Questions & Answers
(so far not in any particular order)
Q1: When is a draught increase considered a major conversion in relation to attained EEDI / EEXI?
A1: For a draught increase without altering the hull, the unified interpretation (as per MEPC.1/Circ.795, as revised) to MARPOL Annex VI, regulation 2.2.17(.1) is to be used and is thus not considered a major conversion. In general increasing the draught has a positive impact on the attained EEDI / EEXI. With reference to the aforementioned circular, the NSI considers a (permanent) decrease of the ship's draft as a major conversion.
Q2: Is the verification of the attained EEXI to be carried out by the ships' Classification Society or may this be done by another RO?
A2: Verification of the attained EEXI includes verification of the EEXI technical file, and possibly verification of the Onboard Management Manual (OMM) and the shaft/engine power limitation. Therefore this can only be carried out by the RO that Classes the ship for Hull and Machinery. See also Resolution MEPC.351(78).
Q3: Is the verification of the CII to be carried out by the ships' Classification Society or may this be done by another RO?
A3: Verification of the CII may be carried out by another RO than the one that Classes the ship, since this is a verification that can be carried out remotely. It should however be the same verifier as for IMO Data Collecting System for fuel oil consumption of ships (IMO DCS) since the CII is to be calculated based on the collected and reported ship fuel oil consumption data which has been submitted to the DCS.
Q4: Is there a margin for the application of an Overridable Shaft Power Limitation (SHaPoLi)?
A4: A SHaPoLi of less than 1% of the rated installed power (MCR) does not need to be applied since this falls within the measurement uncertainty of common equipment.
Q5: Is an additional authorisation for the RO's necessary for attained EEXI / CII verification?
A5: Since the RO's are already authorised to conduct the surveys and to issue the certificates as regulated in MARPOL Annex VI, and the new requirements regarding EEXI and CII are amendments to MARPOL Annex VI, no separate authorisation is required. The Appendix to Annex 1 to the Agreement between the NL and RO dated 03 April 2014 already provides for this.
Q6: Does the EEXI requirement apply to cement carriers?
A6: Yes, a cement carrier is a bulk carrier and cement carriers were also included in the calculation of EEDI reference lines, according to Resolution MEPC.231(65).
Q7: When shall the verification of the attained EEXI be carried out?
A7: During the first IAPP survey after 1-1-2023, as per MARPOL Annex VI, regulation 5.4.7. De-harmonisation of the IAPP is not encouraged.
Q8: What is a heavy load carrier in relation to EEXI?
A8: For the definition of a heavy load carrier the NSI follows the IACS recommendation 170.
An ungeared heavy load carrier is specially designed to carry outsized individual cargoes. The holds and hatches are designed for high deck loads and compared to the size of the ship, it has a low dead weight. The holds are not suitable for transporting bulk cargoes.
According to this IACS recommendation, endorsement for specific ship types mentioned shall be sought with the NSI.
Q9: Are open-top ships exempted from the EEXI requirements?
A9: Only the 'open-top notation' is not enough to be exempted from the EEXI requirements. This is still depending on the ships type and when this is a 'open-top general cargo ship' it should fulfil the EEXI requirements. When the owner wants to exempt the 'open-top general cargo ship', it has to be proven that there is a reduction in carrying capacity and / or an increased propulsion power for the ship type because of its specialized nature.
Q10: When the ship will fall outside of the reference line, is it still required to calculate the attained EEXI?
A10: Calculation of the attained EEXI is required, although the relaxation as mentioned in Resolution MEPC.350(78) may be applied
Q11: Is EEXI applicable to fishing ships >400 GT making international voyages?
A11: No, fishing ships are an exempted ship type.
Q12: Which ships fall into the scope for the EEXI?
A12: The ship categories for which reference lines were calculated and which are in the scope of EEXI, based on MARPOL Annex VI, regulation 23(.1), are:
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Annex VI, regulation:
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Ship category:
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Description:
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2.2.5
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Bulk Carrier
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means a ship which is intended primarily to carry dry cargo in bulk, including such types as ore carriers as defined in SOLAS chapter XII, regulation 1, but excluding combination carriers
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2.2.7
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Combination carrier
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means a ship designed to load 100% deadweight with both liquid and dry cargo in bulk.
