MRV and DCS

Usually, a ship operating solely within the economic zone (200 nm) flies the flag of that country and is subject to national rules which may or may not differ from the international rules. For instace, Norway has a regulation stating that SOLAS and MARPOL, for example, apply with some adjustments – the DCS regulation applies without modification for ships in domestic trade. A ship operating on the Norwegian shelf with a non-Norwegian flag is required to have international trading certificates, which includes the DCS statement of compliance.

Yes, DCS is as a service which can be provided by an RO independent of the class of the vessel, if not instructed otherwise by the responsible flag state authority.

Referring to MARPOL Annex VI, Regulation 19, Applications 2.1 and 2.2, the IMO DCS is not applicable to ships not propelled by mechanical means as well as to platforms, including FPSOs and FSUs and drilling rigs, regardless of their propulsion.

In general, vessels with less than 5000 GT or vessels not required to carry an IEEC (Energy Efficiency Certificate) are excluded from the DCS.

Yes, DNV can perform such verification work upon request by the owner/manager, but not on behalf of such a flag (ref. MEPC.1/Circ.871 from 4 September 2017).

DNV can also submit data to the IMO on a non-statutory basis. If the customer decides to proceed accordingly, we recommend you contact date@dnvgl.com directly for details on how to proceed.

Each manager is responsible for reporting his part of the year, i.e. upon change of company, the previous manager shall submit the report for his part of the year (ref. MARPOL Annex VI, Reg. 22A.5).

In such a case, the manager must request the creation of the related reporting period and submit the FOC-R via the Fleet Status portal on Veracity.

Yes, a flag change triggers an FOCR verification for the respective flag period of the vessel (ref. MARPOL Annex VI, Reg. 22A.4).

1. Develop a Data Collection Plan (SEEMP Part II) and have it reviewed by the flag administration or any duly authorized organization.
2. Monitor and report fuel oil consumption data, hours underway and distance travelled, and have the data verified by the flag administration or any duly authorized organization.
3. Carry a confirmation of compliance on board for the updated SEEMP (from 1 January 2019) and carry the statements of compliance on board for the required fuel oil consumption reports.

Exemptions may be granted by the flag administration from any of the requirements in chapter 4 of MARPOL Annex VI as per IMO MEPC.1/Circ.863 (vessels not normally engaged in international voyages).

• 31 March each year: Deadline for the submission of the annual fuel oil consumption report to the verifier (MARPOL Reg. 22a)
• 31 May each year: Statement of compliance (SoC) for the fuel oil consumption report must be on board

No.

EU MRV applies to Windfarm installation jack-ups as such, but as long as they are operating in windfarm installation (and not transporting cargo from one port to the next), those activities are not within MRV scope. This means the vessel should have an MRV monitoring plan, but do not need to monitor nor report consumption, time and distance when operating in windfarm installation. If they have been working in this way for an entire year, they don’t need to submit an MRV emissions report for that year.

In general, EU MRV is applicable for ships above 5,000 GT. Exempted are warships, naval auxiliaries, fish-catching or fish-processing ships, wooden ships of a primitive build, ships not propelled by mechanical means and government ships used for non-commercial purposes (ref. 2015/757 Art. 2.1 and 2.2). Furthermore, it is not applicable for ship movements and activities not serving the purpose of transporting cargo or passengers for commercial purposes, such as dredging, ice breaking, pipe laying or offshore installation activities (ref. preamble [14] of Reg. 757). 

For further information, please refer to the second answer on the EMSA homepage, explicitly excluding offshore windfarm installation activities from the MRV scope.

IMO DCS applies to windfarm installation jack-ups. They are no platforms in the sense of MARPOL Annex VI which would be excluded. They must carry a verified SEEMP II on board (and the related confirmation of compliance) and they must monitor and report their consumption, times and distances at all times and report the annual fuel oil consumption reports.

The SEEMP Part II is also referred to as the ship fuel oil data collection plan. It is part of the SEEMP and describes the procedures for monitoring fuel oil consumption. The SEEMP II document requires confirmation from a verifier. The guideline for the plan is included in Resolution MEPC.282(70) under Paragraphes 6 through 8, and a sample form is provided in Appendix 2.

