MEPC 71. The Impact on Ballast Water Management Compliance Plans

Transcription

1 MEPC 71 The Impact on Ballast Water Management Compliance Plans

2 Meet Your Presenters Chris McMenemy Managing Director Naval Architect & Marine Engineer Involved in Ballast Water Management for nearly 10 years Founding Member of IMarEST Ballast Water Expert Group Widely Publicised on all Areas of Ballast Water Management Retrofit Engineering Specialist

3 Webinar Contents INTRODUCTION & Overview of MEPC 71 Meeting D 2 STANDARDS of BWM CONVENTION & Agreed Modifications to Implementation D 1 STANDARDS BALLAST EXCHANGE Updates for Vessels Struggling to Comply with D 1 Due to Geographical Constraints OTHER UPDATES & AMMENDMENTS Including Same Risk Area, Experience Building Phase & Contingency Measures SUMMARY Of Impact on Compliance Planning

4 Specialists in Vessel Efficiency and Environmental Compliance Dedicated to helping shipowners & operators achieve environmental compliance in as cost efficient a manner as possible.. Environmental Compliance & Retrofit Services Include: Ballast Water Management Exhaust Gas Cleaning MRV & CO 2 Reduction Ship Recycling

5 Over 35 Retrofits & Counting Largest retrofitted vessel in world 310,000 DWT VLCC Experience ROPAX vessel retrofit installation in just 100 hours Wide range of vessel types & sizes Global operations & availability A small selection of our clients

6 Our Ballast Water Management Process STAGE 1 Vessel and/or Fleet Compliance Review STAGE 3 Detailed Engineering & Class Approval STAGE 5 Installation & Project Management COMPLIANCE STAGE 2 Vessel Survey, 3D Laser Scan & Feasibility Study STAGE 4 Procurement & Pre Fabrication STAGE 6 Commissioning

7 BWM 20 Years in the Making 2004 IMO Ballast Water Management Convention Adopted 2012 USCG adopted and implemented their Final Rule 2017 IMO Ballast Water Management Convention enters into force on 8 th September IMO s Guidelines for Control and Management of Ships Ballast Water to Minimise the Transfer of Harmful Aquatic Organisms & Pathogens 2008 The first ballast water treatment systems, suitable for compliance with the D 2 standard, are installed 2016 The IMO Ballast Water Management Convention finally achieves its ratification requirements on 8 th September Final dates for compliance

8 MEPC 71 BWM Agenda July 2017 D-2 Implementation Schedule Ballast Water Exchange Contingency Measures BWM How to Do It Manual Code for Approval of BWMS Experience Building Phase Updates to Guidelines & Circulars Survey & Certification Recent BWMS Approvals

9 MEPC 71 Debunking the Myths! The BWM Convention has not been postponed..! The D 2 requirements have not been pushed back until ! Owners have not gained a 7 year reprieve..! D 1 Ballast Exchange has not been postponed..! De harmonisation before September 2017 is no longer beneficial..!

10 D 2 Compliance Timeline for New Vessels (Regulation B 3.5): Amendments to D 2 Implementation for "new ships" (ships constructed on or after 8 September 2017) : it is agreed to apply the entry into force date of the BWM Convention as the date to conduct Ballast Water Management that at least meet the standard described in regulation D 2 D 2 Compliance Timeline for Existing Vessels (Regulations B 3.1, 2,3, 4 and 10): for "existing ships" (ships constructed prior to 8 September 2017): the first IOPP renewal survey after entry into force: this applies when that the first renewal survey of the ship takes place on or after 8 September 2019 or a renewal survey has been completed on or after 8 September 2014 but prior to 8 September the second IOPP renewal survey: this applies if the first renewal survey after 8 September 2017 takes place before 8 September In this case, compliance must be by the second renewal survey (provided that the previous renewal survey has not been completed in the period between 8 September 2014 and 8 September 2017). D 2 Compliance Timeline for non IOPP vessels (Regulation B 3.8): Existing Ships which are not subject to hold an IOPP certificate shall comply with the standard described in regulation D 2 from the date decided by the Administration, but not later than 8 September They will be required to comply with regulation D 1 until such time.

