Marine Operations Note: 02/2018 - EU MRV & IMO DCS – CO2 Air Emissions

MARINE OPERATIONS NOTE 02/2018

(This Marine Operations Note revokes Marine Advisory 01/2018)

Dear Shipowner/Operator/Master:

The purpose of this Marine Advisory is to provide guidance on compliance with EU MRV regulations, under reference a. and MARPOL, Annex VI, regulation 22A (IMO Data Collection System (DCS)).

General Overview

Both reference a. and b. apply to ships of 5000 gross tonnage and above.

The MARPOL regulation applies to all ships in the Liberian fleet. The flag Administration is responsible for ensuring compliance, including verification and reporting of ship fuel oil consumption data. The EU regulation applies to all ships that call on ports in Europe. The EU regulation includes a provision that the Commission shall review the regulation and shall, if appropriate, propose amendments to this regulation in order to ensure alignment with an international agreement (IMO DCS).

The Administration actively participated in the development of the IMO DCS and closely followed the development with the EU MRV Regulation in order to determine the most efficient way forward to serve our Liberian flag Shipowners. There are several common requirements between the two schemes, including monitoring, verification and annual data reporting. Considering the common requirements of the EU MRV and IMO DCS schemes, there are efficiencies to be gained in implementation both schemes by combining key compliance aspects to the extent possible. This will avoid unnecessary duplication, reduce administrative burdens and thus provide a cost-efficient, streamlined and quality focused service for shipowners covering both regulations.

Considering there are various entities that have been accredited under the EU MRV scheme, including Classification Societies recognized by Liberia, we are offering our Liberian flag shipowner and operators two options for a single service provider to cover both EU MRV and IMO DCS:

1. Classification Societies recognized by Liberia that have achieved EU MRV verifier accreditation (Classification Society Verifiers); or
2. Independent EU MRV accredited verifiers (non-Classification Society Verifiers)

Shipowners have the option to choose either a Classification Society Verifier or a non-Classification Society Verifier. The Verifier will undertake all the verification work covering both the EU MRV and IMO DCS regulations. The Verifier will conduct the complete verification services required for the EU MRV, including issuance of the approval documentation and reporting. The Verifier will conduct the verification services required for the IMO DCS and the Administration will issue the approval documentation and report the required data to IMO.

Appendix 1 contains the list of Classification Societies recognized by Liberia and independent EU MRV accredited verifiers with whom the Administration has entered into a cooperation agreement for delivering this service. Each offers shipowners a streamlined and combined compliance service covering both the EU MRV and IMO DCS regulations.

Compliance Process

The implementation schedule shown in Appendix 2, and in summary the Classification Societies Verifiers recognized by Liberia and non-Classification Society Verifiers will undertake all the necessary work with the exception of the following tasks that will be carried out by the Administration:

• Issuance of SEEMP (Part II) Confirmation of Compliance with MARPOL, Annex VI, Regulation 22;
• Issuance of annual fuel oil consumption Statement of Compliance with MARPOL, Annex VI, Regulation 22A;
• On-board verification of Confirmation of Compliance and Statement of Compliance;
• Mandatory annual IMO DCS reporting under MARPOL, Annex VI, Regulation 22A.

The Administration’s fee for this service is USD375 per ship each year services are performed. The Classification Society Verifier or the non-Classification Society Verifier selected for the combined EU MRV and IMO DCS services will invoice the shipowner/operator directly for this service.

For more information, please contact the Technical Department at technical@liscr.com or telephone +1 703 790 3434.

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Appendix 1 ‐ LIST OF AUTHORISED EU MRV & IMO DCS VERIFIERS

Appendix 2 ‐ Implementation

StepsSteps 13 andto 7 :2 Initial: Initial and and whenever for contract any renewal modifications and change are made of Verifier

Steps 8 to 14: Repeated every year