Guidance on the fuel EU maritime monitoring plan
IMPLEMENTING COMMISSION REGULATION (EU) on the template for monitoring plans pursuant to Regulation (EU) 2023/1805 of the European Parliament and of the Council of 13 September 2023 on the use of renewable and low-carbon fuels in maritime transport and amending Directive 2009/16/EC
Main additions to the FuelEU Monitoring Plan.
- B.4 OPS: equipment for shore power supply
- B.5 Zero emission technology: For ships not using OPS
- B.6 Electric power demand: At berth
- B.7 Wind-assisted propulsion (WASP): Description and use
- B.8 Updating procedures: For fuel consumers, OPS, ZET and WASP
- B.9 Emission factors: Monitoring and reporting
- C.1.6 Monitoring OPS Energy: Procedures.
- C.1.7 Monitoring ZET Energy: Procedures.
- C.1.8 Fuel consumption in ice: Procedures
- C.3.3 Ice conditions: Registration of entry/exit
- C.3.4 Time at sea and mooring: recording procedures
- D.2.4.5 Fuel consumption: OPS, ZET, ICE, time at sea/berth
- E.5 Internal Assessments: Monitoring activities for FuelEU Maritime Data.
Disclaimer: The above sections are important additions to the FuelEU Monitoring Plan. However, they are not exhaustive and should be considered complementary to the existing EU ETS and MRV Monitoring Plans.
Key points to check for the plan from section B.1 to B.3
- The entity responsible for complying with this Regulation is the shipowner, defined as the shipowner or any other organization or person, such as the manager or bareboat charterer, who has assumed responsibility for the operation of the ship from the shipowner and who, by assuming such responsibility, has agreed to assume all the duties and responsibilities imposed by the International Management Code for the Safe Operation of Ships and for Pollution Prevention, as implemented within the Union by Regulation (EC) no. 336/2006 of the European Parliament and of the Council ( ISM company).
- ICE class (Table B.1 of the plan) - ICE class update as for any ship with ice class IC, IB, IA or IA Super or equivalent ice class, the shipowner may request until December 31, 2034 to disregard the additional energy consumption due to sailing in ice conditions.
- Nature of shipowner (Table B.2 of the plan) - Shipowner and ISM company (when the shipowner is also an ISM company), ISM company different from shipowner (when the shipowner is different from an ISM company).
- Technical description of fuel consuming unit (B.3) - The performance/power value of MCR listed on the EIAPP certificate should be used. If the fuel consuming unit is not required to have an EIAPP certificate, the MCR on the nameplate shall be used.
Table B.6. Determined total electric power demand of the vessel at berth.
As stated in the electrical load balance or electrical load study used to demonstrate the ship's compliance with Regulations 40 and 41 of Chapter II-1 of the SOLAS Convention. If the ship cannot provide this reference, the value considered is 25% of the total of the maximum continuous powers of the ship's main engines as stated in their EIAPP certificate issued in application of the MARPOL Convention or, if the engines are not required to have an EIAPP certificate, on the engines' nameplate.
Table B.7 Description of wind-assisted propulsion equipment (WASP) (if applicable).
"Wind-assisted propulsion" means partial or complete propulsion of a vessel by wind energy generated by wind-assisted propulsion systems such as, inter alia, rotor sails, kites, hard or rigid sails, soft sails, suction wings or turbines
Table B.8. Procedures, systems and responsibilities used to update the completeness of the list of fuel consumers, OPS equipment, zero emission technology and WASP
Companies should provide details of the systems, procedures and responsibilities used to update the completeness of the list of fuel consumers during the reporting period.
Example
Procedure: In the event of changes to the fuel consumers for ships under the management of the shipping company, the technical manager is responsible for fully informing the assigned chief engineer of the changes and providing him with all necessary information. The chief engineer in charge should check and update the list of emission sources in the relevant monitoring plans and in all other reports and documents maintained by the company, if applicable, with the latest information on the emission sources on board, to ensure completeness and accuracy.
Note - This section is the same as the EU ETS monitoring plan, but if OPS equipment, zero emission technology and WASP are installed, the section should be updated.
Table B.9. Procedures for monitoring and reporting the well-to-tank and tank-to-wake emission factors of energy used on board, in accordance with the methods specified in Article 10 and Annexes I and II
Companies must comply with the default "well-to-tank" emission factor values specified in Annex II of the regulation for fossil fuels. However, there is an exception: companies may deviate from these default values if they can provide actual values certified according to a system recognized by the Commission. This certification process applies to biofuels, biogas, RFNBO (Renewable Fuels of Non-Biological Origin) and recycled carbon fuels. The certification is in accordance with Article 30(5) and (6) of Directive (EU) 2018/2001 or, where applicable, relevant provisions of Union legal acts relating to renewable and natural gases and hydrogen within internal markets.
However, companies may deviate from the default values for the tank-to-wake emission factors in Annex II of the Regulation, with the exception of the tank-to-wake CO2 emission factors for fossil fuels, provided that the actual values are certified by laboratory tests or direct emission measurements.
Part C Activity Data.
Table C.1.2. through Table C.1.5 of Fuel Eu Monitoring Plan are identical to EU ETS Monitoring Plan.
a. Table C.1.2. Procedures for determining fuel in bunkers and fuel in tanks.
- Table C.1.3. Regular cross checks between bunker quantity as specified by BDN and bunker quantity as indicated by on-board measurements
- Table C.1.4. Method of determining fuel density.
- Table C.1.5. Level of uncertainty associated with fuel control
Table C.1.6. Procedures for monitoring energy supplied by onshore power supply (OPS) (if applicable).