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2.2.9
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Containership
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means a ship designed exclusively for the carriage of containers in holds and on deck.
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2.2.11
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Cruise passenger ship
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means a passenger ship not having a cargo deck, designed exclusively for commercial transportation of passengers in overnight accommodations on a sea voyage.
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2.2.14
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Gas carrier
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means a cargo ship, other than an LNG carrier as defined in paragraph 2.16 of this regulation, constructed or adapted and used for the carriage in bulk of any liquefied gas
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2.2.15
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General cargo ship
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means a ship with a multi-deck or single deck hull designed primarily for the carriage of general cargo. This definition excludes specialized dry cargo ships, which are not included in the calculation of reference lines for general cargo ships, namely livestock carrier, barge carrier, heavy load carrier, yacht carrier, nuclear fuel carrier
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2.2.16
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LNG carrier
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means a cargo ship constructed or adapted and used for the carriage in bulk of liquefied natural gas (LNG).
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2.2.22
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Refrigerated cargo carrier
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means a ship designed exclusively for the carriage of refrigerated cargoes in holds.
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2.2.26
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Ro-ro cargo ship
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means a ship designed for the carriage of roll-on-roll-off cargo transportation units
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2.2.27
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Ro-ro cargo ship (vehicle carrier)
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means a multi deck roll-on-roll-off cargo ship designed for the carriage of empty cars and trucks
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2.2.28
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Ro-ro passenger ship
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means a passenger ship with roll-on-roll-off cargo spaces
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2.2.29
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Tanker
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means an oil tanker as defined in MARPOL Annex I, regulation 1 or a chemical tanker or an NLS tanker as defined in MARPOL Annex II, regulation 1.
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The ship types (based on above mentioned ship categories) which are not included in the calculation of reference lines for use with the EEDI are described in Resolution MEPC.231(65), Table 2. Subsequently, the following ships are outside of the scope of EEDI:
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Ship category:
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Ship type:
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Description:
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0.1 Bulk carrier
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Bulk carrier, laker only
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A single deck cargo vessel with dimensions suited to the limitations of Great Lakes of North America trade, unsuitable for open sea navigation. Hatches are more numerous than standard bulk carriers, and much wider than they are long.
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Bulk carrier (with vehicle decks)
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A bulk carrier with movable decks for the additional carriage of new vehicles.
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Bulk/oil carrier (OBO)
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A bulk carrier arranged for the alternative(but not simultaneous) carriage of crude oil
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Ore/oil carrier
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An ore carrier arranged for the alternative(but not simultaneous) carriage of crude oil.
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Ore/bulk/products carrier
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A bulk carrier arranged for the alternative(but not simultaneous) carriage of oilproducts.
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Bulk cargo carrier, self-discharging, laker
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A Great Lakes bulk carrier fitted with a conveyor belt
(or similar system) and a boom which can discharge cargo alongside or to shore without the assistance of any external equipment.
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Powder carrier
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A single deck cargo vessel for the carriage of fine powders such as fly ash. There are no weather deck hatches.
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Refine sugar carrier
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A single deck cargo vessel for the carriage of refined sugar. Sugar is loaded in bulk and bagged in transit (BIBO – Bulk In – Bag Out).
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0.2 Gas carrier
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LPG/chemical tanker
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An LPG tanker additionally capable of the carriage of chemical products as defined in the International Bulk Chemical Code.
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0.3 Tanker
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Shuttle tanker
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A tanker for the bulk carriage of crude oil specifically for operation between offshore terminals and refineries. Is typically fitted with bow loading facilities.
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0.4 Containership
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Passenger/
containership
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A containership with accommodation for the carriage of more
than 12 passengers.
