Russian Maritime Register of Shipping develops alternative fuels requirements and introduces ship’s carbon intensity calculation tool

May 27, 2022

Russian Maritime Register of Shipping (RS) has developed requirements for ships equipped to use alternative fuels.

The relevant Circular Letter (No. 312-09-1760c) is accessible at rs-class.org in the Online Information – RS Circulars section and enters into force on July 1, 2022.

The new requirements are integrated in the Rules for the Classification and Construction of Sea-Going Ships and cover ships, equipped to use methanol and ethanol as fuel. RS also introduces the new class notation distinguishing marks LFLFS (Me) and LFLFS (Et), i.e. Low Flashpoint Liquid Fuelled Ship, (Мethanol) or (Ethanol). The new marks will be assigned to the ships compliant with the new requirements as well as with the International Code of Safety for Ships Using Gases or Other Low-Flashpoint Fuels (IGF Code) and the IMO Interim Guidelines for the Safety of Ships Using Methyl/Ethyl Alcohol as Fuel (MSC.1/Circ.1621).

Under the development, a range of existing documents regulating the use of methanol and ethanol as ship fuel were analyzed, the advantages and the challenges of alcohol fuel were assessed, the design and operation case study took place.

The new requirements cover all the key structures and systems, define the crew safety measures and the approach to the safety of navigation for LFLFS ships. The requirements are demanded due to the increasing interest to alternative fuels in the maritime transportation agenda associated with increasing oil fuel rates, requirements to reduce NOx, SOx and CO2 emissions as well as to ship energy efficiency. Further development of the RS requirements covering methanol and ethanol application as ship fuel will be based on the ship operation case study.

Russian Maritime Register of Shipping (RS) has developed an online calculator for shipowners to estimate ship’s Carbon Intensity Indicator (CII) values based on the quantity of fuel oil consumed and the distance traveled per calendar year. The tool also enables to determine the ship’s operational carbon intensity rating.

The requirements to calculate the attained and the required operational carbon intensity indicators were introduced by the MARPOL Annex VI amendments adopted at the 76th session of the IMO’s Marine Environment Protection Committee (MEPC 76) and become mandatory from January 1, 2023. After 2023, the annual calculation is required for certain types of 5000 GT and above ships engaged in international voyages. The shipowner is responsible for the calculation and may engage a competent organization to perform it.

Based on the attained CII and fuel oil consumption data the ship’s flag state maritime administration or its recognized organization rates the operational carbon intensity according to the А-E scale with A being the major superior grade. A low-rated ship (D for three consecutive years, or E) is required to develop a corrective action plan being part of the enhanced Ship Energy Efficiency Management Plan (SEEMP). The SEEMP shall also include an implementation plan documenting how the required annual operational CII will be achieved during the next three years starting from 2023.

RS recommends the shipowners to determine the CII and the associated operational carbon intensity rating based on the existing fuel oil consumption data of 2019-2021 and to take the top priority corrective actions for a smooth transition to the new requirements compliance.

This new online tool offers preliminary calculations of the CII values and does not cancel the obligation of the shipowner to provide a detailed calculation to the maritime administration or a recognized organization. The report generated does not constitute the regulatory statement of compliance with the IMO requirements.

The RS new MARPOL Annex VI services currently cover the review of the EEXI technical file, ship’s Onboard Management Manual (OMM) for shaft / engine power limitation system and the enhanced SEEMP as well as rating the ship’s carbon intensity.