AGENDA
38th Meeting of INTERTANKO’s
ENVIRONMENTAL COMMITTEE
1200hrs to 1700hrs
Tuesday 4th March
INTERTANKO London Office
St Clare House, 30-33 Minories
London EC3N 1DD
continuing
0900hrs – 1230hrs
Wednesday 5th March 2014
Grange Tower Bridge Hotel
45 Prescot Street
London E1 8GP
1. Minutes
2. Membership
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
Environmental Initiatives and Projects
Environmental Information Sharing
NPDES – VGP
Ship Recycling
Port Reception Facilities
Biofouling and Antifouling
Environmental Performance
Liaison with Environmental Organisations
Date and Place of next Meeting
Any Other Business
Joint ISTEC Items
13. Ballast Water Management
14. Garbage Management
15. Environmental Performance on ships in operations IMO & EU (MRV) rule development
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ANTI-TRUST/COMPETITION LAW COMPLIANCE
INTERTANKO’s Anti-Trust/Competition law Compliance Statement INTERTANKO’s policy is to be
firmly committed to maintaining a fair and competitive environment in the world tanker trade, and
to adhering to all applicable laws which regulate INTERTANKO’s and its members’ activities in these
markets. These laws include the anti-trust/competition laws which the United States, the European
Union and many nations of the world have adopted to preserve the free enterprise system, promote
competition and protect the public from monopolistic and other restrictive trade practices.
INTERTANKO’s activities will be conducted in compliance with its Anti-trust/Competition Law
Guidelines.
1. Minutes
The Minutes from the previous meeting held in Istanbul on the 12th and 13th September were
circulated to the Committee on 10th October 2013. No comments were received. The Minutes are
enclosed as Annex I.
The Action Items from the last meeting are enclosed as Annex II and are updated as of 20th February
2014.
The Committee is invited to adopt the Minutes of the last meeting and comment as appropriate on
the Action Items from the last meeting.
2. Administrative matters
The Committee membership as of 20th February 2014 is provided as Annex III.
MOL Bulkship Europe has expressed an interest in joining the Committee and we await a nominee
from their company.
The Committee had, at its last meeting, consider amendments to the Terms of Reference. These
were made in order to bring into line all INTERTANKO Committee Terms of Reference. The
amendments tabled and approved by the Committee were adopted by the Council at its meeting in
November 2013. The latest version of the Terms of Reference are included as Annex IV.
The Committee will note that the term for Chairmanship is two years with the option of an
additional two more years. Noting that Mr. Reppas has held the position for two years, the
Committee will be invited to consider the Chairmanship at the meeting.
The Committee is invited to note and comment as appropriate.
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3. Environmental Initiatives and Projects
This agenda item has been included as a request from members at the last Committee meeting to
increase dialogue and the exchange of ideas on environmental initiatives and projects. This item is
therefore set to allow Committee members to share information on environmental projects or
initiatives being undertaken within their companies. For example, experience with energy efficiency
devices or management ideas as well as experience with BWMS.
The Committee members will be invited to provide presentations on company environmental
initiatives and or projects.
4. Environmental Information Sharing
The Committee agreed at its last meeting that it is worthwhile sharing information on environmental
issues to the entire INTERTANKO membership, as is frequently undertaken on safety based issues in
forums such as the Informal Tanker Operator Safety Forum (ITOSF). These circulars could follow the
same sort of pattern with root cause and lessons learnt but instead focused on environmentally
related incidents.
The Committee will be invited to consider contributions to circulate among the membership and
commence the work agreed at the last meeting.
5. NPDES – VGP
Following the workshop at the Committee’s last meeting and additional contributions by members
of the Environmental Committee and ISTEC, the INTERTANKO Guide was launched on 20th November
2014. The Guide is free to download from the INTERTANKO website:
http://www.intertanko.com/Global/Environment/IO_Guide_for_implementing_EPA_2013_VGP.pdf
Since the launch of the Guide, the EAL subject continues to present members with challenges. One
such challenge has been the reporting of compliance for the use of non-EALs in situations that are
deemed to be ‘technically infeasible’ according to the VGP 2013.
Committee members have brought this issue to the attention of the Secretariat and have requested
the Committee consider the development of a standard reporting format for use by INTERTANKO
members. It has been noted that some third party entities are offering to develop templates for
members but a standardised model template for use by all INTERTANKO members may be sufficient
and act as an industry standard.
The Committee will be invited to consider the development of a standard template during the
meeting.
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6. Ship Recycling
The European Regulation on Ship Recycling was published in the Official Journal of the EU on 10 th
December meaning that the Regulation will enter into force on 30th December 2013.
The European regulation is closely in line with the provisions of IMO’s Hong Kong Convention on Ship
Recycling, however, it also goes beyond some of the HKC requirements.
One of the key elements of the European Regulation is the enforcement of the Inventory of
Hazardous Materials (IHM) through Port State Control. In addition, the European Regulation requires
that ships flagged by EU Member States are only dismantled in EU-approved ship recycling facilities
fulfilling specific standards.
In order to facilitate adequate implementation, the European Commission has assumed an advisory
role in interpreting the Regulation. The Commission is therefore working on an informal guidance on
ship recycling facilities (SRFs) to be presented when Commission officials visit SRFs outside Europe in
the months ahead. In addition to this guidance, a consultant will be tasked with providing
interpretation of other difficult elements (including IHMs) in the coming months.
The Secretariat has been involved in the development of the Regulation throughout, for example by
meeting with key Members of the European Parliament, to ensure that the regional legislation
remains as close as possible to the Hong Kong Convention. The Secretariat will continue to closely
monitor developments at EU level on this issue.
The Secretariat is continuing to develop the summary guidance document which explains the
requirements of the European Regulation in terms of the IHM. Alongside this guidance the
document will also outline the IMO’s requirements and highlight any differences. Furthermore, with
the entry into force of the European Regulation, the guidance document will detail the
implementation schedule for carrying IHM’s.
The Committee will be invited to note the developments on this issue and comment as appropriate.
7. Port Reception Facilities
Further to the consideration of a summary of reports received since 2011 the Committee, at its last
meeting, recommended to the Council a change in the Membership Criteria to urge members to
report more frequently on inadequate reception facilities. The Council, at its November meeting in
Hong Kong, endorsed the proposal with the following text now incorporated into INTERTANKO’s
Membership Criteria:
2.14 Inadequate Reception Facilities Reports
To report instances of inadequate port reception facilities to the Flag Administrations and to copy
INTERTANKO into all such reports.
The Council further requested that all the relevant forms be made available on the INTERTANKO
website and that all members are reminded of the need to report.
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There remain only a very small number of INTERTANKO member companies that submit alleged
inadequacy forms on a regular basis.
In Europe, the long awaited PRF interpretative guidelines are expected to be released "soon". A
technical document put together by EMSA has been finalised and will feed into the Commission’s
work. The Commission officials are however still considering in what form the new non-legislative
Guidance will be published, e.g. publish a Commission Recommendation, guidance or some other
document. With this indecision it is anticipated that it will take some time before it is finished.
At the same time as the development of the Guidelines, the Commission is due to submit an
evaluation report concerning the implementation of the PRF Directive to the European Parliament
and the Council (as per Article 17). The work on the guidance and this report is carried out in
parallel.
The Committee is invited to note the development in regards to the reporting of inadequate facilities
as well as the activity in Europe on the Directive and its associated Guidelines.
8. Biofouling and Antifouling
Following a small Working Group meeting held between Committee members in Athens in late 2013
a report on the progress of the Model Biofouling Management Plan will be given at the meeting.
The Committee will be invited to note the development and ongoing work on the Model Biofouling
Management Plan.
9. Environmental Performance
Following the last meeting the Environmental Performance Database and Benchmarking tool has
been made available to all members of ISTEC and the Environmental Committee.
The Committee will be invited to comment on the website and provide feedback on areas for
improvement.
10. Liaison with Environmental Organisations
The Committee will be invited to update the members on any ongoing projects with Environmental
Organisations which may be relevant to the Committee’s Agenda.
11. Date and Place of next Meeting
The Committee will be invited to consider the date and place of the next meeting.
12. Any Other Business
The Committee will be invited to table any additional items not already included in the Agenda Notes.
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Joint ISTEC Agenda Items
13.
Ballast Water Management
Since the Committee last met the first compliance date of 1 December 2013 for the USCG
requirements has passed. As of 18 February 2014 the USCG has granted 17 extensions to vessels that
were due to meet this compliance date. A number of members have sought clarification to the
extension provision which has in general revolved around the size categories being included in this
first compliance date. A quick summary of the compliance date application is provided for
information:
(1) 1st December 2013 : A USCG approved BWMS should be installed on all new vessels with a keel
laid after 1st December 2013 (i.e. new buildings of all size categories)
(2) 1st January 2014 : A USCG approved BWMS should be installed at the first dry docking after 1st
January 2014 for all vessels with a ballast capacity greater than 1500m3 but less than 5000m3 (i.e. all
existing and new build vessels in this size category)
(3) 1st January 2016 : A USCG approved BWMS should be installed at the first dry docking after 1st
January 2016 for all vessels remaining vessels, i.e. existing vessels of a ballast capacity greater than
5000m3 and keel laid before 1 December 2013 as well as all existing vessels with a ballast capacity of
less than 1500m3
In addition to the USCG rules, the USCG and the EPA have issued a memorandum in which the EPA
has declared its position in relation to the extensions being granted by the USCG. The Memorandum,
and the EPA’s associated enforcement response policy, dated 27 December 2013, states that the
enforcement policy only applies to situations when:

