The European Maritime Safety Agency (EMSA) published an analysis of the delivery of ship-generated waste and cargo residues in 40 European ports. The analysis is part of the review of the EU Directive on port reception facilities, which dates back to 2000. Ramboll, the Danish consultancy which prepared the analysis, finds that, generally, there seems to have been an increase in ship-waste delivery from 2004 to 2008 for European ports.
In 2009 and 2010 a decrease was noted, which was most likely due to less traffic as a result of the crisis.
An important question the consultants had to address concerned the effect of the fee system. According to the Directive all EU Member States have to implement an indirect fee into the port waste fee system. All ports have introduced such an indirect fee, but in many different models. The report concludes that it is difficult to say whether one system is better than the other. The waste volume figures, which were provided by the ports and analysed by Ramboll do not document that one waste fee system is more efficient than the other. The ports' choice of waste fee model seems for some ports to rely on historical reasons and the fact that the waste fee system was in place before the EU Directive was enforced.
Although the provisions of the Directive on cost recovery systems clearly states that ports and port reception facilities cannot provide an incentive for ships to discharge their waste into the sea, it leaves room for interpretation to the Member States and the ports in its requirements to design the indirect fee to contribute significantly to the costs of port reception facilities, irrespective of the actual use of the facilities. Therefore a number of individual models have been implemented in Member State's ports, which the consultants designate as ‘unfortunate’ since the incentive of waste delivery in ports may differ from port to port and in different regions. Most ports prefer to contract out both the collection and treatment of ship-generated waste and cargo residues. This indicates that a majority of ports value the experience from private operators regarding collection and treatment. The consultants were unable to identify any significant differences in delivery behaviour for ports, which have contracted out these activities to private operators or prefer to carry out themselves.
“Because of the existing differences in costs for operating a waste reception facility among Member States, a fully harmonised fee system covering all costs would be impossible and should therefore not be an objective”, said ESPO Secretary General Patrick Verhoeven, “We however suggest that an exchange of best practices on parameters, principles and methods for fee calculation could be a helpful way forward in creating a more level playing field.” ESPO further agrees that fees should be fair, transparent and non-discriminatory but underlines that in some countries the port authority is not given the competence to set the fee for port reception facilities. ESPO recommends therefore that all port authorities are being consulted when setting the fee, even if they do not have full control over it. In that way all port authorities can bring forward their practical experience in this matter and consult on whether the fee actually represents a realistic price.
Together with the European shipowners’ association ECSA, ESPO will be joining a workshop of the European association of port reception facility providers in Europe (Euroshore) on the implementation of the Directive, which will be held in Antwerp on 25 October. The EC impact assessment on the review of the Directive is now about to be completed and the Commission’s proposals are most likely expected around April 2013. The two main options that are being considered are either an in depth legislative review, or minor amendments to the Directive with parallel provision of guidance and recommendation on key identified areas.
Source: E.S.P.O. (European Sea Ports Organisation)