Validation report form for GS voluntary project activities

GS-VAL-VPA-REP(12-2017) Page 1 of 62

Validation report form for GS voluntary project activities under PoA

VALIDATION REPORT

Reference number and title(s) of the

specific-case VPA(s)

Ref. no. Title

VPA-2 Programme for the application of advanced hull coatings to reduce shipping fuel consumption (PAHSF) VPA No. 2

Version number of the validation report 1.0Aa

Completion date of the validation report 19/02/2018

Title and GS ref. no. of the PoA (where

applicable) into which the specific-case

VPA(s) is/are included

Programme for the application of advanced hull coatings to reduce shipping fuel consumption (PAHSF)

Ref no. GS 3492.

Version number of the PoA-DD into which

the specific-case VPA(s) is/are included Version 05 of 25/08/2015

Coordinating/managing entity (CME) International Paint Ltd., a company in the AkzoNobel Group

Host Party(ies) N/A

Estimated annual average emission

reductions or net GHG removals in the

crediting period (tCO2e) for each

specific-case VPA

VPA Ref. no.

Estimated annual average

emission reductions or net GHG

removals in the crediting period

(tCO2e)

2 45,924 tCO2

Sectoral scope(s) for each specific-case

VPA

VPA Ref. no. Sectoral scope(s)

2 7. Transport

Selected methodology(ies) for each

specific-case VPA

VPA Ref. no. Selected methodology(ies)

2 Gold Standard methodology: Reducing Vessel Emissions Through the Use of Advanced Hull Coatings (version 2)

Name of DOE RINA Services

Name, position and signature of the

approver of the validation report

Laura Severino – Sustainability & Food Certification Compliance Head


SECTION I. Executive summary

Purpose and general description of the VPA The VPA under the PoA will be ships travelling between ports in different countries. The fuel consumed in these trips is classified as international bunker fuels and the emissions from the combustion are not part of the GHG national inventories. Each VPA comprises a set of ships that are coated with an advanced hull coating and each ship can claim carbon credits for a single docking cycle with the application of the advanced hull coating. The advanced hull coating helps in reduction of hull friction and hydrodynamic drag, thereby reducing fuel consumption. Since ships typically use fossil fuels, reduced fuel consumption would reduce CO2 emissions

Location N/A It is to be noted that each VPA within the PoA comprises a set of ships, identified by the ship names and their unique ship identification numbers according to the International Maritime Organisation (IMO). Further the names and IMO numbers of the ships within this VPA are discussed in the table in section A.3 of the VPA-DD.

Scope of validation The scope of validation is to have an independent evaluation of the VPA by a DOE against the GS requirements and principles, on the basis of the VPA-DD, GS Passport and PoA-DD. Validation is a requirement and it is seen as necessary to provide assurance to stakeholders of the quality of the VPA and its intended generation of VERs and sustainability development.

Validation process Validation is conducted using RINA procedures in line with the GS requirements and principles and applying standard auditing techniques. The validation assessment involved a document review of relevant documentation, the interview and/or on-site visit and reporting. Validation is not meant to provide any consultancy towards the project participants. However, stated request for clarifications and/or corrective actions may have provided input for improvement of the VPA.

Conclusion RINA commissioned by International Paint has performed the validation of the VPA “Programme for the application of advanced hull coatings to reduce shipping fuel consumption (PAHSF) VPA No. 2”, with regard to the relevant GS requirements and principles for VPAs. In conclusion, it is RINA’s opinion that the VPA “Programme for the application of advanced hull coatings to reduce shipping fuel consumption (PAHSF) VPA No. 2” as described in the VPA-DD version 03 of 18/12/2017 and GS Passport version 02 of 18/12/2017, meets all relevant GS requirements and principles, and correctly applies the Gold Standard Methodology “Reducing emissions through the use of advanced hull coatings”, version 2.0 of 17/11/2014.

SECTION II. Validation team, technical reviewer and approver

II.1. Validation team member

No. Role

Typ

e o

f re

so

urc

e

Last name First name

Affiliation (e.g. name of

central or other office of DOE or outsourced

entity)

Involvement in

Desk r

evie

w

On

-sit

e in

sp

ecti

on

Inte

rvie

w(s

)

Valid

ati

on

fin

din

gs

1. Team Leader IR MENON Rekha Rina India -

2. Validator IR BURAGOHAIN Champok Rina India -


3. Technical Expert

IR ZHOU Jun Rina China -

II.2. Technical reviewer and approver of the validation report

No. Role Type of

resource Last name First name

Affiliation (e.g. name of

central or other office of DOE or

outsourced entity)

1. Technical reviewer IR LIU HuiFeng RINA China

2. Technical Expert support Technical reviewer

IR SCHENONE Michela RINA Central Office

2. Approver IR SEVERINO Laura RINA Central Office

SECTION III. Means of validation

III.1. Desk review

The VPA-DD version 01 of 25/10/2016, version 02 of 03/07/2017 and version 03 of 18/12/2017, in particular the applicability of the methodology, the eligibility criteria of inclusion of the VPA in the registered PoA, the baseline determination, the additionality, the starting date, the monitoring plan, the sustainability indicators, the stakeholder consultation, the environment impact assessment, the emission reductions calculation were assessed as part of the validation. All documents reviewed of referenced during the validation are listed in Appendix 3.

III.2. On-site inspection

It is confirmed by GS that the audit can be performed virtually by means of collection of relevant evidence and data and is not necessary to physically visit all the ships.

Duration of on-site inspection: N/A

No. Activity performed on-site Site location Date Team member

1.

…


III.3. Interviews

No. Interviewee Date Subject Team member

Last name First name Affiliation

1. Morrison Alison Senior Business Manager (The Fremco Corporation Inc.)

27/02/2017 Project description, operational life time, crediting period, baseline and project estimation, Emission Reduction calculations, data recording, data transfer and storage, QA/QC procedures.

Rekha Menon, Champok Buragohain

2. Dutt Gautam Vice President, Science and Technology (MGM Innova )

27/02/2017 Rekha Menon, Champok Buragohain

3 Portolano Alberto Energy saving Dept-Technical Dept (Grimaldi Group)

10/03/2017 to 15/03/2017

Baseline Data and project data, technical issues, fuel consumption monitoring, data collection, storage and technical specifications of hull coat.

Rekha Menon

4 Wei Ronnie Product Manager-Fouling Release (Akzonobel)

III.4. Sampling approach

>> N/A

III.5. Clarification requests, corrective action requests and forward action requests raised

Areas of validation of compliance No. of CR No. of CAR No. of FAR

General description of the VPA(s)

Title of the proposed or registered PoA

Title(s) of the proposed specific-case VPA(s) and the corresponding generic VPA(s)

Specific-case VPA design document

Specific-case VPA GS Passport 1

Purpose and general description of the specific-case VPA(s)

1

Environmental analysis 1

Local stakeholder consultation 1

Do No Harm Assessment 1

Impact Assessment – Sustainable Development Matrix 1

Eligibility of VPA(s) and estimation of emissions reductions

Applicability of selected methodology(ies) and/or standardized baseline

1

o Deviation from methodology

o Clarification on applicability of methodology, tool and/or standardized baseline

Sources and GHGs 1

Description of baseline scenario 1

Demonstration of eligibility for the VPA(s)

Estimation of emission reductions or net GHG removals by sinks

o Explanation of methodological choices 1


o Data and parameters fixed ex ante

o Ex ante calculation of emission reductions or net GHG removals by sinks

o Summary of ex ante estimates of emission reductions or net GHG removals by sinks

Application of the monitoring methodology and description of the monitoring plan

o Data and parameters to be monitored 1

o Description of the monitoring plan 1

o Description of the sustainability monitoring plan

Total 12

SECTION IV. Internal quality control

The draft final validation report before being submitted to the client is subjected to an independent technical review to confirm that all validation activities have been completed according to the pertinent RINA’s procedures. The technical review is performed by a technical reviewer(s) qualified in accordance with the RINA’s qualification procedure.

SECTION V. Validation opinion

RINA has performed the validation of the VPA Programme for the application of advanced hull coatings to reduce shipping fuel consumption (PAHSF) VPA No. 2, with regard to the relevant GS principles and requirements. The reviews of the VPA-DD and the subsequent follow-up interviews have provided RINA with sufficient evidence to determine the fulfilment of the stated criteria. The VPA meets the eligibility criteria and correctly applies methodology Gold Standard methodology: “Reducing vessel emissions through the use of advanced hull coatings”, version 2.0 of 17/11/2014. An analysis, as provided by the applied methodology, demonstrated that the proposed VPA is not a likely baseline scenario. Emission reductions attributable to the activity are additional to any that would occur in the absence of the programme. The monitoring plan provided the collection and archiving of data sufficient to ensure that emission reductions can be verified. The description of the VPA includes verifiable eligibility criteria on inclusion of the VPA under the registered PoA, and appropriate operational and management arrangements have been established for the implementation of the VPA.

SECTION VI. Validation findings

SECTION A. General description of the VPA(s)

A.1. Title of the proposed or registered PoA

>> The title of the registered PoA is “Programme for the application of advanced hull coatings to reduce shipping fuel consumption (PAHSF)”, version 5 of 25/08/2015

A.2. Title(s) of the proposed specific-case VPA(s) and the corresponding generic VPA(s)

Specific-case

VPA title and

reference

number

Version number

of the specific-

case VPA-DD

Host Party

Generic VPA title,

identification/reference

number

Version number

of the PoA-DD

into which the

VPA is included

Programme for the application of advanced hull coatings to reduce shipping fuel consumption (PAHSF) VPA No. 2 (GS 5406)

03 N/A 3492 05


A.3. Specific-case VPA design document

Means of validation The validation involves cross check between versions of the CPA-DD form used by project proponent and the valid CPA-DD form available at the UNFCCC website during the time of the VPA validation. VPA-DD was reviewed for compliance with instructions for filling in CPA-DD form.

Findings N/A

Conclusion Gold Standard doesn’t provide any specific template for VPA-DD. PP has developed the VPA-DD and included the required details, which is accepted by RINA. Further RINA confirms that the VPA-DD is based on the currently valid CDM-CPA-DD-Form /15/ and is completed in accordance with Instructions for filling out the component project activity design document form for CDM component project activities.

A.4. Specific-case VPA GS Passport

Means of validation The GS VPA passport version 01 of 25/10/2016, version 02 of 28/03/2017 and version 03 of 18/12/2018 /03/ submitted by International Paint Ltd have been the basis for the validation process. Validation is as per GS requirement V2.2 /10/, Gold Standard Passport template (Annex R to Toolkit version 2.2).

Findings CR 01 The project title of VPA passport and VPA-DD is not consistent. PP is further requested to provide GS comments on the pre-feasibility assessment report. For more details on closure, please refer to Appendix 4. CR 01 is closed.

Conclusion RINA confirms that the above Gold Standard Passport is based on the currently valid GS Passport is in accordance with the latest version of the Gold Standard

Passport template (Annex R to Toolkit version 2.2).

A.5. Purpose and general description of the specific-case VPA(s)

Means of validation The purpose of the VPA is to reduce the GHG emissions through the application of advanced low resistance hull coatings instead of traditional coating which reduce hydrodynamic resistance thus reducing fuel consumption for ship propulsion /01/. The VPA under the PoA are ships travelling between ports in different countries. The fuel consumed in these trips is classified as international bunker fuels and the emissions from the combustion are not part of the GHG national inventories. Each VPA comprises a set of ships that are coated with an advanced hull coating and each ship can claim carbon credits for a single docking cycle with the application of the advanced hull coating. For reaching the goal of reducing GHG emissions the Intersleek products based silicone system, are used which: (a) have lower toxicity rating to both the environment and humans compared to biocidal system thus reduce contamination of seawater by avoiding the release of any biocidal antifouling agent; (b) reduce hull friction and hydrodynamic drag reducing fuel consumption thus reduce GHG emissions from fuel consumption/combustion /01/. The products included in this VPA are Intersleek 700, Intersleek 900 and Intersleek 1100SR /26/.

RINA checked the MEPC of the IMO, meeting MEPC 69 briefing document dated 22/04/2016 /38/, 2016 IMO report to UNFCCC and resolution MEPC 282(70) i.e 2016 guidelines for the development of Ship Energy Efficiency Management Plan (SEEMP) adopted on 28/10/2016 /39/ confirms that IMO has made mandatory the ships to record and report there fuel consumption data. However, It doesn’t state that advance hull coating is mandatory for the ships. Thus, RINA confirms that there are no mandatory requirements for the application of the anti-fouling system. Point 2.1 of Annex 1 to regulation EC No. 782/2003 of the European Parliament and of the Council of 14/04/2003 on the prohibition of organotin compounds of ships, found that the ships were in compliance with the regulation /25/.


The expected operational lifetime of the VPA is determined for each ship and it is the length of the docking cycle which is typically 60 months for the cargo vessels, or shorter (36, 30 or 24 months) for some other ships /01/. The length of the crediting period is strictly related to the duration of the docking cycle until each ship is coated again, therefore the overall crediting period for the VPA starts on the date that the first ship received the advanced hull coating and end when the last ship with the advanced hull coating reaches the end of its docking cycle. The proposed VPA comprises of 3 ships. Noted that the ship, which received the last coat among all the other ships was Grande Nigeria (IMO No. 9246580) on 21/09/2015 /40/, and considering the longest docking cycle for any ship with the baseline coating could be as long as 60 months, the docking cycle would end on 21/09/2020, which is the end of the period. It was further confirmed from the manufacturer of the advanced coating that the ship owners may delay recoating hulls with advanced coatings, since these products are expected to degrade slower than baseline coatings/17/ and thus, the operational lifetime is extended by one more year i.e. to end on 21/09/2021. The concept was validated at the time of PoA registration and also agreed by GS. It is checked that the start date of the PoA considered is 01/01/2010 /01/ and the start date of the VPA-2 considered is 20/01/2012, which is the earliest date at which either the implementation or construction or real action of the VPA begins. In this case is represented by the application of the advanced hull coating. The date was confirmed with the data plan reports (data plan coating diary) and accepted /40/. This was further checked with the POs and proposal acceptance emails /44/ from the ship owners for each ship. Noted that the POs were dated earlier to advanced hull coat date, which was found to be appropriate and accepted by RINA team. The start date of the VPA is in line with the glossary of CDM terms, version 09.1 of 1/09/2017. RINA confirms that the start of the proposed VPA is after the start date of the PoA. It was further noted that GS has agreed to include the ships coated with advance hull coating after 09/11/2010, since this is the date of the methodology PIN submitted to GS /02/. The ships included in VPA-2 coated with advanced hull coat starts from 20/01/2012 to 21/09/2015 /40/. Assuming the date of inclusion of VPA as 02/02/2018, the start date of the crediting period considered is from 02/02/2016 i.e. the crediting period will start two years prior to the Registration date. A single 10-year crediting period is selected and the start date of the crediting period is fixed on 02/02/2016, which would end on 21/09/2021, considering the operational lifetime of the latest advanced hull coating date. The VPA is expected to reduce 459,241 tCO2e of carbon emission through the entire crediting period of 10 years making an annual average to be 45, 924 tCO2e. The calculation of estimated ERs was found to be in compliance with the methodology /07/ and PoA-DD /01/.

Findings CR 02

1. PP is requested to provide evidences to support prior consideration of carbon revenues, operational life time of the project.

2. Contract copies of CME with the ship owners, included in the VPA-2. 3. Necessary approvals and clearances of each ship included in the VPA. 4. Evidences to ensure that the advanced hull coating is not a mandatory

requirement for ships. 5. Case studies or proven articles, which confirm that application of advanced

low resistance hull coatings instead of traditional coating reduces hydrodynamic resistance thus reducing fuel consumption for ship propulsion.

For more details on closure, please refer to Appendix 4. CR 02 is closed


Conclusion RINA was able to verify all the documented evidence listed above during the validation process and can confirm that data and considerations are complete and accurate. Moreover RINA confirms that the description of the proposed VPA, as contained in the PoA-DD and VPA-DD sufficiently covers all relevant elements, is accurate and complete and that it provides the reader with a clear understanding of the nature of the proposed GS project activity.

SECTION B. Environmental analysis

Means of validation The environmental analysis is undertaken at the VPA level for the ships included in each VPA /17/. The VPA involve international shipping operating in international waters, thus no host country requirements concerning the environmental impact assessment are considered. The PoA and the VPAs involves international shipping operating in international waters, thus there is no distinction between one VPA and another. The Intersleek products have positive environmental impacts as a biocide-free product eliminates the release of the biocides in to the marine environment. Moreover the products have higher volume of solids and required low film thickness that means 40% reduction in paint volume and 60% reduction in VOC emissions for the first application and for the future dockings the paint volume is reduced by 75%, VOC by 80% and waste packaging by 60%. As per the LCA study the Intersleek systems lead to reduced fuel and coating consumption which demonstrate that it is more eco-efficient than the biocidal systems and it reduces dependence on scares resources, especially copper, and emissions of VOC, which are more important aspects when looking at the overall environmental impact of paint /17/.

