28th Meeting of the Environmental Committee

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28th Meeting of the Environmental Committee Powered By Docstoc
                                 28 Meeting of INTERTANKO’s

                      ENVIRONMENTAL COMMITTEE
                                    Tuesday 20 January 2009

                                              Great Room
                                        Le Méridien Dubai Hotel
                                          Airport Road, Dubai
                                         United Arab Emirates
                                        Phone: + 971 4 217 0000
                                         Fax: +971 4 282 1650


              INTERTANKO’s Anti-Trust/Competition law Compliance Statement

INTERTANKO is 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 this market. These laws include the anti-trust and competition laws, which
the US, 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. This meeting will be conducted in compliance with these laws and in
accordance with INTERTANKO’s anti-trust/competition law guidelines.


       1. Minutes
       2. Membership

Policy Issues
       3.    Greenhouse Gas Emissions
       4.    US - NPDES
       5.    Environmental Benchmarking
       6.    Ship Strikes with Cetaceans
       7.    Marine Noise Pollution

Reporting Items
       8.    Port Reception Facilities
       9.    Biofouling
       10.   Ship Recycling
       11.   Ballast Water Management
       12.   TMSA Related Matters
       13.   Liaison with Environmental Organisations
       14.   Date and Place of next Meeting
       15.   Any Other Business
1. Minutes

The minutes from the last meeting, held in London on 3rd October 2008, are enclosed.

  Minutes London

The Committee is invited to approve the minutes from the last meeting.

2. Membership

The Committee will recall that, at its last meeting, the Chairman announced that he would be
stepping down and invited the Committee to consider a new Chairman at its next meeting.

The Committee will be invited to nominate a new Chairman.

The Committee membership is enclosed for reference. Members are invited to advise the
secretariat of any amendments to the list.


Agenda for INTERTANKO’s Environmental Committee                                  Page 2 of 16
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3. Greenhouse Gas Emissions

During the joint meeting with ISTEC, the Environmental Committee will be invited to contribute to
the discussion on GHGs. The following background and updates are common to both the ISTEC
and Environmental Committee agenda notes.

3.1 Regulatory developments and update on GHGs

Below is the secretariats report from MEPC 58 giving the status of regulatory developments on
GHG. The additional information in these notes provides an update on developments since
MEPC 58 and are aimed to generate discussion on the possible strategy INTERTANKO should
follow on the various elements.

 GHG report from


One important development since MEPC 58 was that the European Parliament adopted the
package of climate change laws on 17 December 2008. This revised Emissions Trading Directive
now includes an agreement between the EU Member States (the Council) and the European
Parliament on future inclusion of shipping in the EU-ETS; it states that if the IMO has not
approved international GHG reduction targets by the end of 2011, the Commission is to produce
a proposal to include carbon emissions from the international shipping sector in the EU-ETS. The
inclusion of shipping is to take effect by 2013 at the latest. The precise text reads:

“In the event that no international agreement including international maritime emissions in its
reduction targets through the IMO has been approved by the Member States and/or no such
agreement through the UNFCCC has been approved by the Community by 31 December 2011,
the Commission should make a proposal to include international maritime emissions according to
harmonised modalities in the Community reduction commitment with the aim of its entry into
force by 2013. Such proposal should minimise any negative impact on EU competitiveness,
taking into account the potential environmental benefits.”

Based on the above it is now expected that the European Commission will make use of an
external report that has been commissioned from a consortium led by CE Delft. The report will
apparently analyse the various policy options for reducing carbon emissions from international
shipping and, having been contracted for 12 months from October 2008, the findings will be
presented to the European Commission in the autumn of 2009. It is hoped that preliminary
findings will be presented in time for MEPC 59 (July 2009), so that the IMO can be given an
opportunity to react and elaborate ahead of the Copenhagen UNFCCC meeting at the end of the
year. Clearly, how best to deal with shipping emissions at an international level will also be a part
of EU preparations for the Copenhagen COP meeting.

There are important elements on the EU’s strategy which still need to be clarified and elaborated
on. Most importantly the EU has not yet defined in any detail what it would be prepared to
consider as a satisfactory outcome from the IMO but, it indicates that EU remains committed to
do “whatever it takes” in order to achieve its 20% reduction goals by 2020.

