Frequently asked questions on SEEMP Part III

What are the benefits of using a digital SEEMP III solution?

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The SEEMP III generator from DNV will reduce your workload, save time and ensure that prompt compliance is achieved.

Benefits:

  • Proposed energy efficiency measures
  • Dynamic planning and easy updating
  • Automatic integration for CII monitoring (Emissions Insights)
  • A more efficient and smoother verification

How can I prepare for SEEMP III verification?

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A1: You must ensure that the prefilled form with ship particulars from our database is correct:

  • The deadweight value should be in line with the International Energy Efficiency Certificate.
  • The gross tonnage value should be in line with the International Tonnage Certificate.
  • The ship type should be in line with the International Energy Efficiency Certificate.
  • The ice class should be checked with reference to Finnish-Swedish Ice Class Rules corresponding to the vessel’s class notation.

A2: You should familiarize yourself with estimated CII and preliminary ratings based on submitted DCS data. Emissions Insights, which is available in Veracity, is a good tool for this purpose. After that, you should start considering which measures can be applied to improve the CII for each vessel. DNV Advisory may assist you in determining suitable measures and combination of measures, while MEPC 282(70) chapter 5: “GUIDANCE ON BEST PRACTISES FOR FUEL-EFFICIENT OPERATION OF SHIPS” and the IMO Appraisal Tool (Appraisal Tool: GreenVoyage2050 (imo.org)) can support you in this process.

Does DNV offer the SEEMP III generator for vessels without DCS service from DNV?

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SEEMP III generator is meant for our DCS customers only as an expansion of our DCS service to capture the CII scope which will be a part of the DCS delivery.

Does DNV provide a template for the preparation of the SEEMP III plan?

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DNV provides a web application (app) for creating and submitting the plan for verification on the DNV customer portal. You should submit plans through this app instead of manually preparing SEEMP III plans.

Are the SEEMP III plans subject to approval?

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The SEEMP III is subject to verification by the flag or an RO. After verification, a Confirmation of Compliance (CoC) will be issued.

What is the deadline for submitting SEEMP III plans to DNV for verification?

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The deadline for the initial verification of the SEEMP III is 31 December 2022. To ensure the SEEMP is verified within the deadline, it should be submitted for verification in due time.

What is the CII and the CII rating scheme?

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The Carbon Intensity Indicator (CII) is a measure of how efficiently a ship transports goods or passengers and is given in grams of CO2 emitted per cargo-carrying capacity and nautical mile. The ship is then given an annual rating ranging from A to E, whereby the rating thresholds will become increasingly stringent towards 2030. The CII applies to all cargo, RoPax and cruise ships above 5,000 GT.

The yearly CII is calculated based on reported IMO DCS data, and the ship is given a rating from A to E. For ships that achieve a D rating for three consecutive years or an E rating in a single year, a corrective action plan needs to be developed as part of the SEEMP III and verified.

What ships does the CII apply to?

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The CII applies to all ships above 5,000 GT of the following MARPOL ship types: bulk carriers, gas carriers, tankers, container ships, general cargo ships, refrigerated cargo carriers, combination carriers, LNG carriers, vehicle carriers, Ro-Ro cargo vessels, Ro-Ro passenger vessels and cruise ships.

When the CII will be calculated based on reported data?

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The first DCS reporting year for which a CII will be calculated is 2023, and the first rating will be given in the first half of 2024 based on the 2023 reporting year.

What are the further required steps if the vessel had a rating E (once) or D (three times)?

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In case of an inferior rating, meaning a D rating for three consecutive years or one E rating, the SEEMP III must be updated with a corrective action plan and verified before the Statement of Compliance (SoC) is issued. The corrective action plan should consist of an analysis of why the required CII was not achieved and include a revised implementation plan in order to achieve the required CII (middle point of the C rating).

Does the SEEMP III need to be verified every three years?

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Yes, if the vessel was not affected with inferior ratings (E once or D three times), after three years the revised three-year implementation plan documenting how the required CII will be achieved during next three years, with yearly targets, procedures for self-evaluation and improvement should be submitted by the company.

Is the digital CoC sufficient or should the hard copy of CoC be kept on board?

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The digital certificate is sufficient.

What will be the consequences for ships be that are not able to achieve the required annual CII after being rated as D for three consecutive or a single year rated as E?

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Any enforcement mechanism from the IMO in such a case is still to be decided and will be part of a review to be carried out in 2025. In the meantime, however, we anticipate that this may have a focus with stakeholders such as flag, PSC, vetting and commercial parties which may impose actions or restrictions. Whether failure to implement the SEEMP III should be a detainable deficiency is still also up for discussion.

Is achieving C environmental rating enough?

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DNV strongly recommends achieving required CII which is a midpoint of C environmental rating in order to meet IMO’s trajectory of decarbonization until 2050.  However, if the company is not able to meet midpoint C in the upcoming three years, there are no consequences already established by IMO for the time being if the vessel achieves a C rating below the midpoint. 

Do I have to report measures if I meet required CII?

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No. If your vessel’s CII starting point is above the required CII you are not required to report any measures in SEEMP Part III.

What is CII starting point, what is required CII, what is target CII?

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CII starting point – value synced from the Emissions Insights, basing on submitted DCS data, used as a baseline of calculation of the target CII Required CII – CII value that has to be achieved in the upcoming 3 years Target CII – CII starting point together with the effect of the measures, has to be lower than Required CII in the submitted SEEMP Part III 

Why are my correction factors not included in my starting CII? 

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Correction factors are not included in your CII starting point because until June 2022, requirements for CII correction factors were not yet established by IMO. From 2023, DNV will start collecting additional data in DCS reporting scheme basing on which you will receive two separate CII values in the Emissions Insights: CII without correction factors and CII with correction factors.

What will I need to do if I pick trial CII in the generator? Are there any benefits?

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Additional data will be required to be delivered to DNV in order to calculate trial CII for such vessel. DNV does not provide any benefits for using trial CII.

Can we base our CII starting point on 2020 data?

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If you think that Emissions Insights’ estimated CII from 2020 better reflects operational performance of the vessel, of course you can change your CII starting point in the generator and provide us a clarification why would you like to use this CII instead of 2021 estimated CII.

What documents should be uploaded if we would like to confirm our different CII starting point?

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Clarification why does 2021 estimated CII synced from Emissions Insights not reflect normal operational efficiency of the vessel or the document with the calculations will be sufficient for verification purposes.

SEEMP Part III Generator tutorial videos

Landing page tutorial

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Introduction tutorial

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Calculation methodology tutorial

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Self-evaluation & review tutorial

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Measures tutorial

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Requesting verification tutorial

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Related links

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MRV and DCS

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CII – Carbon Intensity Indicator

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