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Ballast Water Management: How the Indian Ports can Benefit?
Patrick Donner, Associate Academic Dean World Maritime University Malmo, Sweden and Giriraj Singh Rathod, Deputy Secretary, Mumbai Port Trust Since the introduction of steel hulled vessels, water has been used as ballast. Ballast water is essential to maintain safe operating conditions through out a voyage and stabilise vessels at sea. Notwithstanding its operational advantages, use of water for ballast poses serious ecological, economic and health problems due to the transfer of a multitude of marine species that survive in the host environment.

This problem was first recognised in the North Sea in 1903 with mass occurrence of the Asian phytoplankaton algae Odontella (Biddulphia sinensis). But it was brought to the attention of IMO’s Marine Environment Protection Committee (MEPC) in the late 1980s by Canada and Australia, which experienced particular problems with invasive species, eventually resulting in the adoption of the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM Convention) in 2004. (IMO)

The Approach
The obligation to prevent and control the introduction of alien species into the marine environment basically rests with each coastal state. This principle was recognised and laid down in the United Nations Convention on the Law of the Sea (UNCLOS), 1982, which in Article 196 states:

States shall take all measures necessary to prevent, reduce and control pollution of the marine environment resulting from the use of technologies under their jurisdiction or control, or the intentional or accidental introduction of species, alien or new, to a particular part of the marine environment, which may cause significant and harmful changes thereto.

In the BWM Convention practically all operational obligations for ballast water management were put on the ships, rather than the ports, with States limiting their role to policing and enforcing the rules. The BWM Convention does in fact, in Article 5, oblige States to provide reception facilities ashore, but only for reception of sediments in connection with cleaning or repair of ballast tanks and reception facilities for ballast water are only hinted at. Consequently, the methods contemplated by the BWM Convention for treating ballast water and sediments focus on methods to be applied onboard the ships carrying the ballast water.

Entry into Force and Applicability
The BWM Convention will enter into force 12 months after ratifi cation by 30 states, representing 35 per cent of the world merchant shipping tonnage (Article 18). Upto 31.8.2012 it is ratified by 35 states representing 27.95 per cent of the world tonnage (IMO).

The BWM Convention will apply to practically all ships. Naval ships are excluded and ships, which only operate within the waters of a state party, may also be excluded as well as ships that are designed or built not to carry ballast water at all. According to Regulation A-3 in the Annex to the BWM Convention, the requirements do not apply in some situations. For example, it does not apply to discharge of ballast water in the same location where it was originally taken or to uptake and discharge of the same ballast water on the high seas, as there would be no transfer of aquatic organisms from one location to another in these cases. Furthermore, the requirements do not apply to accidental discharges resulting from damage to a ship or its equipment or when it is necessary to take or discharge ballast water to avoid or minimise pollution, which are also easily justifiable exceptions. Finally, the requirements do not apply to uptake or discharge of ballast water or sediments necessary for the purpose of ensuring the safety of a ship in emergency situations or saving life at sea. For all practical purposes, this means the convention will apply to almost all cargo carrying merchant vessels.

The world fleet consists of over 100,000 vessels (UNCTAD, 2012). Roughly, half of this number consists of fishing vessels and most fishing vessels are small and operate only in local waters so they may fall outside the scope of the BWM Convention. However, that still leaves about 50,000 vessels, which will have to comply with the BWM Convention. Many smaller cargo vessels trade within limited areas where the risks of transferring harmful invasive species may be limited, but they will still need to have appropriate ballast water treatment equipment installed, or retrofitted, in order to be commercially viable. This represents a massive undertaking and investment for the entire shipping industry.

Ballast Water Management Under the BWM Convention The BWM Convention has an Annex entitled "Regulations for the control and management of ships’ ballast water and sediments" and Section D of the Annex contains the "Standards for ballast water management," which are defined in terms of a ballast water exchange standard (Regulation D-1) and a ballast water performance standard (Regulation D-2).

Ballast water exchange
When the BWM Convention was adopted, there were no approved treatment methods for achieving the prescribed performance standards. Therefore, at that time the only method for preventing the transfer of harmful alien aquatic species from one region to another through ballast water was to exchange the ballast water en route in deep waters. However, ballast water exchange on the high seas exposes the ship to potential dangers both in terms of physical stresses on the hull and potential loss of stability. Naturally, the procedure must be carefully performed and monitored, but erring is human and there have been recorded incidents where ships have come close to foundering due to loss of stability during a ballast water exchange procedure.

However, ballast water exchange procedures can never ensure a complete removal of all organisms so it is not a fully effective method for prevention of transfer of harmful aquatic organisms and, in any case, it is only an interim solution, which will be allowed for some ship types, but only until the first survey after 2016.

