IMO PROMOTION OF IMPLEMENTATION AND ENFORCEMENT OF MARPOL AND RELATED INSTRUMENTS. Comments on the proposal by WWF
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1 INTERNATIONAL MARITIME ORGANIZATION E IMO MARINE ENVIRONMENT PROTECTION COMMITTEE 59th session Agenda item 14 MEPC 59/14/1 19 May 2009 Original: ENGLISH PROMOTION OF IMPLEMENTATION AND ENFORCEMENT OF MARPOL AND RELATED INSTRUMENTS Comments on the proposal by WWF Submitted by Cruise Lines International Association (CLIA) Executive summary: Strategic direction: 7.2 High-level action: Planned output: Action to be taken: Paragraph 12 Related document: MEPC 59/14 SUMMARY This document responds to the statements and suggestions made by the World Wide Fund for Nature (WWF) in document MEPC 59/14 1 This document is submitted in accordance with the provisions of paragraph of the Guidelines on the organization and method of work of the Maritime Safety Committee and the Marine Environment Protection Committee and their subsidiary bodies (MSC-MEPC.1/Circ.2) and comments on document MEPC 59/14 submitted by the World Wide Fund for Nature (WWF). 2 The reference document submitted by WWF appears to contain information that would be more suitable to an information document and appears to propose a new work item in the form of a suggestion for voluntary action by the cruise industry in particular. Be that as it may, CLIA would like to address relevant information not contained in the document and inform the Committee of actions taken by CLIA members in regard to this request for voluntary action and not contained in the discussion. 3 CLIA notes the point made by WWF that: all passenger vessels trafficking in semi-closed and closed sea areas which are threatened by eutrophication, should immediately voluntarily cease to discharge their waste water into the sea, and instead dispose their waste water only in harbour port facilities (MEPC 59/14, paragraph 14). While both CLIA and their sister organization the European Cruise Council (ECC) support the use of shore reception facilities, we note that there are very few ports that are capable of receiving waste water from cruise ships in the quantities necessary to make this a practicable reality. This fact was acknowledged by a For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.
2 MEPC 59/14/1-2 - representative from WWF during ECC meetings in Helsinki in February of WWF advised that a comprehensive study on the current port reception facility issue was being planned and advocated a joint involvement with the cruise industry in undertaking such study. 4 A recent survey indicated that only two ports on the Baltic Area had some shore connections available to cruise ships and that most ports utilize trucks and barges. While this practice may be suitable for other ship types, it is completely inadequate for cruise ships. In fact, only Helsinki and Stockholm have comprehensive reception facilities for waste water at every cruise berth. CLIA notes and appreciates the efforts of IMO and the European Union to address the matter of providing adequate reception facilities. 5 While the cruise industry shares the goal of minimizing waste water discharge into the Baltic and other areas, this document focuses on the contribution of cruise shipping without context other than stating its portion of the shipping industry discharge. In fact, utilizing the composite average values contained in the HELCOM Research Note 2370 (updated 2008) Estimated nutrient load from waste water originating from ships in the Baltic Sea area and applying actual cruise ship voyage, passenger and crew numbers, the ECC finds that cruise ships contribute approximately.0064% of the Nitrogen and.0455 of the Phosphorous total loading of the Baltic Sea. 6 Additionally, it is important to note that this does not take into account that: CLIA and ECC member cruise ships do not discharge untreated/unscreened sewage; that CLIA and ECC member cruise ships utilize shore reception facilities when available; and that no reduction in waste stream quantity is taken for the time passengers and crew are actually ashore in port. 7 In addition, the Cruise Ship Discharge Assessment Report of 29 December 2008 issued by the Environmental Protection Agency of the United States reported that, for ships fitted with an Advance Water Treatment System, a reduction from 58 to 74% of Ammonia Nitrogen, Total Kjeldahl Nitrogen from 70 to 76% and Total Phosphorus from 41 to 98% is achieved. 8 We recognize that while ECC/CLIA member cruise ship discharges represent only an extremely small fraction of the total nutrient loading of the Baltic Sea, we wish to actively engage in minimizing these discharges where practicable and feasible. 