Approved by SMD

Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 1 of 13

EMISSIONS TO AIR

1. Purpose

The purpose of this procedure is to ensure compliance with international and national environment protection
legislation, to prevent air pollution, control and decrease emissions to air from the ships.

2. Scope

The procedure comprises control of following ship emissions to air:

· emissions of ozone depleting substances from ship’s equipment, such as refrigeration and air
conditioning plants, fire-extinguishing systems;
· various emissions from ship’s engines, boilers, incinerators;
· emissions of cargo vapours from tankers (volatile organic compounds).

3. General Provisions

3.1 Definitions

Ozone depleting substances mean substances that deplete the ozone layer, and may be found on
board ship such as (but are not limited) : Halon 1211, Halon 1301, Halon 2402 (also known as Halon
114B2), CFC-11, CFC-12, CFC-113, CFC-114, CFC-115, HCFCs (hydro-chlorofluorocarbons).

Volatile organic compounds (VOCs) are organic chemical compounds that have high enough vapour
pressures under normal conditions to significantly vaporize and enter the atmosphere. Depending on ship’s
cargo numerous and varied VOCs are emitted on tankers with waste gases from cargo handling processes.

Particulate matter (PM), alternatively referred to as particulates or fine particles, are tiny subdivisions of
solid matter suspended in a gas. Diesel particulate emissions are often less than 2.5 microns in size, and
consist of a complex mix of engines oils, sulphates and inorganic materials.

Greenhouse gases (GHG) are gases in an atmosphere that absorb and emit radiation within the thermal
infrared range or trap the heat in the atmosphere. This process is the fundamental cause of the greenhouse
effect - theory of unprecedented global warming with potentially harmful consequences for the environment
and human health. The principal greenhouse gases that enter the atmosphere because of human activities are:
Carbon Dioxide (CO2), Methane (CH4), Nitrous Oxide (N2O), Fluorinated Gases (Hydrofluorocarbons,
perfluorocarbons, and sulfur hexafluoride).

Emission Control Area means an area where the adoption of special mandatory measures for emissions from
ships is required to prevent, reduce and control air pollution from NOx or SOx and particulate matter or all
three types of emissions and their attendant adverse impacts on human health and the environment.
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 2 of 13

SOx Emission Control Area means an area where the adoption of special mandatory measures for
SOx emissions from ship is required to prevent, reduce and control air pollution from SOx.

NOx Technical Code means the Technical Code on Control of Emission of Nitrogen Oxides from
Marine Diesel Engines adopted by 1997 MARPOL Conference, as amended by the IMO. The purpose of
this code is to specify the requirements for the testing, survey and certification of marine diesel engines to
ensure they comply with the nitrogen oxides (NOx) emission limits.

3.2 Requirements

International regulations for the prevention of air pollution from ships were adopted in the 1997 Protocol to
MARPOL 73/78 and are included in Annex VI of the Convention The new/amended MARPOL Annex VI
comes into force on 1 July 2010, which
· sets limits on sulphur oxide and nitrogen oxide emissions from ship exhausts and prohibits
deliberate emissions of ozone depleting substances;
· contains provisions allowing for special SOx ECA to be established with more stringent controls
on sulphur emissions;
· prohibits deliberate emissions of ozone depleting substances, which include halons and
chlorofluorocarbons (CFCs), new installations containing ozone-depleting substances are
prohibited on all ships but new installations containing hydro-chlorofluorocarbons (HCFCs) are
permitted until 1 January 2020;
· sets limits on emissions of nitrogen oxides (NOx) from diesel engines, including a mandatory
NOx Technical Code, which defines how this shall be done;
· prohibits the incineration onboard ship of certain products, such as contaminated packaging
materials and polychlorinated biphenyls (PCBs).

National, regional or local regulations of air emissions from ships are contained in flag State maritime
legislation and promulgated in Company circulars.

3.3 Responsibilities

Ship’s Master shall ensure proper control of all ship’s emissions to air, compliance with international,
national, regional requirements and implementation of current procedure onboard.

