The global shipping industry, comprising about 70, 000 ships, is expected to have to invest around $US100 Billion in new ballast water treatment systems once the International Maritime Organization (IMO) Ballast Water Management Convention enters into force, probably during 2016.
The industry fully supports the objectives of the IMO Convention and the standards that governments have set for killing unwanted marine micro-organisms that can be transported in ships’ ballast water.
But shipping companies still lack confidence that the very expensive new equipment required will be regarded as fully compliant by governments, even though it has been typed-approved, unless serious implementation problems with the Convention are addressed at next week’s crucial meeting of the IMO Marine Environment Protection Committee (MEPC).
The International Chamber of Shipping (ICS) and its member national shipowners’ associations are therefore now engaged in a final flurry of lobbying, following an extensive campaign with governments over several years.
The issues that governments need to address include the lack of robustness of the current IMO type-approval process for the expensive new treatment equipment, the criteria to be used for sampling ballast water during Port State Control inspections, and the need for ‘grandfathering’ of type-approved equipment already or about to be fitted.
In conjunction with a broad coalition of other industry associations, ICS has made a detailed submission to the MEPC explaining the industry’s concerns and a proposed way forward. This takes the form of an MEPC Resolution which would serve as a ‘gentlemen’s agreement’ by IMO Member States that necessary actions will be taken with respect to the Convention’s implementation as soon as it enters into force, and that shipowners who have installed new equipment, in good faith, and who operate and maintain it correctly, will not be unfairly penalised.
On the basis of recent contact with governments, ICS believes that there is now greater understanding of the industry’s concern that new equipment, which has been type-approved in accordance with agreed IMO standards, might subsequently be deemed to be non-complaint. There is growing recognition that it is unreasonable to expect shipowners to invest millions of dollars per ship without any certainty that the equipment will not have to be completely replaced.
ICS is pleased that the Government of Canada – which has previously been sceptical about the industry’s concerns – now appears to acknowledge that there is a serious problem.
Sadly, however, the solution that Canada has proposed to IMO, as an attempt at a compromise, does nothing to address the industry’s fundamental concerns and could actually make implementation even more complicated by introducing a new concept of “minor exceedance” of the Convention’s discharge standards. Simply to define and agree such a standard could take several years of discussion at IMO.
ICS believes that outstanding problems must be addressed now, in advance of the Convention receiving the necessary number of ratifications by governments to enter into force. IMO Member States are therefore being strongly encouraged to consider the draft MEPC Resolution proposed by the industry as the base document for the development of a solution by IMO. The industry wishes to ensure that the Convention will indeed be fit for purpose and that shipowners can prepare for immediate implementation of a new regime that is fair while delivering necessary environmental protection.