The start of the first phase of the European Union’s MRV Regulation this August has marked the next step in shipping’s challenge to comply with ever tighter air emissions rules
By Thomas Kirk, Director for Environmental Performance, ABS
Emissions Monitoring Plans for EU MRV should have been submitted to an accredited verifier by August 31, 2017 and compulsory emissions reporting begin from January 1, 2018. For owners who have already developed and implemented their emissions monitoring plans, it is still essential that actual emissions reports submitted to the EU are verified by an independent third party. As the first externally-accredited class society to perform EU MRV assessments, ABS is helping streamline and simplify the compliance process for owners and operators.
ABS has already helped owners to verify that the information in their monitoring plans is as required by the EU MRV Regulations. ABS will also provide verification that the emissions report is prepared in conformance with the accepted monitoring plan.
No sooner have ship owners begun collecting and submitting CO2 emissions data to the European Union than they must begin a similar process for the International Maritime Organization’s Data Collection System (DCS).
In two years’ time, the industry faces the even greater challenge of compliance with the IMO’s global sulfur cap which will set new standards for limiting air emissions outside emission control areas.
While options for manual MRV compliance exist, owners are concerned with the additional administrative burden on their crews and whether it is sufficiently robust to provide a long-term platform for compliance. Even vessels operated with a dedicated ship management software solution for procurement or maintenance are not necessarily outfitted suitably to perform the functions required for compliance.
The large amount of data to be handled supports the use of an electronic platform that integrates other ship management activities and allows for automated data entry. Integrated and secure electronic data capture can give higher confidence in data and calculations related to MRV reporting.
ABS Nautical Systems Voyage Manager software is designed to integrate fuel consumption data collected manually for noon reports or through the secure, marine-grade NS AutoLogger to a dedicated database, automating and simplifying the compliance reporting process.
Owners will also be positioned to comply with the IMO DCS, which is intended to create a global database of ship fuel consumption starting next year. Under pressure from its own member states and environmental organisations to reduce CO2 emissions from shipping, this is considered a requisite first step to inform subsequent analysis and future policy decisions regarding further mitigation or market based measure.
Owners continue to have choices for compliance with the 2020 global sulfur cap - including the use of low sulfur fuel or fitting of exhaust gas cleaning systems (EGCS), commonly referred to as scrubbers. In either case the costs are considerable – price spread of fuel prices if low sulfur distillate (MGO) is used, or significant capex and opex commitment for a scrubber.
For those considering systems-based compliance, ABS has recently updated its Advisory on Exhaust Gas Scrubber Systems. Additionally we issued guidance on the world’s first scrubber-ready notation, providing important direction for owners who are planning to retrofit their vessel with a sulfur scrubber.
The Advisory includes background on air emission regulations and explores the different types of available scrubber technologies along with the associated installation and operational challenges for each. By looking ahead during the design phase and accounting for possible retrofits in the future, owners are better prepared for future regulatory requirements and able to more cost-effectively retrofit their vessels.
Using the Advisory to understand the unique characteristics of the available scrubber technologies, shipowners and operators will be able to make smarter decisions on the future of their fleets.
ABS also published the ABS Guide for Exhaust Emission Abatement which applies to vessels fitted with an exhaust emission abatement system, including SOx scrubbers, selective catalytic reduction systems and exhaust gas recirculation for nitrous oxide (NOx) emission control.
ABS can provide further support by completing a techno-economic analysis of the arrangements. Such studies consider the impact of capital and operating expenses to determine the life cycle cost of the installation, providing critical information to support vessel owners and operators in the decision making process.