All ship officers must be familiar and ensure strict compliance with the regulations of the Annex VI of
MARPOL 73/78 Convention, as amended. Special attention should be drawn to compliance with the
regulations covering the following areas:
· ozone depleting substances - Reg.12,
· nitrogen oxides (NOx)- Reg.13,
· sulphur oxides (SOx) and particulate matter - Reg.14,
· volatile organic compounds (VOCs) - Reg.15,
· shipboard incineration - Reg.16,
· reception facilities - Reg.17,
· fuel oil availability and quality - Reg.18.

All crew should take care of air protection from pollution and proactively report any noted deficiency or
suggested improvement in order to decrease ship emissions to air.
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 3 of 13

4. Ozone Depleting Substances

Any deliberate emission of ozone depleting substances is prohibited. Deliberate emissions include emissions
occurring in the course of maintaining, servicing, repairing or disposing of systems or equipment, except that
deliberate emissions do not include minimal releases associated with the recapture or recycling of an ozone
depleting substance.

Equipment containing ozone depleting substances shall be delivered to appropriate reception facilities when
removed from ships.

The Master must notify immediately the Company of emissions arising from leaks of an ozone depleting
substance whether or not the leaks were deliberate.

Chief Engineer shall ensure that

· proper inventory of ozone depleting substances is kept onboard,
· use of these substances is under strict control,
· emission of these substances is avoided in the course of maintaining, servicing, repairing or disposing
of systems or equipment, such as refrigeration and air conditioning plants, fixed fire-extinguishing
systems, and
· releases associated with the recapture or recycling of an ozone depleting substance is minimised.

New MARPOL Annex VI entering into force on 1 July 2010 requires that each ship maintains a list of
equipment containing ozone depleting substances and Ozone Depleting Substances Record Book is
maintained for rechargeable systems that contain ozone depleting substances. This Record Book may form
part of an existing log-book or electronic recording system as approved by the Administration.
Entries in the Ozone Depleting Substances Record Book shall be recorded in terms of mass (kg) of substance
and shall be completed without delay on each occasion, in respect of the following:
1. recharge, full or partial, of equipment containing ozone depleting substances;
2. repair or maintenance of equipment containing ozone depleting substances;
3. discharge of ozone depleting substances to the atmosphere:
1 deliberate; and
2 non-deliberate;
4. discharge of ozone depleting substances to land-based reception facilities; and
5. supply of ozone depleting substances to the ship.

5. Nitrogen Oxides (NOx)

Nitrogen Oxide (NOx) emissions means the total emission of nitrogen oxides, calculated as the total
weighted emission of NO2 and determined using the relevant test cycles and measurement methods as
specified in NOx Technical Code.

The nitrogen oxides (NOx) which can be formed include nitric oxide (NO) and nitrogen dioxide (NO2), while
the amounts are primarily a function of flame or combustion temperature and, if present, the amount of
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 4 of 13

organic nitrogen available from the fuel, NOx formation is also a function of the time the nitrogen and the
excess oxygen are exposed to the high temperatures associated with the diesel engine’s combustion process.
In other words, the higher the combustion temperature (e.g., high-peak pressure, high-compression ratio,
high rate of fuel delivery, etc.), the greater is the amount of NOx formation. A slow-speed diesel engine, in
general, tends to have more NOx formation than a high speed engine. NOx has an adverse effect on the
environment causing acidification, formation of tropospheric ozone, nutrient enrichment and contributes to
adverse health effects globally.

Each marine diesel engine with a power output of more than 130 kW installed on a ship, except for those
intended to be used solely for emergencies, shall comply with the applicable emission limit in accordance
with the NOx Technical Code and shall have Engine International Air Pollution Prevention (EIAPP)
certificate.

It is prohibited to carry out alterations, which include any change or adjustment to the system, fittings or
arrangement of diesel engine that may increase the nitrogen oxide emission.

To enable onboard NOx verification procedures the Chief Engineer shall keep Technical File for each
relevant engine and ensure that engine adjustments are within allowable range and engine’s performance
records are being kept.