- OPS (onshore power supply):
- OPS refers to the system that provides electricity to vessels while they are moored (docked) in a port.
- It can operate at low or high voltage and can supply alternating current (AC) or direct current (DC).
- The system includes both shipboard installations and port-side installations.
- Its primary purpose is to directly power the ship's main distribution panel, which powers various on-board functions such as hotel services (e.g., lighting, air conditioning) and charging secondary batteries.
- OPS effectively replaces the need for onboard power generation by auxiliary generators during mooring.
- Shore-side Battery Charging (SBC):
- In SBC, onboard battery energy storage systems (BESS) are charged using shore-side electricity.
- Charging can be by AC or DC power, depending on the specific requirements of the onboard BESS.
- The connection protocol used for SBC is matched to the configuration of the BESS.
- The payload is specified based on the needs of the ship and the capacity of the BESS.
Table C.1.7. Procedures for monitoring energy supplied by an emission-free technology (if applicable).
Fuel cells, on-board electrical energy storage from offshore power generation, on-board electrical energy storage from OPS, on-board electrical energy storage from battery switching, on-board wind power generation or on-board solar power generation.
| Types of technology | General requirements for use |
| Fuel cells | Energy provided by on-board fuel cells with a fuel or system that ensures that when used for power generation, no emissions referred to in Article 3(7) are released into the atmosphere. |
| Onboard electrical energy storage | Power supplied by on-board electrical energy storage systems that have been pre-charged via:
|
| on-board power generation from wind and solar energy | Power supplied by on-board renewable energy sources, either directly to the ship's grid or via recharging interim on-board electrical energy storage. |
Table C.1.8. Procedures for monitoring the fuel consumption of each fuel consumer while sailing in ice conditions
If a ship falls in ice class IA or IA Super (or equivalent ice class), the shipping company has the option to request the exclusion of additional energy consumption due to the technical characteristics of the ship. In addition, if the ice class is updated, the shipowner must update the description of the fuel monitored for each fuel consumer while sailing in ice conditions.
Table C.2.1. through Table C.3.2. of the fuel consumption monitoring plan are the same as the EU ETS monitoring plan.
Table C.2.1. Description of the measuring instruments involved.
Table C.2.2. Procedures for recording, retrieving, transmitting and storing information concerning measurements
Table C.2.3. Procedures for ensuring quality assurance of measuring equipment
Table C.3.1. Procedures for determining and recording the list of trips
Table C.3.2. Procedures for determining and recording distance traveled
Table C.3.4 Procedures for determining and recording time spent at sea and at their moorings
The process includes determining and documenting time spent at sea from the berth at departure in the port of origin to the berth at arrival in the port of destination. In addition, it includes recording time spent at the berth (both at the quay and at the anchorage). Procedures include managing and documenting information on departure and arrival at the port
"Ship at berth" means a ship that is safely moored or at anchor in a port under the jurisdiction of a member state while it is loading, unloading or warming up, including the time it is not engaged in cargo operations. a ship at berth that is not moored at the quay; "voyage" means a movement of a ship that begins or ends at a port of call and is for the purpose of carrying passengers or cargo for commercial purposes
Part D Missing data.
The risk of data gaps should be minimized by developing an appropriate monitoring plan. However, it is not possible to completely eliminate events where data are missing.
There are several reasons for missing data or estimates to provide data to be used in the emissions report. A distinction can be made between events that require data gaps to be closed and events that require existing data to be corrected. Corrections can be made by using secondary data. In contrast, estimates should be used for true data gaps, i.e., when no information is available through the monitoring approach used.
Companies are asked to provide a brief description of the method for addressing missing data related to parameters other than fuel consumption (i.e. list of voyages, distance, total time at sea, cargo carried, number of passengers) and monitoring activities to avoid missing data.
This may be the case if information is missing, lost or found to be corrupt. It should include a backup solution for each parameter and a formula / description of the calculation.
For example, suppose a flow meter did not give values for 1 day. The chief engineer is responsible for noticing this missing data and applying the backup monitoring method, e.g. tank polling. The chief engineer must immediately report the failure to headquarters. If for some other reason the chief engineer cannot fill or detect this gap in the data, the shore side is responsible for filling it by applying formulas, historical data, etc.
Table D.1. and Table D.3 of the Fuel European Monitoring Plan are the same as the EU ETS Monitoring Plan.
Table D.1. Methods to estimate fuel consumption - The selected monitoring method should be different from the method selected under "Selected methods for fuel consumption" in Table C.2.
Table D.3. Methods for handling missing distance travelled data.
Table D.2. Methods to be used for estimating energy consumption from the OPS and ZET (if applicable).
Description of Alternative method to be updated for calculation of energy consumption from OPS and ZET.
Table D.4. Methods to be used to deal with missing data related to date, time and position when entering and leaving the ice corridor, distance traveled when sailing in ice corridor.
Description of alternative method to be updated for handling gaps in the data related to the date, time and position when entering and leaving the ice corridor, the distance travelled when sailing in ice conditions
Table D.5. Methods for treating gaps in data on time spent at sea and at their berth (quay and anchorage) (if applicable)
Description of Alternative method to be updated to address gaps in data on time spent at sea and at their berth (quay and anchorage)
Part E Management
Table E.1 to Table E.8 of the Fuel Eumon Monitoring Plan are the same as the EU ETS Monitoring Plan.
Table E.5. Monitoring activities: Internal evaluations and validation of relevant data - According to the guidelines, the description of Internal evaluation and validation of data for well to tank and tank to wake should be updated.
Questions?
Our experts are at your service