US Coast Guard Oversight of Recognized Organizations | National Academies

A study committee appointed by The National Academies of Sciences, Engineering, and Medicine conducted an assessment of the effectiveness of the U.S. Coast Guard's oversight of recognized organizations and its impact on compliance and on the safety of vessels inspected by such organizations during meetings this week at the J. Erik Jonsson Center in Woods Hole, MA.

Pictured here are committee members (from L): Dr. Kirsi Tikka, Ph.D. a Maritime Advisor and an Independent Non-Executive Director at Pacific Basin Shipping Limited and Ardmore Shipping Corporation, Capt. (Ret.) Kyle McAvoy of Robson Forensic, Inc., Professor Emerita Mary Brooks (Chairperson) of Dalhousie University’s Rowe School of Business, Mr. Hendrik Bruhns of Herbert Engineering Corp., Mr. Thomas R. Menzies of the Transportation Research Board: National Academies of Sciences, Engineering, and Medicine, and Medicine, Dr. William Moore of Shipowners Claims Bureau, Inc., Managers, The American P&I Club, Ms. Vicky Dlugokecki an independent engineering and management consultant, Mr. Mark Hutchins of Transportation Research Board: National Academies of Sciences, Engineering, and Medicine and Mr. Keith Michel of the Webb Institute. Committee Members attending by teleconference and not pictured: Adm. (Ret.) Jim Card formerly of the USCG and Dr. Donald Liu formerly of American Bureau of Shipping (ABS).

Learn more about the Committee and its work here: https://lnkd.in/gbjQYsP

International Port Inspection Campaign on Ship Stability – Are you ready?

The Member Authorities of the Tokyo and the Paris Memoranda of Understanding (MoU) on Port State Control will launch a joint Concentrated Inspection Campaign (CIC) on Stability (in general). The purpose of the campaign on ship’s stability is to confirm that the ship’s crew is familiar with assessing the actual stability condition on completion of cargo operations before departure of the ship and on all stages of the voyage, to create awareness among the ship’s crew and owners about the importance of calculating the actual stability condition of the ship on completion of cargo operations and before departure of the ship, and to verify that the ship complies with intact stability requirements (and damage stability requirements, if applicable) under the relevant IMO instruments. This inspection campaign started on September 1st and will last for 3 months.

 

It is expected that the Tokyo and Paris MoUs will carry out approximately 10,000 inspections during the CIC, but this is subject to any developments during the current COVID-19 pandemic. All inspections carried out will be subject to ongoing health and safety requirements in individual port States.

 

The following questions will need to be answered:

  • Has the ship been provided with approved stability information which can be understood and easily used by the Master and loading officer?

  • Is the data used in the stability check for departure complete and correct?

  • Does the ship comply with the stability criteria as applicable to the ship type?

  • Is there evidence to show that the Master or responsible officer can determine the stability of the ship under varying conditions of service using the approved stability information provided on board?

  • If the ship is provided with a Stability Instrument, is it approved by the Administration?

  • If the ship is provided with a Stability Instrument, does the type of stability software in use meet the requirements for the relevant ship type?

 

Herbert Engineering Corp. can help with any ship stability issues you may have. Please contact any of our US or international offices.

IMO MEPC 76 Meeting Approves Landmark GHG Regulations for Existing Ships

Background

In June the International Maritime Organization (IMO) held their 76th session of the Marine Environment Protection Committee (MEPC). Arguably the most important, and the most time-consuming issue on the agenda of the committee, is the regulation of Green House Gasses (GHG) from ships. Because the IMO is an agency of the United Nations (UN), IMO’s efforts on this subject have been underway since the UN 1997 Kyoto Protocol. The IMO’s GHG emission goals and ambitions are generally aligned with the UN’s 2015 Paris Accord and are officially stated as a 40% improvement in ship GHG intensity by 2030, and a 50% reduction in overall GHG emissions by 2050, both as comparison to base 2008 levels. IMO defines GHG intensity as the CO2 emissions, per ton of cargo, transported per nautical mile.

Previous approved regulations for New Ships

In their ongoing work since 1997, the IMO’s MEPC committee has approved the short-term regulation of GHG intensity improvements for new ships as regulated by the Energy Efficiency Design Index (EEDI), which has been in effect since 2013, the Ship Energy Efficiency Management Plan (SEEMP) for all ships, and the mandatory Data Collection System (DCS) for the recording of fuel oil consumption of all ships beginning in 2019. EEDI began in 2013 with Phase 0, mandatory compliance for new ship beginning with Phase 1 in 2015, and is now in Phase 2, with discussion currently on the required Phase 3 and phase 4 reduction levels.

