in respect of what is now known as a SEEMP II until the new provisions of MARPOl VI, Reg.27 entry into force 01/11/2022.
The MN063 is being amended and a new version will be published shortly to outline the changes in the SEEMP preparation requirements and content.
In a nutshell, the requirements in force on and after 01/01/2023 are as below:
- SEEMP I, the original ship energy efficiency management plan requirements in place since 01/01/2013 - no change;
- SEEMP II, fuel consumption data collection and submission (DCS requirements, currently M-VI, Reg.22A). Where the existing collection plan had been prepared and approved to include a Reporting Organisation/Verifier being the RO that issued the IAPP certificate of the ship no changes are required. Where the existing Reporting Organisation/Verifier is another RO the new arrangements to transfer the function of a Reporting Organisation/Verifier to the RO that issued the IAPP certificate and the necessary SEEMP II amendments and approval shall be put in place on or after 01/07/2023, being the limit date for DCS data transfer to IMO GISIS, but in any case before 01/01/2024. Please refer to Sect.4.3 of MN063. This is a new provision the BMA puts forward to ensure the authority responsible for the DCS fuel data collection and the CII index assessment to be allocated with the same RO to avoid any potential issues in relation to the implementation of the new requirements;
- SEEMP III, new Regulation 28 and the CII requirements EIF 01/11/2022. Preparation and approval shall be completed with RO that issued the IAPP certificate of the ship by 01/01/2023. The BMA fully recognises the challenges in setting up the new CII assessment procedures and drafting the new SEEMP II plan, therefore, and where appropriate, a short additional time past 01/01/2023 may be agreed to allow a particular ship to fully prepare a new and approved SEEMP III. Where the Owners may envisage such additional time may be required an application should be submitted prior to 01/01/2023 via the RO that issued the IAPP certificate of the ship.
In a view of the above the BMA would expect the 2022 DCS fuel consumption data submission may be prepared basis of the existing SEEMP II provisions even where existing Reporting Organisation/Verifier is not the RO that issued the IAPP certificate. However, the 2023 DCS data collection and submission, as well as the first CII assessment, shall be prepared during the first three months of 2024 and then by 31/03 each following year by the RO that issued the IAPP certificate.