The vessel has applied for and received an extension from the USCG and is in compliance
with all requirements of this extension;

The vessel is not in compliance with its ballast water numeric discharge limit under the 2013
VGP;

The vessel is otherwise in compliance with all other provisions of the 2013 VGP, including
submission of a valid Notice of Intent.
In these circumstances, EPA enforcement personnel are instructed to take into account the
conditions expressed in the USCG extension letter. When a vessel has adequately undertaken such
measures, as well as other reasonable measures under the circumstances, the EPA will then consider
such violations of the 2013 VGP ballast water discharge limit a low enforcement priority.
The EPA’s policy is not entirely satisfactory as it clearly states that the vessel will be in violation of
the 2013 VGP ballast water discharge requirements if the vessel discharges ballast water in US
waters (within three miles) without using a ballast water management system. INTERTANKO is
working with other shipping interests in the US to seek a more permanent and satisfactory solution
to this difference in approach between the two US agencies.
In addition to the US developments the IMO adopted a Resolution which introduces a rescheduling
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of the implementation of the Ballast Water Management Convention and pins the application dates
to the entry into force date. This in effect makes all vessels constructed before the entry into force
date ‘existing’ vessels, and allows for the installation of a ballast water management system (BWMS)
on such vessels at the first renewal survey following entry into force. At present 38 countries
representing 30.38% of the world’s registered tonnage have ratified the Convention. The Convention
will enter into force 12 months after the ratification by more than 35 countries representing more
than 35% of the world’s tonnage.
Notwithstanding the positive development in terms of the implementation schedule for the BWMC
the Secretariat has, following guidance from the Council, continued to work with industry colleagues
to raise awareness of the continued concerns regarding the effectiveness of ballast water
management systems and in particular the IMO's type approval process. INTERTANKO has cosponsored a submission to MEPC 66 (Annex V) with the World Shipping Council, BIMCO, Intercargo
and ICS drawing attention to the shortcomings of the type approval Guidelines and the need to
initiate a revision. The submission also proposes a grandfathering for all BWMS that are approved to
the current type approval Guidelines.
The Committee is invited to note the ongoing developments in the US and at IMO on ballast water.
14. Garbage Management
The final draft of the boiler/economizer washdown water best practices are enclosed in Annex VI.
The subject remains with the IMO and will be considered once again at MEPC 66. INTERTANKO were
invited to co-sponsor a Japanese submission on the subject which permits the discharge of WDW
and also provides some guidance in a similar vein to the proposal put forward but declined at MEPC
65. However as noted in EnvComm#02-2014 it was felt that INTERTANKO would be better placed to
support the Japan submission verbally in Plenary at MEPC 66 rather than become a cosponsor. This
would allow us to support the Japan proposal to include washdown water as ‘other similar
discharge’ but allow us the flexibility to then shape the Japanese proposed best practice if, as
expected, it is sent to a drafting group, so that it more closely reflects our own best practice.
The final version of the Japanese paper is enclosed in Annex VII.
The Committee is invited to note the development on the issue and comment as appropriate.
Some members had previously raised the issue associated with the management of cooking ol and
compliance with MARPOL Annex V. The subject was recently raised again at the IMO’s PPR1 subCommittee in which Italy had made a submission in response to a previous paper by the Marshall
Islands, the latter proposing that cooking oil could be burned with fuel oil sludge. In the short, the
sub-Committee could not agree as to the correct management and subsequent record keeping of
cooking oil as it related to its incineration with fuel oil sludge and has invited further comments and
proposals by member states and observes to its next meeting in 2015. In the meantime and after
consultation with several members of ISTEC and the Environmental Committee, the general feeling is
that the correct management of cooking oil is to land to a reception facility or incineration. This was
echoed by the Italian paper. Some members also proposed the incineration of cooking oil alongside
that of oily rags, both of which remain Annex V category wastes.
The Committee is invited to note the development on this issue.
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15. Environmental Performance on ships in operations IMO & EU (MRV) rule
development
All follow up actions decided by the Committee at its last meeting were followed up and addressed
with the INTERTANKO Council meeting (November 2013), the Executive Committee meeting (5
February 2014) and the JWG meeting (12 February 2014).
The draft minutes from the JWG 4th meeting are enclosed as Annex VIII for the Committees
consideration.
The Committee should consider the following important issues:
INTERTANKO Representation at MEPC 66
Based on the feedback and guidance given by the Executive Committee, the JWG also recommended
the following positions on anticipated major issues that could be addressed:
1. Should collection of data be a prerequisite for developing this regulation?
INTERTANKO position: agree with the phase-in rulemaking; IMO uses the initial data collection to
assess: (a) the necessity of developing the rule; (b) the standard to define efficiency and (c) the
target required for compliance. This provides us with the opportunity to support that part of the ICS
submission.
2. Should EEDI complaint ships be subject to such a regulation?
Neither the Executive Committee nor the JWG meetings could reach an unanimous answer. The
large majority of members expressed the view that, if the issue is debated by MEPC 66, INTERTANKO
should express the view that the EEDI compliant tankers should not be subject to the MRV
regulations because these ships will be more efficient through design. It could also be assumed these
ships will adopt adequate technologies to minimise fuel consumption. In addition, further efficiency
through operational measures might be difficult to obtain on these ships and additional
requirements on future ships might become challenging to meet. However, other members of the
Committee were of a different opinion, suggesting that EEDI compliant ships should be subjected to
a stricter operational efficiency target to avoid a two-tier market resulting in existing ships being
