1. of161 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com “… the cornerstone of Chinese marine pollution law system” Effective 1 January 2012 Oil Pollution Regulation in China: A Practical Guide to the New Marine Pollution Legislation

2. of162 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Background Deepwater Horizon Response Encouragement from OPA-90 clients Joint Venture Formed Depot Established

3. of163 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com China Background March 1, 2010 notice of January 1, 2011 start July 2010 Dalian spill Postponed implementation one year Uncertain poorly equipped government-led response Increase in shipping calls & tonnages

4. of164 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Dalian Oil Spill - 2010

5. of165 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Dalian Oil Spill 2010 Two crude pipelines were ruptured and released a reported 1500 tons of oil True nature of the incident not clear to the public Equivalent to Exxon Valdez spill Catalyst for more stringent safety standards

6. of166 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com The Regulations All tankers transporting pollutants in bulk Any other ships > 10,000grt All PRC coastal ports (not Hong Kong) Maritime Safety Administration (MSA) - the authority SPRO Certifications SPRO Contracts

7. of167 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com The Regulations Ship typeTankersNon tankers (Hazardous cargoes) Non tankers Service area Class type within port limits entering & leaving port loading, unloading, bunkering outside port limits entering & leaving port loading, unloading, bunkering outside port limits entering & leaving port loading, unloading, bunkering outside port limits Class 1> 10,000 gtoutside 20 nm > 10,000 gtoutside 20 nm > 50,000 gtoutside 20 nm Class 22000 to 10,000 gt < 10,000 gtwithin 20 nm < 10,000 gtwithin 20 nm 30,000 to 50,000 gt within 20 nm Class 3600 to 2000 gt 20,000 to 30,000 gt Class4< 600 gt10,000 to 20,000 gt

8. of168 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Class 1: All Waters; Oil and Hazardous Class 2: All Waters Within 20 nm; Oil and Hazardous Class 3: Port Waters Class 4

9. of169 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Operational Procedure Spill Response Plan SMS Pollutant Disposal

10. of1610 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com System, Procedures and Software – Safety Management System – Spill Response Plan – Operational Procedure – Pollutant Disposal – Monitoring software Response Vessels, Equipment, Materials and Storage Management and Field Staff Bases & Response time Major Exercise Class 1 OSRO

11. of1611 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com The Early Days – January 2012 MSA vetting of SPRO’s – last minute Nearly all SPRO’s receive certification! Numerous SPRO options in some ports / other ports are monopoly’s – Ningbo / Zhoushan Pricing – Varies depending on port – Some ports have set pricing

12. of1612 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Early Days continued.. Practical Realization – – There was ‘no one stop’ solution for owners – Owners/operators/SPRO’s/IG/MSA all remained uncertain – Agencies (e.g. CMS) seemed to want to hold the industry to ransom – Pricing was (and remains) inconsistent – depending on each ports monopolistic stance!

13. of1613 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Early Days Continued… Limited Coverage Area for SPRO’s Agent domiciled in China must sign SPRO agreement Last minute MSA changes – Consortiums develop – Contract changes Inconsistency among local MSA’s

14. of1614 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Key Players International Group of P&I’s – Initially in the dark – Develop a prominent role – SPRO insurance? ITOPF – Hired by IG – Evaluate response tariffs – Painstaking process!

15. of1615 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Current Issues Some local MSA’s require original copies of agreements ( i.e. Zhanjiang, Xiamen) Companies with branch offices in China may need to sign directly with SPROs Ports controlled by single SPRO (Ningbo, Zhoushan) may require operators to sign long term agreement – Contract not approved by IG Sludge disposal Involvement of ship agent’s Agreements not recognized by local MSA (Caofeidian)

16. of16 Contact Us +1 954 764 8700 | ddettor@resolvemarine.com www.resolvemarine.com Daniel Dettor +1 954 303 5331 ddettor@resolvemarine.com