So, it becomes apparent that EU will be satisfied and may take no action if the industry is able to
deliver that sort of saving. Could the shipping industry make such a commitment, no matter the
increase in demand of transportation at sea in 2020? It is expected that due to NOx emissions

Agenda for INTERTANKO’s Environmental Committee                                       Page 3 of 16
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regulations, engines in "new ships" may not be able to provide any significant fuel saving even
though some improvement might be obtained through better designs. New and magic
technologies to significantly cut the fuel consumption are not predicted to be in place for 2020.
Concluding, new ships are not going to give THE solution for reducing 20% CO2 emissions by
2020 which means that better operations, careful routing and better logistics will have a big share
to obtain such a saving.

Note should be taken that during MEPC 58, OCIMF distributed its “Energy Efficiency and Fuel
Management” brochure which was introduced at the Committee’s previous meeting. The
document is planned to be an annex to TMSA 2 and thus tanker operators should give it due
regard and provide evidence on how they meet various requirements contained in it. In reviewing
this document, the INTERTANKO Council agreed on the following statement:

“INTERTANKO MEMBERS, as part of their commitment to reduce Greenhouse Gas emissions,
inter alia, commit to actively liaise with Charterers to optimise vessel speed and voyage
schedules and call upon ALL Charterers to equally commit to this liaison and on OCIMF to help
facilitate the adoption of optimal vessel speeds and voyage schedules.”

The Committee will be invited to consider these developments, in particular the predictable
expectations for fuel consumption reduction from the EU. Could the industry make such a
commitment? Would it stop EU imposing ETS? Would it have any impact in the IMO
developments on MBI?

3.1.1 Reduction Measures – members’ experiences

A substantial amount of information was gathered during the course of last year relating to
members’ experience implementing GHG reduction measures. As much of the operations and
technology were still under consideration by many of the members at the time of gathering the
information, the Committee is invited to share any further experience gained on energy efficiency

3.1.2 SEMP – IMO and INTERTANKO Guidelines

The industry associations are still in the process of drafting a final version of the Ship Efficiency
Management Plan (SEMP) which is due to be submitted to the IMO on 6th February. While
detailed comments on the draft have been sent, there still remains the question relating to the
regulatory method for the implementation of the SEMP. During consideration of GHG’s by
INTERTANKO’s Council in November 2008, concern was raised with the implementation of the
SEMP via the ISM Code as opposed to MARPOL or a stand-alone resolution. This will have a
bearing on the format of the SEMP and the amount of detail which is contained in the second
part. Note that, on INTERTANKO’s suggestion, the second part of the SEMP is the ship board
part which is intended to solely focus on recording and not on the more detailed elements of
implementing an efficiency plan. The latter is deemed appropriate for the shore side to maintain.
The latest draft of the industry/IMO SEMP is enclosed for information.

Industry Draft SEMP

The Committee will be invited to consider whether the ISM Code or another IMO instrument is
the best option mandating the SEMP.

INTERTANKO’s Council also supported the continued development and completion of
INTERTANKO’s Guide for a Tanker Efficiency and Emission Management Plan as referenced in
the Best Practice on Tanker Emissions and Energy Efficiency, enclosed for reference.

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INTKO Best Practices

The latest draft of INTERTANKO’s Guide for a Tanker Efficiency and Emission Management
Plan is also enclosed for information.

    Draft INTKO
   Efficiency Plan

The Committee will be invited to comment in general terms on the draft and, in relation to the
discussion under agenda item, 3.1.1, provide the secretariat with more detailed written
comments via correspondence.

3.1.3 Operational Index

MEPC 58 has tasked a correspondence group to revisit MEPC/Cir. 471 for refining the definition
of the Operational Index. The work is in progress and the Committee will receive an update at the

The Committee will be invited to take note and comment accordingly.

3.1.4 Energy Efficiency Design Index – Trials and data

A ship GHG design index was adopted at the IMO/MEPC 58 (October 2008) on an interim and
voluntary basis. It has now been re-named as Energy Efficiency Design Index (EEDI). The
proposed mandatory specific formula as enclosed below will be further refined and possibly
adopted in July 2009. IMO has also to decide on the acceptable efficiency values and to decide
on the reduction of such values and the frequency/timing of such reductions.


A likely approach to proposing such standards will begin with an evaluation of the most efficient
new builds today (or new ships built in recent years) to determine a “baseline” of what constitutes
the “best” ships today. Next would be a calculation and negotiation concerning what
improvements are feasible through design innovation and how quickly the improvements can be
put into place in the shipyard. Among the principal issues to be addressed with respect to the
vessel EEDI includes the methodology for survey and certification that a new ship meets the
standard. Presumably, flags and class societies will develop a detailed survey and certification
process for class to determine if a given vessel meets the standard. It has to include the
consequences if the ship does not meet the standard.

