Marine Advisory: 16/2023 - Guidance on interim compliance with MARPOL Annex VI EEXI Requirements(Supersedes Marine Advisory 14/2023)

08 June 2023

Marine Advisory: 16/2023

(Supersedes Marine Advisory 14/2023)

SUBJECT: Guidance on interim compliance with MARPOL Annex VI EEXI Requirements

The following change has been included:

• 1. Guidance for annotating the short term IEEC
  2. Use of reserve power and required CII
  3. Annex on the “Use of a power reserve by un-limiting the shaft / engine power limitation”

Dear Shipowner/Operator/Master/Recognized Organizations:

The purpose of this Advisory is to provide guidance on the interim compliance with MARPOL Annex VI

EEXI requirements. Verification that a vessel’s attained EEXI is in accordance with Chapter 4 (Energy Efficiency) of the 2021 Revised MARPOL Annex VI shall take place at the first annual, intermediate or renewal survey related to the IAPP certificate, whichever is the first, on or after 1 January 2023.

This verification includes confirming that the approved EEXI Technical File is on board the vessel and if any Shaft/Engine Power Limitation system is required to be installed, confirming that:

1. the system is appropriately installed and sealed in accordance with the 2021 Guidelines on the Shaft/Engine Power Limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76)), and,
2. that a verified Onboard Management Manual (OMM) for overridable Shaft/Engine Power Limitation is on board the ship.

The Administration has received numerous requests for extension of the compliance with these requirements due to delays in procuring and installing required Shaft/Engine Power Limitation (SHaPoLi) systems.

In such a case, it is required that an Interim OMM be provided to the vessel’s class society for their verification (if the class society is unable to verify it due to time restraints, then it may be submitted to the Administration for review and verification at planapproval@liscr.com).

The Interim OMM is to describe how the energy efficiency requirements will be managed by manual control until the SHaPoLi/EPL system is installed by providing technical and operational conditions so that the power limitation method satisfies the compliance with the EEXI requirements.

The Interim OMM should also include procedures for use of reserve power, including recording and notification of same without delay to the Administration at regsandstandards@liscr.com and competent authority at the relevant port of destination, using the standardized format in the Annex to this Marine Advisory. Consideration should be given to implementing the measures in the verified SEEMP with respect to the required CII during this period.

Upon receipt of the verified Interim OMM (or after verifying the interim OMM itself), the Administration will issue a letter authorizing the use of the Interim OMM for the time necessary to install the SHaPoLi/EPL system and authorize the issuance of a short term IEEC for the same period along with the reissuance of the record of construction related to the IEEC duly completed in the revised format prescribed in Appendix VIII of the 2021 Revised MARPOL Annex VI.

The short term IEEC should be issued with an annotation that the Administration has permitted the implementation measures for temporary compliance with the EEXI requirements in the interim OMM, pending installation of the SHaPoLi/EPL system.

It should be noted that the IAPP survey should be completed and the IAPP certificate endorsed or renewed after completion of the survey.

Please contact the Regulations & Standards Department at regsandstandards@liscr.com or telephone +1 703 790 3434 for more information.

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ANNEX

Use of a power reserve by un-limiting the shaft / engine power limitation

1. ship type;

1. IMO number;

1. Ship size in DWT and/or GT, as applicable;

1. Ship's limited shaft / engine power and ship's maximum unlimited shaft / engine power;

1. Position of the ship and timestamp when the power reserve was used;

1. Reason for using the power reserve;

1. Beaufort number and wave height or ice condition in case of using the power reserve under adverse weather condition;

1. Supporting evidence (e.g. expected weather condition) in case of using the power reserve for avoidance action;

1. Records from the SHaPoLi / EPL system for the electronically controlled engine during the power reserve was used; and

1. Position of the ship and timestamp when the power limit was reactivated or replaced.