The Technical File is required to accompany an engine throughout its life on board ships. The Technical File
shall, at a minimum, contain the following information:
· identification of those components, settings and operating values of the engine which influences its
NOx emissions including any NOx reducing device or system;
· identification of the full range of allowable adjustments or alternatives for the components of the
engine;
· full record of the relevant engine’s performance, including the engine’s rated speed and rated power;
· a system of onboard NOx verification procedures to verify compliance with the NOx emission limits
during onboard verification surveys;
· a copy of the relevant Parent Engine test data;
· if applicable, the designation and restrictions for an engine which is an engine within an Engine
Family or Engine Group;
· specifications of those spare parts/components which, when used in the engine, according to those
specifications, will result in continued compliance of the engine with the applicable NOx emission
limit; and
· the EIAPP Certificate, as applicable.
The Company is monitoring operational environmental efficiency related to NOx emissions by calculating:
· Emitted Mass of NOx - the total mass of emitted NOx in laden and ballast condition, calculated on
the basis of fuel consumption and engine speed;
· NOx Efficiency - the amount of NOx emitted relative to the transport work performed.

6. Sulphur Oxides (SOx)

SOx emissions mainly depend on sulphur content of the fuel oil. These emissions contribute to a number of
environmental impacts, including the greenhouse effect, local air pollution and acid rain. Quantity of SOx
emissions depends on sulphur content of fuel oil used on board.
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 5 of 13

The new/amended MARPOL Annex VI coming into force on 1 July 2010 requires that the sulphur content of
any fuel oil used on board ships shall not exceed the following limits:
· 4.50% m/m prior to 1 January 2012;
· 3.50% m/m on and after 1 January 2012; and
· 0.50% m/m on and after 1 January 2020.

While ships are operating within an SOx ECA, the sulphur content of fuel oil used on board ships shall not
exceed the following limits:
· 1.50% m/m prior to 1 July 2010;
· 1.00% m/m on and after 1 July 2010; and
· 0.10% m/m on and after 1 January 2015.

For the purpose of this regulation, SOx ECA include the Baltic Sea, the North Sea and any other sea area as
defined by MARPOL 73/78, as amended.

In addition to international requirements set in MARPOL 73/78, as amended, the ship must comply with
national requirements developed by certain countries for sulphur content of fuel oil used on board ships.

With effect from 1 January 2010 European Union (EU) requires use of marine fuels with maximum 0.1%
sulphur content when ships are at berth in EU ports. Ships at berth means ships which are securely moored or
anchored in a EU port while they are loading, unloading or hotteling, including the time spent when not
engaged in cargo operations The only exemption is given to ships staying less than 2 hours in port.

The California Air Resources Board (CARB) has issued fuel requirements applicable to ocean-going vessel
main (propulsion) diesel engines, auxiliary diesel engines (including diesel-electric), and auxiliary boilers
when operating within the 24 nautical mile regulatory zone off the California Coastline (Regulated
California Waters – RCA) . The main elements of the CARB are in two phases:

1. Phase One, beginning on 1 July 2009, requires all main engines and auxiliary boilers to use either
marine gas oil (DMA) with a 1.5% sulphur limit or marine diesel oil (DMB) with a 0.5% sulphur
limit.
2. Phase Two, beginning on 1 January 2012, requires all main engines, auxiliary diesel engines and
auxiliary boilers to use either DMA or DMB with a 0.1% sulphur limit.

Ships using separate fuel oils to comply with these regulations and entering or leaving a SOx ECA shall
carry a written procedure, approved by the Chief Engineer, showing how the fuel oil change-over is to be
done, allowing sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the
applicable sulphur content prior to entry into SOx ECA.

Prior to entering SOx ECA the ship’s Master shall ensure that the ship
· is able to comply with requirements on sulphur content of fuel used; and
· has sufficient stock of low sulphur fuel oil taking into account safety margins.

Master shall ensure that the Chief Engineer is duly notified by OOW prior to entering of SOx ECA in order
to have sufficient time for fuel oil change-over, if necessary.

Chief Engineer shall ensure that following records are entered into engine room logbook:
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 6 of 13

· the date, time, and position of the ship enter or leave SOx ECA;
· the date, time, and position of the ship at the initiation and completion of any fuel-oil-change-over
operation prior to the entry into SOx ECA or after exit from such an area;
· the volume of low sulphur fuel oils in each tank after fuel-oil-change-over.
· additionally in California Regulated Waters (CRW) - the type of fuels used (e.g. heavy fuel oil,
marine gas oil, etc.) in each auxiliary engine, main engine, and auxiliary boiler within RCW.

