Port Waste Management UKHMA Autumn Seminar October 2003 - PowerPoint PPT Presentation

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Port Waste Management UKHMA Autumn Seminar October 2003

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Title: Port Waste Management UKHMA Autumn Seminar October 2003


1
(No Transcript)
2
Port Waste Management UKHMA Autumn
Seminar October 2003
  • Alèxe Finlay
  • Northern Environmental Management

3
Outline
  • Frequently Asked Questions
  • legislation
  • assistance
  • compliance
  • Changes
  • Implementation
  • ideas and possible solutions
  • Summary
  • UKHMA web site and www.nemuk.co.uk

4
Frequently Asked Questions
5
Havent we done this all before?
  • Yes voluntarily in 1995 and under the Merchant
    Shipping (Port Waste Reception Facilities)
    Regulations 1997 (SI no 3018)

6
Why reinvent the wheel?
7
Additional EU legislative layer
  • EU Directive on port reception facilities for
    ship generated waste and cargo residues
  • Came into operation 27 November 2000
  • Operative in UK 28 December 2002
  • Notes supplied!

8
UK response
  • The Merchant Shipping and Fishing Vessels (Port
    Waste Reception Facilities) Regulations 2003 (SI
    no 1809)
  • Made 14 July 2003
  • Came into force 15 July 2003
  • (after a long gestation period …)

9
Is there any assistance in interpretation?
10
Maritime and Coastguard Agency
  • MGN 252 Port Waste Reception Facilities 2003
  • MGN 259 Exemptions to the Port Waste Reception
    Facilities 2003
  • Port Waste Management Planning a Guide to Good
    Practice
  • Maritime and Coastguard Agency www.mcga.gov.uk

11
And, for insomniacs, - IMO
  • Comprehensive Manual on Port Reception Facilities
  • Guidelines on Ensuring the Adequacy of Port
    Reception Facilities

12
Whose responsibility?
  • Applies to any harbour and terminal within the UK
  • Every harbour authority and terminal operator
    shall provide waste reception facilities adequate
    to meet the needs of ships normally using
    harbour/terminal, without causing undue delay to
    ships
  • In landlord ports it may fall to the terminal
    to produce a plan and introduce facilities

13
Pause for thought …
  • Hold on to the port/terminal concept for a few
    minutes …

14
Who needs a plan?
  • Major ports and terminals, and where there are
  • commercial fishing activities
  • coasters loading or discharging
  • passenger vessel operations
  • commercial marinas
  • fish farm jetties etc

15
Who does not need a plan?
  • Where pleasure vessels are not left overnight
  • Where only day recreational and fishing vessels
  • Fish farms
  • Fishing vessels hauled on beach
  • Hotels/sailing club moorings outside the
    jurisdiction

16
Changes
17
Pre entry notification
  • Ships must provide notification before entry into
    port, of the waste they will discharge, including
    information on types and quantities (exception
    fishing/recreational craft authorised/designed to
    carry no more than 12 passengers)

18
Mandatory discharge
  • Ships must deliver their waste to port reception
    facilities before leaving port unless they have
    sufficient dedicated storage capacity for the
    waste, and for it to be accumulated, until the
    next port of call

19
What if the vessels do not comply?
  • Ports do not have to police this
  • Report to MCA ships persistently not notifying or
    landing
  • MCA surveyor will be called upon to investigate

20
Mandatory charging
  • Ships must pay a mandatory charge to
    significantly contribute to the cost of port
    reception facilities for ship generated waste,
    whether they use them or not

21
Exemptions … I
  • MCA may exempt ships from the three obligations
    IF
  • ship is engaged in scheduled traffic with
    frequent and regular port calls and can give
    evidence of an arrangement ensuring the delivery
    of ship-generated waste and payment of charges in
    a harbour or terminal along the ships route

22
What does that mean?!
  • Scheduled a planned list of ETDs and ETAs
    between nominated ports or terminals
  • Regular repeated journeys between those ports
    and terminals and no others (unforeseen
    circumstances etc apart)
  • Frequent at least once a fortnight

23
Proof
  • Completed exemption application form
  • Evidence of the trade of the vessel
  • Evidence of a waste contract with a port/terminal
  • Current receipts
  • Evidence of agreement of port accepting waste
  • Declaration of crew training

24
Exemptions …II
  • Workboats, pilot cutters etc operating
    principally within the jurisdiction do not have
    to comply but are encouraged to work within the
    spirit of the law and use the facilities provided

25
Non compliance
  • A Master finding inadequate facilities will
    take it up with the port/terminal. And, if still
    dissatisfied, reports the inadequacy to the MCA
  • In addition, there will be a set number of port
    inspections per annum (50)
  • MCA investigates and notifies the European
    Commission and port/terminal faces a fine
  • Vessels which do not comply are subject to being
    detained, and to a fine

26
Implementation
27
Amending existing plan
  • Guide to Good Practice mirrors 1997 legislation
    (with additions) as to the process for changing
    your existing plan and could be used as a
    checklist

28
Charging
  • The fees and how they have been calculated must
    be made clear to port/terminal users to show that
    they are fair, transparent and non-discriminatory
    and reflect the costs of the facilities and
    services provided ….

