- ABS has issued a regulatory update.
- It is to remind that amendments to MARPOL Annex VI will enter into force from November 2022.
- It will set the stage for the implementation of the Carbon Intensity Indicator (CII).
Operators need to revise the existing Ship Energy Efficiency Plan to include a Part III for Carbon Intensity Indicator (CII), calculation and rating in order to conform with the revised MARPOL Annex VI accordingly.
A Three Step Process
There is limited time remaining to prepare for compliance with this new regulatory scheme aimed at limiting and reducing the operational carbon intensity of specific vessel types, and pushing operators to make choices that optimize fuel efficiency. ABS highlighted and suggested the following three key steps for compliance.
Step 1: Technical Review
Submit SEEMP Part III for review and verification. A verified SEEMP Part III and its corresponding Confirmation of Compliance must be provided onboard prior to 1 January 2023.
Step 2: Company Audit
Prepare for company audits in accordance with MEPC.347(78). These periodical company audits may include annual audits of the company (company audits) and verifications on board the ship which may coincide with ISM Code audits.
Step 3: Ensuring Compliance
If future vessel modifications affect the SEEMP Part III, then re-verification is required. Regardless of the above, re-verification of the SEEMP Part III will be required every 3 years due to the update of the 3-year CII implementation plan. With regards to SEEMP Part III the following should be included.
- a description of the methodology that will be used to calculate the ship’s Attained Annual Operational CII.
- the Required Annual Operational CII for the next three years
- an implementation plan documenting how the Required Annual Operational CII will be achieved during the next three years.
- a procedure for self-evaluation.
ABS notes that the three-year implementation plan should be SMART (Specific, Measurable, Achievable, Realistic, and Timebound) to the extent feasible and it should include list of measures with time and method of implementation for achieving the required operational CII along with the identification of possible impediments to the effectiveness of the measures.
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