E

MARINE ENVIRONMENT PROTECTION MEPC 80/6/10

COMMITTEE 28 April 2023
80th session Original: ENGLISH
Agenda item 6 Pre-session public release: ☒

ENERGY EFFICIENCY OF SHIPS

ShaPoLi concept for EEDI taking into account first experience

with installations for EEXI compliance

Submitted by Germany

SUMMARY

Executive summary: This document discusses the further development of the Shaft
Power Limitation (ShaPoLi) concept focusing on areas identified
during MEPC 79 by the Working Group on Air Pollution and Energy
Efficiency. Special attention is paid to the first experiences with
ShaPoLi systems in the context of the EEXI certification.

Strategic direction, 3
if applicable:

Output: 3.5

Action to be taken: Paragraph 11

Related documents: MEPC 73/5/1; MEPC 74/5/5, MEPC 74/5/17, MEPC 74/5/26,
MEPC 74/5/29, MEPC 74/5/31; ISWG-GHG 7/2/35; MEPC 75/6/2,
MEPC 75/6/6, MEPC 75/6/8; MEPC 77/6/2 and MEPC 77/INF.29

Introduction

1 During MEPC 79, the Shaft Power Limitation ( ShaPoLi) concept was discussed, and
general support was expressed by the majority of the Working Group on Air Pollution and
Energy Efficiency for the inclusion into the EEDI framework.

2 The first proposal for the ShaPoLi concept has already been presented to MEPC 73.
Although discussed at several sessions, the ShaPoLi concept has not yet been adopted for
the EEDI framework, even though the concept was adopted by resolution MEPC.335(76) for
the EEXI framework at MEPC 76. In the meantime, first applications have already been
implemented.

3 It should be noted that there is a basic difference between the application of the
ShaPoLi concept for EEDI, for new ships, and for EEXI, for existing ships. The aim of EEXI is
to enable existing ship designs to meet the mandated efficiency requirements. For power
limitation for EEDI, the intention is not to keep old ship designs alive. For EEDI, the objective
is to overcome the discrepancy between stricter energy efficiency requirements and required

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propulsion power for safety reasons. Therefore, Germany is of the firm conviction that ShaPoLi
for EEDI is only relevant for two stroke slow speed engines in direct drive application and for
the minimum required propulsion power for vulnerable ship types, meaning bulk carriers and
tankers.

Discussion of the ShaPoLi concept

4 For EEDI, the ShaPoLi concept should only be applied to ships which are subject to
the minimum propulsion power requirement according to circular MEPC.1/Circ.850/Rev.3. As
discussed in document MEPC 77/6/2 (Germany), compliance with the propulsion power
requirement should be proven with level 2 assessment without application of the power
reserve. Alternatively, level 1 assessment with consideration of the power reserve can be
accepted as well.

5 In the context of EEXI, it was agreed to use 83% of the limited installed power, PME is
83% of MCRlim. For EEDI, PME should be 75% of MCRlim. The 75% approach agrees with the
EEDI calculation Guidelines and should not be changed.

6 One reason for the 75% approach for EEDI is from the experience of EEXI
implementation and its certification, differing between the 75% approach for permanent
limitation and the 83% for overridable limitation, causes a lot of confusion and gives the wrong
motivation for permanent limitation instead of overridable power limitation.

7 A ShaPoLi arrangement, which fulfils level 2 assessment of minimum propulsion

power requirement with MCRlim, is in our view considered as an overridable solution as
ShaPoLi offers the power reserve which is not needed according to the minimum propulsion
power requirement. Would one now change the ship design, e.g. a shaft bearing could be
changed to allow loading with more power than MCRlim, then the ShaPoLi system would be
altered from an overridable power limitation to a permanent one and there would be a
significant benefit in the attained EEDI calculation. This would provide unintended incentives
and would falsify our intentions; Germany wants to safeguard the ShaPoLi concept for EEDI.
These points would add unnecessary complexity and would create confusion in its application
which must be avoided right from the beginning.

8 On the issue of an engine power limitation (EPL) system, the Working Group on Air
Pollution and Energy Efficiency recommended to incorporate an EPL in the EEDI framework
as well (paragraph 51 of MEPC 79/WP.9). Although Germany believes that, as discussed in
document MEPC 77/6/2, such an EPL is not needed for new ships because this should be
regarded as a fixed power reduction of the main engine thus it should be possible during the
fabrication or layout of the engine and this should be the preferable way instead of a permanent
engine power limitation. However, if the Working Group and Committee favour the overridable
EPL option to be inserted into the EEDI, then it should be noted that other than for EEXI the
limitation for the mechanically controlled engines is not needed anymore because all engines
can be considered as electronically controlled since electronic governors are standard today.
For the case where EPL for new ships shall still be foreseen, the option for inclusion would be
as follows: In the engineʹs control system, the fuel index limiter should lock the fuel index, or
direct limitation of the power should be implemented. The control panel of the EPL with the
release option should be installed on the ship's bridge including a certain degree of
auto-recording for the power release.

9 The other point is, in Germany's view, the main reason for the 75% approach of
MCRlim is associated to the NOx certification. The difference between EEDI certification during
the building phase and EEXI certification for existing ships must be stressed. Retrofitting a
ShaPoLi solution for EEXI compliance does not change the NOx Technical File. However,
during the building phase, it is possible and there must be an obligation to adjust the

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certification to the intended normal operation range of the ship. When compared to EEXI, for
EEDI the NOx certification should refer to MCRlim instead of MCR, as the power reserve will
only be applied in rare cases. The value of MCRlim is to be stated on the engine's nameplate.

10 In this regard, the test cycles and weighting factors applied for verification of
compliance of marine diesel engines with the applicable NOX limit in accordance with
regulation 13 of MARPOL Annex VI using the test procedure and calculation method as
specified in the revised NOx Technical Code 2008, should be based on MCRlim. This means
that measurements for 25%, 50%, 75% and 100% MCRlim are to be performed on the testbed.
Verification of MCR should be conducted on the testbed, e.g. for safety requirements, like as
provided by ROs and can be used as a reference but measurements for this particular power
setting (unlimited MCR) is not related to NOx certification.

Action requested of the Committee

11 The Committee is invited to consider the above comments and take action as
appropriate, as well as adopt the draft EEDI ShaPoLi guidelines using
document MEPC 77/INF.29 (Germany) as a basis.

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