We hope existing readers enjoy the article once more, and new readers find it engaging. The topic will be discussed in more detail at the Malin Group Barge Owners Seminar, taking place in Glasgow in 2018, check out this link for more information – http://www.malingroup.com/events/
Ballast Water Compliance Challenges – Barges & Pontoons
This article is the first in a series of articles examining compliance challenges of specific vessel types – to assist owners/operators of these vessels in understanding key aspects of ballast water management compliance.
Estimated to make up only 3% of the world’s tonnage, the barge/pontoon industry is somewhat of an afterthought for most BWMS manufacturers.
The main issue facing the barge/pontoon industry is that with such a huge commercial opportunity available in the remaining 97% of the BWMS industry over the next 5 – 7 years, and the complexities and engineering challenges associated with barges/pontoon compliance, manufacturers have had very little motivation to adapt their systems for barge/pontoon applications.
Whilst there are now manufacturers such as Ballast Water Containers aiming to provide barge/pontoon owners with tailored barge/pontoon specific solutions, compliance for barge/pontoon owners and operators is still a very real and sobering thought.
The very question of barge/pontoon compliance has been raised at various industry conference events over the years, including, most recently, during DNV GL’s Webinar, titled; “80 Days to go – Are you ready? The BWM Convention enters into force on 8 September.”
However, there have been few, if any, useful answers to the question. For this reason, Cleanship Solutions has developed this informative article, to help address typical barge/pontoon owners’ questions, and provide some guidance on complying with the legislation.
Are Barges and Pontoons Required to Comply?
The first question that many barge/pontoon owners have is;
“are barges and pontoons required to comply?”
While intuitively unlikely to transport anywhere near as much ballast water as other vessel types, barges/pontoons are indeed still required to comply with the regulatory requirements. The good news, however, is that there is some, albeit limited, scope for individual exemptions.
Under USCG regulations, barges/pontoons which operate within one COTP zone and don’t travel outwith the EEZ are not required to comply with the discharge criteria, however must still comply with the reporting criteria.
Barges/pontoons, however, that do trade between more than one COTP zone and/or outwith the EEZ, will be required to comply with the discharge requirements.
Under the IMO Convention, exemption applications can be filed for individual barges/pontoons. The granting of exemption certificates will be based on the likelihood of the vessel’s trade transporting non-indigenous species, and the onus is on the applicant to demonstrate this likelihood. The BWM Convention outlines the criteria and risk analysis procedures required for exemption applications. Outwith barges/pontoons operating exclusively on specific trade routes, as is the case with vessels such as ferries, exemptions may be costly and difficult to obtain.
It pays to be prepared and stakeholders should establish a dialogue with the relevant Flag State well ahead of the documented compliance dates, to ensure adequate time is available to undertake steps required for either compliance or exemption applications.
Ballast Water Exchange (D-1)
As discussed in our recent article titled; “Implementing Ballast Water Management Plans,” from entry into force (on 8th September 2017), all vessels will be required to conduct ballast water exchange, at least, in order to comply with the D-1 standard.
For many barges/pontoons, carrying out ballast water exchange within the required criteria – i.e. 200 nautical miles offshore and in waters of 200m depth, is a significant, and in many cases, insurmountable challenge.
Many barges/pontoons are not self-propelled, and are towed to their required destinations. For this reason, many of the vessels are completely un-manned during voyages – meaning ballast water exchange is not possible. Many of the vessels are also lacking any infrastructure onboard – such as generators, pumps or ballast pipework, and hence would struggle to undertake a controlled ballast water exchange that meets the requirements of the legislation.
Overall, for the majority of barges/pontoons, complying with D-1 is unlikely to be achievable, meaning, from entry into force, they would be required to comply with D-2.
Confusion over Compliance Responsibilities
With the capital investment required for D-2 compliance so high (at peak demand the cost of retrofitting a barge/pontoon with a BWMS could cost as much as $1,000 per m3/hr ballast flow rate), it is important to understand with whom the responsibility for compliance lies. Within the project cargo market, on a typical transportation project, there are generally various operators involved. The ultimate responsibility for compliance, prior to implementation of the regulations, is somewhat ambiguous and is likely to vary, contractually, from project to project. Post implementation, however, the responsibility is likely to fall on the barge/pontoon owner.
Compliance Dates & Fleet Profile
Based on the documented compliance dates, it is important from an early stage to examine the fleet profile and develop an understanding of the ultimate compliance dates for each vessel in the fleet. At the time of writing, the typical lead time for a BWMS was around 4 – 6 months, and the entire retrofit process from concept study through to Class Approval of the installation design package, could be as long as 4 months itself, so the development of a comprehensive fleet compliance profile is critical to ensure adequate time is allowed for each vessel.