forced to be phase-out prematurely.
The Executive Committee and JWG agreed there is no unanimity of views on this matter. It was
agreed that the Secretariat should take this into account when attending the IMO meeting but also
seek the view of ISTEC and the Environmental Committee at their joint meeting on 5 March.
3. Should the rule set an “one-off” target or should there be a “moving target” over time?
The JWG agreed that the INTERTANKO position is guided as follows: Based on the data collected,
IMO agrees on a final target but considers its enforcement in two or three steps. (e.g. “final target”
10% from a base line with a two-step 5% enforcement).
4. Which data should be reported/collected (how to define Energy Efficiency?)
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The main question is whether the “cargo” should be a criterion used to define Energy Efficiency, thus
requiring monitoring and reporting? There is a significant chance that “cargo” may not be included
into the final data to be collected.
The JWG was unanimously in agreement that INTERTANKO invites MEPC 66 to consider there could
be different ways on how best to define Energy Efficiency in Operation for different ship types.
Therefore, at least for Phase I of the proposed regulation, INTERTANKO would suggest that, for
tankers; the proposed rule should retain collection of data on the “total actual cargo” carried by
tankers for further assessments before a final decision is made. In such a way, INTERTANKO will
follow the views from the membership but it will not lock INTERTANKO on a final position.
5. Who should do verification of data collected?
INTERTANKO should clarify to MEPC 66 that “verification of data reported” cannot be done by PSC
but by Flag/ROs. Such verification should be done through the ISM Code. The verification by PSC
should be limited to “whether ships have reported the annual required data”
6. Should INTERTANKO express views on the US proposed rating concept?
INTERTANKO is not in favour but if discussed at MEPC 66, we should suggest this aspect is addressed
at a later stage of the rule making development.
Data collection and a possible INTERTANKO model
The Council agreed with the ISTEC recommendation to pursue the development of a possible
INTERTANKO model. This model may be based on the proposal by UCL at the JWG 3 rd meeting and it
will be done in cooperation with UCL. An update will be given to the meeting.
Monitoring Plan
The JWG agreed to consider developing a standard/template for a Ship Monitoring, Reporting and
Verification Plan. This can be done in cooperation with ABS and Alpha Marine whose representatives
attended the meeting. The development of such a plan would be a good exercise to better
understand the process of monitoring and verification. The plan might formulate the process
involving monitoring and recoding. For instance, if fuel monitoring is done through BDNs, then the
plan may indicate the steps in taking bunker tank soundings/ROBs at the beginning and end of
voyages, how to check the balances between BDN values and measurements, how to address
discrepancies, level of deviations, etc. Another process would be linked to the use of flow meters to
monitor fuel consumption including type and frequency of calibrations, verification of results, etc.
The Committees will be invited to consider the updates and decide accordingly, particularly with
regard to the INTERTANKO representation at MEPC 66.
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Annex I
Draft Minutes
37th Meeting of INTERTANKO’s
ENVIRONMENTAL COMMITTEE
1000hrs to 1700hrs
Thursday 12th September
continuing
0900hrs – 1230hrs
Friday 13th September 2013
Hilton Istanbul
Cumhuriyet Caddesi Harbiye
34367 Istanbul, Turkey
Tel : +90 0212 310 2525 / Fax : +90 212 2273409
16. Minutes
17. Membership
18.
19.
20.
21.
Greenhouse Gas Emissions – joint ISTEC
Environmental Performance – joint ISTEC
Ballast Water Management – joint ISTEC
Garbage Management – joint ISTEC
22. NPDES – VGP - Workshop Session
23.
24.
25.
26.
27.
28.
Ship Recycling
Port Reception Facilities
Biofouling
Liaison with Environmental Organisations
Date and Place of next Meeting
Any Other Business
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Attendance:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Name
Ko Ko Naing
Antonios Georgantzis
Marina Hadjipateras
Panos Chatzikyriakos
Jan de Brabandere
Henrik von Platen
Dean Tseretopoulos
Prabhat Sharma
Joe Angelo
Jonathon Holloway
Tim Wilkins
Company
Stena Bulk AB / Northern Marine
Consolidated Marine Management Inc
Dorian (Hellas) SA
Seaworld Management & Trading Inc.
Euronav Shipmanagement (Hellas) Ltd.
Samco Shipholding Pte Ltd (ISTEC Chairman)
Triple T Ltd (Observer)
SeaFlag Shipmanagement (Observer)
INTERTANKO Washington (Secretariat)
INTERTANKO London (Secretariat)
INTERTANKO Singapore (Secretariat)
Name
Mike Reppas
Pär Brandholm
Ole Schroder
Erik Carlsen
Oleg Kalinin
Carlos Juan Madinabeitia
Dimitris Stamoudis
Fabio Tagliavia
Muhammad Assuad
Company
Seaworld Management & Trading Inc.
Laurin Maritime AB
Scorpio Tankers
Dampskibsselskabet "NORDEN" A/S
Unicom Shipmanagement Services
Tradewind Tankers S.L.
Minerva Marine Inc.
d'Amico Societá di Navigazione SpA
AET Shipmanagement Singapore
Apologies:
1.
2.
3.
4.
5.
6.
7.
8.
9.
Mr. Ko Ko Naing opened the meeting extending apologies from the Chairman who was unable to
attend the meeting. Mr. Naing, as Vice Chairman, agreed to Chair the meeting in Mr. Reppas’
absence.
The Chairman welcomed the members and noted that the meeting would be conducted in
accordance with the INTERTANKO Antitrust and Competition Law Guidelines. The Committee noted
the Antitrust Guidelines as presented in the Agenda Notes.
1. Minutes
The Minutes from the previous meeting held in London on 6th March 2013 were approved without
further amendment.
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The Committee also noted the status of the Action Items and agreed that where possible date
deadlines should be included in the Action Items.
Action Items
2. Membership
The membership list was updated as advised by the Committee. A revised and updated version is
included below.
Noting that there are currently 13 members on the Committee and that there is scope for a further 5
members as per the Terms of Reference, it was agreed that a note inviting new members should be
included in both the Weekly News and the Environmental Bulletins. Capt. Chatzikyriakos and Mr.
Naing also commented that they would invite members of the ITOSF to consider joining the
Committee.
Membership
September 2013
The members reviewed the proposed amendments to the Committee’s Terms of Reference and
supported the changes proposed by the Council to bring into line all the INTERTANKO Committee
Terms of Reference.
In noting the new paragraph 2.3 on attendance to Committee meetings, it was agreed that the
membership list would include information on the meetings attended by each member.
Action


