Although vessels will be required to carry a Ship Energy Efficiency Management Plan from January 1st 2013, the regulation is not designed to be complex or expensive to implement. The open-ended nature of the regulation however has meant this has not necessarily been immediately apparent to busy owners and operators.
BIMCO, the ship-owners association, concerned that that their members and wider industry are being needlessly encouraged to outsource this at substantial cost, have sought to cut through the hype and enable operators to produce effective, low-cost SEEMPs in-house for their vessels.
They recently produced the Step-by-Step SEEMP which, as well as acting as part of the official SEEMP, guides the owner through identifying the ship specific measure which can then be populated in to the templates on the accompanying CD to complete the process.
Lars Robert Pedersen, Deputy Secretary General, BIMCO commented ,
“BIMCO supported the SEEMP regulation at IMO to enable ship-owners to better optimize their energy consumption. We do not believe, however, there is necessarily any need to pay substantial amounts to third parties to prepare SEEMPs.
“It is our view that a simple SEEMP implemented effectively is better than a complicated document that may not be followed.”
What is the purpose of a SEEMP?
The Ship Energy Efficiency Management Plan is simply a document detailing the operational and technical measures that are being or will be implemented on-board to improve efficiency and therefore reduce fuel consumption.
The idea is that by identifying areas where fuel could be saved, implementing them and monitoring the effect, a positive cycle of reducing fuel consumption is encouraged. It is a soft regulation meaning there is no mechanism to force or even incentivize ship operators to implement the measures listed in their SEEMPs and monitoring and enforcement is limited to simply verifying that the SEEMP exists.
However, given that the SEEMP process gives real potential for saving money through reduced fuel bills, it does make sense for operators to take further the ‘bare compliance’ approach. In order to fulfil the requirements a SEEMP must ‘take account’ of the relevant IMO Guidelines, but the exact content will vary.
Producing a simple yet effective SEEMP
There are four stages identified by the IMO as part of the SEEMP process; plan, implement, monitor and evaluate.
The planning stage, regarded to be one of the most important, should establish the current energy usage patterns of the ship, including its overall baseline efficiency.
The Step-by-Step SEEMP encourages operators to consider the various methods open to them and choose the one most appropriate to them. Some methods are blunter than others and not as sensitive to fuel consumption changes but the key is consistency of approach.
In this planning stage, the measures that can assist in cutting fuel consumption should be identified and prioritized according to their energy-saving potential and their feasibility; again BIMCO are very clear that it is better to have a short, well-implemented programme of the most effective measures than an exhaustive programme that is never implemented.
What measures are open to an operator?
The regulation is so open-ended, and the spectrum of potential measures to improve energy efficiency is so broad – ranging from small, no-cost initiatives such as encouraging crew to switch off lights and appliances, to the installation of major pieces of retrofit equipment such as waste heat recovery systems – that it can be difficult to know where to begin.
The more costly and technologically complex measures of course require a significant amount of assessment and evaluation before implementation. But this should not blind operators to the fact that there are many measures that deliver tangible benefits and can be implemented very quickly.
BIMCO have therefore split a host of measures into ‘Quick Wins’ and ‘Further Investments’. This practical approach means that operators can easily identify those measures that require no investment of only modest upfront investment. ‘Further Investments’ are recommended as something for inclusion perhaps in later iterations of the document.
Crucially, just the process of increasing awareness of and the commitment to energy saving amongst crew and onshore staff should reap benefits in itself.
BIMCO recommends that it is advisable to involve on-board personnel as early and as far as possible. The majority of ‘Quick Wins’ measures are operational matters and as in any professional field, individuals are far more likely to carry out measures thoroughly and consistently if they feel ‘ownership’ of the measure through having been involved in its development.
There is nothing in the regulations that forces measures set out in a SEEMP: implementation is not mandatory and there is no regulatory procedure for checking that measures have actually been put into practice.
Nonetheless, if benefit is to be gained from the SEEMP, then the full cycle needs to followed and thus monitoring and evaluation are vital. This should not place a great burden on either crew of shore-based personnel, but it is important to both see if the measures are having an affect and also in identifying further measures that can be implemented once the first round have become simply ‘business as usual’.
Essentially, the Step-by-Step SEEMP is a product that provides a simple and practical step-by-step method to implementing SEEMP that balances operators’ desire for a straightforward means of complying with the SEEMP regulation with their wish to reap the benefits of energy efficiency measures SEEMP.
It ensures that the SEEMP follows the correct guidelines and also gives it the gravitas that such a document needs both in terms of the crew taking it seriously and it being an official ships document open for inspection.