Development of regulations for Existing Ships

The IMO regulations for short-term measures for existing ships have been under development for several years and were required to be finalized at this sessions MEPC meeting in order to be implemented on schedule, beginning in 2023. What has now been approved, in addition to the EEDI standard for new ships, is a one-time only standard for existing ships called the Energy Efficiency Existing Ship Index (EEXI), and an ongoing regulation for all ships, new and existing, called Carbon Intensity Indicator (CII). All the current and proposed IMO GHG regulations use the ships deadweight for an approximation of cargo carried, since cargo is not recorded as part of the DCS system.

The new EEXI is essentially the one-time 2023 application of EEDI to all existing ships, generally at the EEDI Phase 2 levels. Ships that do not meet the EEXI requirements will typically be required to implement engine power limits to improve their GHG intensities efficiencies, or switch to lower carbon density fuels like LNG.  We anticipate that EEXI will have minimal impact on newer ships in the world fleet that are currently slow steaming or are operating at efficient speeds compared to 2008 levels. However, a significant portion of existing ships are older and less efficient or are designed and operated at higher operational speeds near their MCR ratings. These ships will face substantial power limits and speed reductions beginning in 2023.

The new CII, unlike EEDI and EEXI, is not a design rating, but rather an operational rating based on actual fuel consumed. (Think of this as EEDI being analogous to the window sticker mileage rating on a new automobile, and CII as the actual average mileage that the automobile achieves each year.) CII is also an ongoing rating standard, with progressively higher efficiency standards each year, through 2030.

Setting the initial value and annual reduction rates for CII

The major discussion at this recent MEPC 76 meeting was about the starting value of CII for 2023 and the annual reduction rates for the years 2023 through 2030.

IMO CII.png

From the plot above it can be seen that the GHG efficiencies of the world shipping fleet have continually improved since 2008 and have been measured by the 4th GHG Study to be 78% of the 2008 values in 2018. These improvements are primarily the result of three contributing factors:

 - general ship and engine efficiency improvements,
 - larger more efficient ships replacing smaller less efficient ships, and
 - existing ships operated at lower speeds (slow steaming) 

What was agreed and approved at MEPC 76

It can be seen from the figure above that the GHG intensity values for the world fleet have been generally on track toward the IMO’s target of 60% of 2008 GHG levels (a 40% improvement). The recently approved CII starting level in 2023, assumes these trends should generally continue between 2018 and 2022, to establish the 2023 starting value of CII. The approved reduction factors for 2024, 2025, and 2026, at 2% per year, have been set based on maintaining this general trajectory for existing ships toward the IMO 2030 intensity goal. Since GHG emissions and attained emissions levels will be continually monitored, it was decided that the reduction levels for 2027 through 2030, could be deferred and decided later, so that they could be adjusted as necessary to assure a trajectory meeting the IMO goal.

Some countries (including the USA) and some Non-Governmental Organizations (NGO) recommended substantially higher reduction rates for CII. But most of the IMO represented countries felt that the proposed values were meeting the agreed target GHG reductions and could be adjusted after 2026 if required based on monitoring of the world fleet.

CII, while not perfect, is a landmark regulation that will significantly impact many of the world’s existing ships over the next decade. Its requirements are significantly more than business-as-usual and will push the global maritime industry on an overall trajectory towards meeting the IMO’s 2030 goal of a 40% improvement in GHG intensity by 2030.

What’s Next

Concurrent with the implementation of these “short-term” measures, IMO has also started down the path of the development of mid- and long-term technical and market- based measures. These efforts will be essential to meet IMO’s ambitious further goal of 50% total GHG reductions for the ever-growing world maritime fleet compared to 2008 levels by 2050. It is generally believed, that to attain these ambitious goals, by 2030 most new ships will need to be based on alternative low carbon fuels and shipboard technologies that are still under development and not currently readily available. In addition to technical GHG emission regulations, many countries and NGOs believe that market-based measures such as fossil fuel taxes or carbon levies will be necessary to incentivize the necessary investments in ship decarbonization research, prototype installations, as well as fuel production and fuel delivery infrastructure for the future near-zero carbon fuels. Those could be renewably produced hydrogen, ammonia, methanol, and other bio- and synthetic-fuels. IMO’s work on these mid- and long-term measures begins in earnest at the next IMO MEPC session beginning on in late November 2021.

