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  • 2008 December 16

    Recommendations of Round Table participants furnished to RF executive and legislative authorities

    Within the framework of Transtek-2008 exhibition held in St. Petersburg, PortNews IAA supported by RosMorPort FSUE, Russian Association of Marine and River Bunker Suppliers as well as the Association of Sea Commercial Ports held a Round Table meeting “Port Service as an Instrument to Improve Port Attractiveness”. The Round Table participants discussed the problems of operation and perspectives of port class vessels’ renovation as well as issues, which economic entities face in the Big Port of St. Petersburg when preventing and responding emergencies related to oil spills.

    The speeches and the discussions held at the Round Table meeting helped to determine four major controversies within legislation framework as well as between regulations and their implementation by regulatory bodies and economic entities. Such controversies result in decrease of competitiveness and attractiveness of Russian ports.  The controversiesaredetermined in the following areas:

     

    • development, expertise, coordination and approval of Plans on Prevention and Response to Oil Spills (OSR Plan);

     

    • handling of ship waste and port charges;

     

    • operation of single-hulled vessels in seaports;

     

    • problems of companies operating azimuth-type tug-boats.

    The Round Table participants have made proposals and recommendations aimed at further improvement of the RF ports’ efficiency, competitiveness and attractiveness.

    The proposals related to OSR Plans development:

    1. To solicit the RF Transport Ministry for the necessity to cancel the requirements set forth in the RosMorRechFlot head’s letter No IZ-27/7146 dated 15.08.2008 (approval of OSR Plans for bunkering companies). OSR Plans necessarily subject to approval of the Harbour Master provided that a bunkering company has signed an agreement for OSR services with Emergency Response Teams (ERT) attested by either Central Committee of the transport complex or regional certification committees of the RF Emergency Ministry.

    2.  To clarify the following issues with the Ministry of Transport:

    • what document is to confirm that Emergency Response Team is a part of a transport complex;

     

    • if RosMorRechFlot violates RF legislation (antimonopoly legislation, in particular) when demanding from Administration of Big Port of St. Petersburg to prevent activities of organizations having no agreements with Emergency Response Teams attested by RF Transport Ministry’s Committee, considering that only Baltic Basin Emergency Response Department FSUE has obtained the required authorization from the Transport Ministry and that its services cost much more as compared with those of other organizations;

         

    • on the ground of what documents RosMorRechFlot and GosMorSpasSluzhba officials held activities on July 15-17, 2008 on inspection of organizations outside the Ministry’s competence;

     

    • why RosMorRechFlot officials think that vessels registered by State Inspectorate for Small Vessels are not entitled to implement OSR functions. Stringent Regulations on seaport (clause 2.6.1.5.) entitle small vessels registered by SISV to move in the port regardless the aim of the movement (placement of slick bars, collection of floating litter or spilt oil products).
    • Ask RF Emergency and Transport Ministries develop unified requirements to authorization and equipment of ERT engaged in prevention and response to emergency situations in RF ports.
    • Recommend Administration of Big Port of St. Petersburg to unite all ERT of the port into an integrated system for prevention and response to emergency situations according to the port’s OSR Plan, and to determine membership and activities of Operation Management Headquarters (OMH) on localization and response to emergencies going beyond local.
    • Speed up ratification of an International Convention on Oil Pollution Preparedness, Response and Co- operation, 1990 and work out a mechanism for compensation of damages related to OSR activities in a port.

    When discussing ecological operations at vessels calling on RF ports the Round Table participants noted that the Order of the Federal Tariff Service No 522-т/1 dated 20.12.2007 “On approval and application of rates for port charges in RF seaports” dos not contain any list or classification of garbage to be disposed of within the framework of an ecological charge. However, under Annex V to MARPOL 73/78 garbage includes all kinds of food, domestic and operational waste generated during the normal operation of the vessel. Thus the garbage does not include waste related to cargo or oily water generated during emergency situations on board the vessel.

