Port Waste Management UKHMA Autumn Seminar October 2003

1
(No Transcript)
2
Port Waste ManagementUKHMA Autumn
SeminarOctober 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