Q9 (20 Marks) International Conventions
SSEP • Written Exam

(a) Discuss International Maritime Organization (IMO) Data Collection System (DCS) for fuel oil consumption of ships covering following: (10)

(i) Applicability of ship size (GT)

(ii) When the requirement of Data Collection System (DCS) entered into force

(iii) What data required to collect ship

(iv) The aggregated data is submitted to who and when (frequency) to submit

(v) Relevance of SEEMP pertaining to Data Collection System (DCS)

(b) List out the main differences between the EU Monitoring, Reporting and Verification (MRV) regulation and International Maritime Organization (IMO) Data Collection System (DCS). (10)

Appeared In: Jun 2024

Verified Model Answer (Text Solution)

Structured for DG Shipping MEO Class II examination scoring criteria.

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(a) The IMO Data Collection System (DCS) for fuel oil consumption is a mandatory requirement for certain ships, aimed at supporting efforts to enhance energy efficiency and reduce greenhouse gas emissions from international shipping.

(i) Applicability of Ship Size (Gross Tonnage - GT):

  • The IMO DCS applies to each ship of 5,000 GT and above.
  • Such ships are required to collect and report specified data on fuel oil consumption annually.

(ii) Entry into Force of DCS Requirements:

  • The legal requirement is laid down in Regulation 22A of MARPOL Annex VI, which entered into force on 1 March 2018.
  • However, data collection became mandatory from calendar year 2019, starting on 1 January 2019.
  • For the first reporting period (2019), the submission deadline was by the end of March 2020.

(iii) Data Required to Be Collected by the Ship:

As per Appendix IX of MARPOL Annex VI, the following data must be submitted to the IMO Ship Fuel Oil Consumption Database:

  1. Ship Identification Details:
    • Name of the ship
    • IMO number
  2. Reporting Period:
    • Calendar year period for which data is submitted
    • Start date (dd/mm/yyyy)
    • End date (dd/mm/yyyy)
  3. Technical Characteristics of the Ship:
    • Ship type (as per Regulation 2 of Annex VI or otherwise specified)
    • Gross Tonnage (GT) – as per International Convention on Tonnage Measurement of Ships, 1969
    • Net Tonnage (NT) – as per the same convention
    • Deadweight Tonnage (DWT)
    • Power output (rated power) of main and auxiliary internal combustion engines over 130 kW (in kW)
    • EEDI (Energy Efficiency Design Index), if applicable
    • Ice Class, if applicable
  4. Operational Data:
    • Fuel oil consumption by fuel type (in metric tonnes)
    • Methods used to collect fuel oil consumption data
    • Distance travelled
    • Hours underway

(iv) Submission of Aggregated Data:

  • Within three months after the end of each calendar year, the ship must report the aggregated values for each data point to its Administration or an authorized organization.
  • Submission is done via electronic communication and in a standardized format provided by the IMO.

(v) Relevance of SEEMP (Ship Energy Efficiency Management Plan) to the DCS:

  • The SEEMP is required to include a description of the methodology that will be used for data collection as per Regulation 22A.
  • It must also outline the processes for reporting the data to the ship's Administration.
  • This ensures consistency, transparency, and compliance with DCS requirements.
Part (b)

Differences Between EU MRV and MARPOL Data Collection and Reporting

EU Monitoring, Reporting, and Verification (MRV) Regulation:

1. Scope:

  • Applicable to ships larger than 5,000 GT calling at any EU port, regardless of flag.
  • Focused on CO2 emissions from all voyages to, from, and between EU ports.

2. Reporting Requirements:

  • Ships must monitor and report CO2 emissions, fuel consumption, and other relevant information on a per-voyage and annual basis. Data includes CO2 emissions, distance traveled, time spent at sea, cargo carried, and transport work.

3. Verification:

  • Emission reports must be verified by accredited third-party verifiers to ensure accuracy and compliance.

4. Public Disclosure:

  • Emission data is made publicly available by the European Commission to enhance transparency and promote accountability.

MARPOL Annex VI Data Collection System (DCS):

1. Scope:

  • Applicable to ships of 5,000 GT and above engaged in international voyages.
  • Focused on fuel consumption and CO2 emissions, but also includes data on energy efficiency.

2. Reporting Requirements:

  • Ships must collect and report fuel consumption, distance traveled, and hours underway on an annual basis.
  • The data is reported to the ship's flag State, which then reports aggregated data to the International Maritime Organization (IMO).

3. Verification:

  • The flag state is responsible for verifying the data before submission to the IMO.

4. Confidentiality:

  • Data reported under MARPOL DCS is aggregated and anonymized before being made available to the public, maintaining confidentiality of individual ship data.
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