11 Amendments to D 2 Implementation Sept 8, 2014 Sept 8, 2015 Sept 8, 2016 Sept 8, 2017 Sept 8, 2018 Sept 8, 2019 Sept 8, 2020 Sept 8, 2021 Sept 8, 2022 Sept 8, 2023 Sept 8, 2024 REG B-3/5 Ships not subject to IOPP Certification D-2 Compliance no later than Sept 8, 2024 REG B-3/ st IOPP Ren Survey Completed > Sept 8, 2019 D-2 Compliance OR REG B-3/ IOPP Ren Survey Completed 1 st IOPP Ren Survey Completed > Entry Into Force D-2 Compliance REG B-3/10.2 APPLIES IF REG B-3/ DOES NOT APPLY 1 st IOPP Ren Survey > Entry into Force 2 nd IOPP Ren Survey > Entry into Force

12 D 2 Amendments Impact on Planning De-harmonisation is no Longer Beneficial Vessels with IOPP renewals between 8 th September 2014 and 8 th September 2017 obtain no benefit from the D 2 amendments the first IOPP renewal after entry into force will remain their compliance date. Maintaining IOPP Renewals May be Prudent Vessels undertaking IOPP renewals after entry into force but prior to 8 th September 2019 can gain until up to 2024 to comply pushing back IOPP renewals as far as possible may be a sensible approach* USCG Requirements Apply Regardless Regardless of how and when a vessel is required to comply with the amended D 2 standard, the USCG compliance requirements will still apply being the first drydocking after January 2014, or 2016, depending on capacity. Newbuilds will Require D-2 Compliance All vessels built after entry into force will be required to comply with the D 2 requirements immediately upon entry into service. Owners can no longer simply leave space for a future retrofit.

13 D 1 Standards & Ballast Water Exchange Existing Ballast Water Management Convention Requirements: Regulation B 4 Ballast Water Exchange 1 A ship conducting Ballast Water exchange to meet the standard in regulation D 1 shall:.1 whenever possible, conduct such Ballast Water exchange at least 200 nautical miles from the nearest land and in water at least 200 metres in depth, taking into account the Guidelines developed by the Organization;.2 in cases where the ship is unable to conduct Ballast Water exchange in accordance with paragraph 1.1, such Ballast Water exchange shall be conducted taking into account the Guidelines described in paragraph 1.1 and as far from the nearest land as possible, and in all cases at least 50 nautical miles from the nearest land and in water at least 200 metres in depth. BUT WHAT IF MY VESSEL TRADES IN WATERS THAT CANNOT MEET THIS CRITERIA..?

14 D 1 Standards & Ballast Water Exchange MEPC 71 Approved the following: Under BWM.2/Circ.62 Application of the BWM Convention to ships operating in sea areas where ballast water exchange in accordance with regulation B 4.1 and D 1 is not possible: Vessels that cannot meet the requirements of Regulation B 4.1, due to geographically constrained voyages, should record the reason why a ballast water exchange was not conducted Vessels that cannot meet the requirements of Regulation B 4.1, shall not be expected to meet the requirements of D 2 Vessels shall not be expected to deviate from their intended voyage, or delay the voyage, in order to conduct ballast water exchange It should be noted that vessels undertaking voyages within waters that do meet the requirements of B 4.1, or through waters in which local Port States have designated specific ballast exchange areas, will be expected to comply with the D 1 standard.

15 D 1 Exchange Impact on Planning Coastal / Short-Sea will Benefit Vessels operating in coastal areas or short sea operators that seldom, if ever, trade in waters that meet the requirements of Regulation B 4.1 can now avoid having to carry out exchange. Ports May Have the Final Say Ports may hold all the aces, and insist that vessels not conducting ballast exchange meet specific local requirements. This may well be likely in port areas sensitive to invasive species such as Republic of Ireland. D-1 is not Acceptable Under USCG For sea going vessels trading into the US, ballast water exchange and the D 1 standard is not an acceptable method of compliance under USCG requirements. Owners should ensure they meet the requirements of USCG. Newbuilds will Require D-2 Compliance All vessels built after entry into force will be required to comply with the D 2 requirements immediately upon entry into service. D 1 compliance will not be acceptable for a newbuild vessel built after entry into force.

16 Other Updates & Amendments Experience Building Phase: MEPC 71 adopted a resolution on the experience building phase associated with the BWM Convention including activities such as: Non Penalisation Gathering of data related to the implementation and operational experience of BWMS Data Analysis Subsequent review of the BWM Convention and consideration of possible amendments based on experience Non penalisation of vessels that install BWMS in advance of D 2 compliance date that experience non compliance despite proper use and maintenance of system Data Gathering Analysis of data reported considering the implementation of the convention and any unforeseen safety or environmental concerns Subsequent Review

17 Other Updates & Amendments Contingency Measures: MEPC 71 approved guidelines on Contingency Measures which provide guidance to owners, operators and port States when dealing with a vessel arriving with non compliant ballast water. Contingency measures may include: Managing all or part of the ballast water in a method acceptable to the port Other operational actions Discharge to another vessel or shore facilty Ballast Water Exchange as agreed by the vessel or port State

18 Other Updates & Amendments Same Risk Area: MEPC 71 adopted amendments to the G7 Guidelines for undertaking risk assessments in accordance with Regulation A 4 of the Convention including, it is understood, guidelines on how risk assessments for same risk area can be supported by numerical & scientific evidence. It is worth noting that same risk areas still remain a distant reality and the amendments to the G7 Guidelines do not off much in the way of simplification of the requirements of Flag States. Revised G8 Timeline: MEPC 71 agreed that BWMS approved in accordance with earlier versions of the G8 Guidelines, not later than 28 th October 2018, may continue to be installed onboard vessels until 28 th October 2020.

