What is an SEEMP?
A ship-specific Ship Energy Efficiency Management Plan (SEEMP) provides a structured approach to monitoring and improving ship and fleet efficiency performance over time. It shall be developed considering guidelines adopted by the IMO and encourages the shipowner to consider new technologies and practices at each stage of the plan.
The IMO has taken a lead through MARPOL and other regulatory instruments to enhance energy efficiency and reduce greenhouse gas emissions from shipping. In July 2011, the Marine Environment Protection Committee (MEPC) of the IMO made the SEEMP mandatory for new and existing ships above 400 GT from 1 January 2013. In 2021, the enhanced SEEMP regulation was adopted requiring all cargo, RoPax and cruise vessels above 5,000 GT and trading internationally to have an approved implementation plan on how to reach the required CII (Carbon Intensity Indicator) on board as part of the SEEMP from 1 January 2023.
Also, as part of the CII regulation, for ships with a D rating for three consecutive years or an E rating in a single year, a corrective action plan needs to be developed and approved as part of the SEEMP.
When developing or revising an SEEMP, the process should follow a cyclical approach Plan – Do – Check – Act:
- PLAN includes ship- and company-specific measures, human resource development and goal-setting, while bearing in mind the need to minimize on-board administration.
Important considerations:This is the most crucial phase of the SEEMP development and should reference company goals and processes, ship-specific features in technical and operational spheres, training, competence, and timelines.
- DO includes attention to establishing and implementing an appropriate system that allows for each selected measure to be rolled out according to the plan. Important considerations: Any “system” can involve a mix of tools, processes and record-keeping that, when combined, enable the implementation of specific energy efficient initiatives. A communication plan that identifies who is responsible for each step in the process will both increase awareness and the likelihood of sustainable activity. The SEEMP may be part of the vessel’s Safety Management System mandated by the ISM Code. It can form the cornerstone of a broader energy management initiative, or it can be kept separate, focusing on compliance only
- CHECK describes the establishment of a monitoring system utilizing various tools, existing and new, that can provide a qualitative and quantitative basis for self-evaluation and subsequent performance review.
Important considerations: This is perhaps the hardest area to activate in a consistent manner. The interaction of the right tools, systems and processes is crucial for measuring achievement and ensuring sustained improvement. Many organizations collect data from a wide range of sources, but not all manage this information systematically so that they know how well they are performing or whether they are on track.
- ACT completes the continuous improvement cycle by assessing the effectiveness of implemented energy efficiency actions, identifying ways to improve associated processes and formerly reporting results to stakeholders.
Important considerations: Plan to communicate both good and not-so-good news to interested parties. This will increase awareness and build trust in the programme and activities. In addition, seek regular feedback from others via meetings, presentations, and emails to check and validate plans as they unfold.
Why use DNV to assist with an SEEMP?
While it is certainly possible for any operator’s energy manager or senior superintendent with energy efficiency duties to write a compliant SEEMP, many vessel operators opt to have the SEEMP for their vessels created by professional experts in marine energy management.
There are various reasons for this, such as:
- Learning from industry best practice
- Resource limitations – avoid wasting the superintendent’s time on formulating compliant text
- Compliance is ensured
In our opinion, an SEEMP is a crucial first step towards the comprehensive energy management of any fleet. Based on rigorous analysis of trading patterns, vessel speeds over time, actual vs. desired fuel consumption and so forth, a fully-fledged energy efficiency programme should be started and maintained. It shall encompass technical and operational measures, both on board and in the office, together with training and a goal-driven continuous improvement process.
The Enhanced SEEMP regulation adopted by IMO in 2021, demonstrates why it is advisable to develop and maintain a GHG strategy on company level. DNV may assist with fleet specific strategies and roadmaps for individual ships, including GHG performance assessments and benchmarking of existing fleets (e.g. EEXI, CII) against established targets. The roadmaps, which may be an integrated part of the vessel-specific SEEMPs, may indicate when to switch from conventional fossil fuels to fuels with lower-carbon footprints and then to carbon-neutral fuels. An enhanced energy efficiency of ships will also be needed – involving the rethinking of operations and a greater uptake of proven energy recovery and efficiency technologies. DNV will enable you to meet the targeted CII rating, set by the company’s strategy or as result of under-performance as per the CII regulation. The result of working with DNV on your enhanced SEEMP will be to have a consistent and robust mandatory, ship specific energy efficiency management plan, supporting your company’s emission strategy on fleet level and for individual vessels.