29th Meeting of INTERTANKO’s

ENVIRONMENTAL COMMITTEEMonday 28th September 2009

0930hrs-1730hrs

OSG Ship Management (GR) Ltd. 110 Vouliagmenis Avenue and Zamanou Street

Glyfada Athens, Greece 16674Tel: + 30.210.911.9300Fax: + 30.210.911.9302

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INTERTANKO’s Anti-Trust/Competition law Compliance Statement

INTERTANKO’s policy is to be firmly committed to maintaining a fair and competitive environment in the world tanker trade, and to adhering to all applicable laws which regulate INTERTANKO’s and its members’ activities in these markets. These laws include the anti-trust/competition laws which the United States, the European Union and many nations of the world have adopted to preserve the free enterprise system, promote competition and protect the public from monopolistic and other restrictive trade practices. INTERTANKO’s activities will be conducted in compliance with its Anti-trust/Competition Law Guidelines.

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1. Minutes2. Membership

Policy Issues3. Ballast Water Management4. Port Reception Facilities5. Biofouling6. Ship Recycling7. Greenhouse Gas Emissions8. Environmental Benchmarking

Reporting Items9. US - NPDES10. TMSA Related Matters11. Ship Strikes with Cetaceans 12. Marine Noise Pollution13. Liaison with Environmental Organisations14. Date and Place of next Meeting15. Any Other Business

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1. Minutes

The minutes from the last meeting, held in Dubai on 20th January 2009 were circulated on 29th

January (EnvComm #05-09) and are enclosed.

The Committee is invited to approve the minutes from the last meeting.

2. Membership

Members will recall that at the last meeting, Mr Oleg Kalinin of Unicom Shipmanagement Services had requested to take a seat on the Committee. The Committee supported this request subject to approval at the next meeting.

The Committee membership is now at its maximum with 16 members. Continued interest from members of INTERTANKO continues however and the Committee is requested to consider whether it is worthwhile expanding the Committee maximum to 18 members.

The current membership listing is enclosed. Please note that ITOPF have yet to advise who would replace Dr. Tosh Moller.

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POLICY ISSUES

3. Ballast Water Management

3.1 Ballast Water Treatment Technology: INTERTANKO Criteria

A number of ballast water treatment systems have now been type approved and are being marketed to the shipping and ship building industries by their manufacturers. Those systems using active substances are gaining basic and final approval at the IMO and will also be undergoing the process of type approval. On the regulatory side, a number of countries including the US and Norway are moving forward with the implementation of the Convention requirements. With this in mind and the agreement at the last MEPC meeting that no further delay for the Convention implementation dates, the industry is being encouraged to begin the process of installing treatment systems on new and existing ships.

Both the Environmental Committee and ISTEC have in the past expressed reservations regarding the installation of ballast water treatment systems. Following discussion with the Chairmen of both Committees it was suggested that a set of criteria be established by the members based on their own assessment of suitability for the installation of ballast water treatment systems for both new and existing tankers.

To facilitate discussion on this subject, members are invited to prepare and consider in advance, the following points:

- What is available on the market;- Their suitability for tankers;- Pros and cons of systems from a technical and operational viewpoint; - Experience from any members.

To assist this discussion and consideration of an INTERTANKO criteria, members are invited to consider the questions distributed by the IMO to facilitate dialogue between owners and treatment system vendors, see below (BWM.2-Circ.21.pdf).

3.2 USCG Notice of Proposed Rule Making

On 28th August this year, the USCG issued a Notice of Proposed Rule Making pertaining to the standards of discharge for ballast water treatment systems installed on US and non-US flagged vessels discharging ballast in US waters.

The discharge standards being proposed are being implemented in two phases:

1. Phase One as per the IMO discharge standards and entry into force dates2. Phase Two as of 1st January 2016 with implementation of discharge standards 1000x

greater than the IMO standards

Details of the dates are given below:

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Proposed Implementation Schedule for the Phase-One Ballast Water Management Programme

Vessel’s ballast water capacity(cubic meters, m3) Vessel’s construction date Vessel’s compliance date

New vessels: All On or after January 1, 2012 On Delivery

Existing vessels:Less than 15001500–5000 Greater than 5000

Before January 1, 2012 Before January 1, 2012Before January 1, 2012

First drydocking after January 1, 2016 First drydocking after January 1, 2014 First drydocking after January 1, 2016

