IMPLICATIONS OF THE BWMC

Transcription

1 IMPLICATIONS OF THE BWMC Anna Ziou, Policy Manager, UK Chamber of Shipping Wednesday 23 November 2016

2 IMPLEMENTATION SCHEDULE MEPC 71 (July 2017) will consider supporting: A: Resolution A.1088(28) : First IOPP renewal survey > EIF or B: Alternative text developed at MEPC 70: - First renewal survey as determined by the Committee following the date of entry into force of the Convention if this survey is completed on or after 8 September Second IOPP renewal survey if the first renewal survey following the date of entry into force of the Convention is completed prior to 8 September A ship constructed on or after 8 September 2019 shall conduct Ballast Water Management that at least meets the standard described in regulation D-2. 2

3 IMPLEMENTATION SCHEDULE Will there be a delay? The alternative text: Is a delay only for ships which renewal IOPP survey is completed prior to 8 September Does not benefit those deciding to decouple their IOPP certificate; The final decision will be made at MEPC 72 (April 2018). If none of the proposals achieve 2/3 support during MEPC 71 then Regulation B-3 of the BWMC may apply. Will shipowners consider not fitting a BWMS and wait till 2018 or will consider decoupling of IOPP Certificate to be on the safe side? 3

4 REVISED G8 GUIDELINES Application: Administrations not later than 28 October 2018; Installation onboard on/after 28 October 2020; Reference dates subject to availability review; A considerable number of vessels will be required to install systems approved in accordance with the existing Guidelines (resolution MEPC.174(58) as from 8 September USCG Type Approval availability and alignment? 4

5 ROADMAP Shipowners who have installed, maintained and operated correctly BWMS approved in accordance with the Guidelines (G8) (MEPC.174(58)) should not be required to replace these systems, for the life of the ship or the system, whichever comes first, due to occasional lack of efficacy for reasons beyond the control of the shipowner and ship's crew. Early movers should not be penalized i.e. sanctioned, warned, detained or excluded. Nevertheless, the PSC will have the right to take actions to protect the environment i.e. not permit discharge of ballast water that does not meet the D-2 standard.

6 CONTINGENCY MEASURES Undertaken on a case by case basis. Shipboard contingency measures: Should be approved by the flag Administration; Should be included in the ballast water management plan of the ship; May be used if accepted by the port State; Port-based contingency measures: Should be approved by the port State; Requires cooperation between the port and the ship; 6

7 CONTINGENCY MEASURES Topics to be considered: 1. Risk Assessment in ports 2. Port-based treatment systems: a) standard connections b) port or ship infrastructure required (reception facilities, hoses, cranes, etc.); c) barges, BWTBoats, ships, etc.; d) treated water delivered from port; e) dosing of brine or chemicals; 7

8 CONTINGENCY MEASURES 3. Shipboard contingency measures: 1. ballast water exchange (not suitable for all regions); 2. ballast exchange with water treated by BWMS; 3. recirculation of ballast water; Pros and cons of measures to deal with specific scenarios, ship types and trades. 8

9 SHORT SEA SHIPPING Short Sea Shipping requirement based on political boundaries rather than risk level. Regulation B-3 & Resolution A.1088(28): Ships will be required to comply with either regulation D-1 or D-2 until such time as regulation D- 2 is enforced. Report of MEPC 68/21 para 2.54 states that ships that are unable to undertake D-1 ballast water exchange due to lack of suitable waters in which to complete the operation are not required to meet regulation D-2 until D-2 is enforced No legal status. IMO Unified Interpretation at PPR 4 Will it have legal status? 9

10 SHORT SEA SHIPPING North Sea exchange areas 10

11 SHORT SEA SHIPPING Other areas? Ireland will comply with the provision in point 5 of the Resolution, requiring the D1 or D2 standard to be met until the D2 standard is required. Ireland will designate Ballast Water exchange areas off the south and west coast of Ireland. Ships may avail of those areas to met the application requirements of the Resolution. Ships will not be required to divert to conduct exchange. No areas will be designated in the Irish sea because they do not meet the Convention requirements. 11

12 SHORT SEA SHIPPING Exemptions Same risk area Demarcation of boundaries Who pays for surveys? Who owns the data? Who stores and keeps data up to date? Risk assessment costs Depends on data availability Requirement to monitor How expensive are the surveys (Euro 61k 83k?) Last up to 5 years with review after months Risk of withdrawal at short notice (alternative means?) Require a target species list 12

13 DOMESTIC SHIPPING According to Article 3.2 (d) the Convention does not apply to ships of a Party which only operate in waters under the jurisdiction of another Party, subject to the authorization of the latter Party for such exclusion. According to the MCA if a vessel undertakes an international voyage or enters the water of another State then the requirements of the Convention will apply. Article 3.2 (d) could apply to some offshore vessels and dredgers, however it will depend upon their particular operating patterns and certifications. 13

14 IOPP RENEWAL The UK does not support the decoupling of the IOPP certificate as the HSSC system was brought in to benefit shipowners, however there is no legal requirement for the IOPP to be included in HSSC. If an owner goes ahead and decouples the IOPP certificate, the UK will look to realign surveys at the next renewal date which may result in a number of surveys having to be undertaken early in order to once again achieve harmonisation. The role of PSC? 14

15 FUTURE WORK - Decide on the enforcement schedule; - IMO Unified Interpretation for short sea shipping; - USCG Type approval; - Availability of revised G8 type approved systems; - Interpretation of the Convention by port States; - Exemptions collaboration is needed; - Contingency measures and ports role; - Ratification of the BWMC by the UK ( months); 15