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Latest developments on SEEMP Part III & CII

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Carbon Intensity Indicator, CII, introduced by IMO, is a short-term measure to reach a target of 40% reduction in CO2 emissions by 2030. It was decided during the MEPC 75 meeting that the ships with more than 5000 GT have to report their annual attained carbon intensity to the Flag Administration. Based on the CII value, a rating will be assigned to each ship that will determine the performance of the ship and consequently, its viability.

During MEPC 76, IMO adopted the CII regulation and revised Marpol Annex VI but till MEPC 77, there were no clear guidelines ON how to monitor, calculate or prepare to comply with this regulation. Much awaited MEPC 78 gave a definitive approach to ship owners on the upcoming regulation of CII.

From 2023, there will be three parts of SEEMP that a company has to maintain:
  • SEEMP Part I: SHIP MANAGEMENT PLAN TO IMPROVE ENERGY EFFICIENCY (to be maintained by ships more than 400 GT; related to EEOI and other voluntary measures the company is taking to improve its operational efficiency)
  • SEEMP Part II: SHIP FUEL OIL CONSUMPTION DATA COLLECTION PLAN (to be maintained by ships more than 5000 GT; related to IMO DCS data monitoring and reporting to the administration)
  • SEEMP Part III: SHIP OPERATIONAL CARBON INTENSITY PLAN (to be maintained by ships more than 5000 GT; related to calculation of CII and implementing measures to reduce it)
It is strongly encouraged to revise the SEEMP Part I and reflect on the actions taken to achieve the CII requirements when preparing SEEMP Part III. The scope of CII and SEEMP Part III remains the same as SEEMP Part II, i.e, it applies to ships with more than 5000 GT.

As per regulation 26.3.1 of MARPOL Annex VI,  a ship operator has to prepare SEEMP part III which should describe the following:
  • A methodology that will be used to calculate the ship's attained annual operational CII.
  • The required annual operational CII
  • An implementation plan documenting how to achieve the required annual operational CIIs during the next three years.
  • A procedure for self-evaluation and improvement
Part III of the ship’s SEEMP should be updated in case of voluntary modifications or necessary corrective actions are involved (every three years). If a ship achieves an attained operation CII rating of “D” for three consecutive years or “E” for one year, then the company has to come up with a corrective action plan which will then have to be approved by Flag Administration or ROs approved by the Flag Administrations.

The timeline to prepare the SEEMP Part III and subsequent approval by Flag Administration is December 31st, 2022.

From January 01, 2023, the IMO DCS data monitoring should start. From 2024, the IMO DCS data along with the attained and required CII will be verified. From 2024, the IMO DCS SoC will have the annual operating CII rating mentioned on it.

MEPC 78 did not bring anticipated good news, especially for the cruise lines, as most of the correction factors proposed, such as voyage adjustment due to bad weather, waiting time, and voyage adjustment for short voyages (less than 72 hours), etc, got rejected.

On the other hand, tankers stood out as the most beneficial category after the correction factors, such as voyage adjustments for shuttle tankers, for STS voyages, boiler fuel consumption for cargo heating, etc. got approved. 

The update in the methodology to calculate the attained CII is the inclusion of correction factors and voyage adjustment factors which are as follows:

Correction factors:
  • 𝑓𝑖 is the capacity correction factor for ice-classed ships
  • π‘“π‘š is the factor for ice-classed ships having IA Super and IA
  • 𝑓𝑐 represents the cubic capacity correction factors for chemical tankers
  • 𝑓𝑖,𝑉𝑆𝐸  represents the correction factor for ship specific voluntary structural enhancement
 Fuel adjustments:
  • Fuel Adjustment for distance traveled through the ice, endanger the safe navigation of the ships (𝑭π‘ͺπ’—π’π’šπ’‚π’ˆπ’†,𝒋)
  • Fuel Corrections for Shuttle Tankers or STS voyages on tankers (TFj )
  • Fuel Corrections relating to electrical power used for reefer containers, cargo cooling for Gas, LNG Carriers, discharge pumps (𝑭π‘ͺπ’†π’π’†π’„π’•π’“π’Šπ’„π’‚π’,𝒋 )
  • Fuel Corrections relating to Boiler Fuel Consumption for cargo heating, cargo discharge (𝑭π‘ͺπ‘©π’π’Šπ’π’†π’“,𝒋)
  • Fuel Corrections relating to other related fuel consumption devices such as standalone engine-driven cargo pumps during discharge operation of tankers (𝑭π‘ͺ𝒐𝒕𝒉𝒆𝒓𝒔,𝒋 )
In case the above voyage exclusion or correction factors are applied, the ship should still report total fuel oil consumption (t) of each type of fuel, total hours underway (h), and total distance travelled (nm) to the Administration pursuant to regulation 27 of MARPOL Annex VI.

- Shubham Jain, EU MRV / IMO DCS Manager Back to all Verifavia Shipping News
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