Findings CR03 1. PP is requested to provide the environmental impact analysis reports

undertaken at the VPA level. 2. Provide the eco efficiency reports for each ship.

For more details , please refer to Appendix-4. CR03 is closed.

Conclusion RINA confirms that the project does not result any negative environmental and social impact and meets the sustainable development criteria as defined by GS requirements.

SECTION C. Local stakeholder consultation

Means of validation The stakeholders identified for VPAs under this PoA are shipping companies participating in the VPA as well as workers at the manufacturing plant of the advanced hull coating. It was noted that the consultation was not carried out physically but by means of emails. The Project activities under this VPA involve ships that are in voyages. Hence there is no specific geographical location where local stakeholders may be consulted. Thus, stakeholder consultation carried out in the form of emails was accepted by RINA. It was checked that the invitation to submit comments for the international paint employees was sent on 15/08/2016 and the deadline to provide the comments requested was 31/08/2016 /19/ and invitation to regional representatives of international paint to solicit stakeholders comments from shipping companies was sent on 12/08/2016 and the deadline for requesting the comments was 11/09/2016 /20/. The feedback form from the shipping companies and employees of international paint was checked and noted that there were no negative comments and the same was accepted by RINA. It was further noted that all the project related documents were made publicly available in GS registry for public comments on 29/03/2017, which was confirmed by checking email sent by GS registry to Fremco International, dated 29/03/2017 /45/. However, it was agreed by GS to share the VPA-2 related documents, via email to the stakeholders. RINA checked the invitation email on the SFR to international paint employees and employees of shipping companies’ /19/ /20/. The responses from the stakeholders received /18/ checked and noted that there were no negative comments. It is also checked that for the methods of continuous inputs & grievance mechanism, the client has provided phone no and link to the website /41/. The comments received are directed to Dr. Richard Towns, Market Segment Manager – Fouling Release, who is also the main contact for International Paint as project


proponent. Dr. Towns would either reply directly to any such feedback, or seek answers from others before replying. The PP has confirmed that till date, they haven’t received any comments or feedback.

Findings CR 04

1. The invitation tracking table and minutes of physical meeting, annex-1 and annex-2 of LSC report discusses about the meeting held at PoA level and VPA-1. Please be specific to VPA-2.

2. Not clear on how the employees of international paint were selected to

provide the stakeholder comments.

3. For the methods of continuous inputs & grievance mechanism, the client has provided phone no and link to the website. The LSC report is not transparent on the phone no. belongs to who and whom shall the stakeholders contact. Not clear on how the stakeholder phone calls are documented and how the actions will be carried out. It is further checked that the link provided in the website doesn’t work. Also clarify on who has the access to the link and how the comments would be addressed.

4. PP is requested to clarify on the date when the LSC feedback round

documents were available for public comments. PP is also requested to provide evidences of the same and copies of the comments received during the LSC feedback round.

Conclusion The adequacy of the local stakeholder consultation is confirmed due to: - The local stakeholders relevant to the CPA have been invited; - The summary of the comments received are provided in the GS-passport

and cross-checked through the filled in feedback forms and emails received /46/, thus it is confirmed they are completed;

Based on the above assessment, the validation team hereby confirms that there were no negative comments from the stakeholders and they hold positive attitude towards the project. RINA confirms that the stakeholder consultation process held for the project activity meets the requirement of GS requirement version 2.2.

SECTION D. Do No Harm Assessment

Means of validation “Do no harm assessment” of the project is discussed in section F.1 of the VPA Passport /03/. The “Do no harm assessment” is based on the UNDP (United Nations Development Program) safeguarding principles. All the safeguarding principles are assessed in terms of risk, and the explanations and references are provided for each principle to justify the evaluation of the degree of risk.

Human rights. Since the change is in manufacture of hull coating material, the VPA is not complicit in human rights abuses, does not affect human settlements and any critical cultural heritage.

Labour Standards. The advanced hull coating is manufactured in the United Kingdom, the United States and Singapore where the national and/or international labour standards are required to be applied. RINA checked the same with the respective websites /24/ and confirmed to be in order.

Environmental Protection. As discussed above, the environmental analysis is undertaken at the VPA level. As confirmed by the “Energy and GHG emissions savings analysis” the biocidal-free hull coatings has environmental benefits including reduced paint volume, reduced volatile organic compound (VOC) emissions and no release of biocides into the aquatic environment. No negative

impact is expected from the VPA to be included in the PoA. RINA checked the documents “eco-efficiency, a new tool to support better decisions on hull coating investment: , 09/2010” /27/ and “Eco-efficiency assessment by Akzonobel and reviewed by IVL Swedish Environmental Research Institute” /28/ confirms that Intersleek 1100SR is a biocide-free fluoropolymer fouling control system, which improves several aspects of coating performance compared to the silicon based fouling control system Intersleek 700 and the widely used biocide fouling control system Intersmooth 7460HS. Examples of improvements are lower surface hull roughness, better coefficient of friction and better foul release properties, which relatively to the Intersmooth 7460HS system, leads to reduced fuel consumption of


up to 9 % according to observations by ship owners. The environmental aspects that were quantified are: use of energy and material resources, contribution to global warming potential (GWP), acidification potential (AP), photochemical ozone creation potential (POCP) as well as human and marine toxicity. The Intersleek systems reduce dependency on scarce resources, especially copper, and emissions of VOC, which are important aspects when looking at the overall environmental impact of paints. Moreover, as the Intersleek products are non-biocidal and do not selfpolish, a considerably lower amount of paint is required to coat the vessel, leading to low emissions from the paint and lower toxic components to the environment. This significantly reduces the predicted toxic load associated with the paint components to both humans and the marine environment

Anti-corruption. The VPA does not involve and is not in complicit in corruption. The project activity involves transaction between private parties. The project proponent, International Paint Ltd has signed the heads of terms for carbon credit sharing agreement with all the shipping companies of the 30 ships included in this VPA /29/, which was checked and accepted by RINA team.

Findings CR05

Environmental Protection: PP is requested to provide evidences to support that the environmental impacts are favourable and there is no risk. Further, the VPA-Passport states that the environmental impacts with baseline are favourable. However, this is not clear. Please demonstrate the environmental impacts with regards to project scenario.

Anti-corruption: The project activity involves transaction between private parties. i.e between the CME (International Paint Ltd) and ship owners/operators. PP is requested to provide the contract copies between the CME and ship owners for the ships included in this VPA. For more information, please refer to Appendix 4. CR05 is closed.

Conclusion RINA confirms that the “do no harm assessment discussed for the project activity meets the requirement of GS requirement, 2.2

SECTION E. Impact Assessment – Sustainable Development Matrix

Means of validation The sustainable development matrix is discussed in the VPA passport /03/ and it is in accordance with the Gold Standard requirements /10/. The defined the GS indicators in the SD are given below including their scores.

Air Quality. Score +. Reduced fuel consumption in ship engines means that less fuel is burnt with less emission of SOx and Nox from combustion. At the same time the application of the Intersleek system reduces emissions of VOC compared to the biocidal systems /27/ /28/.

Water quality and quantity. Score +. The application of the advanced hull coating (Intersleek) would reduce the amount of paint released into the marine environment. Moreover, since Intersleek is biocide-free, no biocide will be released to the marine environment /27/ /28/.

Soil condition. Score +. The Intersleek products are substantially lower in toxicity compared to biocidal systems and thus it does not affect the soil ecosystem /27/ /28/.

Other pollutant. Score +. Since the Intersleek system has no biocides means that none are released into the water; compared to the baseline coating, low quantity of copper is used and thus it reduces the potential acidification; less waste is generated due to less paint is needed /27/ /28/.;

Biodiversity: the intersleek system being biocid-free it does not impact the loss of biodiversity via food chain /27/ /28/.

Quality of employment. Score +. The application of the Intersleek system reduces emissions of VOC compared to the biocidal systems thus workers are exposed to less contamination. It is further checked that the PP has developed documented procedures like Carbon Credit Process Steps.pdf, Carbon Credits Webinar Revision 02.pdf, Data collection method.pdf, Dry docking procedure.pdf, which will be used in training the ship owners/30/ operators and to dry dock workers.

Livelihood of the poor. Score 0. As the project reduces shipping fuel costs, it


would reduce the cost of getting products to markets, indirectly benefitting those who depend on their production being sent by ships market.

Access to affordable and clean energy. No impact, thus 0.

Human and institutional capacity. Score +. The application of the advanced hull coating to save fuel as well as the application of the monitoring methodology to evaluate ship fuel consumption would add to human and institutional capacity of ship owners and operators.

Quantitative employment and income generation. 0. Ships are coated in different locations many of which are in developing countries. The employed in the activity would acquire skills involving a sustainable technology. Moreover, since there is less VOC emissions, workers are exposed to less contamination.

Balance of payments and investment. 0. Many of the ships are registered in developing countries. However, even by geographical location, CO2 emissions are dominated by ships from Non-Annex 1 (developing) countries their geographical location is in developing countries (Non-Annex I) and the CO2 emissions are dominated by ships from Non-Annex I countries /31/. There is no change in impact.

Technology transfer and technological self-reliance. Score +. Since CO2

emissions are dominated by ships from Non-Annex I countries, the GS carbon credits would help to promote the transfer of advanced coating technologies to these countries and to ship owners and operators in general.

Findings CR 06

Air quality: Evidences to support “Intersleek systems are inherently higher in volume solids and lower in VOC compared to biocidal systems. Biocidal systems are typically 50-60% volume solids and 340 to 500 grams per litre VOC; Intersleek systems are >70% volume solids and <240 grams per litre VOC. PP is requested to provide copy of the LCA study. PP is requested to provide International Paint, “Eco-efficiency – a new tool to support better decisions on hull coating investments”, Sept. 2010” and also Exo environmental analysis report as discussed in the VPA-Passport.

Quality of employment: Evidences of the training provided to the ship owners/operators and to dry dock workers. Also ongoing training evidences to PPs own staff around sustainable technologies, and the topics of carbon and emission reductions resulting from improving fuel economy. PP is requested to provide copy of the report from “Haifeng Wang, Economic costs of CO2 emissions reduction for non-Annex I countries in international shipping. Energy for Sustainable Development, 14 (2010) 280–286” For more information, please refer to Appendix 4 CR 06 is closed.

Conclusion RINA confirms that conservative approach has been applied by PP to demonstrate sustainable development matrix of the project activity which is in line with GS requirement version 2.2


SECTION F. Eligibility of VPA(s) and estimation of emissions reductions

F.1. Applicability of selected methodology and/or standardized baseline


Means of

validation The GS methodology “Reducing emissions through the use of advanced hull coatings”, version 2.0 of 17/11/2014 /07/ is applied. Each VPA will meet the criteria defined in the applied methodology as it ensures that:

Applicability criteria VPA PAHSF Project 1 Crite

ria is

met?

The ship is not new i.e. it had at least one full docking cycle of operation with the traditional biocidal hull coating

RINA checked the data plan reports /40/. Apart from this, dates were also cross checked with the publicly available sites like marine traffic.com and vessel finder.com. It is confirmed that none of the ships are new and had at least one docking cycle with the baseline traditional biocidal hull coating. The baseline coating were also checked with antifouling certificates, dry dock reports, data plan reports, other documents from baseline paint manufacturer and ship owners /32/.

YES

Evidence is provided on time for validation to demonstrate that the advanced hull coating does not contain any biocides or other toxic materials.

The eco-efficiency reports of each ships /17/ confirms that the Intersleek system does not contain any biocides or other toxic materials. The above study was submitted to a third party critical review who certified that the study fulfils the relevant requirements for an eco-efficiency analysis /28/.

YES

The ship did not undergo engine overhaul or replacement or any other modifications that would reduce its fuel consumption.

Dataplan reports are provided to demonstrate that the ships didn’t undergo engine overhaul or replacement or any other modifications that would reduce it fuel consumption /40/

YES

Evidence needs to be provided to indicate hull cleaning dates in the baseline period

Dataplan reports are provided /40/ no hull cleanings took place in the baseline period. Further PP has confirmed that, in case there are any underwater cleanings in the project period, carbon credits may be limited as indicated in the methodology. The same is included as one of the monitoring parameter to be checked at the time of verification. Hence RINA accepted the justification.

YES

Certain countries or groups of countries may impose fuel efficiency conditions for ships , in those cases ERs would not continue to be eligible.

There are no mandatory requirements for the application of the anti-fouling system. Point 2.1 of Annex 1 to regulation EC No. 782/2003 of the European Parliament and of the Council of 14/04/2003 on the prohibition of organotin compounds of ships, found that the ship was in compliance with the regulation /25/. Also, checked with most recent IMO regulations “Guidelines on the method of calculation of the attained Energy Efficiency Design Index (EEDI) for new ships /33/ /34/.

YES

ERs can only be claimed for one single projects docking cycle for each ship included in the project activity.

Checked the ER sheets /35/ and the ERs are only claimed for single docking cycle.

YES

If biofuel blends are used the % or petroleum and biofuel components of each fuel purchase should

be recorded. No credits are claimed for biofuel consumption.

As confirmed by the ship owners the biofuel blends are not used; However, the same can be confirmed only during verification.

Incases biofuel blends are used PP has agreed to apply the condition as mentioned in the methodology.

YES

Data are available for the entire baseline docking cycle and confirmed by official documentation.

The condition can be checked only at the time of verification. PP has confirmed to exclude the ships, which does not meet this condition. The same was accepted by RINA.

YES

Fuel consumption used for navigation purpose in baseline period should be used for regression analysis. Fuel consumption including manoeuvring activities, data is not used for regression analysis.

The condition needs to be checked at the time of verification. YES

The project applicant shall bear the cost of a professional statistician contracted by The Gold Standard Foundation for the validation of: - The results of the regression analysis applied to the submitted project activity in line with the model(s) provided in the methodology;

A new regression model presented for approval by The Gold Standard Foundation prior to the submission of a project activity

As per the information provided by the PP the underlying statistical model was not changed, so that a review by a statistician should not be necessary. The same was accepted by GS during VPA-1 validation.

YES

Methodology is applicable to manufacturer of the

advances hull coating and not to the individual ships or shipping company . It is applicable in case of shipping companies with own sufficient number of vessels for them to apply for carbon credits.

The project proponent, International Paint Ltd has signed the

heads of terms for carbon credit sharing agreement with all the shipping companies, whose ships are included in the project activity /29/.

YES

When the coating manufacturer is the aggregating entity the ship owner shall make available the fuel consumption data

Contract copies between Project proponent and shipping companies checked /29/, wherein one of the conditions is to provide the fuel consumption data of ships to the coating manufacturer and the same was accepted.

YES.

In addition the applicability condition of the following methodological tool are applicable: Tool for the demonstration and assessment of additionality - Version 07.0.0 /42/. The tool is

applied in the context to identify that there is at least one credible and feasible alternative that would be more attractive than the proposed VPA. Details are explained in section F.4 of this report.

Tool to calculate project or leakage CO2 emissions from fossil fuel combustion – Version 2 /43/. The tool is applied in the context of calculated the CO2 emissions from fossil fuel combustion based on the quantity of fuel combusted and its properties.


Findings CR 07 1. PP is requested to provide the data plan reports and antifouling certificates and

inspection and testing reports of each ship. 2. Evidences to cross check the built month and year of the ship. This was not

transparent in the website vessel finder.com 3. PP is requested to provide the eco-efficiency reports and LCA study. 4. PP is requested to provide the most recent IMO regulations “Guidelines on the

method of calculation of the attained Energy Efficiency Design Index (EEDI) for new ships.

5. Ship log records to confirm the fuel consumption. 6. Though the statistical model is not changed in this VPA, the methodology

applicability requires the project applicant shall bear the cost of a professional statistician contracted by The Gold Standard Foundation for the validation of “the results of the regression analysis applied to the submitted project activity in line with the model(s) provided in the methodology”.

7. PP is requested to provide the ODA declaration form. Please refer to Appendix 4 of the report for more details. CR 07 is closed.

Conclusion RINA hereby confirms that the selected baseline and monitoring methodology is applicable to the Project, which complies with all the applicability conditions therein and the selected version is valid at the time of submission of the proposed project activity. It is also confirmed that all applicable tools are correctly applied for the project activity.

