IMSML Website Article 31/2024: Resolution MEPC.365(79) - Adoption of 2022 Guidelines on Survey and Certification of the Energy Efficiency Design Index (EEDI)

This article is a continuing of the measures found in Appendix 1 of Malaysian Shipping Notice (MSN 08 / 2023), where Malaysia implements Resolutions Adopted by the 79th Marine Environment Protection Committee (MEPC 79). More specifically, this article is on Annex 10 which contains the Resolution of MEPC.365(79) which provides details of the 2022 Guidelines on Survey and Certification of EEDI. The guidelines dovetail with Regulation 5 of MARPOL Annex VI (as amended) which deal with 'Surveys'.

Resolution MEPC.365(79) is an 'invitation' by IMO's Marine Environment Protection Committee to member states to enact national laws which give force to and implement set forth in MARPOL Annex VI (as amended). The 2022 Guideline supersedes the 2014 Guidelines which were originally brought into force by Resolution MEPC.254(67) as amended by Resolutions MEPC.261(68) and MEPC.309(73) respectively.

Guideline 2 - Defintions

A 'verifier' is an 'administration' or 'organisation duly authorised by it', which conducts the survey and certification of EEDI, see Guideline 2.1. What amounts to a 'ship of the same type' takes into account lines such as sheer plan and body plan. However, this excludes additional hull features such as fins, and principal particulars of which are identical to that of the base ship, see Guideline 2.2.

A 'tank test' under Guideline 2.3 includes:

[1] Model towing tests;

[2] Model self-propulsion tests;

[3] Model propeller open water tests.

Note, that under Guideline 2.3, 'numerical calculations' may be:

[1] Accepted as equivalent to model propeller open water tests; OR

[2] Used to complement the tank test conducted (eg to evaluate the effect of additional hull features such as fins, etc on ship's performance). Of course, this must have the approval of the verifier.

Guideline 3 - Application

The 2022 Guidelines are applicable to 'new ships'. There must be an application for:

[1] An initial survey;

[2] Additional survey.

Note, that these are surveys specified in Regulation 5 of MARPOL Annex VI, and have been submitted to a 'verifier'.

Guideline 4 - Procedures for Survey and Certification

Regulation 22 of MARPOL Annex VI and the EEDI 2022 Guidelines is the basis on which the attained EEDI is calculated, see Guideline 4.1.1. According to the 2022 Guidelines, there are two stages for the survey and certification of the EEDI:

[1] Stage 1 - Preliminary verification at the design stage;

[2] Stage 2 - Final verification at sea trial.

The information provided to the verifier may contain confidential information. This may require the protection of intellectual property rights, and the verifier may have to sign a non-disclosure agreement, see Guideline 4.1.2.

The verifier should be given the necessary information for the verification process (and other relevant background documents), see Guideline 4.2.1. The EEDI Technical File should be written in English and should contain, see Guideline 4.2.2:

[1] Deadweight (DWT) or Gross tonnage (GT);

[2] Maximum continuous rating (MCR) of the main and auxiliary engine;

[3] Ship speed;

[4] Fuel type;

[5] Specific Fuel Consumption (SFC);

[6] Estimated power curve;

[7] Principal particulars and classification notations of the propulsion system and electricity supply system;

[8] Description of energy-saving equipment;

[9] Calculated value of attained EEDI;

[10] Specifically for LNG carriers:

[a] Type and outline of propulsion systems;

[b] LNG Cargo Tank Capacity;

[c] Shaft power of propeller shaft;

[d] Maximum continuous rated power for steam turbine;

Guideline 4.2.3 provides for ships equipped with dual-fuel engine(s), eg LNG and Fuel Oil. The specific fuel consumption of gas fuel should be applied, taking to account that:

[1] The final decision on primary fuel rests with IMO;

[2] The ratio of calorific value of gas fuel (LNG) to total marine fuels (HFO/MGO) at design conditions should be equal or larger than 50 percent, taking into account a formula which takes into account the total net tank volume of gas fuel to the density of gas fuel, to the calorific value of gas fuel to the filling rate of such fuel.

According to Guidelines 4.2.4, the specific fuel consumption (SFC) of both the main and auxiliary engines should be quoted from the approved NOX Technical File. Correction can then be made by reference to ISO 15550:2002 and ISO 3046-1:2002. If the NOX Technical File has not been approved at the time of the application of the initial survey, the test reports of the manufacturers should be used.

Ships governed by MARPOL, Annex VI, Regulation 24, are subject to a tank test which generates results the power curve for preliminary verification. If there are tank test of ships of the same type, there may be no need to conduct a tank test as the technical justification is available. This preferably requires the agreement of the shipowner, shipbuilder and approval of the verifier, see Guideline 4.2.5.

Pursuant to Guideline 4.2.7, a non-exhaustive list of the following additional information may be requested by the verifier:

[1] Description of the tank test facility;

[2] Lines of a model ship and an actual ship for verification that the tank test was appropriate;

[3] For verification of the deadweight, the lightweight of the ship and its displacement table;

[4] Method and results of the tank test in a detailed report;

[5] Detailed calculation process of the ship’s speed (including roughness coefficient and wake scaling coefficient);

[6] Where exempted, reasons for exempting a tank test.

