By Rear Adm. Paul Thomas, assistant commandant for prevention policy, U.S. Coast Guard
This is an edited version of a post that first appeared on Maritime Commons. It is reproduced with permission.
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In early December, I published a six-part series providing an update and information about the Coast Guard’s ballast water regulations and implementation.
Rear Adm. Paul Thomas. USCG photo.
During recent discussions at the International Maritime Organization (IMO) ballast water management convention, the challenges associated with testing ballast water treatment systems were discussed at length. This is a complex issue. A robust type-approval process is crucial, as is industry innovation to help drive environmental change.
It’s no secret. There is a great deal of angst over ballast water management system regulations and type approval processes in the U.S. Many in the shipping industry have called for measures to ensure that we are never again put in a position where regulations call for technology that doesn’t yet exist, or type approval requirements that cannot be met by commercially available technology. However, the very nature of the environmental challenges facing the shipping industry not only precludes the elimination of such dilemmas, it demands them.
Shipping is the engine that drives the world economy. It raises the global standard of living and allows markets to flourish. Capacity demand for global shipping will grow significantly. By some estimates, that growth may top 50% by 2050. At the same time, the sustainability of industry and societal demands will require a reduction in shipping’s environmental footprint.
It is a significant challenge to grow capacity while reducing the environmental impact. The shipping industry plays a key role in meeting this challenge, but so do the regulator, innovator, and non-governmental environmental organizations.
Regulation can provide the critical forcing function that drives innovation and encourages technological developments to meet the environmental challenges. This occurs when regulations set ‘stretch’ goals and incentivize investment to meet those goals. Regulations that embrace the status quo and codify existing commercially available technology only serve to stifle innovation and prevent industry from meeting environmental challenges. Both the IMO BWM Convention and the U.S. BWM regulations set a discharge standard that represents a stretch goal, and they drive investment and innovation towards the development of solutions that are both effective and practical. Future environmental challenges will require similar regulatory forcing functions.
Robust, mandatory, consistent and transparent type approval procedures coupled with testing protocols carried out by independent authorities ensure that the complex systems developed to meet environmental stretch goals are reliable and effective. Type approval procedures that are not mandatory, can be applied inconsistently, and are not transparent, introduce market uncertainty. This makes it difficult for regulators to incentivize early adopters.
The recent IMO report on the implementation of the ballast water performance standard (G8 standards) bears this out. The report concluded that the non-mandatory nature, inconsistent interpretation and application of the standard, and lack of transparency of the test results have reduced confidence in the credibility of both the G8 approval regime and some of the 50 IMO-approved systems.
While there are not yet any ballast water management systems approved to the U.S. type approval standard, many are currently being tested. When testing is complete, the results will be transparent, repeatable, reliable and applicable to the full spectrum of ballast water encountered by global shipping. These systems will provide the market certainty that is needed to meet the ballast water challenge in this dynamic, diverse industry.
Regulations that set stretch goals and demand robust type approval requirements to drive innovation and investment must also provide flexibility to ensure the right balance between the possible and the practical. Coast Guard ballast water regulations provide that balance by extending the compliance deadline when appropriate alternative mitigation measures are in place – even while the cutting edge technology is under development.
It is essential to heed lessons learned from ballast water regulations as we address future environmental challenges and ensure the sustainability and productivity of the global shipping industry.
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The views and opinions expressed in this blog are the author's and not necessarily those of WorkBoat.