F.1.1. Deviation from methodology

Means of validation N/A

Findings N/A

Conclusion N/A

F.1.2. Clarification on applicability of methodology, tool

Means of validation N/A

Findings N/A

Conclusion N/A


F.2. Sources and GHGs

Means of validation According to the applied methodology /07/ “The project boundary is the physical, geographical location of the ships to which the hull coating is applied. The project boundary covers the routes where each ship consumes fuel and where emissions occur. Since, improved hull coating reduces fuel consumption only during movement; only the cruising (or navigation) part of each route is considered (i.e. excluding ports, dry docks and manoeuvres) for the purpose of determining fuel consumption and emissions. In cases, where fuel consumption for navigations is not separately recorded, the project boundary would include “navigation and manoeuvring.” In both baseline and project scenarios, the same “boundary” for fuel consumption data is used.

GHGs involved

Description

Baseline emissions CO2 Fuel consumption by ship engines during voyages , which excludes rough seas

Project emissions CO2 Fuel consumption by ship engines during voyages , which excludes rough seas

Leakage NA

As discussed in the VPA-DD, the combustion of fuels in the engine also produces small amounts of methane (CH4) and nitrous oxide (N2O). Since there would be a reduction in the fuel consumption in project scenario compared to baseline, this will also lead to reductions in methane and nitrous oxide emissions. However, these emissions reductions have been neglected for conservativeness and the same was accepted by RINA. It is further noted that the ship coating involves electricity consumption. Since it is the case in both baseline and project. The same is excluded from ER calculations.

It is also expected that the ships involved in the VPA will not undergo underwater cleaning. Thus by not accounting the process & associated emissions with the present baseline scenario, the methodology is conservative. It is also checked that the emission sources which are not addressed by the applied methodology and which are expected to contribute more than 1% of the overall expected average annual emissions reduction have not been identified.

Findings CR 08 PP is requested to clarify with evidences that with the advanced hull coating, the vessels will no undergo underwater hull cleaning. Provide the data on fuel consumption for the ships involved in the VPA. For more details on closure, refer to Appendix 4 CR 08 is closed.

FAR 1 is raised. PP has confirmed that Ships that undergo hull cleaning in the project docking cycle while none occurred in the baseline docking cycle can only claim emission reductions under this methodology up to the time of the hull cleaning. PP has confirmed to analyse the situation of hull cleanings in baseline and project cycles , and submit the same along with the ship performance data at the time of verification. The same needs to be checked during the verification.


Conclusion By checking the information and evidences available /02/ /29/ and by the physical site, RINA can confirm that all the emission sources and gases have been included in the project boundary and the description in the VPA-DD is accurate and complete, and also that the selected sources and gases are justified for the proposed project activity

F.3. Description of baseline scenario

Means of validation The “CDM Tool for the demonstration and assessment of additionality” is used as the basis for the identification of the baseline scenario and evaluation of additionality. The VPA comprises of 30 ships. The baseline scenario is defined for each ship at the VPA level. For each ship included in the VPA, it is demonstrated that the baseline scenario for the ship is the application of a biocidal foul release coating that was also applied in the previous hull coating cycle, which is nothing but the alternative 2 of sub-step 1a of step 1. PP has chosen common practice analysis to justify the selected baseline.

According the applied methodology /07/, the common practice analysis is carried out applying the 3 steps. The analysis is conducted at two level of technology: level 1 is silicone coating while level 2 is fluoro polymer /49/. The factor F shall be greater than 0.2 and the difference between the total number of ships per category and the ships those apply technologies different than the technology applied in the proposed project activity shall be greater than 3. The result of the common practice analysis is that the LNG carriers and cruise ships are not eligible because the F is greater than 0.2 for both the level services and would not be eligible for Gold Standard carbon credits. The baseline scenario is identified at the PoA level and at the VPA level is used different data for the baseline calculation. Therefore the baseline scenario is the fuel consumption of ships applying biocidal antifouling hull coating excluding the LNG carriers and cruise ships which would be not eligible for Gold Standard carbon credits due to the results of the common practice analysis.

Noted that the Common practice analysis considers all ships in service, determined from Lloyds Register, which is the most detailed shipping activity data base /48/. International Paint has access to this data base, and compiled the information. The analysis also uses the number of ships coated with Intersleek products, from IP own statistics /47/, and an estimate of application of competitor products from industry data bases and trade publications. It is also checked that PP has considered the ships that have started commercial operation before the start date of the VPA as well as after the start date, which is more conservative. Hence accepted.

According the applied methodology /07/ and the additionality tool /42/ the baseline scenario is the fuel consumption of ships applying biocidal antifouling hull coating excluding the LNG carriers and cruise ships, which would be not eligible for Gold Standard carbon credits based on the results from common practice analysis, as discussed above.

Findings CR 09 Provide evidences for the values used in the file “Common_practice_test 31aug16 clean.xlsx”, also clarify, why intersleek 970 and 1100SR not considered in the evaluation. Not clear, if the ships considered in the common practice analysis have started the commercial operation before the start date of the project. PP is further requested to clarify Panamax Tanker, Passenger/ Ro-Ro, Ro-Ro /Cargo and pure car carrier is referred to which category vessel of common practice analysis sheet. Provide an independent, third party review of advanced hull coatings, published in Fathom (2013)


For more information, please refer to Appendix -4 CR 09 is closed.

Conclusion The approved baseline methodology /07/ has been correctly applied to identify the most reasonable scenario and the identified baseline scenario reasonably represents what would occur in the absence of the proposed GS VPA-2.

F.4. Demonstration of eligibility for the VPA(s)

>> As per the assessment in the table below, RINA confirms that the eligibility criteria for inclusion of the VPA in the PoA are in accordance with the Standard for demonstration of additionality, development of eligibility criteria and application of multiple methodologies for programme of activities, version 03.0 of 26/07/2013 /08/. Moreover RINA confirms that VPA meet these minimum eligibility criteria:

Do the eligibility Criteria

cover as minimum the

following?

Does the Specific VPA(s)

meets eligibility criteria?

(a) The geographical boundary

of the VPA including any time-

induced boundary consistent

with the geographical boundary

set in the PoA;

Geographical boundary is not involved in the PoA.

A set of 30 ships are identified and included in the boundary. They are identified under the IMO numbers verified through the website vesselfinder.com and marine traffic.com /22/.

(b) Conditions that avoid

double counting of emission

reductions like unique

identifications

of product and end-user

locations (e.g. programme

logo);

Each VPA includes a set of ships which are identified by the number issued by the International Maritime Organization.

A set of 30 ships are identified and included in the boundary. They are identified under the IMO numbers verified through the website vesselfinder.com and marine traffic.com /22/. The CME keeps a record of all ships included in this and all previous VPAs, to guarantee that there has been no double counting. CME also checks with Gold Standard to ensure that other Gold Standard projects or PoAs presented for similar project activities do not include any of the ships included in the proposed VPA. It is checked from the gold standard website that other than this project, there are no other VPAs or projects registered with the same methodology.

(c) The specifications of

technology/measure including

the level and type of service,

performance specifications

including compliance with

testing/certifications;

The technology comprises advance hull coating and the three main advanced products are denominated Intersleek 1100SR, Intersleek 900 family (comprising Intersleek 960 and Intersleek 970) and Intersleek 700 family (specifically Intersleek 757).

Checked with the data plan reports /40/ and PO /44/.

(d) Conditions to check the

start date of the VPA through

documentary evidence;

The start date of each VPA is checked through the evidence of the date on which the advanced coating is/was applied.

The start date of the VPA-2 considered is 20/01/2012, which is the earliest date at which either the implementation or construction or real action of the VPA begins. In this case is represented by the application


of the advanced hull coating. The date was confirmed with the data plan reports and accepted /40/. The start date of the VPA is in line with the glossary of CDM terms, version 09.1 of 1/09/2017. RINA confirms that the start of the proposed VPA is after the start date of the PoA.

(e) Conditions that ensure

compliance with applicability

and other requirements of

single or

multiple methodologies applied

by VPAs;

Each VPA to be included in the PoA will meet the applicability conditions specified in the methodology.

Yes, it meets the applicability conditions. For more information, please refer to section F.1 above.

(f) The conditions that ensure

that VPAs meet the

requirements pertaining to the

demonstration of additionality

as specified in Section A above;

The additionality is demonstrated at the PoA and VPA level.

As discussed in the additionality section of this report, the common practice test is applied for each ship category confirming additionality for all ships included in the specific VPA /02/. For more information, please refer to section F.3 above.

(g) The PoA-specific

requirements stipulated by the

CME including any conditions

related to

undertaking local stakeholder

consultations and

environmental impact analysis;

As per the GS local stakeholder consultation must be carried out comprising ship owners and operators, as well as people at the manufacturing facilities where the advanced hull coating is manufactured.

The local stakeholder consultation and environmental analysis are done at VPA level.

Please refer to section B and C above for more information.

(h) Conditions to provide an

affirmation that funding from

Annex I parties, if any, does not

result in a diversion of official

development assistance;

ODA is not involved in the PoA/VPA .

ODA dated 24/04/2017 is included in Appendix 2 of the revised VPA DD /02/. It is confirmed that there is no finding that results in a diversion of official development assistance.

(i) Where applicable, target

group (e.g.

domestic/commercial/industrial,

rural/urban, grid connected/

off-grid) and distribution

mechanisms (e.g. direct

installation);

The target group is defined as shipping industry.

The target group is defined as shipping industry.

(j) Where applicable, the

conditions related to sampling

requirements for a PoA in

accordance with the approved

guidelines/standard from the

Board pertaining to sampling

and surveys;

No sampling and survey is applied for the specific VPA.

No sampling and survey is applied for the proposed VPA-2.

(k) Where applicable, the

conditions that ensure that

every VPA in aggregate meets

The PoA is a large scale and thus the criterion is not applicable.



the small-scale or micro-scale

threshold criteria and remains

within those thresholds

throughout the crediting period

of the VPA;

(l) Where applicable, the

requirements for the de-

bundling check, in case VPAs

belong to

small-scale (SSC) or micro-

scale project categories.



F.5. Estimation of emission reductions or net GHG removals by sinks

F.5.1. Explanation of methodological choices

Means of validation The emission reduction ERy by the proposed VPA /02/ during the crediting period is the difference between baseline emissions (BEy), project emissions (PEy) and emissions due to leakage (Ly) as follows.

Baseline emissions.

The baseline emissions are calculated as the fuel consumption which is the fuel that the ship would consumed if it had the historical, baseline coating. The historical data on daily fuel consumption are analysed using the regression approach which is in accordance with the applied methodology /07/. The following formula is used:

Where BFC is the quantity of fuel type that would have been combusted in ship durind a specific year (excluing the fuel not used for propulsion), and COEF is the CO2 emission coefficient of fuel type in year (Tco2/mass or volume unit). According the methodology the COEF is determined as per the methodological tool to calculate project or leakage CO2 emissions from fossil fuel combustion /31/. Option B is chosen where COEF is determined using NCV and EF standard values as per the IPCCC guidelines /23/.

The regression analysis /25/ of each ships is the base for the baseline emissions estimation. Each analysis contains data provided by the ship owner, as weather parameters, voyage parameters, fuel consumption separately for navigation and maneuvering activities.

Leakage.

As per the applied methodology /07/ the PoA/VPA comprise the uses of one coating product instead of another, no leakage effects are expected.

Findings CR 10 PP is requested to provide the ER spread sheets for each ship and the supporting evidences. VPA is not clear on how the project emissions are accounted. Please refer to Appendix 4 for more details. CR 10 is closed.

Conclusion The proposed VPA-2 correctly applies the approved Gold Standard Methodology “Reducing emissions through the use of advanced hull coatings”, version 2.0, dated 17/11/2014, which is as per the registered PoA.


F.5.2. Data and parameters fixed ex ante

Means of validation The following table list the data and parameters fixed ex ante.

Data/parameter Unit Value applied

Assessment

1 NCV residual fuel oil TJ/Gg 40.4 The values are consistent with the registered VPA . The same was also cross checked with the IPCC guidelines Volume Energy (table 1.2 and 3.5.2) /23/ and found to be correct.

2 NCV marine diesel TJ/Gg 43.0

3 NCV low Sulphur heavy fuel oil

TJ/Gg 40.4

4 NCV liquefied natural gas

TJ/Gg 48.0

5 EF residual fuel oil Kg/GJ 77.4

6 EF marine diesel Kg/GJ 74.1

7 EF low Sulphur heavy fuel oil

Kg/GJ 77.4

8 EF liquefied natural gas

Kg/GJ 56.1

Findings N/A

Conclusion RINA confirms that the parameters listed above are fixed ex-ante and used for baseline, project emissions and leakage emissions calculation in accordance with the applied methodology and methodological tools and they are the same used at the validation stage.

F.5.3. Ex ante calculation of emission reductions or net GHG removals by sinks

Means of validation The ER calculations ex-ante is calculated by means of the values available in the eco-efficiency reports of each ship included in the VPA-2 /17/. The values provided for estimate of CO2 emissions from fuel savings, denominated “Off-shore Global Warming Potential are available for each ship in there eco-efficiency reports. Using the assumed docking cycle for each ship, and using the known date for application of the advanced hull coating, the end of the docking cycle for each ship is estimated. During this period, emissions reductions per year are determined from the annual average of the difference in “Off-shore Global Warming Potential” using the Biocidal coating (baseline) and advanced hull coating (project). Partial years, at the start and end of the docking cycle for each ship, are determined by pro-rating annual emissions. This was checked with “VPA 2 vessels data summary 18Dec2017.xlsx” /35/ and accepted.

Findings CR 10 Please refer to F.5.1 CR 10 is closed.

Conclusion It has been confirmed that the ex-ante calculation of emission reductions has been found to be satisfactorily demonstrated in the VPA DD vis a vis the ER calculation sheet and confirms that: - The ER calculation as described in D.6.3 of the CPA-DD is correct. - The calculation provided in the excel calculation sheet is correct. RINA confirms that the CPA-DD meets the requirements of para 144 of VVS.

F.5.4. Summary of ex ante estimates of emission reductions or net GHG removals by sinks

Means of validation The validation team has checked the ex-ante calculation in section D.6.3 and D.6.4 of the VPA-DD as well as the excel worksheet in detail /35/. The total emission reduction expected from VPA over the entire crediting period of 10 years is 459,241 tCO2e which makes the annual average to be 45,924 tCO2e.

Findings CR 10 Please refer to F.5.1 CR 10 is closed.


Conclusion It has been confirmed that the summary of ex-ante estimates of emission reduction has been satisfactory demonstrated in the VPA-DD vis a vis the ER calculation sheet and also confirms that: - The annual, total and average values for baseline, project and leakage emissions as well as emission reductions have been listed correctly in the VPA-DD.


F.6. Application of the monitoring methodology and description of the monitoring plan

F.6.1. Data and parameters to be monitored


Means of validation The ex-post parameters that are mentioned in the methodology are included in the VPA-DD and in the monitoring plan, and are provided in compliance with the methodology.

Parameter Description/Assessment

1 j ship Identification number and name of the ship. The data is available from the ship owner or from the coating manufacturer. The monitoring frequency is once when the ship is coated. Cross checked the vessel IMO numbers with the website vesselfinder.com /22/ and the same is found to be consistent and appropriate.

2 date_prev(j). Date on which the previous coating application was finished on ship j. The data is available from the ship owner or from the coating manufacturer. The monitoring frequency is once when the ship is coated and it is recorded at the dry dock where the coating is applied.

RINA checked the same with : Dry dock reports, data plan report, antifouling

certificates, other documents from baseline paint manufacturer and ship owners /32/

3 Previous coating material (j). The data is available from the ship owner or from the coating manufacturer.

The monitoring frequency is once when the ship is coated and it is recorded at the dry dock where the coating is applied.

The baseline coating type was checked with Dry dock reports, data plan report, antifouling certificates, other documents from baseline paint manufacturer and ship owners /32/. Further the specifications were checked

with website of coating manufacturer /36/.

4 Hull cleaning (underwater) in baseline period (j) and project period.

Hull cleaning in the baseline was checked with data plan reports and it is confirmed that no such activity took place /40/

5 Date_adv(j) Date on which the advanced coating application is finished on ship (j). The data is available from the coating manufacturer. The monitoring frequency is once when the ship is coated and it is recorded at the dry dock where the coating is applied. Checked the data plan report for all the 30 ships to confirm the date of advanced hull coat. Same was found to be correct and accepted.

6 Advanced coating material (j). The data is available from the ship owner or from the coating manufacturer. The monitoring frequency is once when the ship is coated and it is recorded at the dry dock where the coating is applied. The advanced coatings applied comprise Intersleek 1100SR, Intersleek 900 family (comprising Intersleek 960 and Intersleek 970) and Intersleek 700 family (specifically Intersleek 757), aslo checked with the website /37/

7 Main engine fuel (j).: ship log records to will be checked to confirm the usage of main engine fuel. Further fuel purchase invoices to confirm the type of the fuel.