19 Other Amendments Impact on Planning Moving Early May be Beneficial Under the experience building phase and the agreed approach to non penalisation of early movers, owners may benefit from installing early. Those who install a system at a later date are unlikely to receive the same leniency regarding non compliance. Ports May Have the Final Say Ports may hold all the aces, and insist that vessels not conducting ballast exchange meet specific local requirements under the guidelines for contingency measures. Same Risk Area is a Risky Bet Owners and operators hoping to take advantage of same risk areas to avoid the need to comply with the D 2 requirements may be taking a big gamble. Whilst the G7 guidelines have been updated, it still remains prohibitively expensive and complicated to achieve a same risk area exemption. Revised G8 Guidelines With MEPC 71 agreeing to allow BWMS approved under existing G8 guidelines to be installed onboard until 28 th October 2020, Owners may benefit from moving early and installing current systems, with fewer limitations on Type Approval certificates.

20 Summary of Impact on Compliance Plans Summary of D-2 Amendment Impact: Summary of Other Updates Impact: Summary of D-1 Exchange Impact: De-harmonisation is no Longer Beneficial Vessels with IOPP renewals between 8 th September 2014 and 8 th September 2017 obtain no benefit from the D 2 amendments the first IOPP renewal after entry into force will remain their compliance date. Maintaining IOPP Renewals May be Prudent Vessels undertaking IOPP renewals after entry into force but prior to 8 th September 2019 can gain until up to 2024 to comply pushing back IOPP renewals as far as possible may be a sensible approach* USCG Requirements Apply Regardless Regardless of how and when a vessel is required to comply with the amended D 2 standard, the USCG compliance requirements will still apply being the first drydocking after January 2014, or 2016, depending on capacity. Newbuilds will Require D-2 Compliance All vessels built after entry into force will be required to comply with the D 2 requirements immediately upon entry into service. Owners can no longer simply leave space for a future retrofit. Moving Early May be Beneficial Under the experience building phase and the agreed approach to nonpenalisation of early movers, owners may benefit from installing early. Those who install a system at a later date are unlikely to receive the same leniency regarding non compliance. Ports May Have the Final Say Ports may hold all the aces, and insist that vessels not conducting ballast exchange meet specific local requirements under the guidelines for contingency measures. Revised G8 Guidelines With MEPC 71 agreeing to allow BWMS approved under existing G8 guidelines to be installed onboard until 28 th October 2020, Owners may benefit from moving early and installing current systems, with fewer limitations on Type Approval certificates. Same Risk Area is a Risky Bet Owners and operators hoping to take advantage of same risk areas to avoid the need to comply with the D 2 requirements may be taking a big gamble. Whilst the G7 guidelines have been updated, it still remains prohibitively expensive and complicated to achieve a same risk area exemption. Coastal / Short-Sea will Benefit Vessels operating in coastal areas or short sea operators that seldom, if ever, trade in waters that meet the requirements of Regulation B 4.1 can now avoid having to carry out exchange. D-1 is not Acceptable Under USCG For sea going vessels trading into the US, ballast water exchange and the D 1 standard is not an acceptable method of compliance under USCG requirements. Owners should ensure they meet the requirements of USCG. Newbuilds will Require D-2 Compliance All vessels built after entry into force will be required to comply with the D 2 requirements immediately upon entry into service. D 1 compliance will not be acceptable for a newbuild vessel built after entry into force.

21 Further Resources Cleanship Website Cleanship Solutions Website Weekly compliance articles Comprehensive compliance guides Useful tools & tips Regular informative webinars Physical events & conference The ultimate BWMS guide

22 the Ultimate BWMS Guide Replace this with your image Over 55 BWMS available to search through Up to date approval status including USCG Filter manufacturer, type & details included Search by more than 20 different technical / commercial parameters The ultimate ballast water management system guide is a ground breaking resource for all things ballast water management providing ship owners and operators around the world with a wealth of useful information & data on ballast water treatment technologies, manufacturers & systems. The guide is 100% free to access and reference, and is available now at: bwmsguide.cleanshipsolutions.com Direct contact details to each manufacturers sales teams & websites

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