THE IMO DATA COLLECTION SYSTEM (DCS)
In January 2013, a new Chapter 4 was added to MARPOL Annex VI, providing regulations on energy efficiency for ships. Regulation 22 requires that a Ship Energy Efficiency Management Plan (SEEMP) be kept on board each ship. Further amendments to MARPOL Annex VI, adopted at MEPC 70, establish a mandatory IMO DCS for the collection and reporting of fuel oil consumption data for each type of fuel used by a ship (resolution MEPC.278(70)). As such, the SEEMP has to be developed in two parts, as described below:
- Part I – ship management plan that provides a possible approach for monitoring ship and fleet energy-efficiency performance over time, applicable to ships of 400 GT and above engaged on international voyages.
- Part II – methodologies used to collect fuel oil consumption data, applicable to ships of 5,000 GT and above engaged on international voyages.
The regulation applies to ships of 5,000 GT and above, with the exception of:
- Ships engaged on domestic voyages;
- Ships not propelled by mechanical means;
- Platforms, including FPSOs, FSUs and drilling rigs
In the case of a ship which is normally engaged on domestic voyages but which, in exceptional circumstances, is required to undertake a single international voyage, an exemption from any of the requirements in Chapter 4 of MARPOL Annex VI may be sought from the Administration. Please see MEPC.1/Circ.863 for guidance.
From the allowable data collection methods (refer to SEEMP Part II: Fuel oil consumption data collection plan), the IMO DCS requires the collection of data on the total annual fuel oil consumption. Apart from berthing and travelling at sea, this data consists of fuel consumption due to activities including but not limited to anchoring, drifting, bunkering/de-bunkering, supply stops, maintenance, cargo loading/offloading, and ballast and commercial purposes.
Timeline for IMO DCS:
- 1 March 2018 – entry into force
- Before 31 December 2018 – new SEEMP Part II (data collection plan) included in SEEMP and flag/Recognized Organization (RO) will ensure that Part II complies with the regulation
- 1 January 2019 to 31 December 2019 – commence annual monitoring for calendar year
- 2020 onwards – ships to submit data within three months after calendar year to the Administration or any organization duly authorized by it (by 31 March at the latest)
- A Statement of Compliance (SOC) is to be issued within two months of receiving data by the Administration or any organization duly authorized by it (by 31 May at the latest)
- Data will be submitted to the IMO by the Administration or any organization duly authorized by it within one month of the issuance of the SOC.
SEEMP Part II: Fuel oil consumption data collection plan
Part II of the SEEMP shall include a description of the methodology used to collect the data required by Regulation 22A.1 of MARPOL Annex VI and the processes used to report the data to the ship’s Administration. Fuel oil consumption includes all fuel oil consumed on board (regardless of whether the ship is underway or not), including but not limited to the following:
- Main engines
- Auxiliary engines
- Gas turbines
- Inert gas generator
Various methods that by ships can use for annual fuel oil consumption data collection are stipulated in resolution MEPC.282(70) – 2016 Guidelines for the Development of a SEEMP, as detailed below.
- Method 1 – Bunker delivery notes (BDNs) BDNs, the standard document required by MARPOL that contains information on fuel oil delivery (e.g. name of receiving vessel, port, date, quantity and characteristics of fuel oil), can be used to determine fuel oil consumption, as illustrated in Figure 5. According to MARPOL Annex VI, BDNs have to be retained on board for three years. Figure 5: Method 1 (BDNs)
- Method 2 – Flow meters Through the use of flow meters on board that measure the daily fuel consumption of all relevant fuel oil consuming processes, the annual fuel oil consumption can be tabulated. For this method, the data collection plan should include a description of the flow meters and their link to specific fuel oil consumers, and the calibration of the flow meters.
- Method 3 – Bunker fuel oil tank monitoring Daily fuel oil consumption data measured by tank readings are aggregated, including bunkering and debunkering. A summary of the monitoring data should be kept on board.
- Travelling distance and hours
Distance travelled over ground in nautical miles should be recorded in the logbook, whereas distance travelled while the ship is underway under its own propulsion should be included in the aggregated data of the distance travelled for the calendar year.
Hours underway – the aggregated duration of time that the ship is underway under its own propulsion – should be submitted to the Administration.
- Direct CO2 emissions measurement
Direct CO2 emissions measurement is not required by Regulation 22A of MARPOL Annex VI. However, if this method is used, measurement equipment and its locations should be described in SEEMP Part II, and calibration and maintenance records of this equipment should be kept on board.
Reporting and verification: For the purpose of the IMO DCS, an Administration may authorize an organization to carry out the following:
- Receive a ship’s data
- Verify the data for compliance with requirements
- Issue SOC
- Submit the data to the IMO
In reference to section Timeline for IMO DCS, the first monitoring period for the IMO DCS will be the calendar year 2019. At the end of this year (and subsequent calendar years), each ship shall aggregate the data collected annually. Within three months of the end of the calendar year, the ship shall report the required information as stipulated in Appendix IX of MARPOL Annex VI (i.e. identity; period of calendar year; technical characteristics of ship; fuel oil consumption data and data collection methodology; distance travelled; and hours underway) to the Administration or authorized organization.
Verification of the reported data will be carried out by the Administration or authorized organization. Additional documentation to facilitate the verification process may include the data collection plan, BDNs, disaggregated data, resolution of data gaps and other documents (e.g. logbook or arrival reports). Through the verification process, the Administration or authorized organization confirms the following:
- Consistency of the reported data and calculated values
- Completeness of the data
- Reliability and accuracy of the data as described in the data collection plan as part of the SEEMP
Upon receipt of the reported data and on the satisfactory completion of the verification, the Administration or authorized organization will issue an SOC. Within one month of the issuance of the SOC, the Administration or authorized organization will submit the verified data to the IMO Secretariat, where it will be anonymized and form part of the IMO Ship Fuel Oil Consumption Database.