DNV provides a web application (app) for creating and submitting the plan for approval on the DNV customer portal. Clients should submit plans through this app instead of manually preparing their SEEMP II plans.

DNV also offers the possibility to have MRV monitoring plans verified by us and approved as SEEMP II if the client confirms in the app that the monitoring methods for the IMO DCS are the same as for the EU MRV.

The regulations require that the SEEMP contains the above-mentioned data collection plan (SEEMP II). The SEEMP II is subject to confirmation by the flag or an RO. After confirmation, a confirmation of compliance will be issued.

Yes, subject to authorization and approval by the respective flag. Vessels not under DNV class are also welcome to order the DNV DCS verification service (SEEMP II and annual FOC report verification). In certain cases, the flag may decide that the RO performing the DCS certification should be the same RO covering the statutory.

No, the fuel consumed by the EG engine or the LBEs is not considered fuel in terms of MARPOL since it is not used for propulsion or operation. If the EG engine is, however, used for operational purposes, it must be regarded an auxiliary engine and, as such, that engine has to be listed as an emission source, its consumption be monitored and the emissions be reported.

Yes, SEEMP II should be submitted separately. SEEMP I is not subject to approval. Only part II of SEEMP is subject to approval according to MARPOL Annex VI, Reg. 5.4.5.

Regulations 5.4.1 to 5.4.4 only require the SEEMP to be on board but don't require a check or approval of SEEMP Part I.

No, upon change of flag and/or company, a new SEEMP II has to be submitted and a new CoC issued.

Yes, in such cases DNV GL will approve submitted plans and issue the related confirmations of compliance on DNV's own behalf.

The CoC is not a certificate, it is a compliance letter. In cases of statements of compliance or other certificates, the IMO guideline FAL.5/Circ.39/Rev.2 applies.

Specific flag conditions may apply and must be taken into account.

The DCS regulation requires that ice class be reported as part of the fuel oil consumption report, and it should also be included in SEEMP Part II.

All existing vessels engaged in international trade from 5,000 GT upwards shall have an SEEMP II on board.

Newbuilt vessels shall have the plan on board before starting international trade. In order for DNV to verify the SEEMP II and to issue the confirmation of compliance in time before delivery, clients are advised to submit the plans well in advance.

Plans generated with DNV's app will be approved normally within 1 week or a maximum of 2 weeks after submission.

Depending on the authorization by flag, additional time should be considered for the flag's handling.

DNV does not stamp verified SEEMP II plans, since this is not required by the regulation.

After approval of the SEEMP II, a digital confirmation of compliance (CoC) of the plan with the regulation is issued.

The CoC contains a reference to the approved SEEMP II as evidence that the particular SEEMP II is approved and compliant.

Verified plans shall be kept on board together with the CoC issued by DNV.

DNV is not authorized to issue the confirmation of compliance for some flags, e.g. Liberia or Germany. The confirmation of compliance will be issued by the flag.

Generally yes. If DNV is handling the statutory issues for a vessel, DNV will issue the IEEC for that vessel, also if the SEEMP II was approved by an RO other than DNV, provided flag doesn't require that the RO performing DCS shall be the same RO covering the statutory.

In the SEEMP II generator app, you can now change vessel particulars. After editing, press the Submit button to submit the updated plan.

No, the IEEC does not need to be re-issued due to SEEMP Part II approval/issuance of CoC.

The SEEMP Part II should be updated and approved and the CoC issued before bringing the vessel into service after the takeover.

In order for DNV to verify the SEEMP II and to issue the confirmation of compliance in time before delivery, clients are advised to submit the plans well in advance.

Plans generated with DNV's app will be approved normally within 1 week or a maximum of 2 weeks after submission.

Depending on the authorization by flag, additional time should be considered for the flag's handling.

DNV recommends the SEEMP II is updated using the plan generator app in Veracity to obtain a new compliance document and to avoid issues with third parties, e.g. PSC.