8 Auxiliary engine fuel (j). ship log records to will be checked to confirm the usage of auxiliary engine fuel. Further fuel purchase invoices to confirm the type of the fuel.

9 Engine or other modifications undertaken at the same time as the application of advanced hull coating: The

summary of day by day activities performed during the dry dock was checked with data plan reports /40/ and confirmed that no energy efficiency activities were carried out at the time of advanced hull coating. The monitoring frequency is once at the time of hull coating.

10 Change in fuel at the same time as the application of advanced hull coating: the same justification as above. The monitoring frequency is once at the time of hull coating.

11 Voyage data for ships operating on shorter voyages or on long routes

(a) Date

(b) Daily distance (nautical miles)

(c) Daily streaming time (hours)

(d) Average daily speed through water since last daily record (Knots)

(e) Sea state (Beaufort number)

(f) Vessel condition (ballast/loaded or displacement)

(g) Fuel consumption of the main engine since last daily record (tonnes)

(h) Daily fuel consumption of the auxiliary engine(s) since last daily record (tonnes)

12 Voyage data for ships operating on shorter

voyages

(a) Date of voyage start and end

(b) Distance between departure port and arrival port (nautical

miles)

(c) Voyage time (hours)

(d) Average navigation speed during voyage (Knots)

(e) Sea state (Beaufort number)

(f) Vessel condition of ship at the time of data recording (Ballasts/Loaded or displacement)

(g) Fuel consumption of the main engine for navigation part of voyage (tonnes)

(h) Fuel consumption of the auxiliary engine for navigation part of voyage (tonnes)

The data are available from ship operator and the monitoring frequency is per voyage.

The measurement method and/or equipment have been defined as GPS, fuel flow meter and ship log data.


Findings CR 11

PP is requested to provide evidences of the baseline coating date for the ships included in this VPA.

PP is requested to provide evidences of the baseline coating material for all the 36 ships included in this VPA.

PP is requested to provide the hull cleaning (underwater) dates in the baseline period with supporting evidences and also for the project period is any.

Date on which the advanced coating application is finished on ship (j). The data is available from the coating manufacturer. PP is requested to provide evidences for the same.

PP is requested to provide the evidences of the advance coating material specifications and the test certificates.

PP is requested to provide the ship log records to confirm the usage of main engine fuel. Further provide the fuel purchase invoices to confirm the type of the fuel.

PP is requested to provide the ship log records to confirm the usage of auxiliary engine fuel. Further provide the fuel purchase invoices to confirm the type of the fuel.

PP is requested to provide third party evidences to confirm that no engine or other modifications undertaken at the same time as the application of advanced hull coating.

PP is requested to provide records for the Voyage data for ships operating on shorter voyages or on long routes, which includes (Date, Daily distance (clarify the measurement procedure), Daily streaming time (hours), Average daily speed through water since last daily record (Knots), Sea state (Beaufort number), Vessel condition (ballast/loaded or displacement) , Fuel consumption of the main engine since last daily record (tonnes), Daily fuel consumption of the auxiliary engine(s) since last daily record (tonnes) : clarify the fuel flow meter records, measurement procedures and the calibration frequency of flow meters) and (Date of voyage start and end, Distance between departure port and arrival port (nautical miles), Voyage time (hours), Average navigation speed during voyage (Knots), Sea state (Beaufort number), Vessel condition of ship at the time of data recording (Ballasts/Loaded or displacement), Fuel consumption of the main engine for navigation part of voyage (tonnes), Fuel consumption of the auxiliary engine for navigation part of voyage (tonnes)) For more information please refer to Appendix 4. CR 11 is closed and the following FAR is raised.

FAR 2 The summary of day by day activities performed during the dry dock was checked with data plan reports and confirmed that no energy efficiency activities were carried out at the time of advanced hull coating. However, it needs to be ensured that the ship dint undergo engine overhaul or replacement, or any other modification that would reduce its fuel consumption at any time during the docking cycle for which carbon credits are being claimed. The same needs to be checked during verification.

Conclusion The parameters to be monitored ex-post listed in the VPA-2 including the monitoring frequency and method is as per the methodology and registered PoA-DD

F.6.2. Description of the monitoring plan

Means of validation RINA checked the monitoring plan as described in section D.7.2 of the VPA-DD in detail and confirms that the monitoring plan for the VPA is in accordance with the GS methodology “Reducing emissions through the use of advanced hull coatings”, version 2.0 of 17/11/2014 /07/


Findings CR 12 The VPA-DD is not transparent on the following:

QA/QC procedures.

Uncertainty levels, methods and the associated accuracy level of measuring instruments to be used for various parameters and variables.

Specifications of the calibration frequency for the measuring equipment.

The operational and management structure to be put in place to implement the monitoring plan.

Definition of responsibilities and institutional arrangements for data collection and archiving

Please refer to Appendix 4 for more information. CAR 12 is closed.

Conclusion RINA confirms that the monitoring plan mentioned in the VPA-DD is in accordance with the requirements mentioned in the monitoring methodology and the local regulatory requirements, as well the monitoring arrangements described in the monitoring plan are feasible within the project design. RINA is of the opinion that the monitoring plan will give opportunity for real measurement of achieved emissions reductions for 2 years after the crediting period.


F.6.3. Description of the sustainability monitoring plan

Means of validation The sustainable development matrix is discussed in the VPA passport /03/ and it is in accordance with the Gold Standard requirements /10/. The defined the GS indicators in the SD are given below including their scores.

Air Quality. Score +. Reducing fuel consumption in ship engines means that less fuel is burnt with fewer emissions of Sox and Nox from combustion. At the same time the application of the Intersleek system reduces emissions of VOC compared to the biocidal systems /27/ /28/.

Water quality and quantity. Score +. The baseline hull coating is a class of biocidal antifoulings known as self-polishing copolymers (SPC); these paints are designed to dissolve away into the environment during use and so significant quantities of this paint (which include biocides) is also lost to the marine environment /27/ /28/.

Soil condition. Score +. According the Eco Efficiency analysis reports the Intersleek products are substantially lower in toxicity compared to biocidal systems and thus it does not affect the soil ecosystem /28/.

Other pollutant. Score +. Since the Intersleek system has no biocides means that none are released into the water; compared to the baseline coating, low quantity of copper is used and thus it reduces the potential acidification; less waste is generated due to less paint is needed /27/ /28/; the intersleek system being biocid-free it does not impact the loss of biodiversity /17/.

Quality of employment. Score +. The application of the Intersleek system reduces emissions of VOC compared to the biocidal systems thus workers are exposed to less contamination /17/. It is further checked that the PP has developed documented procedures like Carbon Credit Process Steps.pdf, Carbon Credits Webinar Revision 02.pdf, Data collection method.pdf, Dry docking procedure.pdf, which will be used in training the ship owners/30/ operators and to dry dock workers.

Livelihood of the poor. Score +. As the project reduces shipping fuel costs, it would reduce the cost of getting products to markets, indirectly benefitting those who depend on their production being sent by ships market.

Access to affordable and clean energy. NA

Human and institutional capacity. Score +. The application of the advanced hull coating to save fuel as well as the application of the monitoring methodology to evaluate ship fuel consumption would add to human and institutional capacity of ship owners and operators .

Quantitative employment and income generation. Score 0. Ships are coated in different locations many of which are in developing countries. The employed in the activity would acquire skills involving a sustainable technology. Moreover, since there is less VOC emissions, workers are exposed to less contamination.

Balance of payments and investment. Score 0. Even if many ships are registered in developing countries their geographical location is in developing countries (Non-Annex I) and the CO2 emissions are dominated by ships from Non-Annex I countries.

Technology transfer and technological self-reliance. Score +. Since CO2 emissions are dominated by ships from Non-Annex I countries, the GS carbon credits would help to promote the transfer of advanced coating technologies to these countries and to ship owners and operators in general.

Findings CR 06 Please refer to section E. CR 06 is closed.

Conclusion RINA confirms that sustainability monitoring plan and indicators included in the GS passport confirm to the sustainable development matrix outlined in the GS passport and conforms to GS requirement version 2.2.


Appendix 1. Abbreviations

Abbreviations Full Texts

BE Baseline Emissions

CAR Corrective Action Request

CDM Clean Development Mechanism

CDM M&P Modalities and Procedures CDM

CDM-PCP Clean Development Mechanism Project Cycle Procedure

CDM-PS Clean Development Mechanism Project Standard

CDM-VVS Clean Development Mechanism Validation and Verification Standard

CER(s) Certified Emission Reduction(s)

CH4 Methane

CR Clarification Request

CME Coordinating and Managing Entity

CO2 Carbon dioxide

CO2e Carbon dioxide equivalent

CP Certification Program

VPA Voluntary Programme Activities

CPA-DD Component Project Activity Design Document

DD Design Document

DNA DNHA

Designated National Authority Do No Harm Assessment

DOE Designated Operational Entity

EB Executive Board

EIA Environmental Impact assessment

ER Emission Reductions

FAR FR GS

Forward Action Request Feedback Round Gold Standard

GHG(s) Greenhouse gas(es)

GWP Global Warming Potential

IMO International Maritime Organization

IPCC Intergovernmental Panel on Climate Change

LSC Local Stakeholders Consultation

MEPC Marine Environment Protection Committee

MoV Means of Verification

MP Monitoring Plan

MR MSC

Monitoring Report Micro Scale

NGO Non-governmental Organization

ODA Official Development Assistance

PDD Project Design Document

PE Project Emission

PoA Programme of Activities

PoA-DD CMD Programme of Activities Design Document

PP(s) Project Participant(s)

Ref. Document Reference

RINA SD

RINA Services Spa Sustainability Development

SMP SS(s)

Sustainability Monitoring Plan Sectoral Scope(s)

SSC Small Scale

UNFCCC United Nations Framework Convention on Climate Change

VOC Volatile Organic Component


Appendix 2. Competence of team member and technical

reviewer






Appendix 3. Documents reviewed or referenced

No. Author Title Referenc

es to the

documen

t

Prov

ider

1 International Paint Ltd

CDM-PoA-DD for PoA “Programme for the application of advanced hull coatings to reduce shipping fuel consumption (PAHSF)”

version 5 of 25/08/2015.

PP


CDM-CPA-DD for VPA “PAHSF Project 2” version 1 of 25/10/2016 version 2 of 3/07/2017 version 3 of 18/12/2017

PP


VPA Passport “Programme for the application of advanced hull coatings to reduce shipping fuel consumption”.

Version 1 of 25/10/2016 version 02 of 28/03/2017 version 03 of 18/12/2018

PP


LSC report : VPA 2 of Programme for the application of advanced hull coatings to reduce shipping fuel consumption (PAHSF)

version 1 of 25/10/2016

PP

5 CDM Executive Board

Clean Development Mechanism Project Standard version 07.0 of 01/06/2014

Others


Clean Development Mechanism Validation and Verification Standard

version 07.0 of 01/06/2014

Others

7 Gold Standard Foundation

Gold Standard Methodology Reducing emissions through the use of advanced hull coatings

version 2.0 of 17/11/2014

Others



Demonstration of additionality, development of eligibility criteria and application of multiple methodologies for programme of activities

version 03.0 of 26/07/2013

Others


Sampling and surveys for CDM project activities and programme of activities

version 03.0 of 04/10/2013

Others


The Gold Standard Requirements version 2.2 of 01/06/2012

Others


The Gold Standard Principles 05/2013 Others


The Gold Standard Toolkit version 2.2 of 01/06/2012

Others


Revised Annex C – Guidance on project type eligibility -


The Gold Standard PoA rules and guidance – Annex F (GSV2.2) -


Component project activity design document form for CDM component project activities,

version 03.0 of 25/06/2014

-

16 Gold Standard Foundation:

Annex AM – PoA Passport template, version 2.2

-

17 International paint Ltd

Power point presentation on Fouling control-An Eco Efficiency Analysis for each ship, validated by Swedish Environmental Research Institute, which includes for intersleek 1100 SR and intersleek 900


Local stakeholders consultation feedback form ship owners and employees of international Paint

- PP


invitation to submit comments for the international paint employees Dated 15/08/2016


Invitation to regional representatives of international paint to solicit stakeholders comments from shipping companies

Dated 12/08/2016

PP


Common_practice_test 31aug16 clean Dated 31/08/2016

PP

22 Websites Vesselfinder.com and marine traffic.com Last accessed on 25/05/2017

PP

23 IPCC IPCC – 2006 IPCC Guidelines for National Greenhouse Gas Inventories, Volume 2 Energy, Table 1.2, Table 3.5.2.

- -


24 Labour Laws

https://en.wikipedia.org/wiki/United_Kingdom_labour_law https://en.wikipedia.org/wiki/National_Labor_Relations_Act http://www.mom.gov.sg/employment-practices/employment-act

Last accessed on 25/05/2017

PP

25 European Union

Regulation (EC) No. 782/2003 of the European Parliament and of the Council on the prohibition of organotin compounds of ships

14/04/2003


Intersleek family of products

27 JLA Media Ltd

Eco-efficiency, a new tool to support better decisions on hull coating investment:

Dated 09/2010

PP

28 Akzonobel

Eco-efficiency assessment reviewed by IVL Swedish Environmental Research Institute

Dated 27/02/2015

PP

29 Contracts between International Paint Ltd and shipping companies

Agreement copies between International Paint Ltd and the following shipping companies: 1. Anglo Eastern Ship Management Ltd: Blue Marlin 2. Kawasaki Kisen Kaisha, Ltd: Aegean Highway, Corona

Infinity, dated 27/12/2017 3. Flota Suardiaz.: Bouzas, Galicia and L’Audace, dated

10/08/2016 4. Navicar: Tenerife Car, dated 10/08/2016 5. TMS Dry Ltd: Andama 6. Laurin Maritime: MT Cavatina 7. Balearia: Martin I Soler, dated 29/12/2014 8. Grimaldi, dated 11/06/2014 9. Intergis Shipping: DK INITIO, DK IONE 15/09/2015 10. MESM (Mideast Ship Management): MESM Ghazal, MESM

Jana, MESM Kahla dated 14/04/2015 11. Cardiff Marine: Botafogo, Corossol, Desimi, Scorpio and

Solana 12. Tirrenia di Navigazione: Vincenzo Florio 24/02/2015


Carbon Credit Process Steps.pdf, Carbon Credits Webinar Revision 02.pdf, Data collection method.pdf, Dry docking procedure.pdf,

PP

31 Haifeng Wang

A supplementary study, to support the relevance of developing countries to international shipping

01/09/2010

PP

https://en.wikipedia.org/wiki/United_Kingdom_labour_law

https://en.wikipedia.org/wiki/National_Labor_Relations_Act

http://www.mom.gov.sg/employment-practices/employment-act


32 Baseline coating dates

Baseline coating date

As per the documents: Dry dock reports, data plan report, antifouling certificates, other documents from baseline paint

manufacturer and ship owners

19-01-2012 Jotun: CDO Drydocking report : Anglo Eastern- Blue Marlin

27-01-2011 PPG Protective and Marine coatings: Balearia Martin i Soler Tin free certificate

07-07-2010 International paint : Data plan report : Cardiff Marine- Andama

26-01-2010 Newbuild date: Cardiff Marine -Botafogo

05-02-2010 Newbuild date :Cardiff Marine- Corossol

24-09-2011 Newbuild date :Cardiff Marine- Desimi

19-03-2009 Newbuild date : Cardiff Marine- Scorpio

09-05-2010 Newbuild date : Cardiff Marine- Solana

22-08-2007 Ministerio de Fomento: antifouling certificate: Flota Suardiaz -Bouzas

11-06-2008 International paint : Data plan report :Flota Suardiaz -Galicia

15-08-2008 Ministerio de Fomento: antifouling certificate :Flota Suardiaz -L'Audace

07-06-2011 RINA: International antifouling system certificate: Grimaldi -Eurocargo Genova

09-08-2009 Jotun: CDO Drydocking report: Grimaldi -Grande Atlantico

05-07-2012 Inarme: Grimaldi -Grande Buenos Aires

19-07-2012 Inarme : Grimaldi -Grande Francia

15-09-2012 RINA: International antifouling system certificate: Grimaldi - grande nigeria

05-05-2012 Grimaldi : Grande San Paolo

01-07-2011 RINA: International antifouling system certificate: Grimaldi - grande sierra leone

14-02-2012 RINA: International antifouling system certificate: Grimaldi - Repubblica

29-06-2011 RINA: International antifouling system certificate: Grimaldi - Repubblica del Brasile

