Page 39 - ΝΑΥΤΙΚΑ ΧΡΟΝΙΚΑ - MARTIOS 2023

CII: AN OPEN DISCUSSION

DECIPHERING WHY SEEMP AND COLLABORATION

THE COMPLEXITIES ARE KEY TO GETTING CII RIGHT

OF THE There will always be teething issues and E ratings, namely corrective action

when a new regulation comes into plans – which must also be implemented
force. At BIMCO, however, we have via the SEEMP.
rarely experienced a regulation that The ship is obliged to document in the
has thrown the industry into as much SEEMP which concrete measures will
turmoil as the CII regulation. However, be used to bring it back to the mid-point
if shipowners fix their eyes on five let- rating of C (the target CII or required
ters: SEEMP, and work in close collabo- CII mentioned above). Since all ships
ration with charterers, the industry may can supposedly achieve a “C” rating by
be off to a good start despite a regula- applying the approved measures, com-
tory framework that is complicated and pliance lies in the application of the
From 1 January 2023, it has become mandatory for all ships to calculate their attained Energy Efficiency Existing Ship Index imperfect. implementation and corrective action
(EEXI) to measure their energy efficiency and to initiate the data collection for reporting their annual operational carbon About two months ago, the CII reg- plans in the SEEMP, and not in the
intensity indicator (CII) and CII rating. ulation entered into force. While the rating itself.
The CII determines the annual reduction factor needed to continuously improve the ship’s operational carbon intensity framework may change over time from a
within a specific rating level. However, implementing the IMO indicator as a short-term measure to achieve decarbonisation mathematical perspective, the intent of Managing CII takes two: the ship-
goals has raised questions, with many stakeholders of the international shipping community already calling for modifica- the regulation is here to stay. Indeed, in owner and the charterer
tions to the index. its current form, the most efficient ship Another common misunderstanding is
In the following pages, industry experts discuss their first conclusions from the implementation of the CII, propose solu- out there is one that is always empty that responsibility for compliance lies
tions for its improvement, and also refer to how the BIMCO clause affects relations between shipowners and charterers. and never calls at a port, but just roams with the charterer. It is correct that the
the oceans at eco-speed. While such CII framework is an operational regula-
a scenario is unlikely for commercial tion and that any commercial decision
reasons, it would give the ship the best on the ship’s operation will directly
possible CII rating. In addition, actual affect its rating. However, it is the Inter-
commercial utilisation of the ship would national Safety Management (ISM)
worsen its rating. company that is responsible for a ship’s
regulatory CII compliance.
The misunderstanding aiming for “C” In the commercial world, without close
While much focus is on the ratings (A, co-operation and commitment from the
B, C, D and E), and particularly on the operators of the ship, managing the task
mid-point of the letter C, all eyes should to improve a ship’s CII will be a difficult,
in fact be on the five letters: SEEMP. even impossible, task.
The Ship Energy Efficiency Management The CII framework will fundamentally
Plan is the primary compliance tool in change the way shipowners and charter-
the framework. The required implemen- ers collaborate. There will be no busi-
tation plan documents how a ship will ness as usual if a ship is to achieve the
achieve the required CII for the next target CII year after year. Century old
three years – with measures, timelines, practices and standards are therefore
responsible personnel. It also deliber- up for a significant revisit.
ates any impediments related to the
measures listed. The CII rating: labelling a trade or a
It is a common misunderstanding that a ship?
ship must achieve a C rating to be com- Another issue that we often encounter
pliant. The fact is that any rating, A, B, when we advise our members about the
by Lars Robert Pedersen, C, D or E, is in fact a compliant rating. CII framework is that a low rating sup-
BIMCO Deputy Secretary General There are however consequences of D posedly equals an inferior ship, a ship

38 39