Challenges in the implementation of MRV regulation Yiannis Kokarakis Bureau Veritas
Target CO 2 Emission Reduction Energy EEDI indicators and EEOI SEEMP environmental management plan. IMO/MRV in SEEMP Reg. 22A Market-based measures. Maybe! AXIOM: What is not measured can not be reduced European Commission, (2015/757), REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport IMO fuel consumption data collection
MRV What is it? Vessels should monitor: - Fuel consumption - Distance traveled - Time spent at sea - Loaded cargo Annual energy efficiency indicators Total cost= 76,400,000 Ships larger than 5.000 gt. These ships represent about half of the fleet calling at EU ports, and are the source for about 90% of greenhouse gas emissions Vessels moving to and from EU ports
Application Time Line August 31 st 2017. Operators must submit to the Recognized Organizations a monitoring plan for their vessels. January 1 st 2018. Monitoring starts April 30 th 2019. Operators submit their reports for 2018. June 30 th 2019. EC publicizes CO 2 reported for 2018. Get Certificate of Compliance Repeat cycle Repeat cycle
MRV and CO 2 Based on the ISO 14000: The aim is to keep the temperature rise below 2 C. It is hoped that with the MRV regulation will achieve up to 2% reduction in annual emissions. Improve the efficiency of fleet by: Reducing speed Frequent cleaning of the hull Addition of energy saving devices to enhance flow to the propeller Use of energy of exhaust gases
New Obligations Distinction between the routes to and from EU ports Fuel consumption association with transportation work Reporting to public authorities.
Checks Each ship must have a monitoring plan approved by an RO Checking compliance of monitoring plan with the provisions of Regulation MRV 2015/757 Check that monitoring is in accordance with the monitoring program Document of Compliance Issuance
Verification hints The verifier has the following options to ensure the accuracy required: The data stored can be compared with the data reported Testing if sufficient flow-meters are installed The reported data can be cross-referenced with other parameters of fuel delivery (Bunker Delivery Notes, Manual of Fuel Movements, Logbook) Comparison of the consumption of the ship concerned with that of comparable ships
Various Issues It is required to cover also other parameters, such as weather conditions, currents and the condition of the hull The index EEOI ignores the basic parameter of the weather and the condition of the hull Data from logs of the ship, bunker delivery receipts (Bunker Delivery Notes) and noon reports
Challenges Problems with uncertainty of the amount of fuel and inaccurate flow meters It is necessary to protect commercially sensitive data and personal data of the ship The distance traveled based on AIS and LRIT position data can be calculated with reasonable accuracy. Who pays???
Monitoring Methods Bunker Delivery Notes (BDN). Quantity of fuel purchased. Monitor the fuel tank. The difference between the two measurements is taken as the fuel that has been consumed. Flow-meters. Continuous readings of the flow of fuel going to the engines. Direct emission measurement. Direct exhaust measurements are considered more accurate. Computational models.
Bunker Delivery Note The accuracy of the method depends largely on the quality and accuracy of the information contained in BDNs. Assumptions: all fuel sold is consumed, the precise carbon content is known as well as the amount of fuel in the tank. Considerable data processing. Therefore, the administrative burden is too high. Factors that determine the consumption (speed, load, weather conditions) are not listed under BDNs.
Bunker Delivery Note MARPOL Annex VI Regulation 18.5 requires the following items to be included in the bunker delivery note: Name and IMO number of receiving ship Port Date of delivery Name, address and telephone number of the oil supplier Product Quantity in metric tons (mass) Density at 15 C (kg / m 3 ) Sulfur content (% ) Statement signed and certified by the fuel oil supplier's representative that the fuel supplied is in accordance with the applicable paragraph of regulation 14.1 or 14.4 and 18.3 of MARPOL Annex VI.
Oil Theft Cappuccino effect Accurate measurement of fuel tanks in the transport barge before and after the supply, based on the correct trim / list. Record the actual temperature of the fuel in the tank before / after delivery. Differences may result from either innocent or deliberate error as air intake (phenomenon "cappuccino") or giving incorrect temperatures. The fuel is sold by the weight (mass) and delivered volume. Differences at third and fourth decimal place in density values can cause loss of hundreds of thousands.
Monitoring Fuel Tanks Fuel consumption can be calculated from the fuel level in the reservoirs at the beginning and end of the trip. The level is measured electronically, ultrasonic or manual readings with a tape measure and a digital thermometer. Sounding Boards are required to convert the freeboard of the fuel volume. The density of the fuel is necessary to calculate the corresponding mass. The accuracy is affected by the heel and the inclination and the movement of the ship. The reporting is expected to be lengthy.
Continuous Measurement of Fuel Consumption The monitoring of fuel consumption is performed using flow meters for main and auxiliary engines. The accuracy of measuring fuel largely depends on the type of equipment. A wide variety of flowmeter types are available, such as electronic, mechanical, optical and pressure based.
Flow-meter Principles
Direct Exhaust Measurements Typical greenhouse gas monitored include sulfur dioxide, nitrogen oxides, carbon dioxide, as well as speed and opacity measurements It can be controlled if the corresponding calculation module receives continuous data from the emission control devices It is possible to check the accuracy of the installation via an alternative mobile unit at the port The crew cannot identify whether a particular machine or boiler operates inefficiently on the basis of the overall measurement It costs about $ 125,000
Selection Process Monitoring How accurate is the measurement of fuel consumption/uncertainties? Can the monitoring system be tampered? Is there contingency for failures/data gaps? How easily can the data be verified? What is the charge for data collection and control? Can the data create incentives to reduce emissions? What additional information would be required to determine the energy efficiency?
Comparison Of Methods For Monitoring
Conclusions Accurate and complete fuel consumption monitoring and analysis is required MRV alone will not lead to a significant reduction of emissions or efficiencies The legislative proposal of the European Commission should serve as a pilot project for a global implementation Anonymous publication of the overall trends and uniform presentation and verification of data should be useful Create a database of performance data and emissions. This will give a realistic picture of CO 2 emissions of shipping in conjunction with the introduction of innovative monitoring technologies