Ship’s Chief Engineer shall ensure strict ship’s compliance with Company bunkering procedures and
MARPOL 73/78 Convention Annex VI, Reg. 18 regarding bunker delivery notes, declarations and fuel oil
samples.

The Company is monitoring operational environmental efficiency related to SOx emissions by calculating:
· Emitted Mass of SOx - the total mass of emitted SOx in laden and ballast condition, calculated on
the basis of fuel consumption, fuel quality and sulphur content;
· SOx Efficiency - the amount of SOx emitted relative to the transport work performed.

7. Particulate Matter (PM)

7.1 General PM control measures

Particulate air pollution comes from internal combustion engine or boiler exhaust and is a combination of
fine solids such as dirt, soil dust, ashes, soot and aerosols chemically formed in the atmosphere from gaseous
combustion by-products. Black carbon or elemental carbon, often called soot, is composed of pure carbon
clusters, skeleton balls, and is one of the most important source of PM pollution.

Solid particulates can be removed by filters. Particulate filters offer retrofit opportunities. However, because
these devices require specific equipment conditions to operate effectively they cannot be used in some
applications. Filters work best with newer engines that achieve higher sustained engine exhaust temperatures.
Filters also require the use of low sulphur bunker. Low sulphur fuels can provide effective PM control.
Reducing the sulphur content of fuels provides a direct fuel related reduction in PM emissions. More
importantly, low sulphur fuel allows the use of emission control technologies that have been proven effective
in providing significant PM control. Smoke testing at different equipment operating conditions and loads
may also provide PM control.

Equipment should be operated in full accordance with manufacturers’ instructions to reduce PM emissions
and Chief Engineer shall ensure that:
· main engine and auxiliary engines turbochargers, auxiliary boilers burners, fuel oil pumps, valves and
etc. are in good working condition and correctly adjusted;
· fuel purification plant, fuel burning equipment, fuel injector systems, turbo-charger systems, vessel’s
incinerator plant are operated in efficient manner according to manufacturers’ guidelines;
· fuel oil treatment is carried out in accordance with specifications of engines’ manufacturer and fuel
oil laboratory recommendations based on test of fuel oil samples;
· washing and blowing of any boiler, auxiliary engine exhaust manifold and main engine/ auxiliary
engine turbocharger is carried out on a regular basis and complies with manufacturers’ requirements
and AMOS planned maintenance system;
· cleaning of soot catchers and spark arresters should be carried out at least every 3 months.
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 7 of 13

7.2 Funnel emission control

Emission of smoke from the funnel must be always correctly controlled and local port regulations regarding
atmospheric pollution strictly adhered to.

Duty engineer should perform regular sighting of the funnel gases to verify that the combustion is efficient
and emission of black smoke is avoided. Deck officer of the watch (OOW) also should pay due attention to
the condition of the funnel emissions and he is to advise the duty engineer if he has any concern regarding air
pollution, heavy soot or sparks emission.

On tankers spark emission from funnel is a serious fire hazard. If sparks are emitted from the funnel, any
cargo, ballasting or tank cleaning operations in progress must be stopped immediately, all tanks openings
closed, fixed fire extinguishing system activated. If the ship is at sea, altering of ship’s course must be
considered as soon as possible to avoid sparks falling on the tank deck.

7.3 Soot blowing procedure

To avoid accidental uncontrolled emission of soot and/ or sparks from ship’s funnel the soot blowing of
boilers, engine exhaust manifolds and turbochargers must be carried out
· in strict accordance with equipment manufacturers’ instructions;
· on a regular basis according to AMOS maintenance system;
· before entering into a port/ relevant emission control area;
· under permanent visual funnel emission control by the crew.

Soot blowing in port is strictly prohibited as well as any adjustments to ship’s equipment that can cause soot
or spark emission from the funnel.

Just before the soot blowing the responsible ship’s engineer shall
· agree the operation with OOW to avoid soot falling on tank deck, taking into account wind direction;
· check the condition of spark arresters;
· arrange for continuous visual control of funnel emissions during the operation;
· ensure that reliable communications are established between all involved parties.

Equipment soot blowing should be recorded in AMOS maintenance system, engine room logbook or
pre-arrival checklists as appropriate.