DNV requires ships to submit disaggregated data by regularly reporting on specific events throughout the year (para 4.1). Event reports are required to calculate:

• Consumption data: based on log abstract reports (arrival/noon/departure) containing position, fuel consumption, distance and time. At minimum, ships should report on all port departures and arrivals. In addition, DNV recommends that these reports be supplemented bym, for instance, noon reports to ensure that there is at least one daily report.
• Fuel balance: based on bunker delivery note reports and log abstracts reports containing remaining on board (ROB). DNV requires reporting at bunkering (BDN) and a remaining on board (ROB) report at the start, mid and end of the year.

Ships need to report voyage data / log abstracts to DNV in a digital manner. The data can be submitted by a system-to-system connection or manually with data files (e.g. .csv) in our customer portal. System interface specifications and an Excel to .csv format converter are provided to ensure that the format of the data is correct when submitted to DNV’s system.

Yes. By using DNV’s combined reporting template, you can report both.

Customers are advised to contact their customer support to ensure the contractual basis is set for the needed verification service scope, i.e. that DCS is also covered.

That is not required since the fuel consumed by the EG engine or the LBEs is not considered fuel in terms of MARPOL, as it is not used for propulsion or operation.

We do not, however, require the deduction of those amounts if included in the total consumption.

If the EG engine is, however, used for operational purposes, it must be regarded an auxiliary engine and its consumption be monitored and the emissions be reported. The fuel consumed for deck lifters, deck chipping machines or hold washing machines is to be reported since these systems are related to the operation of the vessel.

Each company is responsible for reporting voyage data and submitting FOC reports for their part of the year. This means administrations (or ROs) have to verify as many FOC reports for a vessel as the vessel changes companies during the year.

Regarding MEPC.282(70)/Chapter 7.1/1.3, our understanding is as follows:

If a voyage extends beyond the end of the data reporting period, the fuel oil consumption of the part of the voyage belonging to the previous reporting period is assessed as follows:

Remainings on board (ROB) are measured at the start and at the end of the voyage in order to determine the fuel oil consumption for the entire voyage. The consumption to be reported for the first part of the voyage (C) is then calculated by multiplying the total voyage fuel oil consumption (X) with the ratio between the duration of the first part of the voyage (Y) and the duration of the total voyage (Z), hence C = X*Y/Z.

Yes, any distances travelled at sea (also including drifting) shall be reported as distance travelled.

No, only fuel consumption for combustion for propulsion or ship operation has to be reported.

No, only fuel consumption for combustion for propulsion or ship operation has to be reported.

No, for the DCS, consumption does not need to be split between port and voyage times. Please note, however, that time at sea is the time between departure from berth and arrival at berth.

As per the regulation, the time spent at sea is defined as the time spent under own propulsion. We interpret this as the time between departure from berth and arrival at berth, including drifting, DP and tug assistance / towage but excluding anchorage.

The ship has the following options:

1. Departure from berth and arrival at berth
2. Daily reports such as noon reports or any other daily reports
3. Combination of 1 and 2

In the bunker reports, the IMO number of the vessel receiving the bunker shall be entered.

We have not specified minimum distances, i.e. any distance travelled should be reported.

We recommend that vessels with such service patterns report via daily noon reports.

This is up to the user’s preference. But, since DNV provides managers with a quality check of the data as they come in, we recommend taking advantage of this by submitting the data on a frequent basis in order to fix any issues timely.

The deadline specified in MARPOL (Annex VI, Reg. 22A. 3), namely "within three months after the end of the year", refers to the annual aggregated fuel oil consumption report (FOCR) to be submitted for approval. The digital log abstract and bunker reports (disaggregated data) need to be submitted prior to the FOCR so that DNV's system can use them to prepare the FOCR and present it to the manager for his review and submission for verification. Since the disaggregated data need to be free from issues before the DNV system can aggregate them to the FOCR, managers should submit these data on a frequent basis throughout the reporting year to take advantage of DNV's data quality check service in order for the manager to be able to fix any issues in the monitoring of the data in a timely manner.

Cargo monitoring is not required for DCS at all. The cargo capacity (i.e dead weight, GT, NT) of the vessel is declared in the annual FOCR as dead weight as a proxy instead.