Ballast Water Treatment
There are a number of methodologies to treat ballast water in order to limit, eliminate or render harmless aquatic organisms and sediments in ballast water to the extent defined in the ballast water performance standard. The treatment process could be mechanical, physical, chemical or electrical, or combinations of these. However, the different treatment methodologies are not discussed within the scope of this paper.

The obvious implication is that appropriate equipment for treatment of ballast water must be installed on most ships and that equipment will then have to be properly operated by the crew who also need to maintain accurate records of all ballast water operations undertaken. Although most ships, irrespective of size, carry ballast water, the problems facing ships in effectively managing the ballast water tends to differ depending on the size of the ship. For a smaller ship, the amount of ballast water is obviously less, but at the same time, smaller ships often carry cargoes over shorter distances, so time may be a constraining factor in achieving effective treatment of the ballast water. On the other hand, large ships, such as crude oil tankers, large dry bulk carriers and car carriers are mostly operated on long routes, but they also have to treat huge volumes of ballast water. If the technology chosen treats ballast water only while ballast is taken on, capacity constraints might add considerably to the time the vessel has to stay in port before departure and this could have significant effects on the cost of operation/earning capacity of the vessel.

Ballast Water Management - Alternatives On-board or Ashore?
As per the Australian conceptual approach (AQIS 1993a), there are three basic treatment scenarios for ballast waters; ship-board, involving onboard facilities for treatment during ballasting or en route; port-based, referring to a dedicated ship or barge fitted with treatment equipment, which can service berthing ships; and land-based, involving a connecting pipeline or barge to transport the ballast water from the berthing ship to a storage facility and/or treatment plant.

The focus of most of the research so far was on the on-board ballast water treatment systems. However, deploying the available technologies routinely applied for water and wastewater treatment it may be possible to develop treatment systems on-shore quickly and cheaply. (Cohen & Foster, 2000)

On-shore Treatment Vs On-board Treatment
The methods contemplated by the BWM Convention for treatment of ballast water may be the same regardless of whether the equipment is installed on board a ship or ashore, but the difference lies in the effectiveness of the processes employed where shore-based installations would appear to have several advantages compared to treatment of ballast water on board. The advantages and disadvantages have been discussed in several studies (eg AQIS 1993, Stemming the Tide 1996, Donner 2010, Pereira et.al. 2010) and are, therefore, only outlined here.

Advantages of on-shore treatment would be (i) fewer space and power constraints, (ii) treatment managed by dedicated staff (professionals) rather than rotating ship’s crew and hence, operations likely to be more consistent and reliable rendering it easier to monitor and regulate the treatment process and effluent quality, (iii) economies of scale in constructing and operating relatively few on-shore treatment plants and (iv) treatment only of the water quantity actually discharged.

On the other hand, the disadvantages of on-shore treatment would be (i) high cost of land for treatment plant in some areas (although a floating ‘treatment ship’ may offer an alternative at reasonable cost), (ii) possible delays to ships during off-loading of ballast water and (iii) no treatment of ballast water discharged prior to ships’ entry into port (such as when a ship must lessen its draft before crossing a shallow bar or entering a shallow port). (Cohen, 1998).

Are Shore-based Ballast Water Facilities Justifi able?
The BWM Convention will enter into force 12 months after ratification by 30 states, representing 35 per cent of the world merchant shipping tonnage (Article 18). This level of ratification will be achieved in the not too distant future. When the BWM Convention 2004 does enter into force, ships carrying ballast water will have to comply with the requirements to manage the ballast water so that it meets the specified ballast water performance standard, which means having the necessary equipment installed and to operate it, in some cases immediately from the date of entry into force and in some cases after a transition period which may extend to 2019.

The investment in the actual treatment equipment will depend on the installed treatment capacity and costs ranging from USD 50,000 to USD 2 million have been mentioned (Guidelines on the way for European ballast water sampling 2010). A shore-based facility would require additional investment in pipelines from the berth(s) to the facility. On the other hand, the installation and internal piping on a ship may represent negligible additional costs, if they are incorporated in the design when the ship is being constructed, which appears to already be the case (Eason 2010), but may amount to significant amounts if they have to be retrofitted, which would be the case for practically all existing ships. As an example, one study set the estimated investment in equipment and installation for a 35,000 dwt bulk carrier at USD 810,000 (Green Ship of the Future 2009). It has been reported that the global market for ballast water treatment systems is estimated to be about USD 35 billion (Eason 2010) and that number, presumably does not include the cost of installation on board ships. On the other hand, transferring the ballast water to shore-based facilities (or barges) would also require some retrofitting of vessels – some modification of the internal piping would be almost inevitable and it would be necessary to make it possible to connect hoses to receive the ballast water. A common standard would need to be established for such connections, but existing discharge valves are not standardised. One study estimated that the cost for such modifications would vary between just over USD 100,000 for a 67,550 dwt bulk carrier to almost USD 1.9 million for a 123,000 dwt tanker (Glosten Associates 2002). A complete comparison of the total investments involved for the different alternatives is beyond the scope of this paper as it involves a great number of variables. However, it is safe to say that the total investments required for installation of ballast water treatment equipment on upwards of 50,000 vessels that eventually will have to comply with the BWM Convention 2004 represents a massive undertaking and investment for the entire shipping industry and, in the light of the cited examples, probably considerably greater than would have been required for shore-based treatment facilities.