20-07-2010 Intergis Shipping responses.pdf

18-06-2010 Intergis Shipping responses.pdf

11-08-2011 Kpdyna: Dry docking report

01-09-2012 Nippon Pain Marine Co Ltd: K Line Corona Infinity

05-01-2010 Newbuild date: Laurin Maritime

03-07-2009 MESM Ghazal newbuild report 2009 com MGM.pdf

04-09-2008 MESM Jana newbuild report 2008 com MGM.pdf

13-03-2009 MESM Kahla newbuild report 2009 com MGM.pdf

15-01-2007 Hempel’s ship data :Navicar Tenerife Car

28-05-2013 Tirrenia- Basin report : Tirrenia Vincenzo

33 MEPC Resolution MEPC 245(66), “2014 Guidelines on the Method of Calculation of the Attained Energy Efficiency Design Index (EEDI) for New Ships”,

adopted on 04/04/2014

34 MEPC Resolution MEPC 215 (63)” Guidelines for calculation of reference lines for use with the Energy Efficiency Design Index (EEDI)”,

adopted on 02/03/2012


35 MGM & Fremco International

Emission reduction spread sheets (VPA 2 vessels data summary 30mar2017.xlsx)” Emission reduction spread sheets (VPA 2 vessels data summary 18Dec2017.xlsx)”,

Version 01 of 30/03/2017 Version 02 of 30/03/2017


36 Paint manufacturer’s website

Website with specification confirming that it is SPC coating

Shipping company

Ship Name Website with specification confirming that it is SPC coating

Anglo Eastern

Blue Marlin http://www.hempel.com/en/products/hempels-antifouling-oceanic-8495k

Balearia Martin I Soler https://docs.td.ppgpmc.com//download/395/395/sigma-sailadvance-dx

Cardiff Marine

Andama

http://www.international-marine.com/PDS/81-M-eng-A4.pdf http://www.international-marine.com/products/info/interswift-655.aspx

Cardiff Marine

Botafogo http://www.ppgpmc.com/Products/7262/SIGMA-ALPHAGEN-650.aspx

Cardiff Marine

Corossol http://www.ppgpmc.com/Products/7262/SIGMA-ALPHAGEN-650.aspx

Cardiff Marine

Desimi


Cardiff Marine

Scorpio http://www.csp.co.kr/downfile/prod/SEA%20GRANDPRIX%20500.pdf

Cardiff Marine

Solana http://www.international-marine.com/PDS/892-M-eng-usa-A4.pdf

Flota Suardiaz

Bouzas http://www.hempel.com/en/products/hempels-antifouling-oceanic-8495k

Flota Suardiaz

Galicia


Flota Suardiaz

L’Audace http://www.hempel.com/en/products/hempels-antifouling-globic-nct-8190m

Grimaldi Eurocargo Genova

http://www.international-marine.com/PDS/77-M-eng-A4.pdf http://www.international-marine.com/PDS/4509-M-eng-A4.pdf

Grimaldi Grande Atlantico

http://www.jotun.com/Datasheets/Download?url=%2FTDS%2FTDS__9060__SeaQuantum+Plus+S__Euk__GB.pdf

Grimaldi Grande Buenos Aires

http://www.jotun.com/Datasheets/Download?url=%2FTDS%2FTDS__18160__SeaConomy+700__Euk__GB.pdf

Grimaldi Grande Francia

http://www.csp.co.kr/downfile/prod/SEA%20GRANDPRIX%20500.pdf

Grimaldi Grande Nigeria

http://www.jotun.com/Datasheets/Download?url=%2FTDS%2FTDS__18160__SeaConomy+700__Euk__GB.pdf http://www.jotun.com/Datasheets/Download?url=%2FTDS%2FTDS__9060__SeaQuantum+Plus+S__Euk__GB.pdf

Grimaldi Grande San Paolo

http://www.jotun.com/Datasheets/Download?url=%2FTDS%2FTDS__18160__SeaConomy+700__Euk__GB.pdf http://www.jotun.com/Datasheets/Download?url=%2FTDS%2FTDS__9060__SeaQuantum+Plus+S__Euk__GB.pdf

Grimaldi Grande Sierra Leone

http://www.buykorea.or.kr/product-details/seacare-af795--3019110.html

Grimaldi Repubblica Argentina

http://www.sinteplastindustria.com.ar/uploads/product/fd7d9e4cb6e51cc367709f373a3aabb3464c59cf.pdf

Grimaldi Repubblica del Brasile


Intergis Shipping

DK INITIO http://www.csp.co.kr/downfile/prod/SEA%20GRANDPRIX%20CF%2010.pdf

Intergis Shipping

DK IONE http://www.csp.co.kr/downfile/prod/SEA%20GRANDPRIX%20CF%2010.pdf

K Line Aegean Highway

http://www.csp.co.kr/downfile/prod/SEA%20GRANDPRIX%20CF%2010.pdf http://www.csp.co.kr/downfile/prod/SEA%20GRANDPRIX%20500.pdf

K Line Corona Infinity

http://www.nipponpaint-marine.com/en/products/datasheets/pdf/12-04B.pdf


PP

http://www.hempel.com/en/products/hempels-antifouling-oceanic-8495k


https://docs.td.ppgpmc.com/download/395/395/sigma-sailadvance-dx

https://docs.td.ppgpmc.com/download/395/395/sigma-sailadvance-dx

http://www.international-marine.com/PDS/81-M-eng-A4.pdf












http://www.hempel.com/en/products/hempels-antifouling-globic-nct-8190m

http://www.hempel.com/en/products/hempels-antifouling-globic-nct-8190m















http://www.csp.co.kr/downfile/prod/SEA%20GRANDPRIX%20CF%2010.pdf











Laurin Maritime

MT Cavatina

https://docs.td.ppgpmc.com//download/395/395/sigma-sailadvance-dx http://www.ppgpmc.com/Products/7297/SIGMA-ECOFLEET-290.aspx

MESM

MESM Ghazal http://www.international-marine.com/PDS/81-M-eng-A4.pdf

MESM

MESM Jana http://www.international-marine.com/PDS/81-M-eng-A4.pdf

MESM

MESM Kahla http://www.international-marine.com/PDS/81-M-eng-A4.pdf

NAVICAR

Navicar Tenerife Car


Tirrenia di Navigazione

Vincenzo Florio

http://www.sinteplastindustria.com.ar/uploads/product/fd7d9e4cb6e51cc367709f373a3aabb3464c59cf.pdf http://www.csp.co.kr/downfile/prod/SEA%20GRANDPRIX%20500.pdf

37 International

Intersleek 757


Intersleek 970


Intersleek 1100SR



PP

38 MEPC meeting MEPC 69 Dated 22/04/2016

PP

39 MEPC IMO report to UNFCCC and resolution MEPC 282(70) i.e 2016 guidelines for the development of Ship Energy Efficiency Management Plan (SEEMP)

Dated 28/10/2016

PP

http://www.ppgpmc.com/Products/7297/SIGMA-ECOFLEET-290.aspx








40 Akzonobel

Data plan reports Anglo Eastern Blue Marlin 10/01/2015 Balearia Martin I Soler 02/11/2013

Cardiff Marine Andama 04/05/2015

Cardiff Marine Botafogo 04/10/2014

Cardiff Marine Corossol 06/05/2015

Cardiff Marine Desimi 15/09/2015

Cardiff Marine Scorpio 24/03/2014

Cardiff Marine Solana 07/05/2015

Flota Suardiaz Bouzas 22/09/2012

Flota Suardiaz Galicia 31/01/2013

Flota Suardiaz L’Audace 18/08/2013

Grimaldi Eurocargo Genova 18/09/2012

Grimaldi Grande Atlantico 15/08/2014

Grimaldi Grande Buenos Aires 18/08/2015

Grimaldi Grande Francia 10/09/2015

Grimaldi Grande Nigeria 21/09/2015

Grimaldi Grande San Paolo 18/01/2015

Grimaldi Grande Sierra Leone 19/01/2015

Grimaldi Repubblica Argentina 28/01/2015

Grimaldi Repubblica del Brasile 19/08/2014

Intergis Shipping DK INITIO 26/10/2013

Intergis Shipping DK IONE 10/08/2015

K Line Aegean Highway 10/12/2013

K Line Corona Infinity 24/03/2015

Laurin Maritime MT Cavatina 16/01/2015

MESM MESM Ghazal 19/04/2014

MESM MESM Jana 15/08/2013

MESM MESM Kahla 08/04/2014

NAVICAR Navicar Tenerife Car 20/01/2012

Tirrenia di Navigazione Vincenzo Florio 24/01/2015

41 International

http://www.international-marine. com/contactus/feedback.aspx , in English

Last accessed on

18/12/2017


Tool for the demonstration and assessment of additionality Version 07.0.0 of 23/11/2012


Tool to calculate project or leakage CO2 emissions from fossil fuel combustion

version 02 of 02/08/2008

44 Shipping companies

Purchase order and contract acceptance email for all the 30 ships included in the VPA.

PP

45 Email from GS to Fremco International and MGM on availability of the documents in GS registry for public comments

29/03/2017 /

46 Shipping companies

Stakeholder feedback forms and email communications from shipping company representatives to International Paint

Dated from 13/04/2017 to 13/12/2017

47 International Paint

IP Vessel Count by Year_2015 calc MGM_corr 29aug17.xlsx Dated 29/08/2017

48 Lloyds Register

VesselCountLloyds31Aug2016.xlsx

49 International Paint

Common_practice_test 31aug16 clean Dated 31/08/2016


Glossary of CDM terms version 09.1 of 1/09/2017

http://www.international-marine/


Appendix-4: Clarification requests, corrective action requests and forward action requests

CR ID 01 Section no. A.4 Date: 06/06/2017

Description of CR

1. The project title of VPA passport and VPA-DD is not consistent.

2. PP is further requested to provide GS comments on the pre-feasibility assessment report.

CME response Date: 30/06/2017

1. The project name has now been made consistent to: Programme for the application of advanced hull

coatings to reduce shipping fuel consumption (PAHSF). VPA No. 2. Also minor change in LSC

Report for consistency.

2. The Pre-feasibility Assessment and project proponent responses are attached, as are the track

changed documents for VPA DD, Passport and LSC report.

Documentation provided by CME

1. Revised versions of VPA DD, VPA Passport and LSC Report will require minor changes and will be

edited as soon as the remaining validation answers have been closed. A few other documents will

require further revisions. They are also highlighted in turquoise.

2. Pre-feasibility assessment:

GS 5406_VPA-2_Fast Track PFA Feedback.pdf

VPA 2 GS 5406 fast track PFA comments and responses 7apr17.pdf

International Paint VPA-2 DD v2 6apr17 tracked.doc

International Paint VPA-2 Gold Standard Passport v2 28mar17 tracked.doc

IP Hull Coating VPA-2 LSC Report v2 28mar17 tracked.docx

Note that the clean versions of the last three documents were submitted to RINA with validation.

DOE assessment Date: 24/08/2017

1.The issue is open.

2.GS comments on the Pre-feasibility assessment along with PPs response checked. The issues , where GS

wants DoEs check has been raised as findings during the validation. Further to the above, few documents

required by GS are not yet submitted.

CR 1 is open based on the above mentioned point n. 1 and 2.


The documents VPA DD; Passport and LSC were revised, to take into account validation comments, and

also because the final number of ships to be included in VPA 2 is 30.


International Paint VPA-2 DD v3 30nov17 tracked.doc

International Paint VPA-2 Gold Standard Passport v3 30nov17 tracked.doc

IP Hull Coating VPA-2 LSC Report v3 30nov17 tracked.docx


1. The project title has been made consistent in the VPA-DD, passport and LSC reports of the latest

version.

2. The pre-feasibility comments raised by GS has been addressed by PP . The same was checked by

RINA and accepted.

CR 01 is closed.

CR ID 02 Section no. A.5 Date: 06/06/2017

Description of CR


1. PP is requested to provide evidences to support prior consideration of carbon revenues, operational

life time of the project.

2. Contract copies of CME with the ship owners, included in the VPA-2.

3. Necessary approvals and clearances of each ship included in the VPA.

4. Evidences to ensure that the advanced hull coating is not a mandatory requirement for ships.

5. Case studies or proven articles, which confirms that application of advanced low resistance hull

coatings instead of traditional coating, reduces hydrodynamic resistance thus reducing fuel

consumption for ship propulsion.


Point 1. Prior consideration: the contracts between International Paint and the shipping companies for the

application of advanced hull coating, as required in the GS methodology, confirm that the shipping companies

are aware of carbon credits, and agree to meet the conditions specified in the methodology.

The operational lifetime of the hull coating is a single docking cycle following the application of the coating.

The period varies from ship to ship. Coatings deteriorate over time, and hulls need to be recoated after some

years. As noted in the Methodology Introduction: “The hull coating is applied on a docking cycle, which is

typically 60 months for most cargo vessels, though the docking cycle for some ships is shorter, e.g. 36, 30 or

24 months, and even as low as 12 months for small passenger ships. Since performance may degrade over

time, fuel consumption and emissions must describe the full docking cycle.”

Point 2. We have provided copies of the contract in the Dropbox folder “2016DGMD23 files for GS VPA 2

inclusion”, subfolder “Contracts with shipping companies”

Point 3. The project activity comprises the use of advanced hull coatings instead of the baseline coating.

Advanced and baseline hull coatings are standard industrial products that are subject to international scrutiny

before their widespread use. In addition, each vessel in the VPA has a unique IMO number, has been sailing

for many years even prior to the application of the advanced coating and is operating in accordance with all

required rules.

Point 4. (1) The Marine Environment Protection Committee (MEPC) of the International Maritime

Organisation (IMO) at its most recent (April 2016) meeting MEPC 69 in its Briefing document (22 April 2016),

confirmed mandatory requirements for ships to record and report their fuel consumption.

(2) Moreover, the 2016 IMO report to UNFCCC notes (p. 22): “The establishment of the IMO Ship Fuel

Consumption Database will be the first in a three-step approach in which analysis of the data collected

(second step) would provide the basis for an objective, transparent and inclusive policy debate in the MEPC

(third step).”

(3) Finally, the Resolution MEPC.282(70) (Adopted on 28 October 2016) adopted the 2016 Guidelines For

The Development Of A Ship Energy Efficiency Management Plan (SEEMP), provides details on how energy

consumption is to be measured and reported.

All three documents, attached as listed below, confirm that the IMO so far has emphasized mandatory

reporting of ship energy consumption, without requiring any requirements for energy efficiency improvement,

much less specific measures such as the use of advanced hull coatings.

Point 5. There are many publications, including those listed in the Gold Standard methodology. We attach a

number of publications, see list in next item.



Point 2: Dropbox folder “2016DGMD23 files for GS VPA 2 inclusion”, subfolder “Contracts with shipping

companies”

Point 4:

1. IMO MEPC Briefing April 2016.pdf

2. IMO to UNFCCC 2016.pdf

3. MEPC.282(70).pdf

Point 5:

1. Pew, 2010. Marine Shipping Emissions Mitigation. Pew Center on Global Climate Change, March.

Global_Marine_Shipping_Emission_Mitigation_-_Pew_Center_2010.pdf

2. Michael Schultz, 2004. “Frictional Resistance of Antifouling Coating Systems.” Journal of Fluids Engineering.

Schultz JFE 2004.pdf

3. Maxim Candries. Frictional Resistance of Antifouling Coating Systems. PhD thesis. Candries_Thesis.pdf

4. Anderson, C., Atlar, M., Callow, M., Candries, M., Milne, A., Townsin, RL, 2003. “The development of foul-

release coatings for seagoing vessels”. Proceedings of the Institute of Marine Engineering, Science and

Technology. Part B, Journal of Marine Design and Operations, No. B4, pp. 11-23. Atlar et al_IMarest 2004.pdf


1. RINA confirms that the start of the proposed VPA is after the start date of the PoA. It was further noted that

GS has agreed to include the ships coated with advance hull coating after 09/11/2010, since this is the date

of the methodology PIN submitted to GS /02/. The ships included in VPA-2 coated with advanced hull coat

starts from 20/01/2012 to 21/09/2015, which is after the date 09/11/2010. Thus, RINA confirms that as per

VVS, the prior consideration of carbon revenues is followed by the client. The operational lifetime of the hull

coating is considered as single docking cycle. The hull coating is applied on a docking cycle, which is typically

60 months for most cargo vessels, though the docking cycle for some ships is shorter, e.g. 36, 30 or 24

months, and even as low as 12 months for small passenger ships. The same was also checked during the

PoA validation and VPA 1 inclusion and further approved by GS. Thus, the same was accepted.

2. The contract copies provided checked. Noted that the contract copies are not available for all the ships.

The following ships are missing:

Corossol: 9395331, Desimi: 9395305, Scorpio: 9389071, Solana: 9395317, Taipan: 9399478, Mega Express:

9203174, Galicia: 9268409, L’Audace: 9187318, Aegean Highway: 9464388, Corona Infinity: 9261932 and

Moby Drea: 7363865.