Proposed Implementation Schedule for the Phase-Two Ballast Water Management Programme

Vessel’s ballast water capacity(cubic meters, m3) Vessel’s construction date Vessel’s compliance date

New vessels: All On or after January 1, 2016 On Delivery

Existing vessels: All Before January 1, 2016

First drydocking after January 1, 2016, UNLESS the vessel installed a BWMS meeting the phase-one standard before January 1, 2016, then 5 years after installation of the BWMS meeting the phase-one standard

Aside form the discharge standards and associated implementation dates for these standards, the proposed rule also provides for a review to assess whether it is practical for treatment systems to be able to meet the 2016 standards. The review is due to be completed in early 2013. The proposed rule states that ballast water treatment manufacturers should test their systems according to the USCG standard protocol and not the IMO’s if they wish to demonstrate compliance with the 2016 standards.

Comments on the proposed rule should be submitted by 27 November 2009. To facilitate the comment process the Chamber of Shipping of America has extracted and summarised the following key questions from the Federal Register:

1. Relative to the two year period between the first practicability review and the second review, is a more appropriate period one year or three years, assuming a second or additional reviews are required?

2. Comment on the appropriate scope of the practicability review and in particular, how and to what extent costs should be considered in the review.

3. Relative to the phase one implementation schedule of 2014/2016 based on ballast water capacity, comment on whether it is possible that ALL existing vessels could meet the 2014 implementation date.

4. The phase two standard includes a grandfather clause for vessels that have installed a phase one compliant system prior to January 1, 2016 so that they would be able to operate for 5 years from the installation date. Comment is requested on whether such a grandfather clause is necessary and whether the five year period is the appropriate time period. Assuming the grandfather clause is appropriate, what is the appropriate time period and why?

5. What are the acquisition, installation, operation/maintenance and replacement costs of technological systems that are able to meet more stringent standards? Provide quantitative cost data specifying complete data sources, type of technology and testing status, and the stringency (at 10X, 100X, 1000X the IMO standard and for sterilization).

6. Are there technology systems that can be scalable or modified to meet multiple stringency standards after being installed? Please provide quantitative data specifying the technology,

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necessary modifications (to go to a more stringent standard), costs, and sources of the information.

7. What are the additional costs for vessels compliant with the phase-one standard to go to the phase- two standard? Please provide quantitative cost data specifying complete data sources, type of technology, and possible phase-two stringencies (at 10x, 100x, and 1000x the IMO standard and for sterilization).

8. What are the additional avoided environmental and social damages and economic benefits of ballast water discharge standards at more stringent standards? Please provide quantitative data and sources for all information.

9. In light of the potentially severe nature of such damages, does the proposed rule ensure to the maximum extent practicable that aquatic nuisance species are not discharged into waters of the US from vessels as required by NISA? Would an approach that bypassed phase one and went directly to the phase two standards be practicable and provide greater protection of the aquatic environment? Please provide quantitative data and sources to support your response.

10. What BWDS is sufficient to adequately safeguard against the introduction of species into U.S. waters via ships’ ballast water? Should the standard provide for zero risk of spreading invasive species via ballast water (e.g. zero living organisms), or should the standard be one that substantially mitigates any risk, but may not eliminate the possibility of species being introduced?

11. For any BWDS identified in response to (10), what is the evidence that the systems can meet either of the BWDS proposed in this NPRM, and what are the timeframes by which such BWDS can be achieved and what technologies are, or will be, available to meet such BWDS.

12. For any BWDS identified in response to (10), what are the costs of such systems for various classes of ships and under differing operating conditions? Additionally, what are power requirements on board those vessels and what additional chemical storage requirements and other space requirements are needed on board those vessels?

13. What are the advantages and disadvantages of a ballast water discharge standard that is more stringent than the IMO standard? Please provide quantitative data and sources of the information.

The Committee is invited to consider the proposed rule along with the questions provided by the USCG and comment as appropriate.

3.3 Model Ballast Water Management Plan

The secretariat is grateful for the comments received from Capt. Hatzikyriakos on Capt. Reppas’ revised Model Ballast Water Management Plan. Further guidance has been received from Bill Millar.

The new draft is undergoing proof reading and will be printed in mid-late October.

The Committee is invited to take note.

