278(70) which should be read in conjunction with IMO Resolution MEPC.282(70): 2016 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP); IMO Resolution MEPC.292(71): 2017 Guidelines for Administration Verification of Ship Fuel Oil Consumption Data; IMO Resolution MEPC.293(71): 2017 Guidelines for the Development and Management of the IMO Ship Fuel Oil Consumption Database; Application This circular applies to all Cook Islands flagged vessels of 5000 gross tonnage and above, except - ships not propelled by mechanical means; platforms, including FPSOs and FSUs and drilling rigs, regardless of their propulsion; ships operating exclusively in Cook Islands waters, provided that such ships are constructed and act in a manner consistent with MARPOL Annex VI Chapter 4, so far as is reasonable and practicable. The main amendment is the introduction of Regulation 22A Collection and reporting of ship fuel oil consumption data; further information is contained in the table below.

Change of Flag and change of Company Ref. Regulation 22A.4 In the event of the transfer of a ship from Cook Islands Flag Administration to another, the ship shall on the day of completion of the transfer or as close as practical thereto report to the Recognised Organisation acting on behalf of Cook Islands Flag Administration, the aggregated data for the period of the calendar year corresponding to Cook Islands Flag Administration, as specified in Appendix IX of IMO Resolution MEPC.278(80), and, upon prior request of that Recognised Organisation, the disaggregated data. Ref. Regulation 22A.5 In the event of a change from one Company (ref. Regulation 2 Par. 49) to another, the ship shall on the day of completion of the change or as close as practical thereto report to the Recognised Organisation acting on behalf of Cook Islands Flag Administration, the aggregated data for the portion of the calendar year corresponding to the Company, as specified in Appendix IX of IMO Resolution MEPC.278(80) and, upon request of that Recognised Organisation, the disaggregated data.

Ref. Regulation 22A.6 In the event of change from Cook Islands Flag Administration to another and from one Company to another concurrently, Regulation 22A.4 shall apply. Ref. Regulation 6.7 a) After determining whether the fuel consumption data have been reported in accordance with Regulation 22A.4, 22A.5 or 22A.6, and if so, the Recognised Organization acting on behalf of Cook Islands Flag Administration shall promptly issue the Statement of Compliance Fuel Oil Consumption Reporting, in accordance with the Appendix X of IMO Resolution MEPC.278(80), to the ship at that time. b) The Statement of Compliance Fuel Oil Consumption Reporting pursuant to Regulation 6.7 of this Annex shall be valid for the calendar year in which it is issued, for the following calendar year, and for the first five months of the subsequent calendar year. (ref. Regulation 9.12). c) The Statement of Compliance Fuel Oil Consumption Reporting shall be kept on board for at least the period of its validity. Change of Recognized Organisation a) In the event of a change of Recognised Organisation on a vessel flying Cook Islands Flag: Cook Islands Flag Administration shall be promptly informed to verify that the new Recognised Organisation is authorised to carry out Fuel Oil Consumption data collection on its behalf. b) On successful verification of Part II of SEEMP, the new Recognised Organisation shall issue a Confirmation of Compliance, which shall be provided and retained on board the ship (ref. Regulation 5.4.5). c) The Confirmation of Compliance shall be issued to the vessel with the new IAPP Certificate. Fuel Oil Consumption Data Collection Ref. Regulation 22A.9 Cook Islands shall delegate Recognised Organisations to collect, verify fuel oil consumption data for vessels flying its Flag and transfer on its behalf to the IMO Ship Fuel Oil Consumption Database via electronic communication and by a standardized format developed by IMO, not later than one month after issuing the Statement of Compliance Fuel Oil Consumption Reporting.

Recognised Organisation Recognised Organisations shall have always available upon request from Cook Islands Flag Administration, with regard to all the vessels flying Cook Islands Flag, the following documentary evidence: - Confirmation of Compliance; - reviewed Part II of SEEMP; - Statement of Compliance Fuel Oil Consumption Reporting; - electronic communication to the IMO Ship Fuel Oil Consumption Database; Reporting of Fuel Consumption Data a) The Secretary-General of the Organization, on the basis of the reported data submitted to the IMO Ship Fuel Oil Consumption Database shall maintain an anonymized database such that identification of a specific ship will not be possible. Parties shall have access to the anonymized data strictly for their analysis and consideration. b) In accordance with Appendix IX of MARPOL Annex VI, the following information must be included in annual cumulative fuel consumption data report:

c) With regard to the fuel oil consumption data and methods and processes of collection, the Part II of SEEMP, Ship Fuel Oil Consumption Data Collection Plan ( Data Collection Plan ) shall be developed for each vessels flying Cook Islands Flag using as guidelines either: IMO Resolution MEPC.282(70): 2016 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP), with specific reference to the APPENDIX 2; IMO Resolution MEPC.292(71): 2017 Guidelines for Administration Verification of Ship Fuel Oil Consumption Data, with specific reference to the APPENDIX 1 and 2; d) Cook Islands Flag Administration shall deem acceptable as methods of collection of fuel oil consumption data, in accordance with Regulation 22A if based at least on the followings: - Fuel quantities bunkered as taken from Bunker Delivery Note (BDN); or - Fuel quantities bunkered as taken from Code H entries in the Oil Record Book Part I; or - Fuel day tank(s) sounding records; or - Fuel meter readings; or - Fuel quantity details based on arrival and departure notice. e) Expired Statement of Compliance Fuel Oil Consumption Reporting are not required to be retained beyond their expiration date, once a new Statement has been issued and delivered on board. f) Where a vessel is not in a position to obtain a new Statement of Compliance Fuel Oil Consumption Reporting following the end of a calendar year due to lay-up, conversion of period of inactivity, the last issued Statement of Compliance Fuel Oil Consumption Reporting shall be retained on board for inspection. For further enquiries, please contact Maritime Cook Islands at technical@maritimecookislands.com In case of the breakdown of flow meters, manual tank readings or other alternative methods will be conducted instead.