ClassIBS

In January 2013, a new Chapter 4 was added to MARPOL Annex VI, providing regulations on energy efficiency for ships. After later amendments, the goal of chapter 4 of MARPOL 73/78 Annex VI, is to reduce the carbon intensity of international shipping, working towards the levels of ambition set out in the Initial IMO Strategy on reduction of GHG emissions from ships.

IMO MEPC 76° (From June 2021) adopted new amendments to MARPOL Annex VI, aimed to reduce ship’s greenhouse gas emissions, including technical and operational measures requiring all ships to calculate their Energy Efficiency existing ship Index (EEXI) and to calculate their Annual Operational Carbon Intensity Indicator (CII), to determine operational carbon intensity rating to improve the energy efficiency of ships.

Regulation 26 requires that a Ship Energy Efficiency Management Plan (SEEMP) be kept on board each ship. Further amendments to MARPOL Annex VI, adopted at MEPC.346(78) – 2022, Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP), establish that in the case of a ship of 5,000 gross tonnage and above, the SEEMP shall include a description of the methodology that will be used to collect the data required by regulation 27.1 of MARPOL Annex VI, and the processes that will be used to report the data to the ship’s Administration (SEEMP Part III). Not later than January 1, 2023, a ship of 5,000 gross tonnage and above, which falls into one or more of the categories in regulations 2.2.5 (bulk carrier), 2.2.7 (combination carrier), 2.2.9 (containership), 2.2.11 (cruise passenger ship), 2.2.14 to 2.2.16 (gas carrier, general cargo ship, LNG carrier), 2.2.22 (refrigerated cargo carrier), and 2.2.26 to 2.2.29 (ro-ro cargo ship, ro-ro cargo ship (vehicle carrier), ro-ro passenger ship, tanker), shall amend and review its SEEMP to include the methodology and details required by regulation 28 of MARPOL Annex VI.

As such, the SEEMP has to be developed in three parts, as described below:

Part I – ship management plan that provides a possible approach for monitoring ship and fleet energy-efficiency performance over time and describe ways to improve the ship's energy efficiency performance and carbon intensity, applicable to ships of 400 GT and above engaged on international voyages.

Part II – this part provides a description of the methodologies that should be used to collect the data required pursuant to regulation 27 of MARPOL Annex VI and the processes that the ship should use to report the data to the ship's Administration or any organization duly authorized by it, applicable to ships of 5,000 GT and above engaged on international voyages.

The regulation applies to ships of 5,000 GT and above, with the exception of:

Ships engaged on domestic voyages;
Ships not propelled by mechanical means;
Platforms, including FPSOs, FSUs and drilling rigs

In the case of a ship which is normally engaged on domestic voyages but which, in exceptional circumstances, is required to undertake a single international voyage, an exemption from any of the requirements in Chapter 4 of MARPOL Annex VI may be sought from the Administration. Please see MEPC.1/Circ.863 for guidance.

From the allowable data collection methods (refer to SEEMP Part II: Fuel oil consumption data collection plan*), the IMO DCS requires the collection of data on the total annual fuel oil consumption. Apart from berthing and travelling at sea, this data consists of fuel consumption due to activities including but not limited to anchoring, drifting, bunkering/de-bunkering, supply stops, maintenance, cargo loading/offloading, and ballast and commercial purposes.

Part III - The purpose of this part is to provide:

A description of the methodology that should be used to calculate the ship's attained annual operational CII required by regulation 28 of MARPOL Annex VI;
The processes that should be used to report this value to the ship's Administration or any organization duly authorized by it;
The required annual operational CII for the next three years;
An implementation plan documenting how the required annual operational CII should be achieved during the next three years;
A procedure for self-evaluation and improvement; and
For ships rated as D for three consecutive years or rated as E, a plan of corrective actions to achieve the required annual operational CII.

Part III of the SEEMP applies to any ship of 5,000 GT and above which falls into one or more of the categories in regulations 2.2.5, 2.2.7, 2.2.9, 2.2.11, 2.2.14 to 2.2.16, 2.2.22, and 2.2.26 to 2.2.29 of MARPOL Annex VI.

Timeline for IMO DCS & CII:

- For Collection and reporting of ship fuel oil consumption data (IMO-DCS) – MARPOL Annex VI regulation 27: From calendar year 2019, all ships of 5,000 gross tonnage and above shall collect data specified in appendix IX of MARPOL Annex VI, for that and each subsequent calendar year or portion thereof, as appropriate, according to the methodology included in the ship’s SEEMP.