29
Guidance
  • … it is expected that ports/terminals will set
    fees at around 30 of the costs of all port waste
    reception facilities …that 30 can incorporate
    the costs associated with planning and provision
    of port waste facilities, the costs of disposal
    of all wastes and the costs associated with the
    administration and charging regime …

30
Integrated -v- independent
  • EITHER the port can set up and manage the entire
    system
  • OR each terminal can act independently

31
Integration - I
  • Advantages
  • central control
  • easier to gather data
  • one port waste management plan
  • no disparity in published tariff
  • commercial opportunities
  • establish best practice
  • fits with Port Marine Management Code

32
Integration - II
  • Disadvantages
  • uneven distribution of administration
  • may require additional personnel/resources
  • expense involved in setting up system
  • collection of additional dues and tariffs
  • volume of exemptions (ie ferry ports) means
    inadequate incoming revenue to run the system

33
Integration - III
  • - and perhaps most significantly
  • this is the MCA preference

34
Independent - I
  • Advantages
  • distribution of workload
  • tariff to suit terminal
  • devolved autonomy
  • could encourage contractors pricing systems to
    be competitive and fair
  • greater element of choice

35
Independent - II
  • Disadvantages
  • differing arrangements could be confusing
  • charging structures diverse
  • could lead to conflict among terminals
  • uncoordinated data submission to MCA
  • too many variations in system

36
Independent - III
  • Plan splitting will need approval from the MCA

37
The choice is yours!
  • but integration would seem to be the more
    favourable route

38
Practicalities
  • Look at the existing arrangements and evaluate
  • Talk to agents etc to see which waste contractors
    offer the most flexible arrangements
  • Work out how much your current system costs
  • Does that break down to a cost per ship?
  • What are your neighbours charging?
  • What data collection method works for you?

39
Evaluation
  • Dont change for the sake of it if the current
    system works, tweak it but dont start again.
  • If you DO think it is capable of improvement, now
    is the chance

40
Choose your contractor
  • Who offers a tailor made service?
  • Who offers a range of receptacles?
  • When is the optimum time/price band?
  • Does the service have to be land based? Can it be
    waterborne?
  • Are transfer and disposal facilities fully
    compliant?

41
Cost - I
  • Government guidelines say 30
  • Is that reasonable for you?
  • Base costings on contractors charges, any
    additional charges, and YOUR cost for extra
    administrative burden
  • Publish this as a separate item on 2004 tariff
    (hence MCA period of grace until January 2004)

42
Cost - II
  • Does the cost you decide to impose per ship
    adequately reflect the new system?
  • Is it in line with your port neighbours?
  • Consult locally to work collaboratively

43
Reporting to MCA
  • Decide upon a method which works for YOU to
    collect information on wastes discharged there
    is an MCA template
  • Electronic means?

44
Consultation
  • In 1997 we consulted first and devised the plan
    second
  • Suggest devise amended system and the explain
    this to your agents, customers, users/waste
    regulators, contractors to invite comment
  • A DONE DEED!

45
A word about DEFRA …
  • DEFRA inspectors are visiting ports re. The
    Animal By-Products Regulations 2003
  • Concerns handling and disposal of catering waste
    from vessel which has arrived from or visited non
    EU country
  • Such waste is regarded as high risk animal by-
    product

46
Simplify this
  • Segregate MARPOL Annex V garbage
  • Keep ALL food waste separately
  • Instruct contractor to transfer and dispose as
    high risk
  • Easier than sorting food waste
  • Advise DEFRA
  • Advise MCA
  • Write it in the port waste plan

47
In Essence ..
  • Evaluate what you do now
  • Decide whether to change completely or amend
  • Find the best contractors for the job
  • Look at current costs
  • Publish a tariff of charges per ship look at
    your neighbours
  • Establish an appropriate data collection system
  • Talk to the MCA before filing the plan!

48
Thank You!
  • Alèxe Finlay
  • Northern Environmental Management
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