Navigating new rules and environmental operation

Navigation is generally defined as the act of directing a ship from one place to another. That can be applied to conventional navigation methods or e-navigation using new technology. The definition is still valid but these days there are more than the physical obstructions and conditions encountered during the voyage that require consideration.

Within their territorial waters, nation states have always had the right to impose on ships whatever restrictions on activities they felt necessary, and since 1983 beginning with MARPOL, international regulations have been developed to cover a wide range of environmental and operational matters. There may not be an obvious link between steering a ship from berth to berth and environmental regulation but as the rules change depending upon where the vessel is at any given moment there is a clear connection to navigation and voyage planning.

There will always be a small number of rogue ship operators that care little for environmental rules, but most do make an effort to comply. That is not always easy to do because of the patchwork of regulations that exist and anything that can help owners to better understand what the rules are is welcomed. As time marches on, more and more regulations and restrictions are being imposed but while there may be some uniformity in international regulations, the application and enforcement varies not only from country to country but in many cases different ports in the same state can have differing requirements.

There are companies that produce products to help in this regard and in mid-2019, NAVTOR teamed up with one of these – Total Marine Solutions (TMS) of Florida to integrate the firm’s Ocean Guardian solution into its NavStation digital chart table. The result is an additional overlay for the passage planning software that allows plans to be made at an early stage and refined if voyage orders change.

Failing to meet environmental regulations can mean severe penalties both in the way of expensive fines or long delays. The problem is that the changes in regulation can happen at quite a rapid pace. For example, when the IMO adopted the 2020 sulphur cap on fuels, it was generally accepted that this would involve burning low sulphur compliant fuels or by using a scrubber to strip the SOx out of the exhaust stream.

Most of the scrubbers installed on ships are open-loop types which discharge washwater into the sea after removal of oil and soot contaminants. There is a great deal of controversy over whether this is polluting or not and the issue is currently under review at the IMO. Despite scrubbers being permitted equipment on ships, some countries and ports have decided to impose restrictions on open loop scrubbers.

There have been a few places where washwater discharged has been banned for many years but in the second half of 2019 and through the first months of 2020, the list has grown rapidly and now there are at least 27 countries with some restrictions or another. Often the decision has been left to local port authorities which has added to the confusion.

To add to the puzzle, there are often conditions attached. For example, in Hong Kong if a ship intends to use scrubbers an application must be made to the Hong Kong authorities requesting for an exemption from using compliant fuel. The exemption application must be made at least 14 days prior to a ship’s first visit to the port. A similar situation exists in Bahrain where discharge of washwater from open loop scrubbers is prohibited within port limits including anchorage areas, however, discharge outside of port limits is permitted provided the ship has obtained a permit from the Marine Safety & Environment Protection Directorate.

Singapore prohibits discharges from open loop scrubbers for ships coming to the port but the prohibition does not apply to ships transiting the Traffic Separation Scheme without calling into the Port of Singapore.

Sometimes the restrictions for scrubber washwater and some other discharges such as food waste and black and grey water are difficult to interpret. This is especially so when a distance from the nearest land is mentioned. A number of countries use methods to extend the distance by including small islands off the main coastline. Discharging waste seemingly well outside the limit allowed may in fact be committing an offence that leads to heavy fines.

The connection between environmental and operational restrictions are sometimes blurred. For example, some ports do not allow hull cleaning or painting to take place in ports and welding or hot work may be restricted or require permission. Another area is disposal of such things as garbage, oily waste and cargo residues. Knowing if landing of such waste is compulsory or voluntary and what sort of charges are made not only avoids penalties but can save costs by being planned in advance.

NAVTOR’s addition of the Ocean Guardian tool gives access to detailed information for over 2,500 ports and almost 4,300 restricted or regulated operations. With new ECAs planned for the Mediterranean and the possibility that some areas may be designated Same Risk Areas for ballast water treatment as well as possible regulation around biofouling in the future, the need for information is accelerating.

If an environmental layer can be added to the NavStation it stands to reason that a similar tool covering other regulations can be devised at some point. There are some software products available that contain this information, but which are not designed for use with NavStation or navigation tools generally. As e-navigation evolves it seems likely that it will also be used for gathering and disseminating commercial information.

This article is the fourth in a short series on the intriguing topic of e-navigation the others can be found here, here and here.

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