Circulate an invitation to join the Environmental Committee to all INTERTANKO members
through the Weekly News and the Environmental Bulletin.
Revert to the Council on the Committee’s support for the proposed changes to the Terms of
Reference.
3. Greenhouse Gases
3.1 Monitoring, Reporting and Verifications (MRV) – EU & IMO rule development
The Committee noted the report provided (attached to the minutes) and agreed that:
-
JWG/MRV continues its activity;
The Terms of Reference be amended to include consideration of a standard format for a
MRV Plan;
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-
-
-
The proposed two-indicator approach might be of value but it first needs to be further
developed. It would bring clarification on the ship’s technical efficiency which is useful
because ships will have to meet a target in different environmental and operational
conditions. Therefore, the Committee agreed INTERTANKO should approach UCL and seek
assistance on these developments;
The Committee also agreed to commission DNVPS to assess (a) an overall correction factor
to account the net amount of fuel which will be used by ships’ engines and installations (fuel
remaining after purification) and (b) the deviation spread of fuels calorific value versus the
calorific value used to calculate the carbon to CO2 coefficient CF;
The Committee agreed in general with the comments drafted on the EU proposed MRV
regulation.
There has been one additional suggestion to consider the bunker tanks volume/capacity
measurement standards. Current information given by ship yards proves to be not reliable. Maybe
the MRV regulations should make reference or require a standard for the assessment of hr bunker
tank capacity.
3.2 EEDI database
The Committee agreed that INTERTANKO should support the IACS proposal as an IMO run database
only.
4. Environmental Performance on ships in operations
An update regarding the website platform for the INTERTANKO Environmental Performance and
Benchmarking Database (EPBD) was provided to the two Committees by the Secretariat. Members
noted that while the platform had been completed and that members of the Working Group had
been provided with access, feedback from the Working Group members suggested that there
remains several key problems to be resolved before it is fully operational. Having noted this
however, it was agreed that all members of ISTEC and the Environmental Committee should be
provided with access to the EPBD so as to speed up the review process.
Action

Circulate access details to all members of the Environmental Committee and ISTEC.
5. Garbage Management
5.1 Boiler wash down water – MARPOL Annex V
Following a brief summary on the outcome from MEPC 65 the Committees considered further action
on the issue. Because the issue remained unresolved and the industry were still without a clear and
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agreed means of managing this discharge, It was agreed that the Committees should provide best
management practice (BMP) as an INTERTANKO members guide on handling this discharge.
Having been provided with a draft BMP by Sokratis Dimakopoulos it was agreed that this would form
the basic draft of the guidance. It was agreed that the BMP should be clearly separated into
guidance on existing and new build vessels. Further comments and amendments have already been
proposed by MARTECMA members and members of the Environmental Committee which would be
taken into account when developing a revised draft. This revised version of the BMP should then be
circulated to the Committees for further comment and approval.
The agreed BMP would form the basis of INTERTANKO’s position going into MEPC 66.
Action


Redraft the BMP taking into account the comments received from members of the
Environmental Committee and MARTECMA.
Circulate the revised draft to the two Committees with a view to receiving final proposed
amendments and approval for circulation to the entire INTERTANKO membership.
5.2 Garbage Management Best Practice
The Committee noted the finalization of the Guide and its intended circulation to all members.
6. Ballast Water Management Systems (BWMS)
The Committees were provided with an update on INTERTANKO’s activity on ballast water
management. Since the last meeting developments had largely been in three areas:
1. At the IMO, MEPC 65 had:
i. Adopted an agreement to enter into a Trial Period for Port State Control once the Ballast
Water Management Convention (BWMC) entered into force. This would see Port States
abstain from criminalising the seafarers or detaining the vessel if the Ballast Water
Management System (BWMS) did not operate correctly;
ii. Adopted amendments to the BWMS certificate in particular the amount of information
required on the certificate and its enclosures. MEPC had also agreed to expand the quantity
of information provided to Administrations by BWMS manufacturers when applying for
approval. This, it was hoped, would improve the transparency of information on BWMS and
importantly highlight any key limitations of the BWMS;
iii. Agreed to a revised implementation schedule for the BWMC, pinning the implementation
schedule for new and existing ships to the entry into force date of the BWMC. Furthermore,
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that the installation dates would be in line with the first IOPPC renewal survey. The draft
would now have to be approved and adopted by the IMO Assembly when it meets in
November 2013.
2. The INTERTANKO Council at its last meeting had noted that while good progress was
made at MEPC 65 to meet the challenges presented by the BWMC there remains concern
relating to the reliability and dependability of type approved BWMS’. In this respect the
Council had instructed the Secretariat to work with other industry associations to propose
changes to the IMO Type Approval process to help overcome these concerns. The
Secretariat has already commenced this work and is liaising with the World Shipping Council
and BIMCO in an effort to gather the core technical information which would provide the
basis for any proposed changes to the Guidelines.
3. The Committees also noted that USCG has still not commenced approval of BWMS, with
no manufacturers having submitted formal applications. It is however understood that three
companies have made enquiries on the approval process and application. It is very likely that
there will be no USCG approved BWMS until 2014.
Members raised concerns that the lack of USCG approved BWMS was placing owners with new
vessels to be delivered in a difficult position when deciding which BWMS to install. Discussion turned
to the use of the extension provision in the USCG rules that could be used by members to obtain an
extension for vessels being delivered after the 1 December 2013 deadline. Members were advised
by the secretariat that the USCG is due to release a policy document in the coming two weeks on the
extension provision which would provide guidance to owners on the application process. It was
agreed that following the release of the USCG policy document the secretariat should develop a
model letter for application of an extension.
Discussion turned to the term of the extension provision with members voicing concern about
whether the extension would be withdrawn soon after a USCG approved BWMS was available.
Would, for example, the USCG provide flexibility as has been done with existing ships and allow new
tankers to have an extension until the ships first drydocking after the first USCG BWMS has been
approved? Furthermore, should this time period for the extension be included in an extension
request, i.e. request the extension until the ships first drydocking after a USCG BWMS has been
approved? The issue was immediately clarified by the USCG during the meeting with the following
communication received by email:
Yes, we will consider extension requests from those who cannot find a
Coast Guard type approved system, whether it's a new build or existing
vessel. The length of the extension will be an appropriate amount of time
so that the vessel can install a system to coincide with their next
drydocking, assuming a type approved one is available when that occurs.
Our policy should be coming out soon, I'm pushing to have it signed in
time for the Miami BW Technology Conference on September 26th. The policy
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will indicate that extensions will not be granted for more than 5 years.
It will also have language that owners/operators should provide to us such
as drydock dates etc,...
The Committee members were grateful for the immediate clarification obtained from the USCG by
the Secretariat.
With this clarification in mind members were reminded that under the ballast water section of the
EPA’s VGP, no such extension would be accepted.
In relation to the EPA’s requirements, the Committees requested clarification on both the use of a
BWMS and the monitoring requirements stipulated in the VGP prior to the application dates, i.e.
should a vessel that has installed a BWMS be obliged to use the BWMS prior to the vessel’s
application dates in the VGP and furthermore, should the monitoring and functionality requirements
of the VGP be implemented before the vessels application dates. The Secretariat agreed to
communicate with the EPA on the subject and gain clarification.
Finally, noting the various questions pertaining to the application of the two ballast rules in the US to
member’s vessels, the Committees requested the Secretariat to issue a decision tree guide on the
application of the two US rules.
Action




