Common deficiencies in Monitoring plans

Incomplete company contact information, such as business address (including city, state, postal/ZIP code and country), contact person's name, business phone number and business email address.

• The list of measuring equipment is incomplete. All equipment used for measurement must be included to ensure the monitoring plan's completeness. Check whether all measuring equipment mentioned in other parts of the MP are listed in this table
• The technical description of the measuring equipment lacks specific details, such as type, model, age, and maintenance strategy
• The listed measuring equipment cannot be used to monitor the given emission source
• There is inconsistency between the measuring equipment mentioned in the "measuring equipment" table, the "emission sources" table and the "fuel tanks" table

A procedure is an overarching document that outlines the general steps and guidelines for a specific process or task. The description of any activity referenced in the monitoring plan must be detailed enough to serve its purpose: providing sufficient information for the administering authority to make an informed decision on whether to approve the monitoring plan. This is only achievable when the procedure is described in enough detail to assess compliance with the legal requirements of the MRV Maritime Regulation.

The NEa expects that the "description of the procedure" should at least briefly cover the following:

• The purpose of the procedure
• The steps of the procedure
• How these steps are executed
• Who is responsible for executing the procedure
• Who is responsible for controlling and maintaining the procedure
• What actions are taken in case of deviations
• When the procedure should be reviewed

Common deficiencies of the procedure

Version number and/or reference to existing procedure:  The version and/or the reference number are not filled in or are not specific. When referring to a document, refer to the specific chapter or page number.

Describing a procedure:

• The procedure description is often overly detailed and resembles a work instruction. The NEa does not expect a detailed document outlining specific step-by-step instructions for executing an activity
• The procedure description is insufficient, as it omits essential general steps necessary for the process or task

Name of person or position responsible for this procedure: the individual or position responsible for the procedure's operation is often listed instead of the manager accountable for quality control. The individual who should be listed as responsible is the manager accountable for quality control, rather than the operational staff.

Location where records are kept: The location where records are kept should be clearly specified. General descriptions such as "on board" or "onshore" are too vague and do not provide sufficient detail. The purpose of listing a precise location is to ensure that inspectors or company personnel can easily locate the documents when required. This may include specifying exact locations, such as a particular office, department, or storage area on board the ship or at the onshore facility, so that the records are accessible without unnecessary delays. Accurate record-keeping locations contribute to efficient audits, inspections, and overall compliance.

Name of the IT system used (where applicable): it is essential to specify which IT system is used as part of the data flow, as this ensures transparency and helps verify data management processes.

• The emission sources mentioned are not specified by type,  installation number ( TAG or equipment code) etc.
• The emission sources are not consistent with Fuel types and Emission Factors

• The specification of used fuel tanks is not complete or is insufficient. It is important to mention in which tank specified fuel is stored and often service- and settling tanks are missing in the list of used tanks. It is important to list all fuel tanks on board including the method to determine fuel density for eacht tank
• The fuel type mentioned is not identical to the fuel type mentioned in the "emission sources" section and "Fuel types and emission factors" section
• The description of the method to determine actual density values of fuel in tanks is missing

• One or more of the listed "fuel types" does not match the fuel types specified in Regulation (EU) 2015/757
• One or more of the listed "fuel types" is inconsistent with the "fuel type" specified in section Fuel Tanks or section Emission sources
• For each fuel type, a method to determine the fuel density of the fuel bunkered should be listed

The back-up method should differ from the monitoring method chosen in the Emission sources section and the Fuel tanks section. The back-up monitoring method should be used in case data is missing, lost or found to be corrupt (for instance because a flow meter failed to output values).

Therefore, the method, measuring equipment and data should be different from those used in the standard monitoring method. The “data gaps” procedure should include a back-up solution for each parameter and a formula or description of the calculations. 

The minimum number of expected voyages per reporting period, falling under the scope of the EU MRV Regulation, is not specified.

The data flow procedure should describe how the data is handled from collecting and recording the measurements to compiling the emissions report. It might be necessary to provide a data flow diagram. Also provide a description of responsibilities and software used. Often, we see data flow procedures that are too general or unclear about specific steps.

Often we see that only the purpose of a risk assessment is described, or that the risks identified are not related to ETS and MRV. The risk assessment procedure should describe how the risk assessment is performed and how mitigating measures are implemented in the control system. It should focus on inherent risks and control risks related to the monitoring and reporting of greenhouse gas emissions for EU ETS and MRV Maritime. It should also describe how often the risk assessment is updated and who is responsible for carrying out the procedure. 

A well-functioning control system is crucial for ensuring compliance with the monitoring and reporting principles of the EU ETS, including completeness, consistency, comparability, transparency, accuracy, integrity, and continuous improvement.

Shipping companies are required to regularly monitor its effectiveness through internal reviews and by incorporating feedback from verifiers during the verification of emission reports. Additionally, feedback from the administrative authority after evaluating the monitoring plan should also be considered to ensure continuous improvement and compliance. If a company identifies that the control system is ineffective or inadequate in addressing identified risks, it must take steps to improve it. This includes updating the monitoring plan and revising the written procedures for data flow activities, risk assessments, and control activities as needed.

For guidance on describing control activities, see :

Guidance document The EU ETS and MRV Maritime, General guidance for shipping companies, Final Version, 4 July 2024, Chapter 6.2