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0.5 General Cargo ship
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Open hatch cargo ship
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A large single deck cargo vessel with fullwidth hatches and boxed holds for the carriage of unitized dry cargo such as forest products and containers. Many are fitted with a gantry crane.
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General cargo/tanker(container/oil/bulk – COB ship)
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A general cargo ship with reversible hatch covers; one side is flush and the other is fitted with baffles for use with liquid cargoes. Containers can be carried on thehatch covers in dry cargo mode.
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General cargo/
tanker
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A general cargo ship fitted with tanks forthe additional carriage of liquid cargo.
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Deck cargo ship
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A vessel arranged for carrying unitized cargo on deck only. Access may be by use of a ro-ro ramp.
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General cargo/
passenger ship
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A general cargo ship with accommodation for the carriage of more
than 12 passengers.
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Livestock carrier
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A cargo vessel arranged for the carriage of livestock.
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Barge carrier
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A cargo vessel arranged for the carriage of purpose built barges (lighters) loaded with cargo. Typically loading is by way of a gantry crane. Also known as Lighter Aboard SHip vessels (LASH).
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Heavy load carrier, semi-submersible
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A heavy load carrier which is semi-submersible for the float onloading/unloading of the cargoes. (see Q8 of this document)
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Yacht carrier,
semi-submersible
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A semi-submersible heavy load carrier specifically arranged for the carriage of yachts. (see Q8 of this document)
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Nuclear fuel carrier
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A cargo vessel arranged to carry nuclear fuel in flasks.
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Nuclear fuel carrier (with ro-ro facility)
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A nuclear fuel carrier which is loaded and unloaded by way of a ro‑ro ramp.
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Barge carrier,
semi-submersible
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A barge carrier which is semi-submersible for the float on loading/unloading of the barges.
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Heavy load carrier
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A cargo vessel able to carry heavy and/or outsized individual cargoes. Cargo may be carried on deck or in holds and may be loaded by crane and/or ro-ro ramps. (see Q8 of this document)
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Q13: Which attained EEXI is to be used for a ship which falls into more than one ship category?
A13: For ships which are falling into more than one categories of ships, as per MARPOL Annex VI, regulation 23(.1), the most stringent attained EEXI, as calculated for the categories the ship falls into, shall be used.
Q14: Which CII is to be used for a ship which may fall into more than one ship category?
A14: For ships which are falling into more than one categories of ships, as per MARPOL Annex VI, regulation 28(.1), the most stringent attained annual operational CII, as calculated for the categories the ship may fall into, shall be used.
Q15: Can the time in port be included in the voyage period for when applying voyage adjustments?
A15: When an ice-classed ship sails in ice conditions to and from a port within the same sea area within the same ice edge:
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the period of time the ship is in that port (port period) may be included in either the voyage period to that port or the voyage period from that port; and
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all fuel consumption for that port period may be included in the voyage adjustment to the calculation of the attained annual operational CII.
For further clarification and instructions see Resolution MEPC.355(78).
Q16: Do the Netherlands' have interpretations on the requirements for the arrangement Shaft Power Limitation (ShaPoLi)
A16: The system should comply with both Res.MEPC.335(76) and IACS Rec. No. 172 - EEXI Implementation Guidelines and it must be approved by Class.
In Section 2.1(.1.3) of Res.MEPC.335(76) the general system requirements for the ShaPoLi among others include 'a control unit for calculation and limitation of the power transmitted by shaft to the propeller(s).'
Section 6.6 of the IACS Rec. No. 172 guideline states that 'this control unit can be independent from the engine automation' and furthermore states that 'Override of limitation should be indicated by giving an alarm'.
Since Res.MEPC.335(76) does not require the ShaPoLi to operate automatically, there is no objection if a ShaPoLi is installed that does not automatically reduce engine power. This means that the power limit function specified by Res.MEPC.335(76) can be arranged as described in section 6.6 of IACS Rec. No. 172. The navigator's acknowledgement of the alarm, followed by manual reduction of speed command is considered as equivalent to automatic power limitation through the ShaPoLi system.