Seek clarification from the EPA on the use of BWMS prior to a vessel’s application dates as well
as the applicability of the monitoring provisions of the VGP prior to the vessel’s application
dates.
Issue the extension clarification received from the USCG to all members.
Once the USCG extension policy had been released, develop a model extension application
letter for use by members.
Develop a decision tree guide on the applicability of the two US ballast water rules, i.e. USCG
and EPA.
7. NPDES – VGP – Workshop Session
The Committee held a workshop session to review the 2013 VGP and consider an update of the
INTERTANKO Guide for the 2009 VGP. The workshop undertook a gap analysis of the two VGP
versions and provided input on a line by line basis.
Noting that the Environmental Committee had considered the issues arising from the revised VGP
(VGP 2013) the subject was also considered during the joint ISTEC and Environmental Committee
session. ISTEC noted that the EPA had confirmed that an air seal may be used in lieu of EALs
although this was believed to be more appropriate for new buildings only. Members of the
Environmental Committee advised further that documentation needs to be maintained to
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demonstrate when it has not been possible to use EALs. In this respect it was noted that Blohm &
Voss as well as Wartsila have issued statements commenting that the use of EALs may damage their
seals. Some noted that problems existed with controllable pitch propellers.
The discussion turned to the advice which should be provided in the INTERTANKO Guide to the 2013
VGP as was under development by the Environmental Committee. In this respect, the two
Committees concluded that the advice should be based on the following points:
i.
It is not advisable to replace stern tube lube while the vessel is afloat. The Secretariat would
seek clarification from the EPA that the switching to EPAs should not necessitate a dry-dock
but be undertaken at the next scheduled dry dock;
ii.
Owners should approach the stern tube manufacturers to confirm the acceptability of the
stern tube seals with EALs, or not. If the latter then this statement should be re-issued
annually by the manufacturer. If the former then the manufacturer should provide a 5 year
guarantee that seals will last with the EALs;
iii.
Documentation related to the non-use of EALs needs to be kept on board the vessel;
iv.
Not all lubricant manufacturers have suitable EALs that meet the EPA specification and as
such a declaration should be obtained from the EAL manufacturer stating that it is an EAL in
accordance with the terms of Appendix A of the VGP.
Action

Include the four bullet points in the INTERTANKO Guidance on the implementation of the 2013
VGP.

Seek clarification from the EPA on necessity of dry docking to switch to EALs against
undertaking the switch at the nest scheduled dry dock.
Complete the revised Guide with the proposed changes made at the workshop session by 1
October and circulate to the Committee for further input.
Complete and circulate to all INTERTANKO members the final version of the Guide by 15
November.


8. Ship Recycling
The Committee considered the impact of the EU regulation together with the use f the Hong Kong
Convention’s Inventory of Hazardous Materials (IHM). There was a general feeling that the method
for maintaining the IHM was variable and that different companies were recording changes in
different ways. Furthermore, there remains a degree of confusion relating to the development and
maintenance of the IHM. Noting the completion of the Asbestos Guide, the Committee were of the
view that a second Guide should be drafted to provide a summary of the IHM requirements from
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developing the IHM to inspections and maintenance. This should cover both the EU and IMO
requirements. Furthermore, that basic best practice guidance should also feature in the guide.
Action

Draft a Guide to the EU and IMO requirements for an IHM covering the development,
maintenance and inspection requirements.
9. Port Reception Facilities
The secretariat provided an overview of the alleged inadequacy reports received from the
INTERTANKO membership since 2011 which showed that there remains a low frequency of reporting
to flag administrations by the industry with only 27 reports having been received by INTERTANKO
during the two and half year period, 2011-2013.
The Committee recalled its decision to withdraw the standalone INTERTANKO feedback form on the
basis that alleged inadequacy reports should be filed using the IMO standard format and sent to the
member’s flag administration. To be able to monitor the level of report the Committee, at that time,
encouraged members to copy these reports to INTERTANKO.
The Committee, in reviewing the data presented, noted that only five reports have been submitted
to the IMO by the receiving flag administrations. It was suggested that this indicates that there is a
considerably high level of under reporting by the flag administrations. If this figure is indicative of all
reports sent to flag administrations by the industry as a whole then only 19% (5 out of 27) of reports
are being forwarded for inclusion in the IMO’s Port Reception Facilities Database (PRFD). This may go
some way in explaining the relatively low number of reports in the IMO’s PRFD and the general
feeling among some IMO member states that the problem of inadequate port waste reception
facilities is no longer significant.
In its assessment of the data, the Committee also concluded that there exist two major bottle-necks
in terms of information on inadequate port reception facilities. Firstly, that the industry continues to
remain reluctant to report. This is based on what is considered as a low number of reports copied to
INTERTANKO over two and half years, i.e. 27 reports. Secondly, that even when such reports are
submitted only about 1 in 5 are actually forwarded to the IMO for inclusion in the PRFD.
Summary of Alleged Inadequacy Reports Received by INTERTANKO Jan 2011 to June 2013
1
Number of Alleged PRF Inadequacy Reports received by
INTERTANKO (2011-2013)
27
2
Number of Reports also uploaded to IMO PRFD
5
3
Number of INTERTANKO Members submitting reports
3
4
Number of different Flag Administrations sent reports
6
5
Number of different Port States
16
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6a
Number of reports submitted to the Port/PRF in question
19
6b
Number of responses from Port/PRF in relation to 6a
12
Action

The Committee requested the secretariat to issue a Weekly News advising the members of the
information provided the Committees conclusions and to encourage members to continue
reporting.

The Committee also requested the inclusion of this information on the agenda for the next
Council meeting and requested the Council to consider amending the Membership Criteria to
include the reporting of inadequate port reception facilities as a standard best practice for all
INTERTANKO members.
10. Biofouling
The Committee noted the follow up from the previous meeting regarding the possible integration of
the standalone Biofouling Management Plan into other ship board management plans such as the
PMS or SMS. Members commented that it is now common place to have a standalone Biofouling MP
as well as a separate Sediment MP on those vessels which traded regularly to the US, noting that it
was easier to demonstrate compliance in this manner.
Some members commented that many of their ship board management plans were now electronic
and that this was acceptable by most port states, including the US. Discussion turned to the use of
electronic record books with the Committee agreeing that it would be useful to keep abreast of the
IMO’s consideration of electronic record books, as was considered by the Committee at its last
meeting.
In its conclusion of the discussion on the Biofouling MP, the Committee agreed that it would be
beneficial to develop a Model Biofouling Management Plan. This could take the form of the original
INTERTANKO Ballast Water Management Plan released in the late 1990s. The Model Biofouling MP
would contain the minimum requirements as stipulated by the IMO and US. A small working group
of members agreed to meet to draft a first version of the Model MP in Greece at the end of October.
Action

Report on IMO developments relating to the use of electronic management plans and record
books and in particular the outcome of MEPC 66 where the electronic Garbage Record Book
was being considered.
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
Develop a Model Biofouling Management Plan taking into account the IMO Guidelines as well
as US Federal and regional requirements. Note the first draft to be developed by an ad-hoc
working group due to meet in Athens on 25th October.
11. Liaison with Environmental Organisations
The Committee noted the low level of focus on shipping from the international environmental
organisations but agreed to continue an open invitation to work with any organisations with similar
objectives to INTERTANKO.
12. Date and Place of next Meeting
The secretariat was asked to liaise with the secretary of ISTEC and agree a suitable date and place for
the next Committee meeting.
13. Any Other Business
13.1
Fines in California
The Committee were advised that the State of California had been issuing fines for spelling mistakes
and the correction of such mistakes on forms and record books.
The Committee took note.
13.2
New Agenda Item Proposals
The Committee supported the proposal to add two new items to the Committees agenda:
1. Environmental Initiatives and Projects
This item would provide a platform for Committee members to share information on
environmental projects or initiatives being undertaken within their companies. For example,
experience with energy efficiency devices or management ideas as well as experience with
BWMS.
2. Environmental Information Sharing
Noting 13.1 on the California fines, the Committee agreed that it is worthwhile sharing
information on environmental issues as is frequently undertaken on safety based issues.
These could follow the same sort of pattern with root cause and lessons learnt but instead
focused on environmentally related incidents.
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Action

Include two new items on the Committees future meeting agendas.
13.3
Ballast water port state control sampling and testing
Following a general discussion on the nature of tests to be carried out on BWMS, members
supported the secretariats continued dialogue with port state authorities on the voluntary testing of
BWMS. It was noted that if port state authorities wished to test certain sampling and testing
equipment then this could be a useful opportunity for owners with BWMS on board to also
undertake independent biological tests of their BWMS.
Action

Continue dialogue with those port state authorities seeking to develop the idea of voluntary
testing of ballast water for vessels with BWMS installed.
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Annex II
Our Ref.: TIM-14490/ 400116
Action Plan from 37th Meeting
Issue
Responsibility
Status
Membership

Circulate an invitation to join the Environmental Committee to all INTERTANKO members
through the Weekly News and the Environmental Bulletin.
Secretariat
Completed.

