Further consideration of the revision of the IMO Ship Fuel Oil Consumption Data Collection System (DCS)
This document comments on proposals to amend the IMO DCS, and recommends support for disaggregating reporting of fuel use when ships are underway and at rest, for different fuel consumers (main propulsion engines, auxiliary engines and boilers) and to index emissions to cargo carried in preference to nominal capacity.
It is also critical that the metrics used to quantify cargo carried must recognize that different ship types are designed for different cargo parameters, at a high level this can be divided into those ships which carry volume and those which carry weight. There are also ship types which do not carry cargo. For container ships use of "TEU-miles" is recommended as the most appropriate measure of cargo carried.