35 States (five more than the required 30) have ratified the Ballast Water Management (BWM) Convention. While the tonnage target has yet to be met we are seeing focus shifting towards compliance options. While for most shipowners, the appropriate compliance option is to invest in onboard systems, are there other options for some owners? If so, what could they be?
The BWM Convention allows for two additional approaches (see below for relevant references to the BWM Convention) not linked to onboard treatment:
- “alternatives” such as discharge to reception facilities,
- “other methods” which are subject to the ‘same level of protection’ and approval by MEPC.
The purpose of this series of blogs is not to look at existing systems and their opportunities or challenges, but rather to look into the question – ‘could some owners benefit from looking at substitute approaches?’ With my colleagues I hope to explore this question in future blogs, if you are interested let us know.
Why focus on substitute approaches? Partly because of a very interesting conversation I had with a shipowner in October last year but also because on-board treatment systems are used intermittently (they are not needed continuously) with the inherent technical challenge for the shipping community, as well as the need to balance the cost benefits that shipowners face.
For me substitute approaches are mainly likely to mean “alternatives”, so treatment systems that would be located elsewhere than onboard. But what would that mean and is it feasible? For me, the implication is that the ‘shipping supply chain’ (that is parties involved in decisions related to owning, chartering, brokering, logistic planning, shippers, ports, cargo handlers as well as cargo owners) would have to actively (actively is the critical word) participate in helping shipowners meet the requirements of the BWM Convention. For a shipowner the benefits are obvious if the ‘shipping supply chain’ would participate. Although there are downsides related to not fitting onboard systems, such as potential impact on second hand value of a ship, charter acceptability, vessel capacity to trade globally, increase in risk mitigation needs and so on.
What might “alternatives” involve? Possibilities include use of:
- onshore facilities in ports or terminals for cleaning or storing ballast water
- transfer of ballast water to another ship, barge etc. for cleaning or storing ballast water
- retain ballast water onboard – not treat it therefore
- ‘cargo’ on return ballast leg to minimise ballast water quantities
- novel ship design that minimises use of ballast water or excludes its use
The first option involves the ‘shipping supply chain’ in providing (and that includes both CAPEX investment and OPEX outgoings) the facilities for receiving, cleaning, storing (in case the ship needs some of it back later) and managing the discharged ballast water. Clearly such onshore facilities would charge for provision of such services. For a shipowner the challenge would be what information would a land based facility want to know about the ballast water, its composition and species content, how much would be charged and how could the shipowner be assured that the land based facilities would meet legal compliance and hence allow the shipowner to meet his legal requirements? Note land based facilities residues would need to be treated as hazardous waste. The second option is basically the same as the first option. The above two options are interesting for gas ships, tankers and bulkers on permanent routes.
In both of the above, which are other options to installing an onboard treatment system, the ship would have to prove that it can carry out normal operations without discharging ballast water to the sea.
The same applies to ships that do not regularly have to discharge ballast but would have to do so before entering port (shallow water), coming into dry dock or after departure when passing a bridge in order to reduce displacement they still have to comply with BWM Convention. In the case of dry dock, a barge system of either storing the water while the vessel is in dry dock (for it to be pumped back in afterwards) or for taking it to onshore treatment would seem a solution worth exploring? Any use of storage is likely to require that the barge or other ballast system (tanks etc.) be cleaned after storage in order to avoid mixing with other sources of ballast water.
The third option – retaining ballast water on board in sealed tanks – would actually mean that the ship is not in scope of the BWM Convention. As such it would not need or have an international BWM certificate. The seaworthiness of this solution would have to be proven on an individual basis. This option while attractive in terms of reducing costs for installing onboard treatment systems would have operational and income consequences.
The fourth option involves the ‘shipping supply chain’ but rather than the port or terminal at which the ships arrives it would involve the broader ‘shipping supply chain’ in considering what ‘goods’ are available or possible could be shipped on the ballast leg journeys. One suggestion has been fresh water to arid regions, but there are bound to be other types of ‘goods’. The challenge for a shipowner is for this to be viable the return ballast legs would always have to include transportation of alternative ‘goods’ so a substantial contribution from the wider ‘shipping supply chain’ is necessary. The global benefit of this approach would stretch beyond the reduction of ballast water and include an improvement in efficiency, for some ship types the ballast water on the ballast legs represents 50% of the displacement.
The fifth option involves ship designers and yards and is more long term but we are seeing ideas emerging.
The team at LR will look in depth at some of the issues raised above and other surrounding issues.
“Alternatives” are options but they have consequences that need to be evaluated for each unique shipowner, ship type, charter and route. For some they are a real option. But my personal guess is that for most shipowners they are an intellectual interesting concept but on a practical level of limited value. Am I right?
In terms of what systems available and types of systems, the following documents are available from our website here:
- New comparison tool for Ballast Water Treatment Technology
- How to comply with the Ballast Water Management Convention – October 2012
- Ballast water treatment technologies and current system availability – September 2012
- Approval and installation of ballast water treatment systems on LR classed ships
- Ten steps to selecting a ballast water treatment system