Alternative Methods of Ballast Water Management Compliance
What if investing significant capital in retrofitting an entire fleet of vessels with permanent ballast water management systems was not the only method of compliance? Sure, many alternative methods of ballast water management compliance have been casually discussed at various conferences and in various publications – but just how close to reality are these alternative compliance methods?
Well, it turns out many of them are already viable options…
Alternative methods of ballast water management compliance can broadly be broken down into the following segments:
Mobile ballast water treatment systems are now, finally, coming to the fold and represent one of the most commercially efficient methods of compliance – but only for owners of particular types of vessels, or vessels operating on fixed trading routes. Indeed, mobile ballast water management solution provider, Ballast Water Containers, claims that mobile treatment solutions could save vessel owners up to 80% of their compliance costs.
Mobile treatment systems are particularly suitable for vessels with low utilisation – such as barges, or minimal, and predictable, ballasting operations – such as fixed route container vessels, liner services etc. An owner investing in a small number of mobile treatment systems, theoretically, could share them between multiple vessels – avoiding having to retrofit each one. The mobile treatment systems could be stored in various ports, and temporarily mobilised to the vessels as they call in – again, avoiding having to retrofit each vessel.
Alternatively, a pre-outfitted treatment barge could be mobilised around a given port to meet the ballasting needs of various vessels calling in to said port.
Mobile treatment systems, however, would not be suitable for vessels that conduct ballast operations frequently, or are involved in irregular trade – unfortunately!
Beyond traditional retrofitting, a permanent (or semi-permanent) port based treatment system offers many vessel owners and operators with a convenient, and presumably cost effective, method of compliance. Companies such as Damen, who have developed their InvaSave port based treatment option, are seeking to offer the industry port based solutions.
With many other effluents and discharges from vessels handled by shore based treatment systems, the concept makes sense – however, where the concept is let down is its lack of global availability. With ballast water management compliance such an important aspect of day to day vessel operation, owners and operators are currently averse to relying on third party service companies, around the world, to manage their ballast water for them. Lack of availability in a specific port, for example, would render the vessel unable to discharge ballast.
Things also start to get particularly complicated when ballast water management legislation is applied.
In the USA, for example, effluents discharged from a vessel to a shore based facility, are thereafter governed by the Environmental Protection Agency (EPA), which has a completely different set of requirements to those of the USCG, and which, to date, have still to be determined for ballast water.
There remain a number of legislative methods for achieving compliance – including exemptions, under IMO, and extensions, under USCG.
Exemptions have been a hot topic within MEPC, and associated IMO related industry bodies, of recent times, and they broadly fall under two specific aspects:
- Fixed Route Exemptions
- Same Risk Area Exemptions
Fixed route exemptions essentially apply to vessels such as passenger ferries or shuttle freighters – vessel trading exclusively on a dedicated route, between two or more international ports. The Convention allows for owners and operators of such vessels to apply for an exemption, if they are capable of demonstrating the appropriate level of risk of transfer of invasive species.
The concept of same risk area is a somewhat new proposal, and covers vessels trading within a particular geographical region. The theory is that if vessel owners / operators can demonstrate an appropriate level of risk of transfer of invasive species within the geographical region, then all vessels operating exclusively within said region could be granted an exemption.
In either scenario, the process of undertaking scientific studies for each potential port, either within a fixed route, or within a geographical area, is currently a time consuming and expensive endeavour – and is likely the cause of so few, if any, exemption applications having been made.
Discussions are ongoing within MEPC and the appropriate industry bodies regarding simplifying the exemption process, however, until such time as amendments are made, exemptions will likely remain somewhat unachievable.
Perceived as being one of the most invasive methods of alternative ballast water management compliance, operational adjustment can actually offer owners and operators with a low up-front investment solution for achieving compliance.
Concepts such as captive ballast are, indeed, sensible and viable compliance options for particular types of vessels. Vessels such as passenger ferries, for example, tend to ballast so seldom that investing significantly to achieve compliance conventionally is somewhat unpalatable. Simply re-configuring the classification of the ballast tanks, re-working the tank plan and gaining Class Approval for the methodology may be the most viable compliance solution. At the very least, it is worth pursuing prior to making significant investment decisions.
Similarly, for vessels such as barges, that only ever conduct ballast operations in one particular body of water at a time (for loading/unloading heavy lift cargoes), owners or operators could, theoretically, achieve compliance by segregating their tanks and ensuring tanks are always fully emptied (and cleaned if required) prior to leaving a particular geographic location.
Operational compliance solutions are always worth investigating, as minimal impact operational changes may present ideal compliance solutions – and avoid significant investment.
Even within the term “alternative ballast water management compliance,” there are some solutions that do not fall under any sub-category. Concepts such as using potable or fresh water, theoretically represent a convenient compliance solution – avoiding significant capital investment. However, owners and operators should ensure they understand the implications of ballasting/de-ballasting using shore provided potable water. Such infrastructure is often unreliable, with varying, and often very low, flow rates – which can have a significant impact on vessel ballasting operations. Acceptance under the legislation is also a challenge for potable / fresh water. Whilst using water from a US public water source is acceptable under USCG requirements, the use of fresh water is generally not considered acceptable under IMO requirements.
One final alternative concept, which the industry has not discussed at length, is the idea of re-using ballast water that has already been treated. Of course, for some technologies this is not a viable solution (UV for example is sensitive to the issues of re-growth), but for technologies that have ongoing residual treatment effects – re-using already treated ballast water between different vessels seems like a sensible, and environmentally friendly, proposition. Of course, the practicalities, both technically and commercially, may be difficult to overcome, but it is an intriguing solution nonetheless.
Overall, it can be demonstrated that there are a number of alternative compliance options out there, many of which are already viable solutions, or are close to being so. It is certainly worth investigating these alternative concepts prior to making significant investment decisions – particularly if your vessels fall under any of the categories discussed in this article.