4. Port Reception Facilities

4.1 IMO Best Practice and ANF/WDR Forms

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Members were advised through the INTERTANKO Weekly News that the IMO’s MEPC adopted the Guide to Good Practice for the Use and Provision of Port Reception Facilities. This is another positive development by the IMO on the issue of adequate port reception facilities and will be useful in benchmarking adequacy by the shipping industry.

Within the Guide reference is made to the use of the Advanced Notification Form (ANF) and the Waste Delivery Receipt (WDR) as standard practice. The Committee will recall that it had supported the use of these two forms regardless of the requirements by the port authority. However, it has been brought to the attention of the secretariat that a number of ambiguities exist in the forms. With the increase in use of these forms and the possible assessment by PSC it is considered essential to provide guidance on completing the forms and ensuring consistency and uniform interpretation across the industry.

By way of an example, the following questions have been raised regarding the ANF:

Reference is made to the last table which as to be completed by the Master when the ship is not going to deliver ALL the waste in the port of call (which is the normal case).

For this table the following questions have been raised:

1. Second column "maximum dedicated storage capacity m3" :

For wastes such as sludge and garbage the answer is clear. However, for "dirty ballast water" there is no any "dedicated" storage capacity. The same applies for "scale and sludge from tank cleaning" which is more or less solid or semi-solid waste.

2. Third column "amount of waste retained on board m3"

Does the amount to be entered refer to the onboard quantity at the time of the notification (e.g. 24 hrs prior to arrival) or to the onboard quantity at the time of the arrival? This is quite important since PSC Officers might use this form to check the reported quantities and find differences between the quantities reported and those actually onboard.

3. Last column "Estimated amount of waste to be generated between notification and next port of call - m3"

IMO has not agreed yet on any formulas to calculate the waste generation. However, assuming that the ship will make the estimation the column is completed so as to allow the Port Authorities to see if the ship (which is not going to deliver all the waste) has the necessary capacity to retain onboard the quantities of waste to be generated until the next port of call.

However, there is no provision in the ANF to accommodate/record the cases where the ship has a treatment system onboard to treat the generated waste (e.g. oily water separator, incinerator etc.) and as such the quantity to be generated is not necessarily relevant to the issue of retention since the ship will treat and legally dispose of this waste. It is therefore not clear how this should be covered in the reporting format and what the Master should record? Perhaps the question should not be how much waste will be generated but how much will need to be stored on board before the next port of call.

As regards sewage, the situation is more complicated if the ship is not fitted with a sewage holding tank and is equipped with only a sewage treatment plant. This raises the question as to what the Master will enter under the columns "maximum dedicated storage capacity m3", "amount of waste retained on board m3" and "Estimated amount of waste to be generated between notification and next port of call - m3".

The ANF and WDR are enclosed for reference and consideration by Committee members prior to the meeting.

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The Committee is invited to consider the development of a guidance document for the uniform completion of the ANF and WDR forms and provide any further areas of ambiguity which need addressing in any such guide.

4.2 Garbage Management Plan

The Chairman has noted that INTERTANKO’s Model Garbage Management Plan has not been updated since 1997. With the introduction of the reception facilities Best Practice Guide, the favouring of recycling options and the review of MARPOL Annex V, the Chairman has suggested that the Guide would benefit from updating and re-launching.

The Committee is invited to consider the current Guide and comment on the need for an updated version to be produced.

4.3 Greywater Discharge and Holding Tanks

It has been noted that countries are introducing requirements to prevent the discharge of treated sewage into territorial waters. Communications with the Turkish Chamber of Shipping confirms that it is prohibited to discharge any water (grey water or sewage) into territorial waters (Turkish Environmental Law No.2872). While Turkey is not a signatory to MARPOL Annex IV members have vessels designed with limited or no holding tank for grey water or sewage as an IMO approved treatment system has been installed instead. When in waters with such a requirement these vessels types face significant problems in terms of waste water storage.

This will also have an effect on vessels trading in US with individual state implementation of the NPDES.

The Committee is invited to comment on this matter and advise possible future action as appropriate.

5. Biofouling

The secretariat has continued to participate in the IMO’s Correspondence Group responsible for developing the IMO’s Guidelines for Biofouling Management. The CG is now into its final period of drafting with the objective of submitting the draft for adoption a next year’s MEPC 60 in March.

