4.1 Planning
4.1.1 Planning is the most crucial stage of part I of the SEEMP, in that it primarily
determines both the current status of ship energy usage and carbon intensity and the
expected improvement of ship energy efficiency and reduction of carbon intensity.
Therefore, it is encouraged to devote sufficient time to planning so that the most
appropriate, effective and implementable plan can be developed.
Ship-specific measures
4.1.2 Recognizing that there are a variety of options to improve energy efficiency
and reduce carbon intensity (e.g. speed optimization, confirming berth availability
and arrival time with port of destination, weather routeing, hull maintenance,
retrofitting of energy efficiency devices, and use of alternative fuels), the best
package of measures for a ship to improve energy efficiency and reduce carbon
intensity depends to a great extent upon ship type, cargoes, routes and other
factors that should be identified in the first place. These measures should be
listed as a package of measures to be implemented, thus providing the overview of
the actions to be taken for that ship.
4.1.3 During the planning process, therefore, it is important to determine and
understand the ship's current status of energy usage. Part I of the SEEMP should
identify energy-saving and carbon intensity reducing measures that already have been
undertaken, and should determine how effective these measures are in terms of
improving energy efficiency and reducing carbon intensity. Part I also should
identify what measures can be adopted to further improve the energy efficiency and
reduce the carbon intensity of the ship. It should be noted, however, that not all
measures can be applied to all ships, or even to the same ship under different
operating conditions and that some of them are mutually exclusive. Ideally, initial
measures could yield energy (and cost) saving results that then can be reinvested in
more difficult or expensive efficiency upgrades identified by part I.
4.1.4 Guidance on best practices for fuel-efficient operation of ships, set out in
chapter 5, can be used to facilitate this part of the planning phase. Also, in the
planning process, particular consideration should be given to minimize any onboard
administrative burden.
Company-specific measures
4.1.5 The improvement of energy efficiency and reduction of carbon intensity of ship
operation does not necessarily depend on single ship management only. Rather, it may
depend on many stakeholders including ship repair yards, shipowners, operators,
charterers, cargo owners, fuel suppliers, ports and traffic management services. For
example, "just in time" – as explained in paragraph 5.2.4 – requires good early
communication among operators, ports and traffic management services. The better the
coordination among such stakeholders, the more improvement can be expected. In most
cases, such coordination or total management is better made by a company rather than
by a ship. In this sense, it is recommended that a company should also establish an
energy efficiency and carbon intensity management plan to improve the performance of
its fleet (should it not have one in place already) and make necessary coordination
among stakeholders.
Human resource development
4.1.6 For effective and steady implementation of the adopted measures, raising
awareness of and providing necessary training for personnel both on shore and on
board are an important element. Such human resource development is encouraged and
should be considered as an important component of planning as well as a critical
element of implementation.
Goal setting
4.1.7 The last part of planning is goal setting.
-
.1 For ships also subject to regulation 28 of MARPOL Annex VI, the goal setting should be
consistent with the continuous CII improvements set out by that regulation,
and should include the relevant information (see paragraph 9.7). These ships
are also encouraged to consider setting ship-specific goals in addition to
the applicable CII requirements that strive for additional energy efficiency
improvements and carbon intensity reductions.
-
.2 For ships or companies not subject to regulation 28, there are no
requirements to define a goal and to communicate it to the public, or to be
a subject to external inspection, surveys, or audits with respect to the
SEEMP. Nevertheless, a meaningful goal should be defined to serve as a
signal on a company's commitment to improve the energy efficiency and carbon
intensity of the ship. The goal can be set using different indicators,
including the annual fuel consumption, Annual Efficiency Ratio (AER),
cgDIST, Energy Efficiency Operational Indicator (EEOI) or other carbon
intensity indicators (CIIs).footnote In all cases, the goal should be measurable
and easy to understand.