With regard to EEDI formulae, the ISTEC was invited to use their own ships’ data and submit the
results. Such information could be useful in monitoring the final results of an acceptable decision
by IMO on the EEDI value set in by regulations. ISTEC also received a circular from the
Japanese Government requesting information that will assist them in better defining the fw factor.
We hope that such information was passed on in order to assist in finalising the EEDI formulae.

The Committee will be invited to address issues related to EEDI and provide further guidance.

Agenda for INTERTANKO’s Environmental Committee                                      Page 5 of 16
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3.1.5 Market Based Instruments (MBI)

The Committee may appreciate an update on the current developments in IMO with regard to
MBI. MEPC 59 will decide in July 2009 how to address various alternatives of MBI, if any.
Currently, the MBI with more concreted proposals are (a) a levy on fuel and an International
Fund that would collect funds that could then be used on projects to reduce CO2 emissions and
(b) an Emission Trading System (ETS).

An International Fund: Levies on Marine Fuel Sales

Denmark has proposed the establishment of an International Fund to generate monies through a
“levy” on marine fuel sales that would then be used on initiatives to reduce GHGs. There are
several prominent sets of issues with regard to discussion of this subject, including:

   o   legal issues, including competence to establish such a measure;
   o   administrative matters, such as who sets, collects, disburses, and monitors the revenues
       generated; and
   o   the purpose of the revenue generation and the dispersal of the funds in a monitored way
       that achieves the purpose.

The basic premise behind the proposal from Denmark is to establish a levy or tax on marine fuel
that would fund an International Compensation Fund for GHG Emissions from Ships, for the
purpose of funding projects to reduce carbon emissions around the world, perhaps focusing on
developing countries. Cyprus has also proposed creation of an international fund serving this
purpose, but proposes that contributions be purely voluntary and not be related to fuel sales.
An outline of the Danish proposal and the key elements in the mechanism are as follows:

   o   Ships must buy fuel at a registered or “licensed” bunker fuel supplier.
   o   Documentation that bunker fuel has been purchased from a registered bunker fuel
       supplier, and that the GHG contributions have been paid, shall be maintained on board
       (not such requirement in MARPOL Annex VI).
   o   The bunker delivery note shall be kept on board as evidence (is already a requirement in
       MARPOL Annex VI).
   o   Mandatory registration of bunker fuel suppliers eligible to sell bunker fuel in compliance
       with the scheme will be introduced and the registered bunker fuel suppliers shall be
       required to collect information on all fuel sold (on a ship specific basis), plus collect and
       transfer GHG contributions to the International GHG Fund Administrator.
   o   A State Party to the new Convention shall require that bunker fuel suppliers within its
       territory become registered or “licensed” bunker fuel supplier eligible to sell bunker fuel
       and comply with the obligations of the new Convention.
   o   The International GHG Fund Administrator shall maintain a global registry of registered
       bunker fuel suppliers and of GHG contributions received where each ship has its own
       account (on a ship specific basis).
   o   There must be open access to the global registry and limited access to the ship
       accounts, i.e. port States shall have access to view accounts for ships entering its ports,
       flag States shall have access to accounts for ships entitled to fly its flag, ship
       owners/operators shall have access to accounts for his ship etc.

The International GHG Fund would be established as a separate legal entity responsible for
allocating and monitoring the revenues generated within the scope of the legal instrument, which
most suitably would be a new Convention on an International GHG Fund. Revenues should be
allocated to specific purposes consistent with the primary objectives in the United Nations
Framework on Climate Change Convention (UNFCCC). The revenues should be allocated to:

   o   Financing mitigation, adaptation and technology transfer and development projects in
       developing countries and SIDS especially.

Agenda for INTERTANKO’s Environmental Committee                                       Page 6 of 16
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   o   Financing non-vessel specific R&D projects of more CO2 efficient ship designs and
       propulsion systems in order to accelerate continuing improvements in this field.
   o   Financing technical cooperation within the existing IMO framework.

The respective apportionment of funds to these three purposes shall be decided by the Parties to
the new Convention.

The understandable initial reaction to a new fuel “tax” proposal from many governments and
industry sources is to express misgivings or opposition. Indeed, some of the IMO member
governments have emphasised their opposition to any proposal that constitutes an international
tax. Others governments have expressed a willingness to further consider such a proposal,
noting that the idea could resemble the system in place through the International Fund for
Compensation for Oil Pollution Damage, where funds on oil shipments are placed in an
international fund to provide monies for compensation in the event of marine oil spills. Others
have also noted that an International Compensation Fund or bunkers’ levy is attractive due to its
potential simplicity and to the less complicated mechanisms that would be necessary to give
effect to the regime. However, the main concern with many Flag Administrations is linked to the
monitoring of fuel purchases and thus of taxes to be paid by individual ships.