Before a sea-trial is conducted, Guideline 4.3.2 requires the following documents to be submitted:

[1] A description of the test procedure for the speed trial;

[2] Final displacement table;

[3] Measured lightweight;

[4] Survey report of deadweight;

[5] NOX Technical File (as necessary).

[6] Description of all the necessary items to be measured and corresponding measurement methods used for developing the power curve under sea trial conditions.

Guideline 4.3.3 mandates that the verifiers attend the sea trial to confirm the following:

[1] Propulsion and power supply systems;

[2] Draughty and trim;

Note, this can be confirmed prior to the sea trial and should be as close as practical to those assumed conditions used for estimating the power curves, see Guideline 4.3.4.

[3] Sea conditions;

Note, Measured in accordance with ITTC Recommended Procedure 7.5-04-01-01.1 Preparation, Conduct and Analysis of Speed/Power Trials (2017, 2021 or 2022 version, as may be applicable at the time of sea trials) or ISO 15016:2015, see Guideline 4.3.5.

[4] Ship’s speed; and …

[5] Shaft power and RPM.

Note, The main engine output, shaft power of propeller shaft (for LNG carriers having diesel electric propulsion system) or steam turbine output (for LNG carriers having steam turbine propulsion system) should be measured by shaft power meter or a method which the engine manufacturer recommends and the verifier approves, see Guideline 4.3.7.

If differences are observed between the estimated power curves and the results of the sea trials, the attained EEDI should be recalculated, see Guideline 4.3.9. For this recalculation, please refer to the EEDI Calculation Guidelines, in particular Paragraph 2.2.2 and 2.2.5. If this cannot be done, the shipbuilder should recalculate the attained EEDI by adjusting the ship speed using an appropriate correction method agreed by the verifier, see Guideline 4.3.9. For gross tonnage, this should be confirmed by the Tonnage Certificate of the ship, see Guideline 4.3.10.

Where there is a major conversion of the ship, Guideline 4.4.1 requires an additional survey with a duly revised EEDI Technical File, taking into account the actual conversion made and other relevant background documents. Pursuant to Guideline 4.4.2, the non-exhaustive list of background documents include:

[1] Details of the conversion;

[2] EEDI parameters changed after the conversion. Technical justification should be provided for each respective parameter;

[3] Reasons for other changes made in the EEDI Technical File (if any); AND …

[4] Calculation summary of the attained EEDI (with each value of the calculation parameters and the calculation process used to determine the value post-conversion).

The verifier should verify the calculation process for the attained EEDI to ensure that it is sound and reasonable, see Guideline 4.4.3. Note, that this should follow Regulation 22 of MARPOl Annex VI and the EEDI Calculation Guidelines. Speed trial are required for verification of the attained EEDI post-conversion.

Appendix 1 - Sample of EEDI Technical File

The file starts with Data. General information to be provided includes shipbuilder, hull no., IMO no., and Ship type. Principal particular to be filled in includes overall length, the length between perpendiculars, breadth and depth (both moulded), summer load line draught (also moulded) and deadweight at summer load line draught, see Paragraph 1.1 and 1.2.

Main engine details include manufacturer, type, maximum continuous rating (MCR), SFC at 75 percent MCR, number of set and fuel type. Similar particulars of the auxiliary engine are also required, see Paragraph 1.3 and 1.4.

Ship speed in deep water at summer load line draught at 75 percent of MCR need to be provided in the file, see Paragraph 1.5.

The power curve estimated at the design stage and modified after the speed trials are to be plotted. It is based on speed in knots and the BHP in kW, see Paragraph 2.

Details of the propulsion system include its primary feature, the main engine, see Paragraph 3.1 and 3.2. For the propeller the following details are required: Type, diameter, number of blades and number of set, see Paragraph 3.1.2. The electrical power system consists of the auxiliary engines (see Paragraph 3.2.1) and Main Generators (see Paragraph 3.2.2). Details required for the main generator include: Manufacturer, Rates Output, Voltage and Number of Set.

The estimation process of power curves at the design stage is provided for in Paragraph 4. This is a flow chart that starts with tank test and moves onto estimation of resistance of the full scale ship, estimation of self-propulsion factors and estimation of propeller open water characteristics. It ends with calculation of the propulsion power of the full scale ship, which is then used to determine the speed and generate the power curves, see flow chart in Figure 4.1.

Description of energy-saving equipment is found in Paragraph 5. The effect of the energy saving are reflected in the EEDI Calculation Formula, see Paragraph 5.1. Other energy-saving equipment can also be documented. For example, rudder fins and propeller boss cap fins, see Paragraph 5.2.

The calculated value of attained EEDI is provided for in Paragraph 6. Calculations start with the basic data (see Paragraph 6.1), then move on to the main engine (see Paragraph 6.2) and then the auxiliary engines (see Paragraph 6.3). Then the calculated value is generated for the attained EEDI, see Paragraph 6.8).