These will be challenging times for ship owners and operators, and they should start by evaluating their existing fleet for compliance.  The impacts of EEXI and CII could be felt sooner and be more severe (in terms of cost and service viability) than rule changes that have been promulgated in the past.  Allowable service speeds (and fuel consumption) may be reduced as early as 2023 with EEXI, or potentially more significantly in following years under CII.  This will impact fleet deployments, decisions on when to make changes in fuel and whether another carbon-based fuel such as LNG is the right move.  Ship scrapping or sale and newbuilding plans could be impacted.  To the extent the entire world fleet is affected, building slots may be more difficult to find.

Herbert Engineering is using its decades of fleet evaluation and ship design and acquisition support experience to help owners understand these changes in their operations and newbuilding plans.  This includes not just a calculation of power limits or design speed reductions, but evaluation of what these limits might mean for actual in-service capabilities, impact on sea margins, and make up speeds, etc.  Some may find little impact until 2030 because of earlier steps taken to slow steam or reduce emissions.  Others may need an overhaul of their fleet deployments, major modifications, fuel conversions, or operational practices (speeds, available sea margin, schedule reliability). 

Herbert Engineering is perfectly positioned with the tools and experience to help our clients with their fleet evaluations and transition planning to meet these new short-term regulations in the most economical way possible, and to contribute to designing future deep-sea ocean cargo transport ships with near-zero carbon emissions.

 

 

Hendrik Bruhns appointed as President of HEC

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Hendrik Bruhns succeeds Spencer Schilling who will formally step down as President on July 1st, 2021. Spencer Schilling, who has worked for HEC for 38 years, 14 of them as President, is happy to pass the torch to the next generation. Spencer explained, “I have been privileged to work with a very talented team here at HEC and our wonderful clients trusted us with interesting and challenging work. We have capable and experienced staff and Hendrik is the perfect person to lead this group into a very exciting future and a continuation of the HEC legacy.” Spencer will remain as a member of the HEC Board of Directors and also remain active in the company, although at reduced levels, to further support Hendrik through this critical transition of management duties and client relationships.  

Hendrik Bruhns, a trained naval architect comes from an 11-year commitment as President of the HEC affiliate and maritime software firm, Herbert-ABS Software Solutions LLC. Hendrik was responsible for all aspects of marketing and operations and successfully improved the customer experience, reinforced the organization's financial strength, and guided investment in new digital capabilities. He started his professional career at MEC Marine Equipment & Consulting, working on container cell guides and lashing equipment. Later he joined the Stability Department of Germanischer Lloyd—heading the stability department from 2002-2008—where he was in charge of planning, approval, coordination, and implementation of ship safety and environmental protection projects, particularly intact and damage stability, ballast water management, fuel tank protection, and collision strength. 

Hendrik had been serving as an Executive Vice President and Manager of Business Development for HEC since January 1, 2021. This transition coupled with his service on the HEC board since 2009, and his time as President of Herbert-ABS, makes him well qualified for management at the highest level and for proper care and support of HEC’s strong client relationships that have developed over the years.

Hendrik Bruhns’ focus will be the continuation of HEC’s offerings in naval architecture, cutting-edge consulting services for ship-design and vessel acquisition, structural and ship stability analysis, and risk and repair assessments. Hendrik will also continue to serve Herbert-ABS Software Solutions LLC as a Board Director, and when necessary, will support Michael Newton, recently appointed as President of the software company. HEC’s 50% stake in Herbert-ABS Software Solutions make their relationship quite unique in the industry as a marine software and engineering firm.

Hendrik Bruhns says that “the success of Herbert Engineering Corp is due to the work culture driven by employee ownership, combined with the mentorship of its up-and-coming talent. These knowledge-sharing investments ensure the success of next generation leaders." 

Fifty-eight years ago, HEC was born from a pioneering spirit and is solidly positioned as a maritime authority with global offices that operate as a single entity with quality procedures and project management implemented on a company-wide basis. HEC’s global reach, with its headquarters in Alameda (San Francisco) and offices globally dispersed in Asia, Europe, Annapolis, and Houston, enables HEC to efficiently serve a diverse spectrum of clients. Maintaining leadership continuity is a key factor of HEC's success; therefore, Hendrik’s position as Chairman of the Board for HEC’s Shanghai company will also remain unchanged.

