FuelEU Maritime Monitoring Plan Guidance Document

COMMISSION IMPLEMENTING 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 

Key additions to the FuelEU Monitoring Plan

B.4 OPS: Equipment for on-shore power supply 

B.5 Zero-emission Technology: For ships not using OPS 

B.6 Electrical Power Demand: At berth 

B.7 Wind Assisted Propulsion (WASP): Description and usage 

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: Entry/exit recording 

C.3.4 Time at Sea and Berth: Recording procedures 

D.2.4.5 Fuel Consumption: OPS, ZET, ICE, Time at Sea/Berth 

E.5 Internal Reviews: FuelEU Maritime Data control activities 

Disclaimer: The sections outlined above represent key additions to the FuelEU Monitoring Plan. However, they are not exhaustive and should be considered as supplementary to the existing EU ETS and MRV monitoring plans. 

Important points to be checked for Plan from section B.1 to B.3

1. The entity responsible for ensuring compliance with this Regulation should be the company, defined as the shipowner or any other organisation or person, such as the manager or the bareboat charterer, that has assumed responsibility for the operation of the ship from the shipowner and that, on assuming such responsibility, has agreed to take over 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).
2. ICE Class (Table B.1 of Plan) – Update ICE class as for any ship having the ice class IC, IB, IA or IA Super or an equivalent ice class, the company may request, until 31 December 2034, to exclude the additional energy consumption, due to sailing in ice conditions.
3. Nature of the company (Table B.2 of Plan) – Shipowner and ISM Company (when shipowner is also an ISM company), ISM Company distinct from Shipowner (when shipowner is Different from ISM company)
4. Technical description of fuel consumer unit (B.3) – The performance/power value of MCR specified on the EIAPP certificate should be used. If the fuel consumer is not required to have an EIAPP certificate, the MCR on the nameplate should be used. 

Table B.4. Equipment to allow connection to onshore power supply (only mandatory for container ships and passenger ships)

‘on-shore power supply’ (OPS) means the system to supply electricity to ships at berth, at low or high voltage, alternate or direct current, including ship-side and port-side installations, when feeding directly the ship main distribution switchboard for powering hotel and service workloads or charging secondary batteries.

The IEC/IEEE 80005-1 standard pertains to High Voltage Shore Connection (HVSC) systems, while IEC/IEEE 80005-3 focuses on Low Voltage Shore Connection (LVSC) systems. These standards define protocols for connecting, transmitting, converting, distributing, controlling, and monitoring systems. While they regulate power systems, equipment, and outlets, the underlying technology and specifications can be intricate. 

However, it does not apply during docking periods, such as dry docking or other out-of-service maintenance and repair.

Table B.5. Zero-emission technology (only mandatory for container ships and passenger ships which do not use on-shore power supply)
‘zero-emission technology’ means a technology that, when used to provide energy, does not result in the release of the following greenhouse gases and air pollutants into the atmosphere by ships: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulphur oxides (SOx), nitrogen oxides (NOx) and particulate matter (PM)

Fuel cells, on-board electrical energy storage from power generation at sea, on-board electrical energy storage from OPS, on-board electrical energy storage from battery swapping, on-board power generation from wind or on-board power generation from solar energy. 

Table B.6. Established total electrical power demand of the ship at berth

As provided in its Electrical load balance or Electrical load study used to demonstrate compliance with Regulations 40 and 41 of Chapter II-1 of the SOLAS Convention. In case the ship is not able to provide this reference, the value considered is 25% of the total of the maximum continuous ratings of the main engines of the ship as specified in their EIAPP certificate delivered in application of the MARPOL Convention or, if the engines are not required to have an EIAPP certificate, on the nameplate of the engines.

Table B.7 Description of Wind Assisted Propulsion equipment (WASP) (when applicable)

‘wind-assisted propulsion’ means propulsion, whether partial or full, of a ship by wind energy harnessed by means of wind-assistance 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 about the systems, procedures and responsibilities used to track the completeness of the list of fuel consumers over the reporting period.

Example

Procedure: In case any change in the fuel consumer occur for the vessels under the Company’s management, the Technical Manager is responsible to fully inform the assigned Superintendent Engineer for the changes and provide them with all the necessary information. The responsible assigned Superintendent Engineer must review and update the list of the emission sources in the related Monitoring Plan(s) and in any other report and document that the Company maintains with the latest information of the emission sources on board, when applicable, in order to ensure completeness and accuracy.

Note – This section is same as EU ETS Monitoring Plan but if the OPS equipment, zero-emission technology, and WASP is installed then 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 to be used on-board, in accordance with the methods specified in Article 10 and Annexes I and II

Companies are required to adhere to the default well-to-tank emission factor values specified in Annex II of Regulation for fossil fuels. However, there is an exception: companies may deviate from these default values if they can provide actual values certified under a Commission-recognized scheme. This certification process applies to biofuels, biogas, RFNBO (Renewable Fuels of Non-Biological Origin), and recycled carbon fuels. The certification aligns with Article 30(5) and (6) of Directive (EU) 2018/2001 or, where applicable, relevant provisions of Union legal acts related to renewable and natural gases and hydrogen within the internal markets.

However Companies shall be entitled to diverge from the default values for the tank-to-wake emission factors set out in Annex II of the regulation, with the exception of tank-to-wake CO2 emission factors for fossil fuels, provided that actual values are certified by means of laboratory testing or direct emissions measurements

Part C Activity data

Table C.1.2. to table C.1.5 of Fuel Eu Monitoring Plan are same as EU ETS monitoring Plan.