With the entry into force of the BWM Convention 2004 becoming a certainty, is there then any reason to construct shore-based ballast water treatment facilities, regardless of the apparently rational, environmentally and economically sound arguments for such facilities? The answer is ‘No’ in the sense that shore-based facilities will not be the global solution instead of the one prescribed by the BWM Convention 2004. Onboard ballast water management facilities will have to be installed whether they are rational or not. But at the same time, shore-based treatment facilities can be justified in certain cases despite the apparent duplication of investment. The basic obligation to prevent and control the introduction of alien species into the marine environment basically rests with each coastal state and some states take this obligation very seriously, especially with regard to particularly sensitive environments. For example, the United States have already introduced legislation, which requires a Vessel General Permit, which aims to eliminate all forms of pollution from ship covering 26 different possible discharges from ships. With regard to ballast water the rules differ from the BWM Convention and require a much higher ‘kill standard’ than the convention (Grey 2009). The Great Lakes is a water system, which has already suffered from the introduction of alien invasive species and is, at the same time a clearly limited area, which could be controlled. Therefore, it is possible to imagine and would probably be feasible, although at considerable cost, to build ballast water treatment facilities in all major ports in the Great Lakes and to require all ships arriving from locations outside the area to use those facilities. There would be some trade-offs for the shipowners as well. Some ships, which trade exclusively in and out of the Great Lakes and are designed for that specific trade route, might not even need to install the ballast water treatment equipment, if they were always to arrive in ballast at ports with reception facilities. And even if the ship has the equipment installed, knowing that the ballast water will (have to) be pumped ashore for treatment will save the time, effort and cost of using the onboard installation. This could be seen as quite attractive, especially since the responsibility and the corresponding liability, including criminal liability, is not just to treat the ballast water, but to achieve the specified result. A very different, but plausible example would be LNG loading terminals. In many cases the LNG tankers are contractually committed for 15 years or more to a specific loading and unloading terminal and the ships always arrive to the loading terminal in ballast. If the loading terminal were to provide a ballast water reception facility, such a ship could effectively do without the onboard installation, at least until its third or fourth special survey. Yet another possible case could be oil terminals in the Arabian Gulf, which could use desalination as a ballast water treatment method and use the water for industrial or irrigation purposes.

About 95 per cent by volume and 70 per cent by value of India’s international trade is carried through maritime transport. The Indian maritime sector provides a variety of services such as cargo handling, ship building and ship repairing, freight forwarding, light house facilities and training of marine personnel. India has 12 major ports, six each on the west and east coasts and about 200 minor ports. (Choubey, 2010)

There has been sustained rise in the volume of exports with revival of growth in the manufacturing sector and improved export competitiveness. The Government has fixed a target of USD 350 billion for exports by the year 2012-13 (Economic Times), which is to be increased to USD 500 billion in 2013-14 (Business Today). Considering the fact that ships arriving to load export cargoes come in ballast to the port of loading while crude carriers engaged in import of crude oil sail in ballast from the port of unloading, extension of port services by providing BWM facilities on shore by the multipurpose ports involved in handling exports of breakbulk commodities and imports of crude oil will be an attractive option.

The ports in India receiving ships with an average age in the range of twenty years can consider providing ballast water treatment facilities on shore as a value added facility to the ships. This will give the Port(s) a competitive advantage, as the additional expenditure of USD 50000 to 2 million to install the equipment on board may not be a commercially viable decision for such old ships.

All that it may need is an amendment to Regulation A3 in the Annexure to the BWM convention to specify that it does not apply in situations where water which has already been treated ashore is taken as ballast.

The entry into force of the BWM Convention 2004 can now be seen as a certainty. Consequently, shore-based ballast water treatment neither is, was nor would be an alternative to replace the BWM Convention, but the question remains whether it could be a viable parallel solution. The potential environmental and operational benefits of shore-based ballast water treatment facilities suggest that they can be an attractive option for some ports or areas.