Marine Advisory: 24/2023 - Ability to Override Engine or Shaft Power Limiting Devices

25 September 2023 Marine Advisory: 24/2023

SUBJECT: Ability to Override Engine or Shaft Power Limiting Devices Dear Shipowners/Operators/Masters and Recognized Organizations: PURPOSE:

The purpose of this Marine Advisory is to inform about the Houston Pilots Dispatch Notice issued on the Ability to Override Engine or Shaft Power Limiting Devices.

BACKGROUND:

In order to comply with recent requirements aimed at reducing greenhouse gas emissions, some vessel operators have installed (or modified existing) engine power or shaft power limiters. In some cases, these limiters may reduce vessel maneuverability in a confined channel, such as the Houston Ship Channel, to an unacceptable level.

For your reference, Section 2.04 of the Houston Pilots Navigation Safety Guidelines states:

2.04 Engine Revolutions

1. The maneuvering revolutions and resultant speeds established for a vessel by her builders and designers must be posted and made available to the Pilot upon boarding. All vessels maneuvering in the Houston Ship Channel must be capable of promptly attaining the maneuvering RPMs as posted in the vessel's wheelhouse.
2. All vessels must be able to alter engine speed and direction promptly considering vessels of similar class and engine type. Vessels must be able to answer all engine and helm commands at all times while underway. Any load limiting or automatic acceleration limiting devices or software that would limit the speed of response to engine orders must be capable of being overridden immediately by the Master or Mate on watch from the bridge in case of an emergency.
3. Any vessel without the capacity to attain its posted RPMs in a timely fashion because of engine maintenance, engine break in requirements, or engine power limiting devices that cannot be overridden may, be restricted to daylight transit and/or additional Pilotage or tug requirements.

To identify vessels that may pose additional risk to the channel due to a power limiting device,

Houston Pilots Dispatch will, at the time an order for pilotage is taken, request the following information:

• • Is the vessel equipped with an engine or shaft power limiter?
  • If yes, is the limiter mechanical or software based?
  • If the vessel is equipped with a mechanical limiter, will it be removed or disabled prior to Pilot boarding?
  • If the vessel is equipped with a software-based limiter, will the ship's crew be able to override it immediately at the request of the Pilot?

The attending Pilot for the vessel transit will confirm the information provided previously to Dispatch during the Master/Pilot exchange.

Houston Pilots encourages all vessel operators and their crews to identify and discuss any potential internal compliance issues related to overriding engine or shaft power limiters prior to their vessel arriving in Houston. While the attending Pilot may request that the power limiter device be overridden, the Pilot may or may not access the additional power allowed depending on the conditions present during the transit.

Any vessels that arrive in Houston that are unable or unwilling to override a power limiter may be subject to transit risk mitigations including, but not limited to: daylight restrictions, additional Pilotage, tug requirements/escorts.

The Houston Pilots Dispatch Notice is attached for ready reference. Please also refer to 15.10 of Marine Notice POL-009, “Overridable Shaft-Engine Power Limitation System (SHaPoLi

/EPL)”.

The Liberian Administration is bringing this to the attention of Vessel Owners/Operators/Masters and Recognized Organizations, and recommends that measures be implemented on board vessels calling Houston so crew are aware of these Houston Pilots requirements and are able to provide the requested information in a timely manner.

Questions regarding this guidance should be referred to regsandstandards@liscr.com or you may call +1-703-790-3434.

* * * * *

September 1, 2023

HOUSTON PILOTS

203 DEERWOOD GLEN DRIVE / DEER PARK, TEXAS 77536

Subj: Ability to override engine or shaft power limiting devices Dear Agent/Ship Operator,

In order to comply with recent International Maritime Organization requirements aimed at reducing greenhouse gas emissions, some vessel operators have installed (or modified existing) engine power or shaft power limiters. In some cases, these limiters may reduce vessel maneuverability in a confined channel, such as the Houston Ship Channel, to an unacceptable level. For your reference. Section 2.04 of the Houston Pilots Navigation Safety Guidelines states:

2.04 Engine Revolutions

1. The maneuvering revolutions and resultant speeds established for a vessel by her builders and designers must be posted and made available to the Pilot upon boarding. All vessels maneuvering in the Houston Ship Channel must be capable of promptly attaining the maneuvering RPMs as posted in the vessel's wheelhouse.
2. All vessels must be able to alter engine speed and direction promptly considering vessels of similar class and engine type. Vessels must be able to answer all engine and helm commands at all times while underway. Any load limiting or automatic acceleration limiting devices or software that would limit the speed of response to engine orders must be capable of being overridden immediately by the Master or Mate on watch from the bridge in case of an emergency.
3. Any vessel without the capacity to attain its posted RPMs in a timely fashion because of engine maintenance, engine break in requirements, or engine power limiting devices that cannot be overridden may, be restricted to daylight transit and/or additional Pilotage or tug requirements.

To identify vessels that may pose additional risk to the channel due to a power limiting device, Houston Pilots Dispatch will, at the time an order for pilotage is taken, request the following information:

• Is the vessel equipped with an engine or shaft power limiter? o If yes, is the limiter mechanical or software based?
• If the vessel is equipped with a mechanical limiter, will it be removed or disabled prior to Pilot boarding?
• If the vessel is equipped with a software-based limiter, will the ship's crew be able to override it immediately at the request of the Pilot?

September 1, 2023

The attending Pilot for the vessel transit will confirm the information provided previously to Dispatch during the Master/Pilot exchange.

Houston Pilots encourage all vessel operators and their crews to identify and discuss any potential internal compliance issues related to overriding engine or shaft power limiters prior to their vessel arriving in Houston. While the attending Pilot may request that the power limiter device be overridden, the Pilot may or may not access the additional power allowed depending of the conditions present during the transit.

Any vessels that arrive in Houston that are unable or unwilling to override a power limiter may be subject to transit risk mitigations including, but not limited to: daylight restrictions, additional Pilotage, tug requirements/escorts.

If you have any questions, or need any amplifying information, please contact Houston Pilots Dispatch at 281-476-8201.

Respectfully,

Captain Clint Winegar

Presiding Officer, Houston Pilots

Encl: Coast Guard Sector Houston-Galveston Marine Safety Information Bulletin 5-23