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Jon Watson
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STS Legislation
The question of STS (Ship to Ship)transfers has been raised at the IMO where IBIA intervened to protect bunkering which already has a number of anti-pollution controls in place, e.g. blowing down the hoses before disconnection, blocking the scuppers to prevent oil spilled on deck flowing into the sea, a recommended operational procedure and there are various training courses conducted by different organisations, and so on.
Of course, there may be scope for improvements in the requirements, the equipment and training needed, but banning bunkering at sea seemed a bit of an overkill and precipitate and which was why IBIA intervened. It seems to me that most pollution incidents seem not to be related to bunkering and such as there are are not the most serious.
There may be better reasons for considering other oil cargo transfers, I couldn't say.
Treaties require the individual nation states to implement the treaty by enacting national legislation. That is the next step and one that is now being undertaken by the UK.
Being the marine industry, what each country does has global impact and especially what the industry needs is a uniform set of regulation.
In the UK the enforcement agency is the UK Maritime Coast Guard Agency. They draft legislation and seek consultation.
A news release from the MCA (http://www.mcga.gov.uk/c4mca/mcga07-home/newsandpublications/press-releases.htm?id=0B023761795D084C&m=2&y=2010 ) leads us to this web site page:
http://www.mcga.gov.uk/c4mca/mcga07-home/shipsandcargoes/consultations/mcga-currentconsultations/cp-con-sts2010.htm
In the preamble is this statement:
QUOTE:
"..... the new draft of the Regulations applies exclusively to cargo transfers or bunkering operations consisting wholly or mainly of oil."
END QUOTE
The web page lists the organisations consulted.
(http://www.mcga.gov.uk/c4mca/sts_consultation_list.pdf )
These organisations presumably will have or potentially have the opportunity to influence legislation.
Like the IMO, there are a number of environmental activist groups including various societies for the protection of animals, the now notorious WWF (The IPCC has been accused of forming policy statements based on reports and articles from, among others, the WWF - Watts UP With That web site has lots of stories about the WWF and the IPCC).
Greenpeace are represented and some rather obscure environmental groups such as KIMO Scretariat and, my personal favourite, "Surfers Against Sewage".
There are a lot of companies that are "environmental consultants".
There are some organisations that legitimately should be consulted but it is curious that some of those that are included are slightly controversial and represent minority interests.
But, given that this is declared to be applied "...exclusively to cargo transfers or bunkering operations..." the most concerning absence is IBIA, the International Bunker Industries Association who have already proven themselves involved at the IMO.
The questions are:
What sort of qualifications do organisations need to be accredited?
Should there be some sort of standard of relevancy and integrity required? Should there be some proportionality or is it to easy to overburden such exercises with too many activist organisations that collectively wield undue influence.
This type of legislation is going to affect the marine industry. That such legislation is increasingly politicised and increasingly apparently subservient to environmental activists and external pressure groups ought to be worrying to the marine industry.
How many Marine industry articles or news stories get reported in the mainstream media compared to activist organisations press releases? Does this mean that the marine industry lacks the representation and recognition that it ought to be accorded?
I have no idea how the UK MCA drew up its list. I have no notion of there being any untoward motives.
On the contrary, I rather suspect that activists are rather more alert to the opportunities and more proficient in the mechanisms of applying pressure and influencing legislation than the interested industry bodies and, probably, the various agencies tasked with various investigative, enforcement and advisory roles.
In an age where science has become politicised and when even scientists resort to larding up reports with highly emotive language, it is all to difficult to know who to include and who not to, who to believe and who to suspect of having a hidden agenda.
What really worries is that the task of advising and creating legislation, that should be well informed with scientific observations, which should draw on the experience of the industry it seeks to regulate and which should be impartially and accurately informed by the scientists, is unduly influenced by activists and those with a political agenda which has little to do with actual conservation. Is this a view that you share or is this an alarmist and unnecessary concern?
How many of you think that the marine industry is under represented and that it needs an overall representative organisation? how much is the industries position weakened by only having representation through a wide range of special interest groups who only get involved when there is some aspect of particular interest and where they cannot represent the overall collective interests of the industry the way the pharmaceuticals industry, the tobacco industry and many others are represented?
Does the marine industry need it own unified representative body, one that can draw the various special interest groups together and can co-ordinate their individual efforts and resources?
Is there really a problem?
It seems to me that the Marine industry is vulnerable in many ways and not least to externally imposed and heavily externally influenced.
Of course, these are just my views. I would welcome any other viewpoints.
Posted: 2/11/2010 1:05:24 PM
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