Soft landing needed
The EC published its proposal for Regulation related to monitoring, reporting and verification of shipping CO2 emissions and other climate related data on 28 June. As usual the devil is in the detail and the detail will only be finalised when the Regulation is finalised but the combination of:-

• significant parameters to be reported for every journey between any two ports of calls;

• aggregating journey data annually including reporting CO2 emission in each member state;

• EC delegated power related to ‘supplementing and amending’ matters related to monitoring, reporting, verification and accreditation;

• annual verification at ‘high’ assurance level.

Results in my plea : can we design a soft landing please so as to allow us to test out some of the requirements and to achieve the level of accuracy and detail the proposal envisages.

Why a soft landing? one of many internal reasons
Shipping records internally, on a daily basis, its fuel consumption as well as the amount of fuel it buys. Internally the focus is on providing management information as well as an indication of when to order more fuel. The absolute value of fuel quantity is not the focus but trends and patterns are critical as they provide early warning of something that needs more investigation / action.

However, there is significant difference between an informal voluntary regime and a regulatory regime.

In a regulatory regime with focus on fuel quantities measurement issues that are of less relevance in an internal regime suddenly become critical. For example the Regulation envisages that for every voyage a ship has to report the ‘amount and emission factor for each type of fuel consumed in total and differentiated between fuel used inside and outside emission control areas. This is in addition to imposing requirements related to uncertainty determination, density and conversion factors. This shift in focus applies to most of the required reporting elements in the EC MRV proposal, even those not specific to fuel consumption.

Internal regimes have little or no experience of these later issues and ships need time to build systems, competence and capacity to meet specific requirements in relation to such issues.

Why a soft landing? one of many regulatory reasons
The proposed Regulation includes a requirement that the annual report, which is aggregate from all the individual (applicable) voyage reports, shall report CO2 emissions in relation to:

• all voyages between ports under a Member State's jurisdiction;

• all voyages which departed from ports under a Member State's jurisdiction;

• all voyages to ports under a Member State's jurisdiction;

I read this to mean that the annual report has to break down the voyage data and allocate it to a specific member state depending on where the journey took place. So as an example the same container ship arrives:
    a) from Singapore into Rotterdam
    b) from Rotterdam it goes to Felixstowe
    c) from Felixstowe it goes to Gothenburg
    d) from Gothenburg to Hamburg
    e) finally from Hamburg to Stockholm

Therefore (assuming I am correct) the annual report would have to include CO2 emissions for the above journeys reported as follows:

1. Singapore to Rotterdam voyage reported as relating to The Netherlands (arriving port)
2. Rotterdam to Felixstowe voyage reported as relating to The Netherlands (leaving port) and UK (arriving port)
3. Felixstowe to Gothenburg and Hamburg to Stockholm voyages reported as relating to Sweden (arriving ports) and UK (departing port) and Germany (departing port)
4. Gothenburg to Hamburg voyage reported as relating to Sweden (departing port) and Germany (arriving port)

This is one of the challenges of data that must be reported annually. Add to this (and the other data reporting requirements) the requirement for verification to meet the ‘high’ assurance level and I foresee some choppy water and confusion ahead.

I would prefer to see a three year soft landing plan, where the requirements on reporting stayed the same but the verification requirement is adjusted to specifying that after three years all reported data shall be verified to the ‘high’ assurance level but allowing some reported data to be verified to a ‘lower’ assurance level initially as experience is gained. P { margin-bottom: 0.21cm; }

Anne-Marie Warris,