To take into account the weather, there is a value generated for a specific attained EEDI for weather, see Paragraph 7. This value takes into account representative sea conditions (such as mean wind speed, mean wind direction, significant wave height, mean wave period and mean wave direction), see Paragraph 7.1. The figures are then used to produce a calculate weather factor, see f(w) at Paragraph 7.2, and calculated value of attained EEDI for the weather, see Paragraph 7.3.

Appendix 2 - Guidelines for Validation of Electric Power Tables for EEDI (EPT-EEDI)

These guidelines will assist in the compliance with IMO validation of electric power tables )EPT) for the calculation of Energy Efficiency Design Index (EEDI), see Paragraph 1. The guidelines ensure a uniformity of the validation process for the required auxiliary engine power, see Paragraph 2. There are specific definition in Paragraph 3 for ‘Applicant’, ‘Validator’, ‘Validation’ all the way to ‘Diversity factor’.

Paragraph 4 - Application

The Guidelines in Appendix 2 are applicable to new ships where an application for an EPT-EEDI validation has been submitted to a validator, see Paragraph 4.2. Paragraph 4.3 clarifies that there are three distinct stages in the validation process:

[1] Stage 1 - Review of documents during the design stage;

[2] Stage 2 - Survey of installed systems and components during construction stage;

[3] Stage 3 - Survey of sea trials.

Paragraph 5 - Supporting Documents

At the very least, the ship electric balance load analysis should be provided, see Paragraph 5.1. As such information is likely to contain confidential information, all or part of it may be returned to the applicant upon request, see Paragraph 5.2. A special column should be inserted into the EPT for any special EEDI condition during sea trials, see Paragraph 5.3.

Paragraph 6 - Procedures for Validation

Preliminary validation starts at the design stage under Paragraph 6.2. The application must have of EPT-EEDImForm, and all the relevant and necessary information, plus the supporting documents, see Paragraph 6.2.1 and 6.2.2. The validator may request for additional information to validate the calculation process taking into account best maritime practices, see Paragraph 6.2.3.

Final validation should at least involve a check of the ship’s electric load analysis. This is to ensure that all electric consumers are listed, with the specific data and calculations in the power table are correct as well as being supported by data from the sea trials, see Paragraph 6.3.1.

Revision of the EPT-EEDI Form and supporting documents may be necessary for the final validation. This revision could be influenced by machinery characteristics and other electrical loads actually installed on board the ship. Changes in the EPT from the design stage to the construction stage should be highlighted to the shipyard, see Paragraph 6.3.2.

Under Paragraph 6.3.3, a desktop check for final validation includes:

[1] Consistency of preliminary and final EPT;

[2] Change of service factors;

[3] Listing of all electric consumers;

[4] Ensure that the specific data and calculations in the power table are correct;

[5] Checking of component specification data (where there is doubt).

A pre-sea trials survey can be conducted with a random number of sample to check machinery characteristics and other electrical loads, see Paragraph 6.3.4. Later during sea trials, a surveyor can check the predicted overall value of electric load by making practical measurements with installed measurement devices, see Paragraph 6.3.5.

Paragraph 7 - Issuance of the EPT-EEDI Statement of Validation

After validating the EPT-EEDI at the preliminary validation stage, the validator should stamp ‘Noted’ on the form, see Paragraph 7.1. After final validation, the validator should stamp ‘Endorsed’ on the EPT-EEDI form, see Paragraph 7.2.

Appendix 3 - Electric Power Table Form for Energy Efficiency Design Index (EPT-EEDI FORM) and Statement of Validation

This form starts with the ‘ship’s ID’ that includes:

[1] IMO no;

[2] Ship’s name;

[3] Shipyard;

[4] Hull no.

The next data is the Applicant’s name and address.

On the right hand side, one has to tick boxes which indicate whether the validation stage is ‘preliminary’ or ‘final’.

The form then requires a summary of the EPT-EEDI result. This includes the following data points:

[1] Ship service and engine loads;

[2] Accommodation and cargo loads;

[3] Diversity factor;

[4] Normal sea-going load;

[5] Weighted average efficiency of generators.

[6] List of supporting documents.

The form concludes with the details of the validator, date of the review, statement of validation number, and the signature of the Validator.

Thank you for reading IMSML Website Article 31/2024

Stay tuned for the next IMSML Website Article 32/2024: Resolution MEPC.366(79) - Invitation to Member States to Encourage Voluntary Cooperation Between the Port and Shipping Sectors to Contribute to Reducing GHG Emissions from Ships

Signing-off for today,

Dr Irwin Ooi Ui Joo, LL.B(Hons.)(Glamorgan); LL.M (Cardiff); Ph.D (Cardiff); CMILT

Professor of Maritime and Transport Law

Head of the Centre for Advocacy and Dispute Resolution

Faculty of Law

Universiti Teknologi MARA Shah Alam

Selangor, Malaysia

Tuesday, 4 June 2024

Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my