- For Operational Carbon Intensity – MARPOL Annex VI regulation 28:

On or Before 01 January 2023 – a Ship Energy Efficiency Management Plan (SEEMP) Part III: Ship Operational Carbon Intensity Plan shall be provided on board, and this shall be done prior to performing any calculations under Regulation 28 of MARPOL Annex VI to ensure that the methodology and processes are in place prior to the beginning of the ship’s first reporting period.

At the end of the calendar year 2023 and after the end of subsequent calendar years, each ship of 5,000 gross tonnage and above which SEEMP Part III and Regulation 28 apply, shall calculate their Attained Annual Operation Carbon Intensity Indicator (Attained CII) from January 1 to December 31, using the data collected as per the Regulation 27 of Annex VI. Comparing it with the Required Annual Operational Carbon Intensity Indicator (Required CII) to determine operational carbon intensity rating A, B, C, D, or E.

Certification required:

Flag Administration or a Recognized Organization duly authorized by them will issue a “Certificate of Compliance” once verify the ship which Part II & III keep on board a specific Ship Energy Efficiency Management Plan (SEEMP), including SEEMP-Part III, as required by MARPOL Annex VI regulation 26.3.
Flag Administration will issue a “Statement of Compliance – Fuel Oil Consumption Reporting and Operational Carbon Intensity Rating” upon completion of verification of compliance with regulations 26, 27 and 28, reported by Recognized Organization.

The Statement of Compliance (SOC) - Fuel Oil Consumption Reporting and Operational Carbon Intensity Rating (SOC-DCS-CII) to be issued by this Administration pursuant to MARPOL Annex VI regulations 6.6 and 6.7 shall be valid for the calendar year in which it is issued, for the following calendar year, and for the first five (5) months of the subsequent calendar year. All Statements of Compliance shall be kept on board for at least five (5) years (Refer to MARPOL Annex VI regulation 9.12).

Data will be submitted to the IMO by the Administration, or any organization duly authorized by it within one month of the issuance of the SOC.

*SEEMP Part II: Fuel oil consumption data collection plan

- Fuel oil consumption.

Part II of the SEEMP shall include a description of the methodology used to collect the data required by Regulation 27.1 of MARPOL Annex VI and the processes used to report the data to the ship’s Administration. Fuel oil consumption includes all fuel oil consumed on board (regardless of whether the ship is underway or not), including but not limited to the following:

Main engines
Auxiliary engines
Gas turbines
Boilers
Inert gas generator

Various methods that by ships can use for annual fuel oil consumption data collection are stipulated in resolution MEPC.346(78) – 2022, Guidelines for the Development of a SEEMP, as detailed below.

Method 1 – Bunker delivery notes (BDNs) BDNs, the standard document required by MARPOL that contains information on fuel oil delivery (e.g. name of receiving vessel, port, date, quantity and characteristics of fuel oil), can be used to determine fuel oil consumption, in accordance with MARPOL Annex VI, BDNs have to be retained on board for three years.

Method 2 – Flow meters Through the use of flow meters on board that measure the daily fuel consumption of all relevant fuel oil consuming processes, the annual fuel oil consumption can be tabulated. For this method, the data collection plan should include a description of the flow meters and their link to specific fuel oil consumers, and the calibration of the flow meters.

Method 3 – Bunker fuel oil tank monitoring Daily fuel oil consumption data measured by tank readings are aggregated, including bunkering and de-bunkering. A summary of the monitoring data should be kept on board.

Method 4 - method using LNG cargo tank monitoring on board: LNG ships use the Custody Transfer Monitoring System (CTMS) to monitor/record the cargo volumes inside the tanks.

Method 5 - method using cargo tank monitoring on board for ships using cargo other than LNG as a fuel, to determine the annual fuel oil consumption, the amount of daily fuel oil consumption data measured by tank readings which are carried out by appropriate methods to the cargo used as a fuel.

Travelling distance and hours
Distance travelled over ground in nautical miles should be recorded in the logbook, whereas distance travelled while the ship is underway under its own propulsion should be included in the aggregated data of the distance travelled for the calendar year.
Hours underway – the aggregated duration of time that the ship is underway under its own propulsion – should be submitted to the Administration.

- Direct CO2 emissions measurement
Direct CO2 emissions measurement is not required by Regulation 27 of MARPOL Annex VI. However, if this method is used, measurement equipment and its locations should be described in SEEMP Part II, and calibration and maintenance records of this equipment should be kept on board.