Revert to the Council on the Committee’s support for the proposed changes to the Terms of
Reference.
Secretariat
Completed.
Secretariat
Completed.
Environmental Performance on ships in operations

Circulate access details to all members of the Environmental Committee and ISTEC.
Garbage Management

Redraft the BMP taking into account the comments received from members of the
Environmental Committee and MARTECMA.
Secretariat
Completed

Circulate the revised draft to the two Committees with a view to receiving final proposed
amendments and approval for circulation to the entire INTERTANKO membership.
Secretariat
Ongoing. Awaiting IMO
approval to use Annex V text.

Include the Garbage Management Guide specific guidance on washdown water following its
consideration at MEPC 65, as appropriate, with a view to completion and circulation to members
in May 2013.
Secretariat
Ongoing (From 36th Meeting)
Secretariat
Completed.
Ballast Water Management Systems (BWMS)

Seek clarification from the EPA on the use of BWMS prior to a vessel’s application dates as well
as the applicability of the monitoring provisions of the VGP prior to the vessel’s application
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dates.

Issue the extension clarification received from the USCG to all members.
Secretariat
Completed

Once the USCG extension policy had been released, develop a model extension application letter
for use by members.
Secretariat
Completed.

Develop a decision tree guide on the applicability of the two US ballast water rules, i.e. USCG
and EPA.
Secretariat
Completed.

Invite a representative from the USCG to speak at the next joint meeting to advise on the USspecific type approval process as well as the USCG’s intended port State control procedures.
Secretariat
Invited – deferred to 2014
(From 36th Meeting)
Secretariat
Ongoing
Ship Recycling

Draft a Guide to the EU and IMO requirements for an IHM covering the development,
maintenance and inspection requirements.
NPDES – VGP

The Committee would continue to commence its work on revising the Guide to the VGP and
await the final version before concluding the revised Guide.
Secretariat / Committee
Completed.

Include the four bullet points in the INTERTANKO Guidance on the implementation of the 2013
VGP.
Secretariat
Completed.

Seek clarification from the EPA on necessity of dry docking to switch to EALs against undertaking
the switch at the nest scheduled dry dock.
Secretariat
Completed.

Complete the revised Guide with the proposed changes made at the workshop session by 1
October and circulate to the Committee for further input.
Secretariat
Completed.

Complete and circulate to all INTERTANKO members the final version of the Guide by 15
November.
Secretariat / Committee
Completed.
Port Reception Facilities
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

The Committee requested the secretariat to issue a Weekly News advising the members of the
information provided the Committees conclusions and to encourage members to continue
reporting.
Secretariat
Completed.
The Committee also requested the inclusion of this information on the agenda for the next
Council meeting and requested the Council to consider amending the Membership Criteria to
include the reporting of inadequate port reception facilities as a standard best practice for all
INTERTANKO members.
Secretariat
Completed.
Report on IMO developments relating to the use of electronic management plans and record
books and in particular the outcome of MEPC 66 where the electronic Garbage Record Book was
being considered.
Secretariat
Await MEPC 66.
Develop a Model Biofouling Management Plan taking into account the IMO Guidelines as well as
US Federal and regional requirements. Note the first draft to be developed by an ad-hoc working
group due to meet in Athens on 25th October.
Secretariat
Ongoing.
Biofouling


Liaison with Environmental Organisations
No action
-
AOB

Include two new items on the Committees future meeting agendas (Environmental Initiatives
and Projects and Environmental Information Sharing)
Secretariat
For forthcoming meeting.