9 Accordingly, the Chairman of ECC in a letter to the Mayor of Helsinki dated 21 April 2009, stated that ECC member lines are fully prepared to commit to measures that mitigate the causes of these types of environmental impact.. A copy of this letter and the full agreement with regard to discharges in the Baltic, listing the ECC Member lines, are attached as annexes 1 and 2 to this document. 10 CLIA also notes that the WWF document suggests this voluntary action be taken when traversing other water bodies other than the Baltic Sea. In addition to our concern that adequate reception facilities are not available in any of these areas, we are of the view that an ecosystem by ecosystem evaluation of each area of concern would need to be undertaken to assess the matter of eutrophication in each before such consideration can be given. 11 Accordingly, CLIA believes that it is premature to consider or submit to a voluntary scheme that would essentially halt cruise operations in this region. Action requested of the Committee 12 The Committee is invited to consider this information and decide as appropriate. ***
3 MEPC 59/14/1 ANNEX 1 Dear Mayor, BALTIC SEA CHALLENGE As the organisation representing the cruise companies operating in Europe, I am pleased to inform you that the members of the European Cruise Council (list attached) can fully subscribe to the Baltic Sea Challenge as set in your letter of 6/6/2008. The letter unfortunately did not reach many of the appropriate persons in the cruise companies when sent last year and we are happy that this has now been rectified. As background, the ECC was formed in 2004 and represents the major cruise companies operating in Europe, and is now widely recognized as their representative body. Central to its role is a commitment to protecting the environment and the evaluation by its members of the environmental impact of their business activities including that on the regions and destinations which they visit. We certainly acknowledge that the Baltic Sea faces a number of environmental challenges including marine eutrophication, and ECC member lines are fully prepared to commit to measures that mitigate the causes of these types of environmental impact. A key element in this is the provision, on a no special fee basis, of adequate port reception facilities to receive waste water effluent at cruise berths which is then effectively treated at the municipal waste water treatment plant. The ECC acknowledges and appreciates that the Port of Helsinki is one of the very few ports in the Baltic which has such arrangements. The ECC would very much like to see the Helsinki model replicated throughout the Baltic and is committed to working with other stakeholders to this end. Yours sincerely, David Dingle CBE Chairman ECC Mr Jussi Pajunen Mayor of Helsinki City Hall, P.O.Box 1 FI city of helsinki Finland ***
4
5 MEPC 59/14/1 ANNEX 2 ECC AGREEMENT ON DISCHARGES IN THE BALTIC European Cruise Council 1. As the organization representing the major cruise companies operating in Europe, the ECC is committed to protecting the environment and the evaluation by its members of the environmental impact of their business activities including that on the regions and destinations which they visit. 2. The ECC recognizes that the Baltic Sea is a unique environment that faces numerous threats, in particular eutrophication, and is committed to working with HELCOM and other stakeholders to reduce eutrophication by the reduction of nutrients. 3. Against this background, the ECC members undertake to discharge waste water ashore at Baltic ports with adequate port reception facilities which operate under a no special fee agreement. 4. ECC members consider port reception facilities to be adequate where a port can receive all waste water effluent via direct line/shoreside pipe connection at its cruise berth which can then be effectively treated at the municipal waste water treatment plant. 5. In addition, the ECC is committed to actively working with HELCOM and other stakeholders to undertake a comprehensive inventory/assessment of port reception facilities in the Baltic. The ECC considers that the overall goal of such an exercise should be to promote and establish adequate port reception facilities (as defined above) throughout the Baltic, with the Port of Helsinki being viewed as the model example. ECC Member Companies: AIDA Cruises Carnival UK Costa Crociere S.p.A Disney Cruise Line Fred Olsen Cruise Lines Iberocruceros Monarch Classic Cruises S.A. Norwegian Cruise Line Pullmantur Cruises S.L. Royal Caribbean Cruise Lines Silversea Cruises Thompson Cruises Tui Cruises GmbH Carnival Cruise Line CDF Croisieres De France Delphin Kreuzfahrten GmbH France Crosieres Hapag-Lloyd Cruises Louis Cruise Lines MSC Cruises Phonix Reisen GmbH Regent Seven Seas Cruises Saga Shipping Co. Ltd Star Clippers Cruises Transocean Tours Touristik GmbH
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