1. Table C.1.2. Procedures for determining fuel bunkered and fuel in tanks 
2. Table C.1.3. Regular cross-checks between bunkering quantity as provided by BDN and bunkering quantity indicated by on-board measurement
3. Table C.1.4. Method for determination of fuel density
4. Table C.1.5. Level of uncertainty associated with fuel monitoring

Table C.1.6. Procedures for monitoring energy provided by onshore power supply (OPS) (where applicable) 

1. OPS (Onshore Power Supply): 

• OPS refers to the system that supplies electricity to ships while they are berthed (docked) at a port. 
• It can operate at either low or high voltage and can provide either alternating current (AC) or direct current (DC). 
• The system includes both shipside and port-side installations. 
• Its primary purpose is to directly feed the ship’s main distribution switchboard, which powers various onboard functions such as hotel services (e.g., lighting, air conditioning) and charging secondary batteries. 
• OPS effectively replaces the need for onboard electricity generation from auxiliary generators during berthing. 

1. SBC (Shore-side Battery Charging): 

• SBC involves charging the onboard Battery Energy Storage Systems (BESS) using shore power supply. 
• The charging can be done with either AC or DC, depending on the specific requirements of the BESS onboard. 
• The connection protocol used for SBC is tailored to the BESS configuration. 
• The charging power is specified based on the ship’s needs and the capacity of the BESS. 

Table C.1.7. Procedures for monitoring energy provided by a zero-emission technology (where applicable)

Fuel cells, on-board electrical energy storage from power generation at sea, on-board electrical energy storage from OPS, on-board electrical energy storage from battery swapping, on-board power generation from wind or on-board power generation from solar energy.

Table C.1.8. Procedures for monitoring fuel consumption of each Fuel consumer when sailing in ice conditions

If a ship holds the ice class IA or IA Super (or an equivalent ice class), the company has the option to request the exclusion of additional energy consumption resulting from the ship’s technical characteristics. Additionally, if the ice class is updated, the company needs to update the description of the fuel monitored for each fuel consumer during sailing in ice conditions. 

Table C.2.1. to Table C.3.2. of Fuel Eu Monitoring Plan are same as EU ETS monitoring Plan. 
Table C.2.1. Description of the measurement instruments involved 
Table C.2.2. Procedures for recording, retrieving, transmitting, and storing information regarding 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 voyages 
Table C.3.2. Procedures for determining and recording the Distance travelled 
Table C.3.4. Procedures for determining and recording the time spent at sea and at berth  

The process involves determining and documenting the time spent at sea, from the departure berth at the port of origin to the arrival berth at the destination port. Additionally, it includes recording the time spent at the berth (both quayside and anchorage). The procedures encompass managing and documenting port departure and arrival information 

‘Ship at berth’ means a ship which is securely moored or anchored in a port falling under the jurisdiction of a Member State while it is loading, unloading or hotelling, including the time spent when not engaged in cargo operations; ‘ship at anchorage’ means a ship at berth which is not moored at the quayside; ‘voyage’ means any movement of a ship that originates from or terminates in a port of call and that serves the purpose of transporting passengers or cargo for commercial purposes 

Part D Data gaps

The risk of the occurrence of data gaps should be minimized by developing an appropriate monitoring plan. However, it is not possible to completely exclude events that require the closure of a data gap.

There are several reasons for data gaps or estimations to deliver data to be used in the emissions report. It can be distinguished between events that require the closure of a data gap and those that require the correction of existing data. Corrective measures can be made by using secondary data. In contrast to this, estimations must be used for real data gaps, i.e. When no information by the applied monitoring approach is available.

Companies will be asked to provide a brief description of the method to treat data gaps regarding the parameters other than fuel consumption (i.e., list of voyages, distance, total time spent at sea, cargo carried, number of passengers) as well as control activities to prevent missing data.

This may be the case if information is missing, lost, or found corrupt. It should include a backup solution for each parameter and a formula /description of the calculation.

For example, assume that a flow meter did not output values for 1 day. The Chief Engineer is responsible for noticing this data gap and applying the back-up monitoring method e.g., tank sounding. The Chief Engineer should report the failure promptly to the managing office. If for any other reason, the Chief Engineer cannot close or detect this data gap, then the shore side is responsible for closing it, by applying formulae, historic data etc.

Table D.1. and Table D.3 of Fuel Eu Monitoring Plan are same as EU ETS monitoring Plan

Table D.1. Methods to be used to estimate fuel consumption – The selected Monitoring Method must be different from the method selected under ‘Chosen methods for fuel consumption’ in table C.2.

Table D.3. Methods to be used to treat data gaps regarding distance travelled

Table D.2. Methods to be used to estimate energy consumption from OPS and ZET (where applicable) 
Description of Alternate method needs to be updated for calculating energy consumption from OPS and ZET.

Table D.4. Methods to be used to treat data gaps regarding the date, time and position when entering and leaving the ice conditions, the distance travelled when sailing in ice conditions.

Description of Alternate method needs to be updated to treat data gaps regarding the date, time and position when entering and leaving the ice conditions, the distance travelled when sailing in ice conditions

Table D.5. Methods to be used to treat data gaps regarding time spent at sea and time spent at berth (quayside and anchorage) (where applicable)

Description of Alternate method needs to be updated to treat data gaps regarding time spent at sea and time spent at berth (quayside and anchorage) 

Part E Management

Table E.1. to Table E.8. of Fuel Eu Monitoring Plan are same as EU ETS monitoring Plan.

Table E.5. Control activities: Internal reviews and validation of relevant data – As per the guidelines the description of Internal review and Validation of data for well to tank and tank to wake should be updated.