Continue dialogue with those port state authorities seeking to develop the idea of voluntary
testing of ballast water for vessels with BWMS installed.
Secretariat
Ongoing.
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Annex III
Contact
Company
E-mail
Antonios Georgantzis
Consolidated Marine Management Inc
Antonios.Georgantzis@cmm.gr
Carlos Juan Madinabeitia
Tradewind Tankers SA, c/o Tradewind Tankers S.L.
cjuanm@tradewindtankers.com
Dimitrios A. Stamoudis
Minerva Marine Inc
dstamoudis@minervamarine.com
Erik Carlsen
Dampskibsselskabet NORDEN A/S
eca@ds-norden.com
Fabio Tagliavia
d'Amico Societá di Navigazione SpA
tagliavia@damicoship.com
Jan De Brabandere
Euronav NV
jan.de.brabandere@euronav.com
Ko Ko Naing
Northern Marine Management Ltd.
koko.naing@Stena.com
Marina Hadjipateras
Dorian (Hellas) SA
Marina.Hadjipateras@eagleocean.com
Michael Reppas
Sea World Management & Trading Inc
mikereppas@seaworldmt.gr
Muhammad Assuad Ahmad
AET Shipmanagement (Singapore) Pte Ltd
massuad@aet-tankers.com
Ole Christian Schroder
Scorpio Tankers Inc.
OSchroder@scorpiogroup.net
Oleg Kalinin
Unicom Management Services (Cyprus) Ltd
O.Kalinin@scf-group.com
Par Brandholm
Laurin Maritime (America) Inc.
paer.brandholm@laurinmaritime.se
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Annex IV
Saturday, 31 August, 2013
Our Ref.: TIM-14490/ 400096
TERMS OF REFERENCE
ENVIRONMENTAL COMMITTEE
1.
AIMS AND OBJECTIVES
1.1.
To develop INTERTANKO’s understanding of environmental issues and to participate in an
informed manner, so that the issues directly affecting tanker operations are better
represented by the Association for the benefit of its members.
1.2.
To develop environmental policies for INTERTANKO to follow up at the IMO and elsewhere,
and to be pro-active in approach.
1.3.
To establish an effective dialogue with environmental groups.
2. MEMBERSHIP
2.1.
The Environmental Committee is composed of a maximum of 18 members at any one time.
The Committee will draw on additional outside expertise if required.
2.2. The Committee members term is two years which can be extended for another two years,
unless other reasons apply and are approved by the Executive Committee. Examples of when
other reasons apply could include when it is difficult to get new members to join a Committee
or the member has specific expertise that would be valuable in the resolution of an important
issue under discussion by the Committee.
2.3. Members should attend Committee meetings and actively participate in the Committee
discussions. Repeated non‐attendance/non contribution may result in a review of Committee
membership by the Committee Chairman and Secretary and a recommendation of removal
from the committee. A Committee member may, on occasion, be represented by an alternate
from his company.
2.4. Membership on the Committee is based on the expertise/qualifications of the individual,
therefore, membership on a Committee rests with the individual, not the company that the
individual works for.
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2.5. The Committee shall be composed of individuals from Member companies that have
experience and expertise which will contribute to the aims and objectives of the Committee
and its work programme items.
3.
CHAIRMAN
3.1. The Committee shall elect from among its members a Chairman and up to two Vice-Chairmen
which are to be approved by the Council.
3.2. The Chairman’s term of office is two years which can be extended for another two years,
unless other reasons apply and are approved by the Executive Committee. Examples of when
other reasons apply could include when a new Chairman cannot be found or the resolution of
an important issue under discussion by the Committee would benefit from the Chairman’s
leadership.
3.2.
The Chairman will also act as a Vice-Chairman to ISTEC on Environmental issues.
4.
MEETINGS
4.1.
The Committee aims to meet at least twice a year.
4.2.
The Chairman may invite observers to the meetings. INTERTANKO’s Chairman, ISTEC Chairman
and Managing Director may participate in the meetings.
5.
TRAVEL EXPENSES
5.1.
The travel expenses of the Committee’s membership should be paid for by the member
company.
6.
TERMS OF REFERENCE
6.1.
The Terms of Reference shall be approved by INTERTANKO’s Council.
7.
SECRETARIAL
7.1. The INTERTANKO Secretariat undertakes the secretarial and administrative tasks for the
Committee.
8.
REPORTING
8.1. The Environmental Committee will report to INTERTANKO’s Council through its Chairman, as
required.
Updated and approved at 37th Meeting held in Istanbul on 12th September 2013.
Endorsed by the Council in Hong Kong on 26th November 2013.
***
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Annex V
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Annex VI
BEST PRACTICE ON THE MANAGEMENT OF
BOILER/ECONOMIZER WASHDOWN WATER
1.
Recognizing that the boiler/economizer washdown water, if discharged directly to sea, may
create oil-like traces on the sea surface which may have an environmental impact, its direct
overboard discharge is NOT recommended.
2
The following measures are suggested as a “best practice” for the management of
boiler/economizer washdown water:
2.1
Ships equipped with a soot-collecting tank
2.1.1 After washing the boiler/economizer gas side, all generated boiler/economizer washdown
water should be collected in the soot-collecting tank.
2.1.2 The soot-collecting tank should be equipped with a drain to the ship’s bilge holding tank
and/or with an eductor for overboard discharge. It is essential to remove as much soot prior to
decanting into the bilge holding tank.
2.1.3
Optionally, the soot collecting tank should be fitted with:
(a) a removable basket with mesh or filter bag at the inlet side of the tank (below the inlet
pipe) for a more efficient separation/removal of the entrained soot particles;
(b) one or more internal subdivisions (stages, sections or weirs) to allow water to cascade
over and facilitate the decanting of the washwater;
(c) a piping/valve arrangement to skim/transfer/drain the top surface level of the tank
(where any trace of oil-like substances might have been accumulated) to the bilge water
holding tank.
An indicative arrangement is shown in the Figures 1 and 2
Figure 1: Soot-drain arrangement
Figure 2: Soot-collecting tank
2.1.4 If the soot collecting tank is equipped with the arrangement set out in 2.1.3(c), then the
“skimmed” top layer of the tank which may contain any oil-like traces should be drained to the ship’s
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bilge water holding tank. Any separated solid soot should be then collected for subsequent
discharge to a port reception facility. The remaining decanted wash water should either be drained
to the bilge water holding tank or discharged overboard through the eductor.
2.1.5 If the soot collecting tank is NOT equipped with the arrangement set out in 2.1.3(c), then any
separated solid soot should be collected for subsequent discharge to a port reception facility. For
ease of storage, the soot can be dried and stored in drums for disposal to a port reception facility.
The remaining decanted wash water should be drained to the bilge water holding tank.
2.2
Ships not equipped with a soot-collecting tank
2.2.1 A filter bag should be installed/clamped at the drain pipe to bilges or to the ship’s bilge
water holding tank.
2.2.2 After washing the boiler/economizer gas side, all generated boiler/economizer washdown
water should be drained through the filter bag in the ship’s bilges or in the ship’s bilge water holding
tank and be handled as bilge water.
2.2.3 An additional filter at the inlet of the Oily Bilge Water Separator should be considered in
liaison with the maker.
2.3
Disposal records
2.3.1 The disposal of any collected solid soot and used filters to port reception facilities must be
recorded in the Garbage Record Book (GRB) as “operational waste”.
2.3.2 The
overboard
discharge
of
clean
decanted
its "skimming") should be recorded in the Engine Log Book.
wash
water
(after
2.3.3 Any draining to the ship's bilge water holding tank is an operation to be recorded in the ORB
Part I (Code D).
__________
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Annex VII
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Annex VIII
14 February 2014
Minutes – 4th Meeting of the ISTEC/EC JWG on MRV
12 February 2014
Thenamaris Office, Vouliagmeni, Athens
Participants
Stamatis Bourboulis, Euronav (Hellas)
Zois Dagaris, Euronav (Hellas)
Sokratis Dimakopoulos, Maran Tankers
Paolo Enoizi, Stolt
Minas Giaouzis, Thenamaris
Maria Sotiriou, Minerva Marine
Takis Koutris, Roxana Shipping
Dragos Rauta, INTERTANKO
Joe Angelo, INTERTANKO
Philip Tsichlis, Alpha Marine
Stamatis Fradelos, ABS
1 Minutes from the last meeting
Adopted.
2. Update on EU MRV proposed regulation & IMO proposed MRV schemes
The secretariat gave an update on the rulemaking process in the EU and presented the
latest proposed schemes at IMO/MEPC 66 for regulating CO2 emissions from ships in
operations. The presentation can be found on the INTERTANKO website.
With regard to the EU MRV process, it was noted there is little chance that the rule will be
completed before of end of April this year when EU elections will take place. However, the
Greek Ministry of Environment has set a goal to complete the work under the Greek
Presidency which means they will try to finalise the rule. Strict follow up is needed.
Another discussion was on the actual definition of the “transport work” in the EU MRV
proposal. It appears to be the same as in the EEOI formula (the sum of cargo transported x
distance for each individual voyage) but since the annual reporting requires ships to report
the “total cargo” and the “total distance”, one should clarify that the transport work is not the
result of multiplying these two aggregate values. The secretariat will clarify with DG CLIMA.
With regard to the other schemes proposed at IMO, the following questions and comments
were noted:
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How would the Annual EEOI proposed by Japan recognise the improvements during
the next 2 or 3 years of data recording? All ships in operations have already taken