8. Volatile Organic Compounds (VOC)

During cargo operations on tankers the need to discharge various types of cargo vapours to the atmosphere is
sometimes unavoidable. The procedures for the various operations are to be found in the relevant vessel type
operations manuals. These are to be read in conjunction with the relevant MARPOL 73/78 and other
regulations relating to the type of gas being vented and are to be strictly adhered to. If the Master has any
doubt regarding compliance he is to contact the Company immediately.

Under the provisions of MARPOL 73/78 Convention Annex VI, Reg. 15 certain ports and terminals may be
designated where VOCs emissions from tankers are regulated. A list of such ports and terminals shall be
circulated by IMO. Designated ports and terminals at which VOCs emissions from tankers are regulated shall
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 8 of 13

ensure that approved vapour emission control systems are provided and are operated safely and in a manner
so as to avoid undue delay to a ship.

A tanker shall be provided with an approved vapour collection system and shall use this system during the
loading of relevant cargoes, a tanker also should comply with OCIMF recommendations regarding vapour
manifolds.

To reduce VOC emissions at any terminal during loading ship’s Master and Chief Officer should initiate and
agree with the terminal use of approved vapour emission collection system and vapour return ashore
whenever possible.

Chief Officer shall ensure that

· closed loading/ discharging/ sampling procedures are always adhered to;
· cargo tank venting system and vapour collection system are in proper working condition and correctly
used;
· portable gas analysers are always used to control the deck atmosphere during cargo operations as
appropriate.

When transporting crude oils, particularly at the start of a loaded voyage, a large build up of vapour pressure
can be observed requiring a controlled release of gas. It is important to establish when a manually controlled
release of pressure becomes necessary for the safe operation of the vessel and when a manually controlled
release should be stopped so as excess cargo vapours are not unnecessarily released to the atmosphere
causing a loss of cargo and air pollution.

Amendments to MARPOL Annex VI, entering into force on 1 July 2010, require crude oil carriers to
develop and have on board an approved Volatile Organic Compound (VOC) Management Plan.

9. Shipboard Incineration

Incineration has a number of outputs such as the ash and the emission to the atmosphere of flue gas. Before
the flue gas cleaning system, the flue gases may contain significant amounts of particulate matter, heavy
metals, dioxins, furans, sulfur dioxide, and hydrochloric acid.

The steam content in the flue may produce visible fume from the stack, which can be perceived as a visual
pollution. It may be avoided by decreasing the steam content by flue gas condensation and reheating, or by
increasing the flue gas exit temperature well above its dew point. Also, with higher incineration
temperatures, the amount of dioxin can be reduced.

Shipboard incineration of generated waste is allowed only in approved shipboard incinerator. All solid waste
collected aboard ship, including those from the engine room, such as oily rags and combustible materials,
must be disposed of in the incinerator and relevant records made in Garbage Record Book.

Shipboard incineration of sewage sludge and sludge oil generated during normal operation of a ship may also
take place in the main or auxiliary power plant or boilers, but in those cases, shall not take place inside ports,
harbours and estuaries.

Incineration of the following substances in ship’s incinerator is prohibited:

 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 9 of 13

· Annex I, II ,and III of MARPOL cargo residues and related contaminated packing materials;
· polychlorinated biphenyls (PCBs);
· garbage, as defined in Annex V of MARPOL, containing more then traces of heavy metals;
· refined petroleum products containing halogen compounds;
· sewage sludge and sludge oil either of which are not generated on board the ship;
· exhaust gas cleaning system residues;
· polyvinyl chlorides (PVCs)

Ship’s Chief Engineer is responsible for correct operation of the incinerator and shall strictly implement the
guidance provided in the manufacturer’s operating manual.

The combustion chamber gas outlet temperature of the ship’s incinerator shall be monitored at all times the
unit is in operation. Where that incinerator is of the continuous-feed type, waste shall not be fed into the unit
when the combustion chamber gas outlet temperature is below 850°C. Where that incinerator is of the
batch-loaded type, the unit shall be designed so that the combustion chamber gas outlet temperature shall
reach 600°C within five minutes after start-up and will thereafter stabilize at a temperature not less than
850°C.