For ship operators, an immediate concern should be linked to a highly probable slow ratification
rate and an uneven geographical distribution of Parties to the new Convention. There are
questions on what would be the ship’s obligations if carrying a flag of a Party to this new
Convention but, which gets no assistance to prove compliance in ports from a non-Party country.
Would ships be restricted to take bunkers in ports of countries which are not Parties to MARPOL
Annex VI and/or to this new Convention? There are many other legal aspects of such a scheme
if IMO will again make ships responsible for decisions and actions that are beyond their control.
Also of concern is how would IMO, the flag States or the port States monitor, control the track of
the money which is supposed to be collected from ships and transferred to the International GHG
Compensation Fund by the registered bunker fuel suppliers.

Emission Trading Schemes

A number of European countries are advocating that the IMO creates a carbon emission trading
scheme (ETS) for shipping, and have indicated that if the IMO does not do so, that they would
advocate that the EU establishes such a scheme applicable to all ships trading in European
ports. An emission trading scheme is often referred to as a “market-based” system on the
grounds that the system would cap emissions (either by industry sector or economy wide) and
sell allowances of CO2 emissions to various industry players, including ship owners and
operators. These allowances or credits could then be traded with other industry players who
have credits available or who require additional credits. As such, a “market” would evolve where
a ton of CO2 credits has a certain monetary value that is then capable of being bought and sold.

It is not clear how EU wishes to define the ETS for shipping. The closest one could come to is
the ETS which is in preparation for aviation. At an industry level, as from 2012, all aircrafts
leaving the EU and landing in the EU will have to meet a global CO2 emission limit which
corresponds to 97% of average 2004-2006 emissions. The limit is reduced to 95% from 2013
onwards. Aircrafts will be given free credits but not enough to cover 100% of the excess of CO2.
It was proposed that some 15% of these credits can be purchased from auctioning. However, the
proposal for aircrafts falls short in giving specific details on how the CO2 limit is translated to
airlines and to the individual aircrafts. How auctioning will work and how this scheme will be

INTERTANKO visited IATA, the AEA (Association of European Airlines) and the SAS office in
Brussels to learn more about the ETS on aircrafts. IATA is at this stage uncertain how the system
will work in practice because the implementation rules have not yet been finalised. The
Commission is currently preparing detailed guidance (implementation rules). With regard to a

Agenda for INTERTANKO’s Environmental Committee                                      Page 7 of 16
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Our Ref.: TIM-14490/1650005
possible lobby-strategy for maritime transport IATA, AEA and SAS would recommend the

    o   Stress the extended benefits of providing transport services but,
    o   Do NOT stress that shipping is only responsible for a small share of global emissions
        because all sectors will be expected to cut emissions.
    o   Do not plead for special treatment.
    o   Show what the industry has done and (more importantly) is doing to reduce emissions.
    o   Be proactive and steer the debate.
    o   Stress that ETS is not supposed to stop growth but rather to put a cap on emissions.
    o   Support a package of different measures to reduce emissions.
    o   The industry needed to be united from the start. This had not been the case for the
        aviation industry where various airlines had lobbied for different solutions based on
        differing perceptions of reality and on what they expected could be realistically achieved.
        This had severely weakened the aviation industry’s position and had enabled DG ENV to
        play various interests up against each other.

Any ETS targeting maritime industry emissions would presumably establish a cap for shipping
based on a given baseline or percentage reduction in total emissions. This seems to depart from
the current IMO concept that ships in service should adopt measures to reduce CO2 emissions
and that the monitoring of the effects of such measures is done by use of an Operational Index
but as a voluntary mechanism. An ETS would change all this and would require a monitoring
system that can be controlled.

Therefore, the shipping industry should consider these developments very closely and
understand the consequences and impact on ships.

Other Possible MBI approaches

It is worthwhile to note two alternative approaches that have been raised in recent discussions,
but not formally proposed:

1. Cargo-Based System: The German Shipowners Association has circulated a conceptual
proposal that would assign CO2 emissions to the cargo with the actual CO2 emissions being
assigned to the importing country. This might be an interesting alternative for tankers. It proves to
raise many questions with regard to the complexity of such a system applied to other ship types,
such as container ships. This would require the creation of an extensive and detailed cargo
tracking system to be in place to follow and record the numerous trans-shipments, de-
consolidations, and cross-border movements of cargoes once they are discharged at their initial
port of entry. It would require information that may be far beyond what is contained in a container
ship’s bill of lading and beyond the knowledge of the ship operator.