3. The justification provided by PP has been checked against vesselfinder.com and marinetraffic.com and the

same was accepted by RINA.

4. RINA checked the MEPC of the IMO , meeting MEPC 69 breifinng document dated 22/04/2016, 2016 IMO

report to UNFCCC and resolution MEPC 282(70) i.e 2016 guidelines for the development of Ship Energy

Efficiency Management Plan (SEEMP) adopted on 28/10/2016 confirms that IMO has made mandatory the

ships to record and report there fuel consumption data. It doesn’t state that advance hull coating is

mandatory for the ships. The justification provided by PP is accepted by RINA.

5. RINA checked the following publications and the same is accepted.

Pew, 2010. Marine Shipping Emissions Mitigation. Pew Center on Global Climate Change, March.

Global_Marine_Shipping_Emission_Mitigation_-_Pew_Center_2010.pdf

Michael Schultz, 2004. “Frictional Resistance of Antifouling Coating Systems.” Journal of Fluids Engineering.

Schultz JFE 2004.pdf

Maxim Candries. Frictional Resistance of Antifouling Coating Systems. PhD thesis. Candries_Thesis.pdf

Anderson, C., Atlar, M., Callow, M., Candries, M., Milne, A., Townsin, RL, 2003. “The development of foul-

release coatings for seagoing vessels”. Proceedings of the Institute of Marine Engineering, Science and

Technology. Part B, Journal of Marine Design and Operations, No. B4, pp. 11-23. Atlar et al_IMarest 2004.pdf

CR 02 is open based on the above mentioned point 2.



2. Contracts and purchase orders.

We have provided complete set of documentation, summarized in “VPA 2 Contracts files and dates

3Dec17.xlsx” These include contracts and purchase orders. In all cases, purchase orders are dated prior

to the application of the advanced hull coating. It should be noted that the purchase order documents

contain highly confidential and sensitive product pricing information belonging to International Paint, and

this information is being provided for validation purposes only and shall not be shared with any third

parties or made publically available in any way.


VPA 2 Contracts files and dates 3Dec17.xlsx

Files as listed in above Excel, column G

DOE assessment Date:

2. Please note that PO of NAVICAR is missing and contract copies for Aegean Highway and corona infinity is

missing

CR 02 is open.


PO for Navicar. There is a single Purchase order document (Flota Suadiaz Bouzas and Navicar

Tenerife Car emails.pdf), which covers both Flota Suardiaz Bouzas and Navicar Tenerife Car. (This file

was uploaded to the Dropbox folder on Dec. 4, 2017)

K Line Application form.pdf – file uploaded Jan. 2, 2018 - contract for K Line Aegean Highway and

Corona Infinity


Flota Suadiaz Bouzas and Navicar Tenerife Car emails.pdf. See Dropbox folder 2016DGMD23 files for

GS VPA 2 inclusion/VPA2 contracts and purchase orders

K Line Application form.pdf. See Dropbox folder 2016DGMD23 files for GS VPA 2 inclusion/Response

files 19dec17


2. Flota Suadiaz Bouzas and Navicar Tenerife Car emails.pdf document checked and the same was

accepted by RINA. Further the contract for for K Line Aegean Highway and Corona Infinity signed with

International paint Ltd , dated 27/12/2017 checked and the same is accepted by RINA.

CR 02 is closed.

CR ID 03 Section no. B Date: 06/06/2017

Description of CR

PP is requested to provide the environmental impact analysis reports undertaken at the VPA level.

Provide the eco efficiency reports for each ship.


There are 36 Eco-efficiency reports, one for each ship, in the Dropbox folder “2016DGMD23 files for GS VPA

2 inclusion”, subfolder “Ecoefficiency Report”


See Dropbox folder “2016DGMD23 files for GS VPA 2 inclusion”, subfolder “Ecoefficiency Report”, made

available to RINA.


Yes, the eco efficiency report for all the 36 ships included in the VPA is checked and the same is accepted.

CR03 is closed.


CR ID 04 Section no. C Date: 06/06/2017

Description of CR

1. The invitation tracking table and minutes of physical meeting, annex-1 and annex-2 of LSC report

discusses about the meeting held at PoA level and VPA-1. Please be specific to VPA-2.

2. Not clear on how the employees of international paint were selected to provide the stakeholder

comments.

3. For the methods of continuous inputs & grievance mechanism, the client has provided phone no and

link to the website. The LSC report is not transparent on the phone no. belongs to who and whom

shall the stakeholders contact. Not clear on how the stakeholder phone calls are documented and

how the actions will be carried out. It is further checked that the link provided in the website doesn’t

work. Also clarify on who has the access to the link and how the comments would be addressed.

4. PP is requested to clarify on the date when the LSC feedback round documents were available for

public comments. PP is also requested to provide evidences of the same and copies of the

comments received during the LSC feedback round.


Point 1. Invitation tracking tables are limited to VPA 2. However, there is a mention of physical meetings

undertaken in connection with the PoA, since these also covered all VPAs within the PoA.

Point 2. International Paint selects the employees and stakeholders by sampling a group of individuals all

of whom are involved in the Intersleek business in terms of R&D, manufacturing and other business

areas. The location of the individuals is varied from one VPA to the next (e.g. Felling, UK for VPA 1 and

Singapore for VPA 2) in order to seek feedback from a variety of people in different geographic regions.

In addition, the stakeholders selected are trained on aspects of the carbon credit program and the

Intersleek connection and relationship to that.

Point 3. The phone number is monitored and staffed daily by various parties within International Paint,

but does not belong to any one person. Any inquiries received are directed to Dr. Richard Towns, Market

Segment Manager – Fouling Release, who is also identified in the project documentation as the main

contact for International Paint as project proponent. Dr. Towns would either reply directly to any such

feedback, or seek answers from others before replying. To date, there have been no such inquiries or

feedback received. The correct website is http://www.international-marine.com/contactus/feedback.aspx.

Point 4. Two attached emails “SFR for VPA2 start date email.pdf” and “GS email re SFR for VPA2 start

date.pdf” confirming start date of the SFR process: March 29 and March 31, 2017.


Point 1:

Revised LSC report - this document will require minor changes and will be edited as soon as we have closed

the validation answers.

Point 4:

SFR for VPA2 start date email.pdf

GS email re SFR for VPA2 start date.pdf



1. Is open.

2. Evidences of stakeholders selected are trained on aspects of the carbon credit program and the Intersleek

connection and relationship to that.

3. PP is requested to make the same transparent in the feedback form, as well as in the passport and LSC

report.

4. Provide the revised LSC report, including the LSC feedback round. Note that the documents were made

publicly available in GS registry for public comments on 29/03/2017, which was confirmed by checking email

sent by GS registry to Fremco International, dated 29/03/2017. However, it is not clear, if the project has

received any comments and if yes, how were these comments addressed.

CR04 is open based on the above mentioned points.


1. The LSC report has been revised to include validation comments and stakeholder feedback round.

2. All seven persons from International Paint (IP) who provided stakeholder comments have submitted

letters confirming their awareness of Gold Standard carbon credits related to advanced hull

coatings.

3. Section E.2 of the revised LSC Report and Section E.3 of the revised Passport now note the

following:

“Please note that the phone number and email address listed above are monitored and staffed

daily by various parties within International Paint, but does not belong to any one person. Any

inquiries received are directed to Dr. Richard Towns, Market Segment Manager – Fouling

Release, who is also identified in the project documentation as the main contact for

International Paint as project proponent. Dr. Towns would either reply directly to any such

feedback, or seek answers from others before replying.”

4. LSC report has been modified to include validation comments and stakeholder feedback round.


IP Hull Coating VPA-2 LSC Report v3 30nov17 tracked.docx

Item 2 above: The file names are listed in the right column of table below. The files are compiled in a ZIP

folder called “Acknowledgement letter for VPA2.zip”

Name Title/function

Confirmation of awareness of GS carbon credits

Chen, Karen Technical Manager, MAR SITE QC Karen.pdf

Im, Yunos Production Manager, MAR SITE PRODN + RM Yunos.pdf

Yeo, Fiona Supply Planning Manager, MAR SITE SUPPLY PLANNING

Fiona.pdf

Spalburg, Melvin

SMU Supply Planning Manager, PCMA Global Supply Planning

Melvin.pdf

Lee, Jeffrey Site Manager Singapore, PCMA Site Singapore Jeffrey Lee.pdf

Khiew, Lee Yen

Regional Solutions Lab Manager (SA), MAR GLOBAL RDNI (TECH SUPPORT)

Acknowledgement_Lee Yen.pdf

Patel, Pritesh Section Manager, MAR GLOBAL RDNI Pritesh.pdf

Items 3 and 4:

3.IP Hull Coating VPA-2 LSC Report v3 30nov17 tracked.docx;

4. International Paint VPA-2 Gold Standard Passport v3 30nov17 tracked.doc



Points 1, 2 and 3 are closed, based on the corrections done in the updated LSC report.

4. PP to confirm , if any stakeholder comments were received in the GS registry. Provide evidence of the

same.

CR 04 is open based on the above mentioned point 4.


Both the LSC and SFR rounds were handled via email for this VPA 2, as feedback was being sought from a

discrete group of stakeholders, namely the vessel owners with vessels in VPA 2 and a small number of

AkzoNobel employees who are aware of, or involved with, the Intersleek carbon credit initiative internally

within AkzoNobel. In a serious of email exchanges with the GS in March, 2017 (excerpts provided in

attached file named "Email GS re SFR process VPA2.pdf”) it was agreed that the redacted documents for

SFR could be sent out via email to the stakeholders for review, although they were as well posted on the

Registry. The SFR process was initiated via emails, including all reminders and follow ups. Following the

lapse of the 60-day required period for SFR, it can be confirmed that any responses for the SFR have been

received via email, and also it can be confirmed that no additional comments were received via the Registry.


Email GS re SFR process VPA2.pdf


Justification provided by PP is acceptable to client.

CR 04 is closed.

CR ID 05 Section no. D Date: 06/06/2017

Description of CR

Environmental Protection: PP is requested to provide evidences to support that the environmental impacts

are favourable and there is no risk. Further, the VPA-Passport states that the environmental impacts with

baseline are favourable. However, this is not clear. Please demonstrate the environmental impacts with

regards to project scenario.

Anti-corruption: The project activity involves transaction between private parties. i.e between the CME

(International Paint Ltd) and ship owners/operators. PP is requested to provide the contract copies between

the CME and ship owners for the ships included in this VPA.


Environmental Protection: Detailed report “Eco Efficiency Assessment” comparing the performance of

Intersleek 700 and 1100 with the SPC coating “Intersmooth 7460HS” is attached. Note that the report was

“Third party peer reviewed”, and “ISO 14040 and ISO 14044 Compliant”. This report has now been included

in the Passport section “Justification choices, data source and provision of references” (p. 27). We do not

know where the Passport “states that the environmental impacts with baseline are favourable”. For instance,

section F.2 notes in several places that baseline coatings contain biocides which have an impact on the

marine environment. This section F.2 also indicates qualitatively the favourable environmental impact of the

project activity compared to the baseline. A quantitative analysis will be a part of the Monitoring Report.

Anti-corruption. Copies of the contracts between CME and shipping companies have been provided in

Dropbox folder “2016DGMD23 files for GS VPA 2 inclusion”, subfolder “Contracts with shipping companies”.


Environmental Protection:

EEA Intersleek 1100SR_report_final_with review statement.pdf

ecoefficiencywhitepaper_sep10.pdf

Anti-corruption. Dropbox folder “2016DGMD23 files for GS VPA 2 inclusion”, subfolder “Contracts with

shipping companies”.



1.RINA checked the documents “eco-efficiency, a new tool to support better decisions on hull coating

investment: , 09/2010” and “Eco-efficiency assessment by Akzonobel and reviewed by by IVL wedish

Environmental Research Institute “ confirms that Intersleek 1100SR is a biocide-free fluoropolymer fouling

control system, which improves several aspects of coating performance compared to the silicon based

fouling control system Intersleek 700 and the widely used biocide fouling control system Intersmooth 7460HS.

Examples of improvements are lower surface hull roughness, better coefficient of friction and better foul

release properties, which relatively to the Intersmooth 7460HS system, leads to reduced fuel consumption of

up to 9 % according to observations by ship owners. The environmental aspects that were quantified are: use

of energy and material resources, contribution to global warming potential (GWP), acidification potential (AP),

photochemical ozone creation potential (POCP) as well as human and marine toxicity. The Intersleek

systems reduce dependency on scarce resources, especially copper, and emissions of VOC, which are

important aspects when looking at the overall environmental impact of paints. Moreover, as the Intersleek

products are non-biocidal and do not selfpolish, a considerably lower amount of paint is required to coat the

vessel, leading to low emissions from the paint and lower toxic components to the environment. This

significantly reduces the predicted toxic load associated with the paint components to both humans and the

marine environment.

2. All the contracts not available.

CR05 is open based on the above mentioned point 2.


As noted in response to CR 2, we have provided complete set of documentation, summarized in “VPA 2

Contracts files and dates 3Dec17.xlsx”


VPA 2 Contracts files and dates 3Dec17.xlsx

Files as listed in above Excel, column G


All the contracts with the shipping companies and international paint are now made available to the DOE.

CR 05 is closed.

CR ID 06 Section no. E Date: 06/06/2017

Description of CR

Air quality: Evidences to support “Intersleek systems are inherently higher in volume solids and lower in

VOC compared to biocidal systems. Biocidal systems are typically 50-60% volume solids and 340 to 500

grams per litre VOC; Intersleek systems are >70% volume solids and <240 grams per litre VOC.

PP is requested to provide copy of the LCA study.

PP is requested to provide International Paint, “Eco-efficiency – a new tool to support better decisions on hull

coating investments”, Sept. 2010” and also Exo environmental analysis report as discussed in the VPA-

Passport.

Quality of employment: Evidences of the training provided to the ship owners/operators and to dry dock

workers. Also ongoing training evidences to PPs own staff around sustainable technologies, and the topics of

carbon and emission reductions resulting from improving fuel economy.

PP is requested to provide copy of the report from “Haifeng Wang, Economic costs of CO2 emissions

reduction for non-Annex I countries in international shipping. Energy for Sustainable Development, 14 (2010)

280–286”



Air quality. See detailed report: Eco-Efficiency Assessment. A comparative study of three fouling control

systems for marine vessels: 1. Intersleek 1100SR, 2. Intersleek 700, 3. Intersmooth 7460HS. VOC and

volume solids are given in Table 2. The report is cited in revised Passport. The report is in fact the LCA study.

The report “Eco-efficiency – a new tool to support better decisions on hull coating investments”, Sept. 2010”

is also attached. Besides the aforementioned general LCA analysis known as “Eco-efficiency assessment”,

Eco-efficiency reports for individual ships are included in Dropbox folder “2016DGMD23 files for GS VPA 2

inclusion”, subfolder “Ecoefficiency Report”

Quality of employment: Four training documents attached. These documents form part of the continuous

training process for International Paint employees located in different locations.

Haifeng Wang paper. Copy provided.


Air quality.

See folder “CR 5”, file: EEA Intersleek 1100SR_report_final_with review statement.pdf

See folder “CR 5”, file: ecoefficiencywhitepaper_sep10.pdf

Dropbox folder “2016DGMD23 files for GS VPA 2 inclusion”, subfolder “Ecoefficiency Report”

Quality of employment:

Carbon Credit Process Steps.pdf

Carbon Credits Webinar Revision 02.pdf

Data collection method.pdf

Dry docking procedure.pdf

Note: GS Passport will require minor changes based on this comment and response

Haifeng Wang paper:

Wang_ESD.pdf


1. Air quality: The documents “eco-efficiency, a new tool to support better decisions on hull coating

investment: , 09/2010” , “Eco-efficiency assessment by Akzonobel and reviewed by by IVL wedish

Environmental Research Institute “ and eco-efficiency reports for all the ships checked. RINA accepts the

justification provided by PP.

2. Quality of employment: Documents (Carbon Credit Process Steps.pdf, Carbon Credits Webinar Revision

02.pdf, Data collection method.pdf, Dry docking procedure.pdf) were checked. However, it is not clear if

these documents were part of the training. PP is requested to provide the minutes of the trainings conducted

and the list of the participants, who participated in the training as well as webinar.

3. Economic costs of CO2 emissions reduction for non-Annex I countries in international shipping by Haifeng

Wang checked and the same is accepted.

CR06 is open , based on the above mentioned point 2.


“Quality of employment” is one of the sustainable development parameters. As such, this parameter will

be included in the Monitoring Report, subject to verification. Therefore a FAR is requested for this point.

Taking into account other validation comments, VPA 2 Passport was revised.


International Paint VPA-2 Gold Standard Passport v3 30nov17 tracked.doc


2. RINA accepts that the quality of employment is a monitoring parameter and records of the same can be

made available by PP during the verification.

