Frequently asked questions on SEEMP Part III

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

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SEEMP III generator will reduce the workload, save time and ensure that prompt compliance will be 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 to prepare for SEEMP III verification?

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A1: The company shall ensure that the prefilled ship particulars from our database are 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 Certifiacte
  • Ice class should be checked with reference to Finnish-Swedish Ice Class Rules corresponding to vessel’s Class Notation

A2: The company should familiarize itself with estimated CII’s and preliminary ratings based on submitted DCS data. Emissions Insights available in Veracity will be a good tool for this purpose.  After that, the Company should start considering which measures can be applied to improve CII for each vessel. DNV Advisory may be assist in determining suitable measures and combination of measures, in addition Resolution 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 in this process.

Does DNV offer the SEEMP III generator for vessels not having a DCS service with DNV?

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

Is DNV providing a template for 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. Company should submit plans through this app instead of manually preparing their 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 a RO. After successful verification, a Confirmation of Compliance (CoC) will be issued.

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

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The deadline for the initial verification of the SEEMP III is 31st December 2022. To ensure that the SEEMP is verified within the deadline it should be submitted for verification in due time. SEEMP Part III, together with Confirmation of Compliance has to be onboard from 1st January 2023.

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 receives 1xE rating or 3xD ratings?

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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 DCS SoC can be 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 (1xE or 3xD), then after three years the revised 3-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 the hard copy of CoC should be kept on board?

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Digital certificate is sufficient.

What will be the consequences for ship not able 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 IMO in such case is still to be decided and will be part of a review to be carried out in 2025. In the meantime we do however 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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No, planning for environmental rating of C in SEEMP Part III is not enough according to SEEMP guidelines. Vessel has to plan for Required CII which is a midpoint of C environmental rating in order to meet IMO’s trajectory of decarbonization until 2050.

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

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

Why are there CII impact ranges for each measure in the generator? Can I exceed these ranges?

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Each measure's CII impact range is based on IMO's Appraisal Tool and our technical experts' industry knowledge. Of course, you can exceed these ranges. In such case, please upload a clarification why do you think that this measure would have such influence on your vessel's target CII or calculations. We do not have any specific documentation requirements.

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 

Can I change my vessel's CII starting point?

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If you think that Emissions Insights’ estimated CII from 2020 or 2019 better reflects operational performance of the vessel or simply would like to use sister vessel's estimated CII, 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 CII starting point should I use for new vessels which do not have any DCS data?

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After registering the vessel in MRV/DCS service, you will get the access to this vessel's calculated Reference CII in the DNV's Emissions Insights. It is based on ship's particulars and can be used as CII starting point in SEEMP Part III generator.

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.

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.

Is there a special consideration or exemption for the CII for refrigerated cargo carriers, considering the high energy consumption for cargo cooling by those vessels?

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Refrigerated cargo carrier (MARPOL Annex VI, Reg. 2.2.22) above 5000GT are subject to CII. As per the IMO MEPC.355(78) CII guidelines G5 (attached), there are currently no correction factors for such vessels.

In case support is needed meeting the required CII and preparing the SEEMP III, you may want to consider contacting advisory services such as DNV maritime advisory for help.

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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CII – Carbon Intensity Indicator

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