2. Market-Based System limited to Ships entering Annex 1 Countries: One environmental
organisation suggested IMO adoption of a market-based trading system limited to ships entering
the ports of Annex 1 countries as defined under the Kyoto Protocol. While this proposal was
presumably meant to offer an idea for how to move forward for those Kyoto Convention Annex 2
governments advocating “differentiated” GHG responsibilities in the maritime sector, it is not all
clear why the numerous Annex 1 countries would find this an attractive solution either from an
environmental perspective or from a political perspective.

Neither of these two concepts has been supported by governments to date. They are discussed
here simply to identify the potential array of ideas on this topic.

However, the UK Chamber of Shipping has recently issued a Press Release giving full support
for an ETS system for shipping. The press release did not provide any ideas on how the ETS
should work on global or even regional basis. INTERTANKO prepared a response to that which
was passed to the press and is enclosed below.

Agenda for INTERTANKO’s Environmental Committee                                       Page 8 of 16
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INTKO Comment on

Statements made by other associations and major shipping companies might unfortunately
indicate that the maritime sector could fall in the same trap as aviation by not coordinating their
efforts through a commonly agreed strategy.

The Committee will be invited to consider all these developments and comment accordingly.

3.2 VOC Management Plan

INTERTANKO is also active in assisting IMO to finalise the Guidelines for the VOC Management
Plan as required under the amendments of MARPOL Annex VI. We have two contributions for
the next session of the IMO Sub-Committee on Bulk Liquids and Gases, as follows:

    o   INTERTANKO and OCIMF joint submission suggesting few corrections on the IMO draft
    o   INTERTANKO and Norway joint submission for a Model VOC Management Plan for
        crude oil tankers.

Model VOC Mgt Plan

The Committee will be invited to consider the latter document and comment accordingly.


On December 18, INTERTANKO’s Washington Office, working together with the industry
coalition consisting of the American Waterways Operators (AWO), the Cruise Line International
Association (CLIA), the Chamber of Shipping of America (CSA), the Lake Carriers Association
(LCA) and the World Shipping Council (WSC), convinced the US government (EPA and
Department of Justice) to submit a joint motion to the US District court requesting a 48 day (until
February 6, 2009) extension of the courts decision to vacate EPA's blanket exemption of all ship
discharges incidental to normal operation of a vessel. The plaintiffs (environmental groups and
certain US states) did not object to this joint motion.

On December 19, the District court judge signed the joint motion and ordered the vacatur
extended until February 6, 2009. INTERTANKO members now have until February 6, 2009 to
assess the final Vessel General Permit (VGP) requirements and provide the necessary guidance
and procedures for their ships to comply with these requirements when entering U.S. waters
commencing on February 6, 2009.

The Committee will recall that at its last meeting agreement was reached on the development of
a model implementation plan to assist compliance with the VGP and provide a harmonised
method for meeting the requirements by the tanker industry.

Subsequent to the last meeting, the secretariat received information from several members
regarding various methodologies for meeting the VGP requirements. In circular EnvComm #13-
08 the secretariat advised members of discussion and work undertaken with the Chairman to
draft an initial model for recording and monitoring the VGP requirements. The five sections are

Agenda for INTERTANKO’s Environmental Committee                                        Page 9 of 16
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 NPDES MP Weekly   NPDES MP Annual   NPDES MP Sample NPDES MP Corrective   NPDES MP
   Inspections       Inspections        Records            Action          Drydocking

The Committee will be invited to comment on the drafts and any supplemental information that
will be required to develop a Model Plan for VGP compliance.

Additional correspondence with members outside of the Committee reveals that there are still
many outstanding questions to be resolved in regards to compliance with the VGP. A proposal
has been forthcoming from an INTERTANKO member suggesting that a web-page on
INTERTANKO’s website be established where members can:

   a. find information/clarifications regarding VGP-related implementation issues (such as
      recent enquiries relating to graywater recordkeeping and state implementation under
      section 6); and
   b. pose queries/questions to the Secretariat and other INTERTANKO members on such

The Committee will be invited to consider the above proposal.