The enclosed document contains the comments submitted by INTERTANKO at the last drafting stage.

The Committee is invited to review the draft Guidelines and advise of any additional comments that should be included during the final round of drafting.

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6. Ship Recycling

The Committee will be aware that since its last meeting in January, the IMO member states have adopted the Hong Kong Convention on Ship Recycling. A copy of the Convention can be obtained from the secretariat and was circulated in Weekly News 31.

A number of members have enquired about the process of sending a vessel for recycling and the best options for ensuring a safe and environmentally sound dismantling of their vessels. The request for advice ranges from commercial contractual advice to yard selection and contact details and to the standard process for readying a vessel for recycling. Noting the need for such guidance the Industry Work Group on Ship Recycling has developed the enclosed ‘Transitional Measures Guidance’ which aims to assist operators in the practical elements of sending a ship for recycling, enclosed.

The Committee is invited to review the draft transitional Measures and provide any further comments or action in regards to industry advice on sending a vessel for recycling.

7. Greenhouse Gas Emissions

Following the adoption of the IMO’s Ship Energy Efficiency Management Plan guidance at its last MEPC meting in July, the secretary has updated the draft Tanker Energy Efficiency Guide as enclosed.

The Committee is invited to review the draft with the aim of adding any final comments at the meeting so that the document can be released.

8. Environmental Benchmarking

Considerable efforts have been made by the Committee to reach a consensus on a standard formula and set of criteria for benchmarking environmental impacts from shipping. It has been suggested that as many members are already utilising certain methodologies and it would be worthwhile considering the use of a system already in use and which has proven successful. In this respect the Committee is provided with the BP methodology, enclosed. This methodology and format is already in use by a number of Committee members.

The Committee is invited to comment on the adoption of the BP methodology for standard use by INTERTANKO members and to form the basis of an INTERTANKO benchmarking system.

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REPORTING ITEMS

9. US – NPDES

The Committee is invited to note the NPDES FAQ section on the INTERTANKO website and comment as appropriate.

http://www.intertanko.com/templates/Page.aspx?id=45387

10. TMSA Related Matters

Noting the near completion of INTERTANKO’s energy efficiency guide and the IMO’s SEEMP, the Chairman has invited the Committee to consider the interaction of these two documents with the TMSA supplement on energy efficiency and fuel management.

The Committee is invited to comment, as appropriate, on the energy efficiency aspect of TMSA.

11. Ship Strikes with Cetaceans

The Committee is invited to the note the Guidance document adopted by MEPC 59 and circulated as an IMO MEPC circular.

12. Marine Noise Pollution

INTERTANKO continues to monitor the developments within the IMO’s Correspondence Group on noise from commercial shipping and its adverse impacts on marine life. At its last meting, the IMO’s MEPC agreed to continue this work with a focused effort on identifying which aspects of a ships’ operation created the most noise and what options were available to reduce this noise.

The Committee is invited to note the continued activity of this Correspondence Group and advise any further action as appropriate.

13. Liaison with Environmental Organisations

WWF have requested INTERTANKO’s comments and advice on a campaign aimed at encouraging flag administrations to ratify and implement international conventions. Entitled, Shipshape, the programme will first look at those flag states that are not ratifying or implementing international and domestic rules, then move on to assess those shop operating companies who continue to use the states identified in phase one of the programme, and then conclude by listing those brands that use shipping companies which use the poorly performing flag administrations.

WWF has a long history in working with industry across many sectors and has helped to set up several successful industry-NGO initiatives aimed at securing win-win outcomes for both industry and the environment. WWF therefore state that they are seeking partners interested in working with them to raise the bar in flag state performance by choosing responsible flag states according to our developed criteria when registering vessels.

The programme is clearly in the developmental stage. WWF are keen to involve INTERTANKO from this early stage and therefore seek our guidance and comments on this initiative.

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The Committee is invited to comment as appropriate.

14. Date and Place of next Meeting

Date Venue Comments

April 2008 Istanbul Back-to-back with ISTEC

October 2008 London

January 2009 Dubai Back-to-back with ISTEC

September 2009 Greece Back-to-back with ISTEC

Noting the previous meeting dates and locations, the Committee is invited to consider the date and place of the next meeting.

15. Any Other Business

The Committee is invited to raise any further items not already covered within the agenda.

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