I wanted to discuss an important topic regarding SEEMP Part 3 compliance for 2023 and share some insights that could potentially help. One thing that’s been noticed is shipowners rushing to calculate the attained CII Rating of their fleet, even when it’s not necessary.
The recorded data for 2022 won’t include the implementation of EEXI. Waiting for the 2023 data would provide more accurate results and a better CII Rating, leading to more effective measures. By including the voluntary CII calculation based on 2022 data, shipowners might end up taking unnecessary measures or drawing false conclusions.
It’s essential to consider that SEEMP Part 3 requires identifying corrective measures to reach the target CII rating. Without an attained CII calculation, shipowners can propose only harmless light measures for now. On the other hand, if the voluntary calculation yields an E or deep D rating, shipowners will need to implement costly measures immediately.
In addition, certain effective measures depend on charterers’ cooperation, making it challenging to implement them before the mandatory CII calculation in 2023.
Considering these aspects, it might be worth discussing whether shipowners should hold off on providing a voluntary attained CII calculation and focus on simpler corrective measures for the upcoming years.
I’d love to hear your thoughts and experiences on this matter. Let’s share insights and help each other navigate SEEMP Part 3 compliance effectively.
Feel free to read the full article on Ship Nerd News here
All of the classes required you to state your attained CII for the years 2019-2021, based on your verified IMO DCS data up to that point. The indicative table showing this was also included in the relevant MEPC. What you are describing is the fact that those data may not be relevant or applicable anymore and that you are probably overcorrecting if you use the latest, let’s say 2021, as a starting point for the reduction necessary and the corresponding measures.
You are correct on this. However, the past data provide a very good indication of the emissions per transport work for a specific vessel. In other words an A - rated vessel if operated poorly, it will be very difficult to become even D. The same applies for E rated vessels.
It is also very easy to see where major changes happened on the operational profile based on the past data, so start identifying the main parameters that affect the CII.
Having submitted to all the major classes the seemp 3 for many vessels, they all required this table to be in the manual. However, not all of them required the 2021 CII to be used as a starting point for two reasons. The first one is what you are describing.
The second and most important one is that the whole spirit of this regulation is optimisation towards a goal. So you are stating what your starting point is, you are setting within the manual a system to help you monitor the CII, responsible personnel, measures that will kick in if you are not complying, other contingency measures etc. You are setting in place a system that will be continuously optimised. The first measures and the first estimation of their impact and the original starting point are just that. An initial estimation. This is a dynamic process not just a one-off manual like SEEMP I.
The most important part here is the monitoring that becomes compulsory in an implicit way. The other important part is the measures become measurable. So it is more important to measure the impact of your measures and be able to verify what you are stating than just guessing.
Thank you for your comment and for sharing your insights on this matter. I completely agree with you that the past data provide a valuable indication of emissions per transport work for a specific vessel. It’s important to have a clear view of the vessel’s operational profile and identify the main parameters that affect the CII.
The key aspect here is monitoring, which becomes implicit and compulsory. It allows ship operators to measure the impact of their measures and verify the stated improvements, rather than relying solely on assumptions.
My intention in sharing this information was to provide an alternative perspective for vessels with low ratings, where simpler corrective measures could be beneficial. However, it’s crucial for all ship operators to carefully consider their specific circumstances and utilize the best approach for their vessels.
Thank you again for your input and valuable contribution to the discussion.