Ballast water clock ticks on
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Although experts had predicted that the IMO’s Ballast Water Convention might well have been ratified by the end of the year and would therefore come into force 12 months later, this is now very unlikely. Some experts are even suggesting that it may not enter force until 2014, resulting in a mad scramble as owners try to meet the requirement that existing ships have appropriate installations at their next intermediate or special survey after 2014. Many believe now that the IMO timetable is completely unachievable.
Estimates vary widely as to how many installations will ultimately be required. Figures range from 35,000 at the bottom end to as many as 70,000 – a pretty wide margin of error. This is partly because owners of older tonnage could well decide that the investment required to equip their ships to continue trading is just not worth it. Analysts point out that ballast water compliance is only one of a range of new regulatory requirements that could well cripple some owners – burning low-sulphur fuel in Emission Control Areas will transform the operating economics for many ferry operators, for example, whilst scrubber technologies could well prove too expensive to install on many older vessels with a relatively short payback period.
Experts in the ballast water field, however, suggest that there is no room for complacency. However much owners may wish the transfer of invasive species in ballast water to be an issue that goes away, the experts insist this will not happen. The IMO’s Convention will inevitably come into force, and sooner rather than later, many believe. So, despite the challenges of operating in markets where many ships are barely breaking even, a proactive approach, rather than a head in the sand, is to be recommended.
Those closely involved in fraught negotiations at the IMO concede that the Convention has a range of shortcomings. But they insist that these are being dealt with. Some point out amendments to an existing IMO Convention cannot be implemented until it has been ratified, but already there are working groups and sub-committees busily drafting new measures which will qualify the Convention’s existing wording and, they say, at least make it workable in practice, just as soon as it enters force.
The fact that the Convention lays down requirements that are not going to disappear into the mists of time means that owners should be actively preparing for compliance. There are, so far, some 23 type-approved systems, but they are based on different technologies, some of which are better suited to some ship operating profiles than others. However, if an owner is preparing to put his ship through an intermediate survey in 2013, it could make good sense to pick an approved system that is likely to suit his ship’s operation, and at least put the shipboard infrastructure in place during the survey, even if he opts not to buy the treatment plant itself until a later date.
For ship repairers, there could be a key business opportunity here. Yards that cater to VLCC owners could align themselves with the manufacturers of treatment systems best suited to VLCC operation. Plant that uses ultra-violet light to kill micro-organisms, for example, has been shown not to work effectively in waters containing high tannin and/or lots of sediment. Such waters are often found in estuaries and where rivers meet the sea. Such systems, therefore, are likely to work well on board VLCCs which mostly dock in relatively deep water, often well out to sea. Ultra-violet systems could be very unsuitable, on the other hand, for coastal vessels and ferries.
Some repair yards have already indicated that they intend to work closely with chosen manufacturers to capitalize on economies of scale and effective installation. By so doing, they could demonstrate their chosen product portfolios to clients preparing to put their vessels through intermediate or special surveys, offering to put some of the necessary shipboard infrastructure in place ahead of time. This could well prove to be a revenue-maximising strategy when the inevitable ballast water stampede gets going. Most owners who had made such preparations would wish that the same yard completed the installation when it became necessary.