CR 06 is closed.

CR ID 07 Section no. F.1 Date: 06/06/2017

Description of CR


1. PP is requested to provide the data plan reports and antifouling certificates and inspection and testing

reports of each ship.

2. Evidences to cross check the built month and year of the ship. This was not transparent in the

website vessel finder.com

3. PP is requested to provide the eco-efficiency reports and LCA study.

4. PP is requested to provide the most recent IMO regulations “Guidelines on the method of calculation

of the attained Energy Efficiency Design Index (EEDI) for new ships.

5. Ship log records to confirm the fuel consumption.

6. Though the statistical model is not changed in this VPA, the methodology applicability requires the

project applicant shall bear the cost of a professional statistician contracted by The Gold Standard

Foundation for the validation of “the results of the regression analysis applied to the submitted project

activity in line with the model(s) provided in the methodology”.

7. PP is requested to provide the ODA declaration form.


Point 1. All Dataplan reports are uploaded in the Dropbox folder “2016DGMD23 files for GS VPA 2

inclusion”, subfolder “Intersleek application Dataplan reports” The list of file names is now attached:

“Dataplan report list.xlsx”. The table includes whether the Dataplan report includes a certification that the

coating is TBT free. Not all Dataplan reports include such a certification. However, all reports include a

detailed description of the coating materials used, and advanced coatings that comprise the project activity

(Intersleek 700, Intersleek 900 and Intersleek 1100SR) are standard products (with specifications indicated in

the PDD) and none of them contain TBT.

Point 2. True, standard internet sites (Vessel finder, Marine Traffic) only show year, not month. We do not

believe Newbuild dates are relevant to the project, except when the baseline coating was applied at

Newbuild. We have included Newbuild dates in the tab “Baseline” of file “VPA 2 Dataplan and baseline report

list 8jan18.xlsx”. The information on baseline coatings has also been completed in this revised Excel

workbook

Point 3. Ecoefficiency reports for each of 36 ships are provided in the Dropbox folder “2016DGMD23 files for

GS VPA 2 inclusion”, subfolder “Ecoefficiency Report”. Each Ecoefficiency report includes an LCA for the

application of the advanced coating compared to baseline coating. An explanation of how the Eco-analysis

works is provided in the PPT: “Walk_through presentation.ppt”

Point 4. The report “Resolution MEPC.215(63) Guidelines for Calculation of Reference Lines for Use With

The Energy Efficiency Design Index (EEDI)”, and the updated 2014 edition “Resolution MEPC.245(66) “2014

Guidelines on the Method of Calculation of the Attained Energy Efficiency Design Index (EEDI) for New

Ships”

Point 5. Detailed ship fuel consumption, both raw and processed to determine baseline and project

emissions will be provided with the Monitoring Report. The VPA DD provides ex ante estimates from the

Ecoefficiency analysis, which is based on a model of ship fuel consumption. See answer to Point 3 above.

Point 6. This requirement is included in the methodology, and indeed was noted in the Gold Standard

Registration Review for VPA 1. However, in our response to the Registration Review, GS clarified in writing

Aug. 19 [2015] and on Skype – “You may use the same statistician opinion document because you are using

the already validated model, which is part of the methodology. The DOE needs to confirm that the application

of the model on updated data is in line with the methodology requirement. This is to ensure that the

assessment approach is carried out in line with the methodology requirements and validated by the DOE.”

See GS document “GS3429_GS2767_Registration Review_Final.pdf” Comment/Request 3, item 10 (p. 5 of

document).

Point 7. Document provided: Annex D signed 24apr17.pdf



Point 1:

All Dataplan reports are uploaded in the Dropbox folder “2016DGMD23 files for GS VPA 2 inclusion”,

subfolder “Intersleek application Dataplan reports”

Point 2:

“Baseline” tab of file “VPA 2 Dataplan and baseline report list 8jan18.xlsx”.

Point 3:

“Intersleek” tab of “VPA 2 Dataplan and baseline report list 21jun17”, included in response to CR 7,

point 2.

Walk_through presentation.ppt

Point 4:

MEPC.215(63).pdf

MEPC 245(66).pdf

Point 5: No documentation at this time

Point 6:

GS3429_GS2767_Registration Review_Final.pdf, p. 5

Point 7:

Annex D signed 24apr17.pdf in Dropbox folder “2016DGMD23 files for GS VPA 2 inclusion”


1. Intersleek application data plan reports of the all the ships were checked. As discussed by PP, all the data

plan reports doesn’t include the certificate confirming that it is TBT free. However, it is clear from the reports

that costing material used were Intersleek 700, Intersleek 900 and Intersleek 1100SR and none of them

contain TBT.

2. Is open.

3.Eco efficiency report for all the 36 ships included in the VPA are checked and accepted.

4. Annex-5, Resolution MEPC 245(66), “2014 Guidelines on the Method of Calculation of the Attained Energy

Efficiency Design Index (EEDI) for New Ships” adopted on 04/04/2014 checked. Also Annex-11, Resolution

MEPC 215 (63)” Guidelines for calculation of reference lines for use with the Energy Efficiency Design Index

(EEDI)”, checked and the same was accepted.

5. The fuel consumption records are only to make sure that no biofuels are used. PP can justify the same

with any other evidences.

6.RINA confirms that that the PP has used a model, which is already validated and is part of the

methodology. The PP has applied the model on the updated data, which is in line with the methodological

requirements. As per the documents “GS3429_GS2767_Registration Review_Final.pdf”, GS has confirmed

that the PP can use the same statistician opinion document since the PP is using an already validated model.

7. ODA is provided in Appendix 2 of the VPA-DD, dated 27/10/2014.

CR07 is open based on the above mentioned points 2 and 5.


1. Closed

2. Complete documentation supporting baseline coating type and application date is now provided,

as summarised in “VPA 2 Dataplan and baseline report list 8jan18.xlsx”

3. Closed. Note, however, that an updated report “VPA 2 Dataplan and baseline report list

8jan18.xlsx” is being submitted.

4. Closed

5. As suggested by validator in phone clarification, the VPA DD has been revised to note the

following “Any use of biofuels in either the baseline or project period will be determined during

data analysis to be presented with the monitoring report.”

6. Closed

7. ODA dated 24/04/2017 is included in Appendix 2 of revised VPA DD


Item 2. Baseline coating information:

VPA 2 Dataplan and baseline report list 8jan18.xlsx lists the documentation for all ships.

Files as listed in column J of Excel document listed above.



2. From the websites, only the year of the build can be checked and not the month and day. The justification

provided by the PP is acceptable to RINA.

5. PP has confirmed that the bio fuel will be monitored during the verification period and accordingly

emissions would be detected in case it is used.

CR 07 is closed.


Description of CR

PP is requested to clarify with evidences s that with the advanced hull coating, the vessels will no undergo

underwater hull cleaning.

Provide the data on fuel consumption for the ships involved in the VPA.


Para 1. The methodology states:

Evidence needs to be provided to indicate (underwater) hull cleaning dates in the baseline period at

the time of registration for carbon credits, and records need to be kept to indicate underwater hull

cleaning during the project docking cycle, following the application of the advanced hull coating.

Ships that undergo hull cleaning in the project docking cycle while none occurred in the baseline

docking cycle can only claim emission reductions under this methodology up to the time of the hull

cleaning.

When we submit the ship performance data with the advanced hull coating (at the time of submission of the

Monitoring Report), we will analyze the situation of hull cleanings in baseline and project cycles.

Para 2. Detailed ship fuel consumption, both raw and processed to determine baseline and project emissions

will be provided with the Monitoring Report. The VPA DD provides ex ante estimates from the Ecoefficiency

analysis, which is based on a model of ship fuel consumption.


No additional documents for this CR.


1. The PP has confirmed to submit the records of hull cleaning in the baseline and project period at the time

of Monitoring report submissions. The same needs to be checked and confirmed during the verification.

2. PP has confirmed to submit the ship fuel consumption log records during the verification . The ER

calculations are calculated based on the ex-ante data available from the eco-efficiency reports.

CR08 is closed and FAR 1 is raised based on the above mentioned point 1.

FAR 1 PP has confirmed that Ships that undergo hull cleaning in the project docking cycle while none occurred in the baseline docking cycle can only claim emission reductions under this methodology up to the time of the hull cleaning. PP has confirmed to analyse the situation of hull cleanings in baseline and project cycles , and submit the same along with the ship performance data at the time of verification. The same needs to be checked during the verification.


Description of CR


Provide evidences for the values used in the file “Common_practice_test 31aug16 clean.xlsx”, also clarify,

why intersleek 970 and 1100SR not considered in the evaluation.

Not clear, if the ships considered in the common practice analysis have started the commercial operation

before the start date of the project.

PP is further requested to clarify Panamax Tanker, Passenger/ Ro-Ro, Ro-Ro /Cargo and pure car carrier is

referred to which category vessel of common practice analysis sheet.

Provide an independent, third party review of advanced hull coatings, published in Fathom (2013)


Para 1. Cell G4 of the Excel sheet states the column title as “Number of ships with Level 2 coating (Intersleek

900+1100)”. Section A.3 of the VPA DD states: “The advanced coatings applied comprise Intersleek 1100SR,

Intersleek 900 family (comprising Intersleek 960 and Intersleek 970) and Intersleek 700 family (specifically

Intersleek 757).” It should be understood that Intersleek 700 and 900 comprises families, while the only 1100

is 1100SR. Thus all advanced hull coatings were considered in the common practice test.

Para 2. Common practice analysis considers all ships in service, determined from Lloyds Register, which is

the most detailed shipping activity data base. International Paint has access to this data base, and compiled

the information. The analysis also uses the number of ships coated with Intersleek products, from IP own

statistics, and an estimate of application of competitor products from industry data bases and trade

publications.

Para 3. The common practice analysis considers certain grouping of ships. However, certain groups may be

subdivided into more finer categories. Thus the common practice analysis considers tankers as a single

group. However, tankers are often divided by size. Thus Panamax is the largest size that can fit through the

Panama canal. This detailed classification is provided in the listing of ships included in the VPA. However, the

common practice analysis is based on the broader categories as defined in the Lloyds Register data base.

Para 4. Document provided: “Fathom Hempel com MGM.pdf”


Paras 1 to 3: no documentation provided.

Para 4:

Fathom Hempel com MGM.pdf


1. The documents “Lloyds Vehicle Count, 2016. See file "VesselCountLloyds31Aug2016.xlsx" and “Number

of ships coated with Intersleek 700, Intersleek 900, Intersleek 1100 from International Paint, see "IP Vessel

Count by Year_2015 calc MGM.xlsx” checked. RINA confirms that the intersleek 900, 700 and 1100 were

used in the common practice analysis test . However, it is noted that for the sheet 2 of the excel file “IP

Vessel Count by Year_2015 calc MGM.xlsx”, the intersleek 1100SR counts from E14 to E35 is not consistent

with counts provided in the row 5 .Please clarify.

2. Noted that the PP has considered the ships before the start date of the project as well as after the start

date, which is more conservative. Hence accepted.

3. Justification provided by PP is accepted.

4. Hull coating for vessel performance by Fathom , marine energy and environment, checked.

CR09 is open based on the above mentioned point 1.


1.There was a transcription error in the file, which has now been affected in “IP Vessel Count by Year_2015

calc MGM_corr 29aug17.xlsx” The file name has been changed in the revised VPA DD. The correction does

not affect any calculations, hence does not affect the outcome of the common practice test.

2.Closed

3.Closed

4.Closed


IP Vessel Count by Year_2015 calc MGM_corr 29aug17.xlsx



1. Revised excel sheet “IP Vessel Count by Year_2015 calc MGM_corr 29aug17.xlsx” checked and the

same is closed now.

CR09 is closed.

CR ID 10 Section no. F.5.1 Date: 06/06/2017

Description of CR

PP is requested to provide the ER spread sheets for each ships and the supporting evidences.

VPA is not clear on how the project emissions are accounted.


The ex ante estimates of emissions reductions are based on the Eco-efficiency analysis for each ship. See

response to CR 7, item 3 and Walk_through presentation.ppt, which explains the Eco-efficiency analysis. The

results are the basis for the estimation of ERs for the project period as summarized in the VPA DD. The

background analysis can be found in “VPA 2 vessels data summary 30mar2017.xlsx”

Ex-ante estimates of project and baseline emissions were determined from estimations of fuel consumption,

in the Eco-efficiency analysis for each ship. Ex post analysis would be based on monitored data covering the

baseline and project periods. These data and analysis would be submitted with the first Monitoring Report.


See Dropbox folder “2016DGMD23 files for GS VPA 2 inclusion”, subfolder “Ecoefficiency Report”,

which includes the analyses for each ship

VPA 2 vessels data summary 30mar2017.xlsx


RINA accepts the justification provided by PP. The ER calculation ex-ante are calculated by means of the

values available in the eco-efficiency reports. The values provided for estimate of CO2 emissions from fuel

savings, denominated “Off-shore Global Warming Potential are available for each ship in there eco-efficiency

reports. Using the assumed docking cycle for each, and using the known date for application of the advanced

hull coating, the end of the docking cycle for each ship is estimated. During this period, emissions reductions

per year are determined from the annual average of the difference in “Off-shore Global Warming Potential”

using the Biocidal coating (baseline) and advanced hull coating (project). Partial years, at the start and end of

the docking cycle for each ship, are determined by pro-rating annual emissions. This was checked with “VPA

2 vessels data summary 30mar2017.xlsx” and accepted.

CR 10 is closed.

CR

ID

11 Section no. F.6.1 Date: 06/06/2017

Description of CR


1. PP is requested to provide evidences of the baseline coating date for the ships included in this VPA.

2. PP is requested to provide evidences of the baseline coating material for all the 36 ships included in this VPA.

3. PP is requested to provide the hull cleaning (underwater) dates in the baseline period with supporting

evidences and also for the project period is any.

4. Date on which the advanced coating application is finished on ship (j). The data is available from the coating

manufacturer. PP is requested to provide evidences for the same.

5. PP is requested to provide the evidences of the advance coating material specifications and the test

certificates.

6. PP is requested to provide the ship log records to confirm the usage of main engine fuel. Further provide the

fuel purchase invoices to confirm the type of the fuel.

7. PP is requested to provide the ship log records to confirm the usage of auxiliary engine fuel. Further provide

the fuel purchase invoices to confirm the type of the fuel.

8. PP is requested to provide third party evidences to confirm that no engine or other modifications undertaken at

the same time as the application of advanced hull coating.

9. PP is requested to provide records for the Voyage data for ships operating on shorter voyages or on long

routes, which includes (Date, Daily distance (clarify the measurement procedure), Daily streaming time

(hours), Average daily speed through water since last daily record (Knots), Sea state (Beaufort number),

Vessel condition (ballast/loaded or displacement) , Fuel consumption of the main engine since last daily

record (tonnes), Daily fuel consumption of the auxiliary engine(s) since last daily record (tonnes) : clarify the

fuel flow meter records, measurement procedures and the calibration frequency of flow meters) and (Date of

voyage start and end, Distance between departure port and arrival port (nautical miles), Voyage time (hours),

Average navigation speed during voyage (Knots), Sea state (Beaufort number), Vessel condition of ship at the

time of data recording (Ballasts/Loaded or displacement), Fuel consumption of the main engine for navigation

part of voyage (tonnes), Fuel consumption of the auxiliary engine for navigation part of voyage (tonnes))



We have converted bullet points into a numbered list, above, for ease of reply.

Point 1: we have some evidence documents at present, however have requested the remainder be obtained from the

vessel owners. We will provide all of this information to the DOE as soon as possible. (Pending completion.)

Point 2: as in point 1, we propose to provide this information as soon as possible. (Pending completion.)

Point 3: as in points 1 and 2, we propose to provide this information as soon as possible. . (Pending completion.)

Point 4: evidence of advanced hull coating application is provided in the Dataplan report for each vessel.

Point 5: The advanced coatings applied comprise Intersleek 1100SR, Intersleek 900 family (comprising Intersleek 960

and Intersleek 970) and Intersleek 700 family (specifically Intersleek 757).

Product specifications can be found as follows:

Intersleek 757 http://www.international-marine.com/PDS/147-M-eng-A4.pdf

Intersleek 970 http://www.international-marine.com/PDS/3782-M-eng-A4.pdf

Intersleek 1100SR http://www.international-marine.com/PDS/10084-M-eng-A4.pdf

Point 6: ship logs for each vessel, which will confirm the usage of the main engine fuel, will be provided for verification

together with the Monitoring Report. Thereafter, it is requested that the DOE can please perform a spot check

assessment to indicate which fuel purchase invoices from select ships it wishes to review as evidence.

