Leading the way; making a difference Ballast Water Management State of Affairs Stamford, 23 rd March 2015 Tim Wilkins INTERTANKO Senior Manager - Environment

Leading the way; making a difference 1. 1.IMO 1. 1.Where we are today 2. 2.Outlook for MEPC US 3. 3.Ballast Water Technology – approvals Ballast Water Management Outline

Leading the way; making a difference Desired outcome: Tanker industry is able to achieve compliance with current and future discharge standards (both regionally and internationally) Focus: 1. 1.Installation and Operation of appropriate and adequate ballast water management systems 2. 2.Compliance and enforcement – need strong, well defined and realistic international regulations Ballast Water Management - State of Affairs INTERTANKO’s Strategic Plan

Leading the way; making a difference Ballast Water Management Convention Adopted in 2004 Entry into force requires ratification by 30 countries, 35% world’s grt Currently, 44 countries, 32.86% grt Bahamas, China, Greece, Malta, Panama, Singapore or UK, each alone could bring the convention into force Argentina and Italy in the process – 34.2% Ballast Water Management - State of Affairs 1.1 IMO: Where we are today

Leading the way; making a difference Ballast Water Management Convention MEPC 64 INTERTANKO et al. submission: Explains the challenges being faced for effective implementation of the BWM Convention and to provide proposals to address those challenges There remain THREE key challenges: 1. 1.Guidelines for approval of ballast water management systems (G8) 2. 2.Availability of Ballast Water Management Systems (BWMS) and logical implementation 3. 3.Balanced procedures for port State control Ballast Water Management - State of Affairs 1.1 IMO: Where we are today

Leading the way; making a difference Ballast Water Management - State of Affairs 1. Guidelines for approval of ballast water management systems (G8) Better quantity and quality of information with increased transparency – (Resolution MEPC.228(65), BWM.2/Circ.43, BWM.2/Circ.33 and BWM.2/Circ.28) MEPC Resolution (adopted MEPC 67): Commence a review and revision of the type approval guidelines (G8) taking into account all the industry concerns Also take into account the US approval procedures and standards Protection for early-movers : those owners who’ve installed BWMS approved to current G8 Reminder of the PSC trial period Details of ‘Grandfathering’ to be agreed 1.1 IMO: Where we are today

Leading the way; making a difference Ballast Water Management - State of Affairs 2.Logical Implementation schedule Assembly Resolution A.1088 (28) adopted, Dec 2013 recommends governments: 1. 1.implement the Convention based on the entry into force date of the Convention 2. 2.considers ALL vessels constructed before entry into force as existing vessels 3. 3.existing vessels to install a BWMS at the first renewal survey (IOPP Certificate under Annex I of MARPOL) after entry into force of the Convention 1.1 IMO: Where we are today

Leading the way; making a difference Ballast Water Management - State of Affairs 3.Balanced Port State Control Procedures Trial Period (initially for 3 years) following entry into force During this period, port states will ‘refrain from detaining a ship or initiating criminals sanctions in the event a BWMS does not meet the discharge standard’ (USA reserved position) Sampling only after clear grounds and any indicative sample should not form the basis for a decision on compliance – 4 Stage approach: 1. 1.Initial inspection 2. 2.More detailed inspection 3. 3.Indicative sampling 4. 4.Detailed sampling 1.1 IMO: Where we are today

Leading the way; making a difference Ballast Water Management - State of Affairs Sharing of experience and information is now vital: 1. 1.Does the BWMS work? 2. 2.Does it work as it was approved to work? 3. 3.Does it meet the discharge standards? 4. 4.INTERTANKO members urged to share information on BWMS installed Using a BWMS in lieu of BWE? 1.1 IMO: Where we are today

Leading the way; making a difference Ballast Water Management - State of Affairs 1.1 IMO: Where we are today Country or Region IMO BWMS Accepted in lieu of BWE? Approval to use the BWMS required? Notes ArgentinaYES AustraliaYES BrazilYESNO CanadaYESNO ChileAwaiting information GeorgiaAwaiting information IsraelAwaiting information Korea (South)NONA BWE is not for biological purposes. Lithuania – Butinge oil terminal, Klaipeda Awaiting information Middle East (ROPME Sea Area(ROPME Sea Area) YESNO Some terminals contradict the ROPME Requirements. Summary – Using BWMS in lieu of Ballast Water Exchange (BWE)

Leading the way; making a difference Ballast Water Management - State of Affairs MEPC 68, May Completed revised G8 Guidelines? 2. Indication of extent of Grandfathering? 1. Guidelines Correspondence Group – 34 issues to address Likely completion, MEPC 69, May 2016 G8 vs Revised G8… 2. Grandfathering Industry submission MEPC 68/2/16: Clarify Grandfathering Protect early-adopters (with current G8 BWMS) For the life of the ship Norway (and others) – 5 year grace period after EIF 1.2 IMO: Outlook for MEPC 68

