(L to R): George Teriakidis, area manager East Mediterranean & Black Sea, DNV; Dimitrios Mattheou, CEO, Arcadia Shipmanagement; and Ioannis Chiotopoulos, senior vice president, regional manager SE Europe, Middle East & Africa, DNV (source: DNV)
Following revised guidelines at IMO MEPC 78, internationally trading ships of 5,000 gt or greater will be required to have a verified SEEMP onboard before 31 December 2022
IMO’s ambitious agenda to reduce greenhouse gas (GHG) emissions from shipping took centre stage at MEPC 78, with one of the key topics being amendments that revised the guidelines for the Ship Energy Efficiency Management Plan (SEEMP).
Any ships of 5,000 gt or greater that trade internationally, except passenger ships, are required to have a verified SEEMP onboard before 31 December 2022 to reduce carbon emissions. These ships must calculate a Carbon Intensity Indicator (CII) with a required rating of C or better. Any ships not meeting this rating will have to improve their carbon intensity.
Classification societies weighed in on the new revised guidelines. DNV describes SEEMP Part III as a dynamic ship-specific document, which is a regularly updated plan describing how a vessel will achieve the required CII over the next three years. The plan sets yearly targets, procedures for self-evaluation and improvement, and a corrective action plan in case of an inferior rating.
Noting the tight year-end deadline to file a verified and approved SEEMP Part III, plan, Lloyd’s Register’s lead regulatory specialist Abhijit Aul said: “The sooner you act, the better it is. The next few years are going to be crucial.”
Speaking during an LR webinar, Mr Aul reminded shipowners and operators that with SEEMP Part III, they must devise a concrete plan for reducing carbon emissions. This would be followed by self-evaluation and a constant review of whether the targets are on track and will be met in the prescribed timeline.
He said it is inevitable that some ships will not achieve the minimum CII requirements and will end up with ratings of D or E. Such ships will have their SEEMP Part III reviewed to include a corrective plan to achieve the required CII. Remedial actions are needed to achieve at least a C rating for the calendar year following the adoption of the corrective plan.
“The sooner you act, the better it is”
On the various proposals for correction factors, Mr Aul said: “If they didn’t make it this time, it doesn’t mean they have been disregarded. For many of them, it just means that the evidence they provided at the time wasn’t sufficient or there wasn’t sufficient time to consider these correction factors in detail. For a number of these correction factors or voyage adjustments, there is a very strong appetite to push the case to gather more evidence to submit to MEPC. It could take a year, it could take years, but we expect to see a number of discussions.”
LR regional advisory services manager Douglas Raitt, said LR can help shipowners and operators by drawing up the three-year implementation plan to achieve the company’s targeted CII, review and update SEEMP Part I and II and provide vessel-specific analysis for improving operational CII.
Besides strategising for reduced carbon emissions, Mr Raitt said that shipowners and operators should also take the resulting future capital and operating expenditure into consideration, with regards to chosen energy efficiency measures, to remain in compliance.
He elaborated: “You have to think, ‘what speed reduction is required to achieve a 5, 10, 15% improvement in the annual efficiency ratio rating?’ It allows the operator to project improvements over a number of years, understand when certain improvements need to be implemented, potentially even budget the implications of capex and opex decisions that need to be made on a variety of ships over the next few years to maintain compliance.
“Once you understand the percentage reductions that you require to maintain compliance with the CII requirements and targets, then you can map out what energy efficiency to achieve and more importantly, phase in over the next few years to remain in compliance,” he said.
These steps can be operational in nature, such as speed reductions, frequent hull cleaning, propeller polishing … all the way to the application of energy-efficient technologies which can allow for a certain percentage of improvement.
Shipowners and operators have to reduce the CII by at least 2% annually to remain in compliance. Mr Raitt encourages “robust” discussions with energy-saving device manufacturers to meet the target, more so for shipowners and operators who want to achieve an A or B banding.
“CII will require more of the shipping industry in terms of data collection and sharing”
Mr Raitt said: “To get SEEMP going now, articulate what that strategy might be [and] get a handle on realistic percentages in improvements. Not all ship types are the same. Not all trading patterns are the same, so there’s a level of detail that needs to be understood by owners and operators.”
First SEEMP Part III verified
Within a month of the approval of the revised guidelines at MEPC 78, DNV presented Athens-based Arcadia Shipmanagement with a certificate recognising its 115,837-dwt crude oil carrier Aegean Myth as the first vessel globally to have aSEEMPIII manual. A verifiedSEEMPPart III must be kept on board from 1 January 2023.
Arcadia Shipmanagement chief executive Dimitrios Mattheou said: “Initiatives like this broaden the values of safety and environmental excellence by implementing effective management systems to comply with incoming regulations to consistently achieve reliable and environmental incident-free performance. This approval by DNV marks the first milestone for smooth compliance with IMO’s requirements.”
DNV Maritime senior VP and regional manager for SE Europe, Middle East and Africa, Ioannis Chiotopoulos, said: “[That we] have been able to complete theSEEMPPart III preparation and approval so quickly after MEPC shows great teamwork and the effectiveness of our new digital tools. The CII will require more of the shipping industry in terms of data collection and sharing.”