Point 7: ship logs for each vessel, which will confirm the usage of the auxiliary engine fuel, will be provided for

verification together with the Monitoring Report. Thereafter, it is requested that the DOE can please perform a spot

check assessment to indicate which fuel purchase invoices from select ships it wishes to review as evidence.

Point 8: the dataplan reports, prepared over the drydock period during which each vessel is having the advanced hull

coating applied contain a day-by-day summary of any activities carried out during that drydock. These dataplan reports

for the 36 vessels in VPA 2 confirm that no engine or other modifications were carried out at the same time as the

application of the advanced hull coating.

Point 9: all of the information requested in this point will be provided during verification together with the Monitoring

Report and individual vessel analysis documents.


1 and 2. The evidence on baseline coating material and application date is summarised in the tab “Baseline” of the file

“VPA 2 Dataplan and baseline report list 8jan18.xlsx”

Points 3 and 4: The Dataplan reports documenting the application of the advanced hull coating for each ship have

been provided. All Dataplan reports are uploaded in the Dropbox folder “2016DGMD23 files for GS VPA 2 inclusion”,

subfolder “Intersleek application Dataplan reports”. Page 2 of each Dataplan report includes a section as illustrated

above, which indicates whether the ship was underwater cleaned in the docking cycle prior to the application of the

advanced hull coating. For all ships in VPA 2, the reports note “NO” as in the example below.

5,6,7 8, and 9: No attachments



1, 2 and 3 : are open.

4.The data plan report for all the vessels checked. However, the files for Cardiff Marine: Solana, Expedo: new

conquest could not be opened. Further the dates for MESM Kahla is not consistent with the Data plan report.

5. The coating material was checked from the data plan reports and the product specifications were checked from the

website links (http://www.international-marine.com/PDS/147-M-eng-A4.pdf, http://www.international-

marine.com/PDS/3782-M-eng-A4.pdf and http://www.international-marine.com/PDS/10084-M-eng-A4.pdf provided

by PP. The same was accepted by RINA.

6. Since the fuel consumption details are used during ex-post verification. PP has confirmed to provide the details of

the same at the time of verification. The same was accepted by RINA.

7. Same as above justification.

8. The summary of day by day activities performed during the dry dock was checked with data plan reports and

confirmed that no energy efficiency activities were carried out at the time of advanced hull coating.However, it needs to

be ensured that the ship dint undergo engine overhaul or replacement, or any other modification that would reduce its

fuel consumption at any time during the docking cycle for which carbon credits are being claimed. The same needs to

be checked during verification.

9. The details and evidences requested will be used by PP at the time of verification. Since the same is ex-post

parameters, RINA accepted the justification provided by PP.

CR11 is open, based on the above mentioned points 1,2,3 and 4.

FAR 2 is raised based on the above mentioned point 8.


1. Baseline coating date. As noted in response to CR 7, we have provided complete documentation supporting

baseline coating type and application date is now provided, as summarised in “VPA 2 Dataplan and baseline

report list 8jan18.xlsx”

2. Baseline coating material. The Excel file noted in point 1 above also includes information on the baseline

coating material (col. H of Excel sheet “Baseline”), with additional supporting information, e.g. coating

specifications in col. L.

3. In the revised VPA DD, we have noted the following “At this time, data from project period have not been

received nor analysed. If there are any underwater cleaning in the project period, carbon credits may be

limited as indicated in the methodology, and copied in the left column”

4. Corrected files for Dataplan report for Cardiff Marine Solana is attached. The ship “Expedo New Conquest”

has been removed from revised VPA. The Intersleek coating date for MESM Kahla has been corrected in the

VPA DD and the Passport (the date is not mentioned in the LSC report). The Excel file of emissions

reduction has also been corrected. However, the change of date did not affect creditable ERs, since the data

changes pertains to a period before the retroactive crediting date.

5. Closed

6. Closed

7. Closed

8. Has been noted as FAR.


1. VPA 2 Dataplan and baseline report list 8jan18.xlsx; files listed in column J are attached.

2. Same as for item 1 above.

3. Revised VPA DD

4. Corrected Dataplan reports for Cardiff Marine Solana.






1.Evidences for the baseline coating dates checked. Noted that following:

Was not able to cross check the baseline coat application dates for the vessels Botafogo, Corrossol,

Scorpio and Laurin Maritime.

For Okinetio the date mentioned is 05/07/2010, Bouzas is is 22/08/2007, Galicia is 12/06/2008, Euro

cargo Genova is November 2009 to March 2010. Grande Sierra Leone is December 2010 to March

2011, Republica Argentina 20/07/2010,DK ione is 10/06/2010, which is not as per the dates

mentioned in the VPA 2 Dataplan and baseline report list 8jan18.xlsx.

2.Evidences for baseline coating material and specifications checked with the manufacturer’s website, certificates and

data plan reports.

3.Data plan report checked . Noted that vessels were not underwater cleaned in the docking cycle prior to the

application of the advanced hull. Further PP has confirmed that if there are any underwater cleaning in the project

period, carbon credits may be limited as indicated in the methodology, and copied in the left column”

4. Please correct the Intersleek coating date for MESM Kahla to 08/04/2014 instead of 04/08/2014, both in the VPA

DD and the Passport

CR 11 is open based on the above mentioned points 1and 4.



1. Baseline coating dates

The baseline coating reports for Botafogo, Corossol, and Scorpio (all of Cardiff Marine) and Laurin Maritime

Cavatina give coating specifications, but not the date. For each of these ships, the coating was applied at new

build. The evidence that the three Cardiff Marine ships were newbuild is listed in the following paragraph. For

Laurin Maritime Cavatina, it is in the next paragraph.

Cardiff Marine ships Botafogo, Corossol and Scorpio. The shipbuilding company website

(http://www.chinasws.com/component_product_center/index.php?typeid=10) lists the ships and gives launch

dates. The data are highlighted in the file “Cardiff Marine newbuild Corossol Botafogo Scorpio com MGM.pdf”

The dates noted for the three ships are: Botafogo (26/01/2010); Corossol (05/02/2010); and Scorpio

(19/03/2009). The dates for Botafogo and Corossol had a one-day discrepancy with values reported in the

summary table. The dates as noted above are shown in the revised summary table: VPA 2 Dataplan and baseline

report list 8jan18.xlsx, sheet “Baseline”. The changed values are highlighted.

Laurin Maritime Cavatina: The shipbuilder indicated the ship was completed in 2009

(http://www.brodotrogir.hr/en/index.php/shipbuilding/reference-list), while

https://www.marinetraffic.com/en/ais/details/ships/shipid:754710/imo:9343209/mmsi:636014408/vessel:CAVA

TINA notes that the year built was 2010. A press release by Laurin Maritime

(http://www.laurinmaritime.com/news/mt-cavatina-has-been-delivered-trogir-shipyard) indicates that the

delivery date was Jan. 5, 2010. We have therefore revised the date by one day in sheet “Baseline” of “VPA 2

Dataplan and baseline report list 8jan18.xlsx”. We have also provided a revised explanation on the new build

date in a footnote to the sheet.

Intergis Shipping DK Initio and DK Ione: there appear to be small discrepancies in the dates reported by the

shipping company to us, and the dates appearing in the baseline coating reports. In each case, the dates reported

by the shipping company, and summarized in “VPA 2 Dataplan and baseline report list 8jan18.xlsx”, are about a

week after the dates reported in the coating reports. The methodology defines the date to be the day on which

the ship leaves the dry dock, i.e. the last day of drydocking. The shipping company provided us this “launching

date” in a response to a set of queries made in March 2017 (See highlighted text in “Intergis Shipping

responses.pdf”.) The discrepancy is likely to be because the coating report notes the day of arrival at the drydock.

Therefore we have chosen the latter date in each case.

Flota Suardiaz Bouzas: we had assumed a mid-month date (15/8/2007) since we only had the month in the then-

available data. The baseline date has now been corrected to the baseline report date (22/8/2007).

Flota Suardiaz Galicia: we have inserted comments to the baseline coating report “Flota Suardiaz Galicia Jun

2008 com MGM.pdf” indicating that the baseline coating date is 11/06/2008. Previously, we only had information

on the month, and had assumed mid-month. We have modified the baseline date accordingly in “VPA 2 Dataplan

and baseline report list 8jan18.xlsx”

Grimaldi Eurocargo Genova: The file submitted earlier “Grimaldi Baseline coating _ Eurocargo Genova.pdf” does

not correspond to the 2011 baseline coating application. We are submitting the correct baseline coating report

(Dataplan report) “Grimaldi Eurocargo Genova Jun 2011 com MGM2.pdf” which is also commented to indicate

that coating date is 07/06/2011, as indicated in sheet “Baseline” of “VPA 2 Dataplan and baseline report list

8jan18.xlsx”

Grimaldi Grande Sierra Leone: the shipping company had informed us that the ship was delivered in June 2011.

Without additional information, we had earlier assumed mid-month, However, we have now found a source

“Grimaldi Grande Sierra Leone delivery news com MGM.pdf” which gives the date to be July 1, 2011. We have

modified the baseline date accordingly in “VPA 2 Dataplan and baseline report list 8jan18.xlsx”

Grimaldi Repubblica Argentina: the baseline application date has been corrected to 14/02/2012, instead of

15/02/2012.

2. N.A.

3. N.A.

4. Thank you for noting the error. The date change affected not only the VPA DD and Passport, but also the LSC Report

and the spreadsheet for calculating emissions reduction (ER). (The potentially creditable ER values were not affected,

since the date change is prior to the retroactive limit.)


https://www.marinetraffic.com/en/ais/details/ships/shipid:754710/imo:9343209/mmsi:636014408/vessel:CAVATINA

https://www.marinetraffic.com/en/ais/details/ships/shipid:754710/imo:9343209/mmsi:636014408/vessel:CAVATINA


1. The following files:

Cardiff Marine newbuild Corossol Botafogo Scorpio com MGM.pdf

Intergis Shipping responses.pdf

Intergis Shipping DK Ione DK Initio newbuild report spp3_e_brochure com MGM.pdf

Grimaldi Eurocargo Genova Jun 2011 com MGM2.pdf

Grimaldi Grande Sierra Leone delivery news com MGM.pdf

VPA 2 Dataplan and baseline report list 8jan18.xlsx

2. The following files were corrected with a new date in the file name, but maintaining version 3, since the changes are very

minor:

International Paint VPA-2 DD v3 18dec17 tracked.doc

International Paint VPA-2 Gold Standard Passport v3 18Dec17 tracked.doc

IP Hull Coating VPA-2 LSC Report v3 18dec17 tracked.docx

VPA 2 vessels data summary 18Dec2017.xlsx


1. Evidences for the baseline coating dates checked. Noted that following:

Furher evidences for baseline coat application dates for the vessels Botafogo, Corrossol, Scorpio and

Laurin Maritime provided. Checked and accepted

For Okinetio, Bouzas, Galicia, Euro cargo Genova, Grande Sierra Leone, Republica Argentina,DK ione, the

dates are corrected in the updated excel sheet “VPA 2 Dataplan and baseline report list 8jan18.xlsx”.

4. Intersleek coating date for MESM Kahla corrected to 08/04/2014 instead of 04/08/2014, both in the updated VPA

DD and the Passport.

CR 11 is closed and the following FAR is raised.

FAR 2 The summary of day by day activities performed during the dry dock was checked with data plan reports and confirmed that no energy efficiency activities were carried out at the time of advanced hull coating. However, it needs to be ensured that the ship dint undergo engine overhaul or replacement, or any other modification that would reduce its fuel consumption at any time during the docking cycle for which carbon credits are being claimed. The same needs to be checked during verification.

CR ID 12 Section no. F.6.2 Date: 06/06/2017

Description of CR

The VPA-DD is not transparent on the following:

1. QA/QC procedures.

2. Uncertainty levels, methods and the associated accuracy level of measuring instruments to be used

for various parameters and variables.

3. calibration frequency for the measuring equipment.

4. The operational and management structure to be put in place to implement the monitoring plan.

5. Definition of responsibilities and institutional arrangements for data collection and archiving



We have converted bullet points above into a numbered list, for ease of reply:

Points 1, 4 and 5:

The person responsible for administering the tasks within the management plan is the Foul Release Segment

Manager, Marine Marketing, International Paint Ltd. This position is currently held by Dr. Richard Towns. In

certain technical aspects, the Manager will be supported by PoA/VPA development consultants. For the PoA

and VPAs thereunder, this consultancy is being undertaken by FReMCo and MGM Innova.

The competencies and roles of the three companies are summarized below:

International Paint, part of AkzoNobel’s Performance Coatings division, is a leading provider of marine and

protective coatings. Within the carbon project, International Paint is the interface with its vessel owner

customers, and the liaison for FReMCo and MGM via which the vessel data is received. Again having been

involved in the carbon project since even before the GS methodology approval, International Paint is very

familiar with all aspects of the project. Moreover, as required by the Gold Standard methodology,

International Paint has agreements with all participating shipping companies, who provide required data for

analysis for the ships included in each VPA under the PoA approved by the Gold Standard (Gold Standard

ref: GS 3492).

MGM Innova is a multinational corporation that specializes in the design, development and implementation

of innovative solutions to help clients incorporate sustainable and low carbon practices in their products,

services, overall business strategy and operations. Having worked on more than 400 projects in 35 countries

around the world, MGM Innova offers unparalleled expertise in generating the solutions required to enable its

clients to build a sustainable business and to mitigate and adapt to the effects of climate change.

The FReMCo Group, founded in 1981, is an industry leading business consultancy with 30 years’ experience

in the environmental arena and carbon credit field. FReMCo’s strategies have improved the financial results

of some of the world’s largest and most successful companies, and it has been involved in a wide variety of

projects around the globe. FReMCo has significant experience in all aspects of the carbon credit area, and

has specific expertise in mobile source projects.

FReMCo and MGM were instrumental in the development of the GS advanced hull coatings methodology,

the Programme of Activities and first Voluntary Project Activity thereunder. Our team has been working on

this project with International Paint since 2009, and is very familiar with all aspects of the project. The

management plan within the PoA and subsequent VPAs was developed in conjunction with International

Paint, to safeguard robust and transparent transfer of data and to ensure compliance with all necessary

procedures outlined within the methodology and PoA. In 2015, FReMCo and MGM won global awards for the

Best Offsetting Project and Best Project Developer – Energy Efficiency in the Environmental Finance survey

of its peers.

Additional supporting documents are:

General Vessel Data Collection Method. Data collection method.pdf

Management System. Project Management System 29jun17.pdf

Points 2 and 3

These refer to instrument accuracy and calibration. The main parameter used in the determination of

emissions is fuel consumption. Ex-ante estimates of baseline and fuel consumption were based on the Eco-

efficiency analysis. For ex-post measurements, fuel consumption data would depend on fuel flow meters in

use. Models of fuel flow meters and their specifications will be provided together with the measured data, in

the first Monitoring Report.

The independent variables used in the regression model and for determining baseline emissions from

measured project data are days from sailing and ship speed. Ship speed is speed over ground, which is

determined accurately from ship location (GPS) and clocks which are accurate.



Points 1, 4 and 5:

Data collection method.pdf

Project Management System 29jun17.pdf


1, 4 and 5: QA/QC procedures, The operational and management structure to be put in place to

implement the monitoring plan and Definition of responsibilities and institutional arrangements for

data collection and archiving were checked with documents General Vessel Data Collection

Method and Project Management System 29jun17. The same was accepted by RINA.

2 and 3: PP has confirmed to provide the details at the time verification. The Uncertainty levels,

methods and the associated accuracy level of measuring instruments to be used for various

parameters and variables and calibration frequency of the measuring equipment’s to be detailed in

the monitoring report and the DoE needs to check the same at the time of verification. The same

was accepted.

CR 12 is closed.

Table 1. FAR from this validation

FAR ID 01 Section No. F.2 Date: 08/01/2018

Description of FAR

PP has confirmed that Ships that undergo hull cleaning in the project docking cycle while none occurred in the baseline docking cycle can only claim emission reductions under this methodology up to the time of the hull cleaning. PP has confirmed to analyse the situation of hull cleanings in baseline and project cycle , and submit the same along with the ship performance data at the time of verification. The same needs to be checked during next verification.

CME response Date: DD/MM/YYYY


DOE assessment Date: DD/MM/YYYY

FAR ID 02 Section No. F.6.1 Date: 08/01/2018

Description of FAR

The summary of day by day activities performed during the dry dock was checked with data plan reports and confirmed that no energy efficiency activities were carried out at the time of advanced hull coating. However, it needs to be ensured that the ship dint undergo engine overhaul or replacement, or any other modification that would reduce its fuel consumption at any time during the docking cycle for which carbon credits are being claimed. The same needs to be checked during verification.

CME response Date: DD/MM/YYYY


DOE assessment Date: DD/MM/YYYY