5. Environmental Benchmarking

At its previous two meetings, the Committee has considered the establishment of an
environmental benchmarking scheme to be placed on the INTERTANKO website. The
Committee agreed at its last meeting that the following data should be recorded:

                                      Cargo and fuel oil records

                                                                      Cargo              Fuel
       Number of Pollution Incidents
       Quantity (MT)
              - on-deck
              - into the water
       Number of Transfers (loading and discharging)

                                           Lube oil records

       Lube oil on board ROB ( at start of reporting period) – (MT)
       Quantity of Lube Oil received within the reporting year (MT)
       Lube Oil ROB (on completion of reporting period)
       Total Lube Oil handled within reporting period

Furthermore, additional waste was not extensively covered during the previous meeting. Michael
Reppas has kindly provided a draft for benchmarking other waste (non-oil) which I enclosed.

   Other Waste

The Committee will be invited to consider the draft for other wastes and provide comments as

Agenda for INTERTANKO’s Environmental Committee                                            Page 10 of 16
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6. Ship Strikes with Cetaceans

Activity relating to this issue has been ongoing in three areas:

6.1 US

Members will have noted the introduction of seasonal speed restrictions (10knots) in the US.
Hard copies of the guidance are being provided by NOAA and can be ordered through their
website: http://www.nmfs.noaa.gov/pr/shipstrike.

In addition to the speed restriction in the so-called Seasonal Management Areas, NOAA is also
assessing the merits of introducing voluntary Dynamic Management Areas. These DMAs are
initiated when sightings of several whale individuals are made. After which a speed restriction of
10knots will be enforced for 15 days.

6.2 IMO

The Committee will recall that it supported the practical approach that the US had taken in its
draft set of Guidelines on minimising ship strikes. This draft was supported at MEPC 58 but
member states and observers were invited to submit further comments on the draft text by the
next MEPC meeting (MEPC 59 in July 2009). Subject to discussion at MEPC 59, the Guidelines
will be adopted and circulated as an MEPC Circular after the meeting. The Guidelines are
annexed in the enclosed document.

Ship Strike Guidelines

The Committee is invited to note the development on this issue and comment further on the draft

6.3 Environmental Organisations and the International Whaling Commission (IWC)

In parallel with the IMO’s work, the International Fund for Animal Welfare (IFAW) and the
International Whaling Commission (IWC) have been working on an awareness campaign for
mariners. The document enclosed is the latest version of the brochure they intend to produce
and circulate. INTERTANKO has provided input on the brochure in an attempt to provide more
practical guidance to mariners and to align the work of the two bodies with that of the IMO.

IFAW ship strike A5

The Committee is invited to note the work of IFAW and IWC and comment on the brochure as

7. Marine Noise Pollution

At its last meeting the Committee was advised of the growing importance of this issue on the
IMO’s environmental agenda and the subsequent submissions by the US and Australia to MEPC
58. Following MEPC 58 INTERTANKO has been a participant in a Marine Noise
Correspondence Group which was provided with the following short terms of reference:

Agenda for INTERTANKO’s Environmental Committee                                     Page 11 of 16
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        “identify and address ways to minimize the introduction of incidental noise into
        the marine environment from commercial shipping to reduce the potential
        adverse impact on marine life, in particular develop non-mandatory technical
        guidelines for ship-quieting technologies as well as potential navigation and
        operational practices”

The US National Oceanic and Atmospheric Administration (NOAA) is coordinating the
Correspondence Group and is taking the work in a positive direction. A summary of the outline
approach directly applicable to shipping is provided below:

   Options for quieting noise from commercial ships should be evaluated relative to the amount
    of reduction achievable, implementation cost (new ship, existing ship) and any collateral
    benefits (e.g., greater fuel efficiency, reduced maintenance and operational costs).

   The options for quieting technologies generally fall into two basic areas: hull/propeller design
    (cavitation) and underwater radiated noise from machinery, but the initial and primary focus
    of our efforts is expected to be on issues related to propeller cavitation.

   Work towards the development of non-binding, technical guidelines.

To begin work on this issue within the Correspondence Group, the coordinator has posed several
questions related to the identification of noise sources from shipping and the current technologies
available to reduce/minimize underwater noise. The questions are provided below:

        1. What are the most important sources of low frequency (less than 1kHz)
        radiated underwater noise from commercial vessels? For each source type,
        please address the following, if applicable and if known:

        a. the characteristics of this source of noise and the conditions under which it has
        been evaluated (i.e., frequency and intensity estimates and measurement

        b. the degree to which this source of noise is currently evaluated during the ship
        design phase (i.e. not at all, on a few ships, on many ships);

        c. the degree to which this source of noise is currently addressed in final builds
        for ships (i.e. not at all, on a few ships, on many ships);

        d. the relationship between the magnitude of this source of noise and the
        regularity of specific ship maintenance tasks;

        e. the relationship between the magnitude of this source of noise and ships’
        operating conditions (i.e. speed, loading, etc.); and

        f. whether this noise source remains significant for ships that are hoteling, in port
        or otherwise stationary.