10. Greenhouse Gases (GHG)

The IMO has embarked on a difficult process to develop an international GHG emission regulatory regime
for shipping. The main greenhouse gas emitted by ships is carbon dioxide (CO2) which enters the
atmosphere through the burning of fuels. Although it is recognised that shipping is the most energy-efficient
mode of transportation in terms of CO2 amount emitted to move cargo per a set distance, there are strong
views that:
· ships have to contribute to the general effort in reducing GHG/ CO2 human produced emissions and
· observations indicate that the total CO2 emissions from ships over the last 20 years has had the
fastest growth, practically by 100%.

In November 2003, the IMO adopted resolution A.963(23) describing policies and practices related to the
reduction of greenhouse gas emissions from ships and expressed the need to achieve the limitation or
reduction of GHG emissions from international shipping. In July 2005, the MEPC approved interim
guidelines for voluntary ship CO2 emission indexing.

It is expected the IMO to agree on a set of requirements aimed at reducing GHG emissions from ships, which
could include three types of measures:
· Energy Efficiency Design Index (EEDI) for new ships;
· Ship Energy Efficiency Management Plan (SEMP), including a ship Energy Efficiency Operational
Indicator (EEOI) for ships already in service;
· Market Based Instruments (MBI) with more concrete proposals such as GHG Compensation Fund,
Emission Trading System (ETS).

A number of European countries suggest that the IMO should create a carbon Emission Trading Scheme
(ETS) for shipping, and have indicated that if the IMO does not do so, that they would advocate that the EU
establishes such a scheme applicable to all ships trading in European ports. The principle of an ETS is often
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 10 of 13

based on capping emissions (either by industry sector or business wide) and assigns allowances of CO2
emissions to various industry players, including ship owners and operators. These allowances or credits
could then be traded with other industry players who have credits available or who require additional credits
in order to avoid exceeding the cap. This is then seen as a market mechanism since a ton of CO2 credits has
a certain monetary value that is then capable of being bought and sold

It is a Company policy to promote low-emission shipping in order to help limit the impact of shipping on
global climate change. The Company has adopted IMO tools to achieve the efficient use of energy and
limitation or reduction of greenhouse gas emissions from ships in operation

The Company is monitoring operational environmental efficiency related to CO2 emissions by calculating:
· Emitted Mass of CO2 - the total mass of emitted CO2 in laden and ballast condition, calculated on
the basis of fuel consumption;
· CO2 Efficiency (or energy efficiency - EEOI) - the amount of CO2 emitted relative to the transport
work performed.

11. EU MRV Regulation

The European Commission (EC) is bringing emissions from shipping into its 2009 climate and energy
package. MRV (Monitoring, Reporting and Verification of CO2 emissions) is designed to progressively
integrate maritime emissions into the EU’s policy for reducing domestic greenhouse gas emissions (EU
regulation 2015/757). MRV requires ship owners and operators to annually monitor, report and verify CO2
emissions for vessels larger than 5,000 GT and which call at any EU port. The results will be published on a
regular basis. Entered into force on 1 July 2015, the regulation will become fully effective on 1 January
2018. Shipping companies will need to prepare a monitoring plan by 31 August 2017 at the latest for each of
their ships that falls under the jurisdiction of the regulation. They will have to monitor and report the verified
amount of CO2 emitted by their vessels on voyages to, from and between EU ports and will also be required
to provide information on energy efficiency parameters (see below). Data collection on a per-voyage basis
will commence on 1 January 2018. Once the data is verified by a third-party organization and sent to a
central database, presumably managed by the European Maritime Safety Agency (EMSA), the aggregated
ship emission and efficiency data will be published by the European Commission by 30 June 2019 and then
every consecutive year. All intra-Union voyages, all incoming voyages from the last non-EU port to the first
EU port of call and all outgoing voyages from a EU port to the non-EU port of call , including ballast
voyages, should be considered relevant for the purposes of monitoring. As the accountable entity, the
Company must:
- develop Monitoring Plan for each vessel and have it assessed by verified before 31 August 2017;
- monitor and verify ship’s reports on emission and activity data, starting from 1 January 2018;
- submit emissions reports for independent verification prior 30 April 2019;
- obtain Document on Compliance for each vessel prior 30 June 2019 nad place it on-board.
Starting from 1 January 2018 the Company will have to monitor and report the verified amount of CO2
emitted by their vessels (>5,000 GT) on voyages to, from and between EU ports. Information such as fuel
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 11 of 13