Leading the way; making a difference Ballast Water Management - State of Affairs MEPC 68, May 2015 ICS press release (Dec 2014) – “ICS will no longer actively discourage those governments that have not yet done so from ratifying the (IMO BWM) Convention, in order that it might enter into force sooner rather than later“ ICS members such as UGS and SSA no longer object to their ratification of IMO BWM treaty by their government INTERTANKO, Intercargo, IPTA, CLIA and WSC want to see the outcome of MEPC 68 on grandfather provision and revision of G8 1.2 IMO: Outlook for MEPC 68

Leading the way; making a difference US Coast Guard Final regulations issued March 2012 (effective 21 June ‘12) Main requirements include: BWE prior to discharge in US waters BWM Plan: reporting and record keeping (fouling management as well) BWM discharge standard (same as IMO), review in 4 yrs Compliance schedule (similar to IMO), (no intent to align schedule with IMO) Acceptance of “Alternative” BWMS for 5 years BWMS not required if no discharge in US waters (12 nautical miles) Ships may request an extension to compliance date for installation of USCG TA BWMS 2. US Ballast Water Management - State of Affairs

Leading the way; making a difference US Coast Guard - Implementation Schedule Decision Tree … 2. US Ballast Water Management - State of Affairs

Leading the way; making a difference US Ballast Water Decision Tree

Leading the way; making a difference US Coast Guard - Implementation Schedule Decision Tree Model Extension Request (MER) Letter Still in use and still relevant! 2. US Ballast Water Management - State of Affairs

Leading the way; making a difference US Coast Guard - Implementation Schedule Decision Tree Model Extension Request (MER) Letter Clarification of USCG Rules 2. US Ballast Water Management - State of Affairs

Leading the way; making a difference US Coast Guard - Extension Requests January 1, 2016 extension date given to more than 250 ships whose drydocking was scheduled for 2014 January 1, 2016 date was chosen to encourage shipowners to put pressure on BWM manufacturer to obtain USCG approval January 1, 2017 extension given to ships whose drydocking was scheduled for early 2015 USCG recognizes that January 1, 2016 date may generate second round of extension requests 2. US Ballast Water Management - State of Affairs

Leading the way; making a difference US Coast Guard – BWMS Approvals A few BWM manufacturers are “aggressively” pursuing USCG approval (no indication which BWMS – more to come!) USCG expects a USCG approved BWMS “by this time (May) in 2015” USCG hopes it can announce a few at the same time, but is not going to hold up the announcement of the first one to wait for a “long time” to include the second or third one USCG indicates they understand potential installation scheduling problem once a BWMS is USCG approved USCG indicates they will be “pragmatic” in requiring when a ship calling at US ports must have a USCG approved BWMS installed 2. US Ballast Water Management - State of Affairs

Leading the way; making a difference EPA – CWA NPDES VGP 2013 (1) To a large extent EPA VGP requirements are the same as USCG: discharge standard compliance schedule Approval of the BWMS is not required BWMS monitoring required: Functional (equipment) Biological (effluent) Biocides 2. US Ballast Water Management - State of Affairs

Leading the way; making a difference EPA - VGP 2013 (2) New ship (keel laid after December 1, 2013) is required to install a BWMS to comply with the VGP, i.e. no acceptance of USCG extension provision in the VGP EPA /USCG MoU – EPA Enforcement Policy announced 27 Dec Vessel with USCG extension is non-compliant (if discharges in US waters – 3 miles), but EPA regards as a low-enforcement priority, provided all other applicable regulations are met Compliance USCG will check for EPA VGP compliance during routine PSC inspections. Liaison between EPA and USCG about dates extension request letter and VGP NoI – dry dock dates should be the same! 2. US Ballast Water Management - State of Affairs

Leading the way; making a difference “A few BWM manufacturers are “aggressively” pursuing USCG approval (no indication which BWMS – more to come!)” Ballast Water Management - State of Affairs 3.Ballast Water Technology - approvals

Leading the way; making a difference 2 independent laboratories authorised (US and Norway) Testing is fully independent and on market-ready BWMS Ballast Water Management - State of Affairs Approval Series USCG Accepted Laboratory Sub LaboratoryCountryCityState NSF International MERC, GSI, Retlif, American Bureau of Shipping; Curtis Strauss LLC (BWMS) USA Ann Arbor MI DNV GL AS DHI-Denmark, Golden Bear Facility, Applica, DELTA- Denmark (BWMS) NorwayHøvikN/A 3.Ballast Water Technology - approvals

Leading the way; making a difference Ballast Water Management - State of Affairs 3.Ballast Water Technology - approvals

Leading the way; making a difference Ballast Water Management - State of Affairs 3.Ballast Water Technology - approvals The dilemma: Currently no BWMS is USCG type approved Ship operator must decide to: 1. 1.install AMS (and hope it gets USCG approval) OR 2. 2.request an extension and wait until there is a CG approved BWMS BUT what if Convention enters into force before we have a CG approved BWMS?

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