Part two of this article compares the IMO DCS regime with the EU MRV regime and also considers some issues arising out of the regulations.
Comments and issues
- Many within the shipping industry agree that it is unnecessary for there to be two regulatory regimes running in parallel which tread very similar ground. Whilst there are significant similarities between the two monitoring and data collection systems in terms of the data to be submitted, there are sufficient differences to mean that additional work is required to deal with both.
- Alignment and harmonisation of the two parallel regulatory regimes is seen as key to ensuring compliance without undue administrative burden and cost. However, it is expected that the two regimes will continue to run in parallel for a number of years to come.
- Some within the shipping community have voiced concerns over the use to which their data will be put, for example, going beyond the aim of establishing and implementing CO2/GHG reduction programs.
- In terms of data which is made available to the public, there is further concern that where the data relates to work and actual amounts of cargo, the data is sensitive and could be of use to competitors in the market. There has been some discussion within the shipping community as to which regime is preferable with the differences in reporting parameters and transparency in published data being among the key issues.
- More importantly, to ensure compliance with both data monitoring regimes, a review of the relevant charterparties and policies is required.