consumption, cargo loads and energy efficiency parameters will be repoerted by vessel via Noon Report (see
Company procedure DPM-03/02). The following data should be monitored for each voyage:
- Fuel Consumption at sea;
- Fuel Consumption at berth;
- Time at sea;
- Distance sailed;
- Cargo on-board in metric tons;
- Transport work;
- Energy Efficiency parameters.
CO2 Emissions monitoring methodologies are the following:
- Method A - Bunker fule delivery note (BDN) and periodic stocktakes of fuel tanks;
- Method B - Bunker fuel tank monitoring on-board;
- Method C - Flow meters for applicable combustion processes;
- Method D - Direct CO2 emission measurement.
The MRV Regulation is only applicable to commercial voyages to, from and in-between any EU or EEA
(European Economic Area) port to load or unload cargo. The EU MRV regulation applies a berth-to-berth
concept for voyages. Hence, a voyage starts at berth and ends at berth. Sailing with a pilot and/or anchoring
while waiting for port entrance are considered to be part of the voyage. However, the time spent at sea shall
be calculated based on port departure and arrival information and shall exclude anchoring. Diffrence between
in-Port and Voyage emissions reporting is described on the following sketch.
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 12 of 13

For reporting purposes, only port calls where either cargo is loaded or unloaded are considered port of call.
Loading from various terminals and transhipment withnin port limitss should be reported as in-Port
emissions. Consequently, stops for the sole purpose of refuelling, obtaining supplies, relieving the crew,
going into dry dock or making repairs to the ship and/or its equipment, as well as stops in port because the
ship is in need of assistance or in distress, stops for ship-to-ship transfers carried out outside ports and stops
for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue
activities are excluded.
The EU MRV regulation has been included in the EEA (European Economic Area) agreement pending
constitutional requirements by Iceland. Therefore, this implies that all references in the MRV shipping
regulation to member states should be interpreted as including EEA states (EU member states, Iceland and
Norway). Some territories belonging to EU member states are not considered EU territories according to the
treaty of accession of the respective member state. As a consequence, ports located in these territories are
considered non-EU ports in terms of the MRV shipping regulation. Territories which are not considered EU
territories, and thus non-EU ports, are Greenland and the Faroe Islands, French Polynesia, Mayotte, New
Caledonia, Saint-Barthélemy, Saint Pierre and Miquelon, Wallis and Futuna, Aruba, Bonaire, Saba, Sint
Eustatius, Curaçao, Sint Maarten, Anguilla, Bermuda, British Antarctic Territory, British Indian Ocean
Territory, British Virgin Islands, Cayman Islands, Falkland Islands, Bailiwick of Guernsey, Isle of Man,
Jersey, Montserrat, Pitcairn, Henderson, Ducie and Oeno Islands, Saint Helena, Ascension and Tristan da
Cunha, South Georgia and the South Sandwich Islands, Turks and Caico Islands, Akrotiri and Dhekelia. It
should further be noted that a port call at Spitzbergen (Svalbard) is also not considered a EU MRV relevant
port call.
Relevant data need to be recorded and aggregated on a voyage basis by ship’s staff and, subsequently, also
aggregated annually by the Company. An exemption is applied to vessels which conduct more than 300
 Approved by SMD
Mikkjal Poulsen
Main Company Manual
MCM-05/02 Emissions to Air 930.301.05.02
Revision no: 5 Date: 19.03.2018 Issued by: Sidorenko Aleksejs Page 13 of 13

voyages per year and all voyages during this year either start from or end at an EU port. These vessels are
excluded from reporting on a per-voyage basis and only have to record and report annual data sets.

12. References

· Annex VI of MARPOL 73/78 Convention

· NOx Technical Code
· IMO Resolution A.963(23) - IMO POLICIES AND PRACTICES RELATED TO THE
REDUCTION OF GREENHOUSE GAS EMISSIONS FROM SHIPS
· EU MRV Regulation - Regulation 2015/757 on Monitoring, Reporting and Verification of Carbon
Dioxide Emissions from Maritime Transport