    According to the world practice, the ports should impose restrictions on collection of garbage in terms of both the time spent in the port (10 days) and the time of the garbage accumulation as well as the volume of garbage.

    The Round Table participants think the following measures are necessary to be undertaken by federal executive authorities:

    To introduce “Regulations on collection of ship waste from vessels subject to ecological charges” developed by Port Fleet CSC jointly with St. Petersburg branch of RosMorPort FSUE.

    To propose that the RF Ministry of Industry and Trade includes the following projects of vessels developed by Port Fleet CJSC in compliance with latest ecological safety requirement (according to Rule 21 of Annex I to MARPOL 73/78) into the “List of conceptual projects of vessels and technical equipment” within the framework of the federal special target program “Development of civil marine equipment in 2009-2016”:

     

    • floating station for oily water treatment with monthly capacity of 15,000 cubic meters. Commissioning of the head vessel in the port of St. Petersburg is scheduled for March 2009;

     

    • vessel for comprehensive servicing of ports and oil spill response.

    As for further operation of single-hull bunkering vessels the participants of the Round Table state the following:

     

    • the majority of Russian bunkering vessels (some 95%) do not conform to Rule 21 of Annex I to MARPOL 73/78 today as to the requirement of double sides;

     

    • the majority of Russian bunkering vessels (some 80%) have been in operation for over 25 years. Averageperiodof operation 30 years;

     

    • according to the most optimistic forecast, it will take at least 5 years for RF shipbuilding industry (considering its current state) to renovate Russian bunkering fleet.

    Thus the participants of the Round Table think the following measures are necessary:

    considering that bunkering is one of the most significant port services contributing to competitiveness and attractiveness of RF ports and considering the right provided by clause 7.1 of the Rule 21 of Annex I to MARPOL 73/78, to solicit the RF Transport Ministry for exemption from compliance with the Rule 21 of Annex I to MARPOL 73/78 for Russian single-hull bunkering vessels ranging from 600 to 5,000 dwt and operating within internal waters of the Russian Federation till 2013 provided that Russian bunkering companies absolutely meet the following requirements aimed at prevention of pollution of the environment:

     

    • any vessel registered with Russian Maritime Registry of Shipping or Russian River Registry of Shipping and claiming the exemption as well as a company bearing responsibility for this vessel operation should obtain a document certifying conformance to requirements of Chapter IX of SOLAS 74;

     

    • any vessel operating for over 10 years should undergo a complex of technical measures to renew the hull to the level 2 SS (for vessels registered with RMRS) or У-2 (for vessels registered with RRRS);

     

    • the navigation zone should be limited by port, roads and coastal area determined by the Register in compliance with local conditions;

     

    • a ship owner’s responsibility for possible damage of the environment should be insured to the amount equal to maximal possible oil spill determined by OSR Plan;

     

    • a ship owner should have a plan for replacement or conversion of vessels to vessels meeting the requirements of the Rule 21 of Annex I to MARPOL 73/78 before 2013 with a list of corresponding activities and a schedule for their implementation.

    The meeting also discussed the problems of the companies operating azimuth-type tug-boats in RF ports. The participants expressed their concern about absence of recommendations from the Federal Agency of Marine and River Transport of the Russian Federation on the use of azimuth-type tug-boats in Russian ports and absence of standard plans for involving tug-boats in mooring operations. According to current practice, Harbor Masters determine the minimum of tug boats needed for the port without taking type of tug-boats into account, which makes involvement of tug-boats meeting latest requirements to mooring safety to be economically unreasonable. Thus it was decided to address the RF Transport Ministry with a proposal to elaborate new guidelines containing recommendations of Russia’s Federal Agency of Marine and River Transport on operation of azimuth-type tug-boats in RF ports and to develop standard plans for involving such tug-boats in mooring operations.

    Recommendations of the Round Table meeting “Port Service as an Instrument to Improve Port Attractiveness” have been sent to the RF executive and legislative authorities.
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