No, it is voluntary, even for ice-classed vessels. We recommend not reporting those figures separately. Those figures shall, however, not be left out but shall be reported together with the non-ice navigation figures.

For DCS, there is no requirement for voyage monitoring. Vessels using the DNV approach for period monitoring for MRV, however, are fulfilling the DNV approach for DCS reporting automatically. In general, if the vessel has to fulfil DCS only, it should report departures and arrivals or one (noon) event per day (ref. the notes sheet in the .csv converter available on the Fleet Status portal [MRV & DCS > Manage Data > Available Templates]).

It is appreciated that you familiarize yourselves with the upload of .csv files to our system.

Immediately after a successful upload, our system will inform you about the number of reports (lines) it has received. By clicking the blue Overview link on the far left in the Manage Data tab, you can get an overview of uploaded log abstracts and bunker reports and the last date of upload for each vessel. You can also download the uploaded data for a certain time frame and make sure that what was received is what you intended to upload.

After a maximum of 24 hours after the upload, you can find that data quality feedback in the data quality tab on the Fleet Status portal.

No, according to MEPC.1 Circ.795 Rev. 3, item 13, interpretation on Reg. 22A.8, the disaggregated data is not required to be kept on board the ship, provided that the disaggregated data can be made available by the company.

The reporting period starts either on 1 January or on the day after the end of a previous period and ends either on 31 December or on the day of a change of flag or of a change of company.

This means that if the vessel does not change flag or company during a calendar year, the reporting period is that calendar year. Otherwise, there will be reporting periods ending and starting at change of flag or change of company (ref. MARPOL IV, Reg. 22A.4 and 22A.5).

The reporting of the fuel type should be according to the ISO 8217 grade, merely viscosity being decisive:

• Grades RME through RMK, Emission factor 3.114: HFO
• Grades RMA through RMD, Emission factor 3.151: LFO
• Grades DMX through DMB, Emission factor 3.206: MGO

The emissions from the combustion of 0.5% VLSFOs, which, depending on the stock of the bunker supplier, may be of residual (HFOs or LFOs) or distillate (MDO / MGO) type, may be monitored as follows:

1. Either use the correct emission factor according to the viscosity and type
2. Or use the highest Cf of the fuels involved, e.g.:
   a. If mixing HFO, LFO and MDO in one tank: use Cf of MDO
   b. If mixing HFO and LFO in one tank: use Cf of LFO

Yes, the consumption of the GCU must be reported. As per MARPOL, “fuel oil means any fuel delivered to and intended for combustion purposes for propulsion or operation on board a ship, including gas, distillate and residual fuels”. GCUs are related to the operation, thus the gas burnt there, even if only for flaring, is for operational purpose, thus qualifies as fuel oil the consumption of which must be reported.

The DCS regulation requires that the ice class is reported as part of the fuel oil consumption report, and it should also be included in the SEEMP Part II.

Within three months after the end of each calendar year (ref. MARPOL Annex VI, Reg. 22A.3).

DNV as RO recommends, however, that FOC reports are submitted as soon as possible after the end of the reporting period to facilitate timely approval.

Five months after the beginning of the calendar year (ref. MARPOL Annex VI, Reg. 6.6).

No, DNV aims to minimize site visits. All data are required to be reported online and will be verified in DNV offices, thus also the FOC report will be verified and the statement of compliance will be issued in the involved DNV offices.

Upon verificiation, a digitally signed statement of compliance will be issued and sent to the client.

Yes, subject to authorization and approval by the respective flag. Vessels not under DNV class are also welcome to order the DNV DCS verification service (SEEMP II and annual FOC report verification).

Yes, just as for MRV, we will also provide clients with the aggregation of the figures for the DCS FOC reports based on their submitted voyage data for their confirmation.

The regulation requires all SoCs to be on board, but does not specify the consequences for the new owner if they have not received it from the previous owner. The consequences are therefore depending on the flag.

No, all vessels of 5,000 GT and above shall carry the SEEMP II on board. Laid-up or docked vessels are no exception. According to MARPOL Annex VI, Reg. 22.2 and 22A.1, FOC-Rs cannot be verified without the SEEMP II.