Hendrik notes that “HEC also offers great value in their ability to produce technically rational, cost-efficient energy solutions and emission-reduction measures to meet regulatory compliance.” Their participation in the International Maritime Organization—the United Nations' specialized agency for the safety of shipping and the prevention of pollution by ships—has also led HEC to their regulatory and technical solutions focus. "The devil is in the details, says Bruhns, so a strong regulatory knowledge in interpreting regulations and guidelines is another pivotal HEC strength.” Hendrik’s participation in the National Academy of Science and a past member of IMO delegations, holding numerous committee positions since 2002, also make Hendrik the informed, forward-looking leader ideally suited to Herbert Engineering.

 

Observations from the 4th IMO GHG Study

Background:

In July 2020, the IMO 4th GHG study was released, and the highlights and an executive summary were presented as a submission to IMO’s Marine Environmental Protection Committee for discussion at the upcoming MEPC 75 (virtual meeting scheduled on 16-20 November 2020). The study was conducted by an international group of experts from academia, Class societies, and non-governmental organizations, with data contributions from BIMCO, Maersk, the World Shipping Council, and others. Previous studies published in 2000, 2009, and 2014, have been used by IMO in addressing the GHG emissions from ships. Each subsequent study has improved on the methodologies used to quantify emissions to date and to project future GHG emissions. Previous, current, and future Studies are intended to promote reasoned debate at IMO and to measure the effectiveness of IMO regulations on GHG emissions.


Some Highlights from the 4th GHG Study:

  • Between 2012-2018:

o   GHG emissions from shipping increased 9.6%, but are slightly down from the 2008 ‘baseline’

o   shipping’s share of global GHG emissions increased slightly from 2.76% to 2.89%

o   the carbon intensity (GHG emissions per ton/mile of cargo transported) decreased by about 30%., with most of this reduction happening in the 2012-2015 period mainly attributed to larger and slightly slower ships.  The pace of decrease in emission intensity slowed between 2015-2018.

  • Without additional regulations, BAU – business as usual, the projections are that the emissions will range from flat to a 50% increase by 2050 as compared to 2018, primarily dependent on world trade growth

  • Emissions in 2020 and 2021 will be lower due to the impact of COVID and reductions in shipping volumes, but this is not expected to impact the long-term trends and results

  • LNG as a fuel saw an 87% increase between 2012 and 2018 with new LNG fueled ships coming online

  • Even with ECAs, the SOx and PM emissions from ships increased globally and this is believed to be based on a gradual increase in sulfur content in HFO fuel through 2019

  • This study is the first that claims to distinguish between domestic and international shipping

  • Unsurprisingly, the large ships are 80-100% on international voyages and the smallest category ships are only 20-40% international

Some observation and comments from Herbert Engineering:

IMO efforts to date have made improvements in the overall fleet efficiency due to EEDI for new ships. This combined with the commercially driven general efficiency improvements gained from larger ship sizes, along with somewhat slower ships speeds, has resulted in holding overall maritime GHG emission levels relatively constant since 2012 despite a very significant 40% growth in seaborne trade.

In the future as further efficiency gains become increasingly more difficult to realize, the long-term IMO GHG targets will need to be primarily met by adopting alternative low or zero carbon fuels. Early short-term contributions to overall GHG reductions can still be made for the existing ship fleet, while they remain in service, by further speed reductions. Mid-term contributions can be made by the adoption of bio-diesel fuels or early scrapping of existing ships replaced with newer more efficient designs. There are some worthy, but minimal, additional contributions to be had from further efficiency improvements or adopting hybrid and renewables (wind and solar).

If IMO is to make good on their on their pledge to reduce the GHG emissions from the marine sector to 50% of 2008 values by 2050, then ship owners and operators can expect ever increasing IMO GHG regulations for both new and existing ships. Upcoming regulations for new ships will likely continue the current EEDI pathway with ever increasing GHG reduction phases, eventually requiring alternative low-carbon fuels to comply. Because of the working life of a ship, the target GHG emissions cannot be met without also addressing existing ships. Upcoming regulations for existing ships are likely to incentivize further speed reductions, biofuel adoption, conversion to other low carbon alternatives, or early scraping.

At Herbert Engineering we are closely following the development of all practical low carbon technologies and have recently completed a series of proposed 2030 build, low and zero carbon ship designs of containerships, bulk carriers, tankers, and product carriers for ABS in their low carbon Shipping Outlook. We currently anticipate that the short and mid-term designs will focus on biofuels, LNG, and hybrid designs; but for the mid to long-term solutions we think hydrogen/ammonia powered fuel cells or ammonia powered ICE’s are strong candidates for future deep-sea long-haul cargo transport.