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EUROSHORE fully supports the initiative of the European Commission to revise and update the EU Directive 2000/59/EC dealing with port reception facilities for ship generated waste and cargo residues. After more than 10 years of implementation it is the appropriate time for evaluation and maybe further harmonization.

The current low oil prices coupled with an economic downtown in shipping with overcapacity and historic low transport prices impacts the business of the PRF’s as well as the sustainability of the shipping lines. It will not so easy for the policy makers to develop more stringent rules for the disposal of maritime waste streams.

The ultimate goal of the EU Directive is bringing as much waste to the shore as possible. To realize this ambitious target, which differs from the MARPOL Convention, the port reception facilities have invested in the extension of their services to cope with new challenges as wash water from exhaust gas cleaning systems, wash waters from the cleaning of hatches that have transported cargoes which are harmful for the marine environment and other types of waste that will occur due to the use of new technology onboard ships.

Within the framework of the revision of the PRF directive, we prefer to harmonize the implementation on the following topics:

  1. A better and EU wide enforcement of the PRF Directive through an efficient monitoring and enforcement mechanism. We plead for an open IT system where all stakeholders can monitor the disposal of waste even up till final disposal. But a system that also allows the inspectors to verify if PRF’s are existing in the ports oversea. In case there is doubt about the availability of such PRF, the precautionary principle should be applied.

    But, the monitoring should not be limited to the use of an IT system. Inspectors should inspect the situation on board ships. We notice that a mandatory delivery of ship generated waste, after an inspection, happens in one to two/three cases.
  1. A functional fee system that allows the port reception facilities to invest further in order to cope with new challenges, and which is sufficient flexible to follow the new trends in the waste market, in particular the principles of “circular economy”.

    The fee system should also motivate ships to deliver their waste ashore. The disposal should not be limited to “symbolic” volumes in order to obtain a waste delivery certificate, but be done in the philosophy of “a good housekeeper”.

    We are aware of the fact, that due to the low oil price, PRF’s are not able to ‘pay’ for the delivery of oily waste, which, hopefully, will not impact the volumes disposed of.
  1. A more harmonized system with respect to exceptions and exemptions. The granting of such exemptions should be combined with the monitoring of the effective delivery of the waste in the ports which are mentioned in the application.
  1. Clear instructions and enforcement of MARPOL provisions on harmful cargo residues. We haven’t seen an increase in volumes of wash waters which seems to be strange since the transitional period came to an end 31.12.2015.
  1. PRF’s should be actively involved in the development of port waste management plans.

EU WIDE ENFORCEMENT NETWORK

The crucial factor in the proper implementation of the Directive is “enforcement”. In countries/ports were a strict enforcement system is in place, we notice high volumes of waste delivered to PRF’s. In countries where it is left to the “market” we see “unrealistic low delivery rates”. This appraisal is based on number of ships and cargo turnover of the respective ports together with the absence of high fee for non-delivery.

Euroshore welcomes the electronic reporting procedure based on the reporting directive, but we believe that also the waste receipt should be reported in SafeSeaNet. We support a further extension of the notification form, to align it with the IMO form.

An EU wide information system that allows ships to be benchmarked, is highly welcomed by the port reception sector. It will allow port state control to identify better non-compliant vessels. In several EU countries, where environmental inspectors are focussing on waste delivery, we noticed a high rate of mandatory delivery of ship generated waste. We also support initiative to monitor in a more systematic way the delivery of cargo residues.

We also welcome the reporting of inadequacies, as most of the actual statements on inadequate reception facilities is not based on verifiable data.

Euroshore prefers to build up a correct partnership with port authorities and shipowners in order to realise a sustainable shipping sector that ultimately will realise a zero discharge.

FEE SYSTEM

We see a wide variety of fee systems in the EU countries and even between ports in the same country. On the one hand, the fee system should be fair and give an incentive to deliver the waste ashore.

We also agree that part of the fee should be used to cover some realistic expenses of the port authority. But, the main part of the fee should compensate the service provider for the cost in treatment technology, collection means, personnel, availability 24/7, lab analyses, storage etc.

In a “normal” business environment the fee would vary with volumes, hazardousness of the waste and time of delivery. Due to existing waste legislation, the service provider should document the type, quantity and quality of the waste, and if needed proof its statements with analysis. That means that the service provider is transparent in all these issues.

At the same time, we have seen in the last 5 years, a tremendous decrease of the oil prices, which results ipso facto, in a zero price or even negative price for our “recovered oil”. Traditional clients of our “dry oil” are licensed companies such as cement kilns, metallurgy and others which are allowed to co-incinerate dry oil. Due to the economic crisis and another purchase policy, the demand for our ‘oil’ dropped significantly together with the price. In case of shortage of storage, some PRF’s need to sell this dry oil to waste incinerator companies because there is no end of waste criteria for recovered oil. (except for the lubricating oils).

WASTE MANAGEMENT PLANS

We believe that PRF’s are vital partners in the development of a port waste management plan. Information on collection, temporary storage and treatment can be given by the sector.

To realize higher recycling percentages, collection of segregated waste can be offered by providing a battery of skips or by direct collection of these streams.

PRF’s that are seen as partners, will offer waste solutions for new or special needs, they will think together with the client in order to work out a balanced and sometimes a tailor made solution.

EXCEPTIONS & EXEMPTIONS

We believe that exemptions should be based on fair and transparent criteria. Vessels engaged in a scheduled traffic with frequent and regular port calls should be able to make their waste arrangements at their convenience. But such an exemption should also be periodically monitored to verify if the ship fulfils all its obligations, namely the disposal of its waste at the indicated ports and PRF’s.

However, ships that are sailing with large amounts of waste, due to their “so-called dedicated storage capacity”, should be obliged to deliver in case there are reasonable doubts that PRF’s are not established in the next port of call.

That means that, if possible, port state control officers or other competent inspectors, should verify by all means, if a PRF is listed for that particular type of waste in the next port of call. Euroshore supports the establishment of a database of PRF’s by EMSA or, as alternative, the better use of the IMO GISIS database.

BETTER ENFORCEMENT OF MARPOL PROVISIONS.

Cargo residues of Annex I, Annex II and Annex 5 should be delivered to shore reception facilities or in some cases these wash waters can be discharged outside special areas respecting a certain speed and dilution.

For port reception facilities it is not so evident to do the required investments as long as the sea is our competitor. For example, we see sometimes “documents” on which certain ports are listed as having not adequate reception facilities for some dry cargo residues, but further investigation learns us, that these copper, zinc and other ores are not unloaded in that particular port.

It is “easy” to say that there are no adequate port reception facilities and immediately parts of the implementation will be delayed. This was true for the Special Area status in the Mediterranean Sea (for dry cargo residues), which results in the fact that ports that were equipped with adequate PRF’s, will face the fact that the utilisation of these PRF’s will drop drastically.

CONCLUSION

EUROSHORE welcomes the initiative of the European Commission to upgrade the PRF Directive. We highly appreciate the fact that we can cooperate in this revision process with the other stakeholders. We believe that such a dialogue contributes highly to a better mutual understanding that in the end will lead to a better legislation.

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