measures to minimise fuel consumption. Further targets below current fuel
consumptions might be difficult to achieve. Will the current efficiency be set as a
target to be maintained in the future, no matter if the demand for trade increases?
The proposal initially forwarded by EC/EMSA is confusing since the data collection is
limited to CO2 emissions and distance but the rational of the scheme and the
calculation example given is based on a use of EIV/EEOI approach. This needs to be
clarified.
Agenda for the 38th Meeting of INTERTANKO’s Environmental Committee
To be held in London on 4th and 5th March 2014
Our Ref.: TIM-14490/ 400000
Page 39
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The US proposes to use Joules/service hours as a criterion. This approach seems to
contradict the scope of the regulation, namely to reduce CO2 emissions. Measuring
the ship’s performance in Joules does not recognise whether the source of energy is
clean of carbon and it would actually penalise use of clear fuels such as LNG and
even solar and other clean energy.
The energy of fuels used by ships in Joules is not given in the BDNs. It needs to be
determined by using the fuels calorific values and such data is not provided in the
BDN. It could be estimated but that adds uncertainty and makes verification difficult.
All schemes presented at IMO do not seem to differentiate between the usage of fuel
onboard ships, whether it is used for the main propulsion and/or for auxiliaries.
Tankers using large auxiliary boilers for cargo operations may have a significant fuel
usage. DP II Shuttle Tankers use fuel to meet safety practices at offshore location.
There is a limit on whether this part of fuel consumption can be reduced/improved.
It was agreed to further study the various proposals when reporting these aspects to ISTEC
and to the Environmental Committee at their joint session on 5 March.
3. INTERTANKO Representation at MEPC 66
Based on the feedback and guidance given by the Executive Committee, the JWG also
recommended the following positions on anticipated major issues that could be addressed:
7. Should collection of data be a prerequisite for developing this regulation?
INTERTANKO position: we agree with the phase-in rulemaking with initial data collection
based on which IMO could assess: (a) the necessity of developing the rule; (b) the standard
to define efficiency and (c) the target required for compliance. This provides us with
opportunity to support that part of the ICS submission.
8. Should EEDI complaint ships be subject to such a regulation?
A difficult decision with a split opinion both in the Executive Committee and in the JWG.
However, in both cases the large majority was against the application of the MRV rules to
the EEDI compliant ships. Reason: the EEDI compliant ships are mandated to be more
efficient by design. It could be assumed these ships will adopt adequate technologies to
minimise fuel consumption which it means technical efficiency is achieved through design.
More efficiency in operations would be achieved through speed reduction. Do ship owners
wish such restrictions as well as an additional certificate for the EEDI compliant ships?
The argument in favour of subjecting EEDI compliant ships to the MRV rule is to set a
stricter target so that one avoids a two-tier market on which ships not EEDI compliant would
be forced to be phase-out.
The JWG concluded it has no unanimity of views on this matter and will raise the question
with ISTEC/Environmental Committee on 5 March.
9. Should the rule set an “one-off” target or should there be a “moving target” over time?
The JWG agreed that the INTERTANKO position is guided as follows: based on the data
collected, IMO agrees on a final target but considers its enforcement in two or three steps.
(e.g. “final target” 10% from a base line with a two-step 5% enforcement)
10. Which data should be reported/collected (how to define Energy Efficiency?)
Agenda for the 38th Meeting of INTERTANKO’s Environmental Committee
To be held in London on 4th and 5th March 2014
Our Ref.: TIM-14490/ 400000
Page 40
The main question is whether the “cargo” should be a criterion used to define Energy
Efficiency, thus requiring monitoring and reporting? There is a significant chance that “cargo”
may not be included into the final data to be collected.
Based on these observations, the suggested INTERTANKO position is as follows:
INTERTANKO invites MEPC 66 to consider that there could be different ways on how best
to define Energy Efficiency in Operation for different ship types. Therefore, at least for Phase
I of the proposed regulation, INTERTANKO would like to propose that, for tankers; the
proposed rule should retain collection of data on the “total actual cargo” carried by tankers
for further assessments before a final decision is made.
In such a way, INTERTANKO will follow the views from the membership but will not lock
INTERTANKO on a final position.
11. Who should do verification of data collected?
INTERTANKO should clarify to MEPC 66 that “verification of data reported” cannot be done
by PSC but by Flag/ROs. Such verification should be done through the ISM Code. The
verification by PSC should be limited to “whether ships have reported the annual required
data”
12. Should INTERTANKO express views on the US proposed rating concept?
INTERTANKO is not in favour but if discussed at MEPC 66, we should suggest this aspect is
addressed at a later stage of the rule making development.
4 Data collection for MRV proposed regulations & preliminary assessment
A review of the data collected and graphs were presented and can be found on the
INTERTANKO website.
The secretariat will add more data recently received but which was not finally checked.
The data on parcel tankers needs to be separately addressed as definitions of a “voyage” or
a “distance of a voyage” or the definition of a tonne-miles calculation (“cargo x miles” for
each voyage). Due to the variety of the trade practices/patterns of such ships, the essential
element within the context of this proposed data monitoring is that all ships adopt the same
model to make statistical assessments valid.
It was noted that the EEOI values of the parcel tankers can vary from simple to triple but if
one removes “cargo” and calculates only CO2/nautical-mile, the values of these tankers are
quite close to each other. However, the JWG considers that even for these tankers, “cargo”
should be retained as an essential measure of efficiency.
5. Possible INTERTANKO model
The JWG reviewed the previous agreements on how to approach and develop a possible
model for assessing the efficiency of tankers in operation and, to the best ability separate the
tanker’s technical efficiency from the “logistic” criteria. Based on the agreement from the last
meeting and with the acceptance of the INTERTANKO Council to pursue that approach, the
secretariat has contacted UCL who has now reverted with a suggested agreement for
cooperation on this matter, including the fees.
Agenda for the 38th Meeting of INTERTANKO’s Environmental Committee
To be held in London on 4th and 5th March 2014
Our Ref.: TIM-14490/ 400000
Page 41
The JWG had a lengthy discussion on whether the model proposed by UCL and agreed to
be further explored by the JWG would actually create an “indexing of tankers” in operations.
It was mentioned that the UGS has very serious concerns with such an approach and thus
many ship owners would not support such a model. However, it was not clarified why this
approach will result in an indexing while any other proposed approach would not end up in
an indexing.
The contra proposal is to use the EEOI as a compliance criterion and, in case of noncompliance, the ship owner could demonstrate through the ship’s S-P curves that the ship
was technically efficient.
The JWG discussed this alternative at its last meeting and, while agreeing that the S-P
curves will be the best way to assess the ship technical efficiency, it was not chosen
because of the many practical difficulties to include such a criterion into a mandatory
regulation. It would require model testing or ship trials on all existing ships, which is a major
undertaking. The reporting and processing of the S-P curves for all ships in one class (type
and size) seem to be quite difficult as well as setting the standard. Therefore, at its last
meeting, the JWG concluded that the UCL approach is the best alternative and easy to
apply.
The JWG agreed that the secretariat pursues the development of the UCL model to follow
up on the JWG commitment to be proactively involved in analysing the impact of various
MRV proposals and find a possible model to best define the ship’s technical efficiency which
can be visible versus the transportation efficiency defined by EEOI or any other of the
proposed schemes.
6. Monitoring Plan
The JWG agreed to consider developing a standard/template for a Ship Monitoring,
Reporting and Verification Plan. This can be done in cooperation with ABS and Alpha Marine
whose representatives attended the meeting.
It was agreed to develop an initial skeleton /list of content for such a plan. The development
of such a plan would be a good exercise to better understand the process of monitoring and
verification. The plan might formulate the process involving monitoring and recoding. For
instance, if fuel monitoring is done through BDNs, then the plan may indicate the steps in
taking bunker tank soundings/ROBs at the beginning and end of voyages, how to check the
balances between BDN values and measurements, how to address discrepancies, level of
deviations, etc. Another process would be linked to use of flow meters to monitor fuel
consumption including type and frequency of calibrations, verification of results, etc.
The JWG agreed to proceed on this project before its next meeting, anticipated to be after
MEPC 66 session, early April.
The participants thanked Minas Giaouzis and Thenamaris for their hospitality and excellent
conditions provided for this meeting.
Agenda for the 38th Meeting of INTERTANKO’s Environmental Committee
To be held in London on 4th and 5th March 2014
Our Ref.: TIM-14490/ 400000
Page 42