The penalties for non-compliance are very strict, and as the industry begins to gather momentum, there is a strong likelihood that many end clients insist on chartering only vessels (or barges/pontoons) that have a method of compliance in place. Building an understanding of the fleet profile and compliance dates is therefore not only critical to ticking the regulatory box, but could ensure the fleet remains competitive in future charter markets.
Industry wide, the currently accepted method of compliance is to permanently retrofit a BWMS within the vessel. The capital costs of the BWMS itself, combined with the complexity of installation generally dictate the total cost to retrofit, however, at the time of writing, an average of $500 per m3/hr ballast flow rate is a sensible figure to work from.
With well in excess of 50 BWMS available on the market (check out our ultimate ballast water management guide for a searchable database of these systems) the selection of the most suitable system for a particular vessel has become a complex task.
These 50+ systems incorporate a wide range of treatment technologies, each of which offers their own benefits and drawbacks depending on the particular vessel applications. Ultimately there is no “one size fits all” solution, and owners/operators will need to pay close attention to the selection of the most suitable technology and individual system.
The practicality and complexity of retrofitting BWMS ranges from vessel to vessel, however barges/pontoons present some very unique, and in some cases prohibitive, difficulties:
Tank (or “dumb”) barges/pontoons face the most significant engineering challenges in order to comply. These vessels generally don’t have any machinery onboard and use portable deck pumps, or other temporary systems installed to the cargo deck for ballasting / de-ballasting operations.
Nonetheless, they are still required to comply and, if planning to comply using traditional retrofitting means, will likely have to take drastic action in order to do so. These barges/pontoons will likely have to convert an existing ballast tank or void space into a new machinery space, install all required infrastructure (generators, cooling water etc) and ensure it complies with Class and SOLAS rules concerning machinery spaces.
Overall a very complex and costly process.
An often overlooked but undoubtedly important problem is power availability. BWMS technologies are generally power hungry machines, which doesn’t fare well for barges/pontoons, which tend to suffer from a lack of available power. In many instances the vessel may require a whole new generator, and associated infrastructure, simply to provide enough power for the new BWMS.
Ballast Pumps & BWMS System Sizing
Another issue associated with retrofitting BWMS to barges/pontoons is the disparity between ballasting requirements for operational purposes (load in/loud out operations) and the ballasting requirements for adjusting the sea-going condition of the vessel. For operational ballasting, many barges/pontoons are equipped with high capacity ballast pumps, ensuring the operational ballasting can be conducted as quickly as possible. Given that operational ballasting involves filling and discharging tanks in one location, there is strong likelihood that this ballast process will not require treatment (clarification of this point will be required with the relevant Flag State on a project by project basis).
Sea-going ballasting on barges/pontoons (which will require treatment) would typically utilize the same, high capacity, ballast pumps, which has a significant impact on the complexity and cost of the retrofit process. A BWMS capable of treating higher flow rates will, intuitively, be physically larger in size, will require larger maintenance envelopes, will be more expensive and, in most cases, will require significantly more power to function.
However, for sea-going ballasting (which will require treatment), the barge/pontoon does not necessarily require such significant ballast pump capacities and it may be a more cost effective solution for such barges/pontoons with high capacity ballast pumps, subject to engineering suitability, to retrofit a smaller capacity ballast pump for sea-going ballast operations only.
Operators should investigate the various options available, undertake a detailed cost comparison and identify which is the best configuration for each vessel.
Ultimately, the retrofit installation of BWMS to barges/pontoons is likely to be a complex, and costly engineering challenge with a number of very important considerations to be made.
Return on Investment
Setting aside the complex engineering challenges associated with barges/pontoons and BWMS compliance, there is also a very significant commercial decision involved. Even a modest fleet of 4 barges, each of which operating with ballast pump rates of 500m3/hr, could, at peak demand, require an investment in the region of $2million. For conventional vessel types which use their BWMS on a daily basis, these figures may be somewhat palatable. For barges/pontoons, however, which tend to have longer off-charter periods, and long mobilisation/de-mobilisation phases on each project, the BWMS could be used as little as 2 days per charter.
Alternative Compliance Solutions
The good news for barge/pontoon owners is that there are a number of “alternative” compliance methods available, some of which may be suitable for the barge/pontoon market. We covered many of these alternative methods in our recent guide titled; “Alternative Methods of Ballast Water Management Compliance.”
Methods such as mobile ballast water management systems, which offer owners the ability to share one system between multiple vessels, or, alternatively, port based solutions, may present commercially attractive options for barge/pontoon owners.
Overall, barge/pontoon owners and operators within the project cargo market are faced with a complicated, costly and uncertain few years with regards to ballast water management compliance. With so few manufacturers, consultants and regulatory bodies willing to step forward and help this niche industry, it is critically important that barge/pontoon owners & operators begin compliance planning immediately, ahead of entry into force.