Industry divided on ballast water convention
Jad Mouawad: There is no need to grand-father systems installed on board ships
IMO Secretary General Koji Sekimizu has expressed his disappointment in the progress made on the ballast water management convention at MEPC 66 in April 2014; he is not alone, writes Wendy Laursen.
For Simon Bennett, director of external affairs at ICS, progress at MEPC66 was disappointing. The study agreed upon will take several years to complete, he said. “And the key thing is they won’t actually make any changes to the regime in advance of it entering into force. We were a bit disappointed because it means we are more or less where we were prior to the meeting… Governments haven’t ratified the convention yet because they’ve still got questions about the implementation regime. It doesn’t make it any easier for them to consider ratification, and it doesn’t make it any easier for the industry to recommend that governments should ratify.”
Specialist ballast water management consultant Jad Mouawad sees two main issues as splitting MEPC. Firstly, whether the G8 Guidelines should be revised prior to entry into force of the convention or not, and secondly, the grand-fathering clause for systems already installed on board ships in case they do not meet the D-2 standards for the number of live organisms permissible in ballast water discharge.
“Mouawad Consulting opposes any changes to the G8 Guidelines prior to receiving feedback from the operations of the systems and prior to actually knowing if the systems are working or not,” said Mr Mouawad. “Related to grand-fathering, there is a major misunderstanding that we want to clarify. Treatment systems already type approved have shown, following the G8 guidelines of the ballast water management convention, that they can meet the D-2 standard. Until the D-2 standard is made stricter, any revision of the type approval guidelines will not require systems to be re-tested or to go through the type approval process again.
“Taking that into account, there is no need to grand-father systems installed on board ships as those will, and are expected to, meet the D-2 standard during discharge. The idea of grand-fathering implies that systems that are type approved and installed on board ships are not expected to meet the D-2 standard; which is, to date, a completely unsubstantiated claim which lacks proof.”
The review group also discussed a paper submitted by India on the application of the convention to reception barges. For Praveen Kumar Mishra, vice-president of the Indian Register of Shipping, who spoke at an event in March, a number of challenges have emerged regarding the convention such as the number of ships requiring retrofitting and the availability of treatment systems and facilities for retrofitting. There are also problems such as crew training, choice and availability of proper systems, surety about their real-time efficiency, delays due to port state control (PSC) inspection and sampling, increased power consumption and additional working hours for crew. “Shipping is in need of an alternative to solve these challenges,” said Mr Mishra, “and that solution, is the re-invented port-based mobile ballast water treatment facility.”
However, there was some disagreement at MEPC about the points raised by India, says Mr Mouawad. The general acceptance was that treatment of the water received by the barge must be done through a type approved treatment system for discharge like any other ship. The Netherlands made an intervention that EU regulations consider such reception barges to be land-based facilities and so must follow the land-based reception facility guidance for approval.
“Since at least early 2013, some of India’s shipping bureaucrats have been re-examining the ballast water reception option again, where first the US west coast port authorities went in the late 1990s, followed later by some Dutch and German ports,” says Dr Rob Hilliard, principal at Intermarine Consulting. “They all took a look and did the basic calculations which showed that land-based reception is trickier and more expensive than first appears. Key stumbling blocks were the installation and operating costs versus the likely number of client ships that would pay for it”.
Dr Hilliard believes India’s presentation has identified what may be the only viable option for any ballast water reception scheme, particularly at any large mixed trade port. “A mobile, barge-like facility that can receive untreated ballast water pumped from a visiting ship needs to treat the water on board to the D-2 standard before discharging it. It does away with the need to reticulate all berths and find land for installing the holding tanks and treatment plant, and the barge - or barges - can also service those ships that need to discharge their wing tanks or other ballast in the port’s anchorages, so as to lighten up for entering a shallow approach channel or berth.”
The size and number of barges required would clearly depend on the port’s geographic spread and the type and frequency of its trade. But one or more treatment barges should be considerably cheaper to obtain and operate than having to reticulate the whole port with pipelines and establish a land-based plant on what is potentially prime coastal industrial or residential estate.
On the other hand, a remote deepwater terminal that’s dedicated to large VLCCs or VLOCs that are on a long term charter may prove the exception. Fitting ballast water treatment systems to these ships is very expensive, owing to their need to discharge some 50,000 to 75,000 tonnes of ballast water at rates greater than 3,000 tonnes/h, and if land adjacent to the remote terminal is cheap enough for the holding tanks and plant, then a barge-based option may be less cost attractive. However, the moment any of the large carriers comes off charter, its owner is faced with the question of what to do with a ship that has no ballast water treatment system on board.
As Dr Hilliard notes there are many questions each port authority or terminal operator has to carefully examine: Exactly how much to purchase then operate barge versus land-based reception facilities? Will the charges imposed on visiting ships be small enough to encourage their shipowners to pay, rather than installing a system on their ships?
“It’s all a bit ‘chicken and egg’, and few shipowners may be willing to take the risk of not installing a ballast water treatment system on the assumption that enough ports or terminals will equip themselves with adequate reception – to prevent delays - and charge a realistic price for each tonne received... Perhaps the owners of small and relatively cheap coastal and river-sea traders that belong to a geographically large ‘mothering’ flag such as India, the Russian Federation or PR China etc may think the risk is worth it - especially if their flag makes enough supportive noise and starts to walk the talk with the reception concept.”
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