4.2 Implementation
Establishment of implementation system
4.2.1 After a ship and a company identify the energy efficiency and carbon intensity
measures to be implemented, it is essential to establish a system for their
implementation. This is done by developing the procedures for energy management,
defining tasks associated with those procedures, and assigning those tasks to
responsible personnel. The implementation system should include procedures to ensure
execution of measures and specify defined levels of authority and lines of
communication. Also, it should include procedures for internal audits and management
review, where relevant. In sum, part I of the SEEMP should describe how each measure
should be implemented and who the responsible person or persons are. The
implementation period (start and end dates) of each selected measure should be
indicated. The development of such an implementation system can be considered as a
part of planning, and therefore may be completed at the planning stage.
Implementation and record-keeping
4.2.2 The planned measures should be carried out in accordance with the predetermined
implementation system. Record-keeping for the implementation of each measure is
beneficial for self-evaluation at a later stage and should be encouraged. If any
identified measure cannot be implemented for any reason, the reason or reasons
should be recorded for internal use. It is recommended that events and operational
conditions outside the control of the ship's crew (for example, waiting for berths,
extended port dwell times, operation in severe adverse weather) which may affect the
ships rating be documented.
4.3 Monitoring
Monitoring tools
4.3.1 The energy efficiency of a ship should be monitored quantitatively. This should
be done by an established method, preferably by an international standard. In many
cases, the monitoring tool should target the goal indicator set out in paragraph
4.1.7 (e.g. AER, cgDIST, EEOI, or other CIIs as agreed by the Organization). If a
quantitative goal is not defined for a ship, a quantitative performance indicator
developed by the Organization (e.g. AER, EEOI, CII) or another internationally
established tool should be selected. A ship subject to regulation
28 is likely to use the CII as its monitoring tool.
4.3.2 If used, these CIIs should be calculated in accordance with the guidelines
developed by the Organization,footnote adjusted, as necessary, to a specific ship and trade.
4.3.3 Ships subject to regulation 28 may use other measurement tools in addition
to the CII, if convenient and/or beneficial for a ship or a company. In the case
where other monitoring tools are used, the reason for the use of the tool and the
method of monitoring should be clarified at the planning stage.
4.3.4 It is highly advised to conduct monitoring at regular intervals for checking
consistency of data and verification assistance. The ship's fuel oil consumption
should be monitored using daily reporting, such as noon reports, or higher frequency
data.
Establishment of monitoring system
4.3.5 It should be noted that whatever measurement tools are used, continuous and
consistent and reliable data collection is the foundation of monitoring. To allow
for meaningful and consistent monitoring, a monitoring system, including the
procedures for collecting data and the assignment of responsible personnel, should
be developed. The development of such a system can be considered as a part of
planning, and therefore should be completed at the planning stage.
4.3.6 It should be noted that, in order to avoid unnecessary administrative burdens
on ships' staff, monitoring should be carried out as much as possible by shore staff
when the data can be automatically transferred, utilizing data obtained from
existing required records such as the official and engineering logbooks and oil
record books. Additional data could be obtained as appropriate.
Search and rescue
4.3.7 When a ship diverts from its scheduled passage to engage in search and rescue
operations, and for which emissions are excluded pursuant to regulation 3, it is
recommended that data obtained during such operations is not used in ship energy
efficiency monitoring, and that such data should be recorded separately.
4.4 Self-evaluation and improvement
4.4.1 Self-evaluation and improvement is the final phase of the management cycle.
This phase should produce meaningful feedback for the coming first stage, i.e.
planning stage of the next improvement cycle.
4.4.2 The purpose of self-evaluation is to:
-
.1 evaluate the effectiveness of the planned measures and their
implementation;
-
.2 deepen the understanding of the overall characteristics of the ship's
operation such as what types of measures can or cannot function effectively,
and how and/or why;
-
.3 comprehend the trend of the efficiency improvement of that ship; and
-
.4 develop the improved management plan for the next cycle through
identification of further opportunities for improving energy efficiency and
reducing carbon intensity.
4.4.3 For this process, procedures for self-evaluation of the ship energy efficiency
management plan should be developed. Furthermore, self-evaluation should be
implemented periodically by using data collected through monitoring. In addition, it
is recommended that time be invested in identifying the cause and effect of the
performance during the evaluated period so lessons learned can be taken into account
when revising and improving the next stage of the ship's energy efficiency
management plan.