        2. What kinds of technologies are currently used to reduce radiated underwater
        noise from vessels of all types, including non-commercial vessels (e.g.,
        oceanographic research, fisheries, military, or other types of vessels)? To what
        extent could such technologies potentially be used on commercial vessels?
        Please indicate the following in response to this question:

        a. the characteristics of the vessel to which the technology is currently applied
        and a description of the technology. Characteristics provided should include
        vessel type, length/breadth, (maximum and minimum) draft, deadweight,
        propulsion type, maximum design speed and typical route;

Agenda for INTERTANKO’s Environmental Committee                                        Page 12 of 16
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       b. the driving force for the development of current technology (e.g., has it been
       developed to address another issue such as anti-fouling paints on propellers or
       technologies to make a fisheries research vessel quiet in order not to scare away
       the very thing being researched);

       c. the noise source onboard the vessel to which the current technology is being
       applied (e.g., propeller, onboard machinery, engine);

       d. whether the technology is commercially available;

       e. the cost and feasibility of applying the technology to existing commercial ships
       (in the context in which they have already been applied);

       f. the cost and feasibility of applying the technology to newly-built ships (in the
       context in which they have already been applied); and

       g. is this technology appropriately applied to reduce underwater noise from ships
       that are hoteling, in port or otherwise stationary?

       3. What additional technologies for reducing radiated underwater noise from
       vessels are currently in research and development or should be advanced
       through research and development? Please indicate the following in response to
       this question:

       a. the type of vessel to which the technology will be applied (e.g., propeller
       cavitation, machinery) and a description of the technology;

       b. the driving force for the research and development of the technology (e.g.,
       noise reduction, fuel efficiency, response to adoption of other shipping-related
       regulations such reduction of air pollution);

       c. the noise source onboard the vessel to which the technology will be applied
       (e.g., propeller, onboard machinery, engine etc.);

       d. whether the technology is being considered for application to existing as well
       as new ships;

       e. the estimated cost and feasibility of applying the technology to existing and/or
       new ships;

       f. whether this technology could be appropriately applied to reduce underwater
       noise from ships that are hoteling, in port or otherwise stationary; and

       g. are there any obstacles to the development of this technology and, if so, how
       are they being addressed?

The Committee is invited to note the development on this issue and the direction that is being
taken within the IMO Correspondence Group. Furthermore, the Committee is invited to provide
input in relation to the Correspondence Group’s questions.

Agenda for INTERTANKO’s Environmental Committee                                         Page 13 of 16
To be held in Dubai on the 20 January 2009
Our Ref.: TIM-14490/1650005

8. Port Reception Facilities

As advised during the previous meeting, the standardised Advanced Notification Form (ANF) and
Waste Delivery Receipt (WDR) were finalised and adopted at MEPC 58. These have
subsequently been circulated to INTERTANKO members.

Furthermore, the IMO’s Correspondence Group has completed its work on the Guide to Good
Practice on Port Reception Facilities which is due to be adopted at MEPC 59 in July. Due note is
given to INTERTANKO’s contribution and initial drafting of this Guide.

On a regional level, the USCG has invited specific comments from the industry on the state of
US reception facilities. This was advised in Weekly News 1/2 issued in January 2009.

The Committee is invited to take note and comment as appropriate.

9. Biofouling

The IMO’s Correspondence Group on Biofouling has now concluded its work and submitted its
report to the BLG sub-Committee. Based on previous discussion and input from the Committee,
INTERTANKO was able to submit comments to the group which have been adequately taken
into account within the final report. The overriding recommendation from the CG has been to
develop practical guidelines as opposed to the other options which included an annex to
MARPOL, an inclusion within the AFS Convention, a stand-alone legal instrument on biofouling
or an inclusion within the Ballast Water Convention.

INTERTANKO’s contributions to the group, other than on the direction of the issue at the IMO,
were focused on the detail of the biofouling guidelines. The final draft from the CG is enclosed
below. Note that this is still under discussion and that the CG is likely to continue following the
BLG meeting with the mandate to further draft biofouling the Best Practices and associated

  Biofouling Draft

Noting that the guidelines are still under consideration, the Committee is invited to provide any
further comments on the draft. In addition, the Committee should note the possible overlap of
recommendations with the NPDES VGP recording and inspection requirements and the potential
for harmonising these two areas of work.

10. Ship Recycling

IMO’s Draft Convention

The draft text of the Ship Recycling Convention was reviewed and endorsed at MEPC 58 and
subsequently forwarded for adoption by a Diplomatic Conference due to be held in Hong Kong,
11-15 May 2009.

There only two significant issues outstanding which are important to note:

     1. Threshold Values

Agenda for INTERTANKO’s Environmental Committee                                     Page 14 of 16
To be held in Dubai on the 20 January 2009
Our Ref.: TIM-14490/1650005
    The Inventory of Hazardous Materials contains a list of materials to be recorded. Alongside
    this list owners are requested to provide a quantity for each material. Concern has been
    raised however that there may exist materials at extremely low levels and that it will be near-
    impossible to quantify or even locate such small value materials. The industry, during MEPC
    58, requested that threshold limits be established to allow small quantities that present a
    tolerable risk to be established. Furthermore, as knowledge improves these threshold values
    may be subject to change and as such should be included in the legal instrument in such a
    manner as to easily be amended in the future. The industry has recommended that the
    threshold values be noted in the Convention but that the absolute figures for the values be
    placed in the Guidelines so that they can more easily reviewed and updated as required.

    2. Entry into Force Criteria

    There is still some considerable deliberation by member states on the entry into force
    criteria. General agreement has however been reached that a recycling state capacity
    element should be included in the entry into force criteria. This is felt important as it will
    ensure that the Convention will enter into force with the more traditional recycling states as a
    signatory and not without. During discussions on this matter within the Industry Working
    Group it was agreed that if necessary the industry associations would aim to ensure that a
    situation in which the traditional recycling states were outside of the Convention could not

The Committee will be invited to take note of the developments in relation to the International
Ship Recycling Convention.

INTERTANKO and Industry Strategy

At the Industry Working Group’s last meeting held in early January, it was agreed that guidelines
for the implementation of the Interim Measures needed to be drawn up swiftly to take into
account the likely increase in recycling over the coming months. INTERTANKO had previously
advised the secretary to the Industry Working Group of this Committee’s deliberations and work
on industry guidance and as such the Industry Working Group is keen for INTERTANKO to assist
with developing the guidelines. While ICS will focus on the commercial transaction it is deemed
appropriate that INTERTANKO, having already provided considerable information on this, focus
on the technical and practical aspects associated with readying a ship for recycling. Documents
and information already submitted by this Committee will be used in the development of the
Guidelines. Any further information, examples or guidance are of course welcomed.

The Committee is invited to note the developments and comment as appropriate.

11. Ballast Water Management

The revised Model Ballast Water Management Plan is now undergoing proof and technical
reading by Mr. Dean Tseretopoulos, INTERTANKO consultant.

The Committee is invited to note the developments on the Model Ballast Water Management
Plan and comment further on any other aspects related to ballast water management,

12. TMSA Related Matters

The Committee will be invited to comment on the new Fuel Efficiency and Management
addendum during discussion on GHGs. Further comments are invited on other environmental
aspects related to TMSA.

Agenda for INTERTANKO’s Environmental Committee                                      Page 15 of 16
To be held in Dubai on the 20 January 2009
Our Ref.: TIM-14490/1650005
13. Liaison with Environmental Organisations

At the Committee’s last meeting, members were advised of the establishment of the World
Ocean Council (WOC). General support was given to cooperating with WOC on sustainability
issues as well as whale strike matters. INTERTANKO has subsequently accepted to sit on a
WOC steering committee charged with organising a WOC event in Belfast in June 2009. The
brochure for the event is enclosed.

  WOC conference
leaflet 26-11-08.pdf

Meanwhile, INTERTANKO has also continued its long standing relations with WWF. Recent
discussions have focused on the promotion of shipping as a sustainable transportation mode ad
the possible collaboration between individual INTERTANKO members and WWF for promoting
this concept.

The Committee is invited to take note and suggest any further action.

14. Date and Place of next Meeting

The Committee is invited to consider the date and place of the next meeting.

15. Any Other Business

Agenda for INTERTANKO’s Environmental Committee                                Page 16 of 16
To be held in Dubai on the 20 January 2009
Our Ref.: TIM-14490/1650005

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